The purpose of this Policy is to demonstrate our commitment to the privacy and protection of personal data collected from its Customers, establishing the rules on the collection, registration, storage, use, sharing, internationalization, and elimination of data collected within the scope of the services and functionalities made available by Dartmouth Management EE and the Dartmouth Group of Companies hereinafter referred to as “Dartmouth”, in accordance with the pertinent laws in force (for example, Lei Geral de Proteção de Dados Pessoais – LGPD for Brazilian residents – , EU General Data Protection Regulation 2016/679 (“GDPR”) or the California Consumer Privacy Act of 2018 (“CCPA” as amended by the California Privacy Act of 2020 (“CPRA”)).
Your privacy is important to us. It is the strict policy of Dartmouth to respect your privacy in relation to any information you may provide us on our website or personally.
We solicit personal information which is critical to provide a contracted service. We do so by legal methods/means, with your consent and knowledge. We also will inform the reason for requesting such information and how it will be used. When and if we store information, we protect fully protect it according to robust security protocols to avoid unauthorized access for whatever use. We may share information about you between or Offices, or with third parties, as necessary for any of the purposes necessary to provide our services. Otherwise we do not share or sell personal information obtained, except when requlaw.to by law .
As a condition of accessing and using our services, you declare that you are over 18 (eighteen) years of age and that you have fully and carefully read the “General Terms and Conditions” as published on our website, fully understanding and thereby granting your free and express consent to the terms stipulated herein. If you do not agree with these guidelines, you must discontinue your access or use.
DATA COLLECTED, FORM AND PURPOSE
Personal data is collected when you voluntarily enter or submit to us when accessing, using and interacting with the features or services made available online and/or in person by Dartmouth, which includes:
| DATA TYPES | PERSONAL DATA | PURPOSE OF USE OF DATA |
| REGISTRATION DATA | Full Name;
Date of birth; Nationality; Address; Telephone; E-mail; Passport No., Country of Issue and Expiration Date; ID No. and Country; Marital status; Employer Name (when applicable); Position (when applicable) |
Identify and authenticate existing customers; Register new customers; Respond to contact requests received through the website; Send institutional emails; Comply with current legislation; Prevent fraud, suspicious and/or potentially dangerous activities. |
Many of our services require you to register with the minimum information necessary to initiate a company/client relationship. When you register, we collect your name, email address, address, telephone number, passport information, date of birth, and other information as per the table above. You may also choose not to provide some information, but please be aware that all information is required to contract any service with us. Dartmouth is not responsible for the accuracy, veracity, or lack thereof of the information you provide, or for its out-of-date nature. It is the client’s responsibility to provide this information accurately and keep it up-to-date.
The consent you provide for the purposes of data use is collected individually, clearly, specifically, and legitimately. You can do so by sending an email to: dpo@scfnbr.com request a change to the consent granted for the processing of your data, the provision of information we have stored about you, or the cancellation of receiving communications from Dartmouth.
The data collected and the activities recorded may be shared:
- With Dartmouth Group of Companies;
- With competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or court order;
- Automatically in case of corporate movements, such as mergers, acquisitions and incorporations;
- Credit restriction controlling companies (SERASA).
The database created through the collection of personal data is owned by Dartmouth. You are jointly responsible for the confidentiality of your personal data. Sharing passwords and access data violates this Policy and the Terms of Use.
| DATA TYPES | STORAGE PERIOD | LEGAL BASIS |
| REGISTRATION DATA | As long as the relationship lasts and there is no request for erasure or revocation of consent | Brazil: Art. 9, section II of the General Personal Data Protection Law |
The data collected will be stored on a server located in Brazil, under the responsibility of Dartmouth.
DISPLAY, RECTIFICATION, LIMITATION AND OPPOSITION
You can request it by email at dpo@scfnbr.com confirmation of the existence of personal data processing, its display or rectification, after due confirmation of the authenticity of the contact. Through this same email, you can also express your objection and/or revoke consent regarding the use of your personal data, and request to unsubscribe from receiving electronic messages.
To ensure our customers receive relevant information, when we send an email with our communication, we receive a notification when it is opened, provided it is available on the customer’s computer. Please note that emails are only sent from the @ scfnbr.com domain .
GENERAL PROVISIONS
Dartmouth has the right to change the content of this Policy at any time, depending on the purpose or need, such as for legal adequacy and compliance with the provision of law or regulation that has equivalent legal force, and it is your responsibility to check it whenever you contact us. If you have any questions regarding the provisions contained in this document, you may contact us by email: dpo@scfnbr.com.
APPLICABLE LAW AND JURISDICTION
For Brazilian users, this Policy will be governed by and interpreted in accordance with Brazilian law, in the Portuguese language, and the Court of the District of São Paulo will be elected to resolve any dispute or controversy involving this document, unless there is a specific reservation of personal, territorial or functional jurisdiction by applicable law.
For users of other jurisdictions, Dartmouth has taken care to adhere to the most rigorous international standards.
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