Legal terms
and Privacy

We only rely on our legitimate interest for specific purposes. This processing of personal data does not, in any way, override the interests, rights and freedoms of the subjects.

4. With whom does PRYOR GLOBAL share your data?

Since it is an online platform, PRYOR GLOBAL may operate jointly with other companies in a wide range of activities, including to provide location features, advertisers, sponsors and commercial partners, online and offline, besides the tools for disclosure and analyzing performance. Therefore, we reserve the right to share your information, including data on location, registration and interests, with the companies below, whenever possible, anonymously, as to preserve at most your privacy.

PRYOR GLOBAL does not practice the disclosure of information that can identify you. These data are for exclusive and internal use to achieve the purposes expressed in the previous item.

We do not rent, sell or transfer your personal data to anyone, except the partner companies listed below: We may share your personal data with third parties, in the following cases:

• Upon court decision or request by government oversight bodies;
• Data transferred to public bodies to comply with current legislation, for example personal data contained in electronic invoices or data from our collaborators necessary for the payment of Brazilian Social Security Institute (INSS) or Guarantee Fund for Length of Service (FGTS);
• Data transferred to financial institutions to provide payment options to our clients or to pay wages to our collaborators and providers;
• Data shared with partners, operators and service providers who participate, directly or indirectly, in the development of PRYOR GLOBAL's commercial activities, such as business representation services in Brazil, legal services (consulting and legal advice, including tax and labor areas), paralegal services, legal representation services, document signing services, services related to the liquidation of companies, accounting services (including services for reviewing financial statements as well as services related to tax bookkeeping and compliance with ancillary tax obligations, such as, for example, advising foreign companies on rendering accounts and providing tax documents to the competent authorities), financial services (which include, but are not limited to: billing, credit, collection, accounts payable, cash flow and bank control services), management and treasury services, payroll management services (by payroll and Human Resources solutions as well as BPO services), insurance companies, reinsurance companies, health operators and other intermediaries operating in the insurance market, DPO (Data Protection Officer) outsourcing services, data storage and processing, verification of registration information, targeted advertising platform, advertising and marketing as well as general advertising services, security and performance monitoring, auditing, collection, payment processing, customer service, email delivery, repair and maintenance services, order and transaction processing and fulfillment, research, data retention and data processing;
• Data transferred for the purpose of agreement performance or for the protection of PRYOR GLOBAL's interests in any type of conflict, including lawsuits;
• Other PRYOR GLOBAL companies: the personal data collected may also be shared with other companies of the Group, which undertake to use the information for the same purposes and with the same guarantees indicated in this Notice.
• In the case of corporate operations such as a merger, acquisition, transformation, spin-off, or a partial or total sale of assets, we may share, disclose or transfer all data from the subjects to the successor organization.

Some of the service providers mentioned above may be located abroad and, in this case, PRYOR GLOBAL adopts additional safeguards to ensure an adequate level of protection of personal data, in accordance with the provisions of the relevant Brazilian legislation.

5. What are the rights of the data subjects?

Personal data Subjects have certain rights with regard to their personal data and can exercise them by clicking here to access the Data Subject Access Request (DSAR) or by email: [email protected].

Subjects' rights are:

• Confirmation that personal data is being processed;
• Access to personal data, in accordance with applicable legislation;
• Correction of incomplete, inaccurate or out-of-date information;
• Data portability;
• Exclusion of data, when these are processed based on the consent of the Subject or when the data is unnecessary, excessive or processed in breach of applicable legislation;
• Requesting information about shared data use;
• Revocation of consent when applicable.
PRYOR GLOBAL will always evaluate the best way to comply with the request to exercise any of its rights. However, PRYOR GLOBAL may fail to comply with your request, in whole or in part, in specific situations protected by law, such as, for the fulfillment of a legal obligation or an agreement it has with you. We emphasize the importance of keeping your personal data accurate and up-to-date. To do so, always keep PRYOR GLOBAL informed if your personal data changes or is incorrect. For security reasons, requests made through the email [email protected] will only be responded if we are sure of the user's identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the subject. This data and information will be protected during the storage period and will be deleted after the legal period for the eventual regular exercise of rights has passed. In cases where PRYOR GLOBAL is the Personal Data Operator, requests will be forwarded to the Controller so that he can evaluate and decide on the measures to be taken.

6. How long will PRYOR GLOBAL store the data to?

The termination of the processing of personal data will occur in the following cases: (a) when the purpose for which the personal data was collected is achieved, and/or the personal data collected is no longer necessary or relevant to achieve such purpose; (b) when the Subject requests the deletion of his data; and (c) when there is a legal determination to this effect, and (d) when the end of processing is determined by the Controller.

In cases of personal data processing termination, with the reasons established by applicable law or this Privacy Notice, personal data will be deleted.

7. How does Information Security work at PRYOR?

To ensure that your personal information is secure, we communicate our privacy and security guidelines to PRYOR GLOBAL employees, and we strictly follow precautionary measures regarding privacy within the company.

We strive to protect your Personal Information, and those entrusted to us by our clients, by physical, technical and organizational measures to reduce the risks of loss, misuse, unauthorized access, disclosure and improper alteration of this data.

With the purpose of ensuring your privacy and protection of your personal data, PRYOR adopts the best information security and secure development practices on the market, that is, we design our products and services to promote protection of your data and where you can manage your information directly. Combined with this concept, we adopt encryption practices in passwords and other critical information, TLS for transfer of data between applications, engagement of cloud services with safety certifications and labels, such as ISO 27001, SOC 1 and SOC 2/SSAE 16/ISAE 3402 and PCI DSS, systems monitoring 24/7, edge firewall with features of IDS (Intrusion Detection System), anti-malware, anti-phishing, content control and VPN.

We strive to protect the privacy of your account and other personal data of yours that we keep in our records but, unfortunately, we cannot ensure total safety. Unauthorized entry and use of the account, hardware or software failure and other factors may compromise the safety of your personal data at any time, thus please help us to keep a safe environment for all. In addition to adopting good security practices in relation to your account and your data, if you identify or become aware of something that compromises the security of your data, please contact us through the service channel available, indicated in item 8 below.

8. Personal Data Officer (DPO) PRYOR GLOBAL provides below the contact details of the Data Protection Officer (DPO), who is responsible for meeting any and all requests by the subjects or the National Authority, which are related to personal data.

For any questions, requests or complaints regarding the processing of personal data, please contact our Personal Data Officer:

DPO EXPERT – (www.dpoexpert.com.br)
Responsible: Rafael Susskind
Substitute Responsible: Renata Adeli Franhan Parizotto
contact: [email protected]

If, despite our commitment and efforts to protect your data, you feel that your data protection rights have not been met, please, contact our DPO. In addition, you have the right, at any time, to file a complaint directly with the National Data Protection Authority, if you believe that the rights over your personal data have been infringed.

9. Changes to the Privacy Notice

Although our Privacy Notice has been presented in a clear, concise and objective manner, do not hesitate to consult PRYOR's DPO if you have any doubts about this important document or even about the personal data processing activities we carry out. Since we are always trying to improve our services, this Privacy Notice may be updated. Therefore, we recommend that you visit this page periodically to be aware of the changes. In case of relevant changes that require a new consent from you, we will publish such update and request a new consent from you.

Therefore, PRYOR GLOBAL reserves the right to update or modify this Notice, at any time and without prior notice. However, we will always publish the new revised version on our website. If there are changes in the way we treat personal data, you will be informed to check if you intend to continue using our services.