The provisions set out in this section apply to individuals located in Brazil and are intended to supplement this Privacy Policy in accordance with the Lei Geral de Proteção de Dados Pessoais (“LGPD”). For the purposes of this section, references to Personal Data shall have the meaning given under the LGPD.

If you are located in Brazil, and to the extent required by applicable law, the provisions of this section shall prevail over any conflicting provisions of this Privacy Policy.

If you have any questions regarding this section or wish to exercise your rights under the LGPD, you may contact us at dpo@remofirst.com. 

Legal Bases for Processing

RemoFirst processes Personal Data in accordance with the legal bases permitted under the LGPD. Depending on the circumstances, these legal bases may include, for example, where processing is necessary:

a. to comply with a legal or regulatory obligation;
b. for the performance of a contract or procedures preliminary to a contract to which you are a party;
c. for the regular exercise of rights in judicial, administrative, or arbitration proceedings;
d. to protect life or physical safety;
e. for the protection of health, where applicable;
f. to meet RemoFirst’s legitimate interests or those of a third party, except where your fundamental rights and freedoms prevail; or
g. based on your consent, where consent is required under applicable law.

For additional information regarding the legal bases on which we process your Personal Data, please refer to the relevant sections of this Privacy Policy describing how we use Personal Data and the applicable legal bases for processing.

Categories of Personal Data Processed

Information regarding the categories of Personal Data processed by RemoFirst is set out in the section titled “Types of Personal Data We Collect” of this Privacy Policy.

If you have any questions about the categories of Personal Data we process, you may contact us at: dpo@remofirst.com.

Purposes of Processing

RemoFirst processes Personal Data for the purposes described in this Privacy Policy, including in connection with the operation of the Website, Platform, and Services, the provision of workforce, payroll, employer of record, and related services, compliance with legal obligations, relationship management, security, fraud prevention, business operations, and other legitimate business purposes.

Further information on the purposes for which we process Personal Data is available in the relevant sections of this Privacy Policy describing when and how we collect Personal Data and how we use Personal Data.

If you have any questions about why we process your Personal Data, you may contact us at: dpo@remofirst.com.

Your Rights Under the LGPD

Subject to applicable law, individuals located in Brazil may have the following rights in relation to their Personal Data:

a. the right to confirm the existence of processing of their Personal Data;
b. the right to access their Personal Data;
c. the right to correct incomplete, inaccurate, or outdated Personal Data;
d. the right to request anonymization, blocking, or deletion of unnecessary or excessive Personal Data, or Personal Data processed in non-compliance with the LGPD;
e. the right to request portability of Personal Data to another service provider or product supplier, subject to applicable regulations and protection of trade and industrial secrets;
f. the right to request deletion of Personal Data processed based on consent, except where retention is permitted or required by law;
g. the right to obtain information about the public and private entities with which RemoFirst has shared Personal Data;
h. the right to obtain information about the possibility of denying consent and the consequences of such denial;
i. the right to withdraw consent at any time, where processing is based on consent; and
j. the right to petition the Autoridade Nacional de Proteção de Dados (“ANPD”) or other competent consumer protection authorities.

RemoFirst will not discriminate against you for exercising your rights under applicable law.

To exercise any of your rights under the LGPD, please contact us at: dpo@remofirst.com. 

Where a request is manifestly unfounded or excessive, including due to its repetitive nature, RemoFirst reserves the right to act in accordance with applicable law, including refusing to act on the request where legally permitted, and will provide the relevant reasons where required.

If you request confirmation of processing or access to your Personal Data under the LGPD, please indicate whether you seek a simplified disclosure or a complete disclosure. Where a complete disclosure is requested, RemoFirst may respond within the timeframe permitted under applicable law.

International Transfers of Personal Data

RemoFirst may transfer Personal Data outside Brazil in accordance with the LGPD and other applicable legal requirements.

Where applicable, transfers of Personal Data outside Brazil may take place, for example:

a. where the transfer is necessary for compliance with a legal or regulatory obligation;
b. where the transfer is necessary for the performance of a contract or preliminary procedures related to a contract to which you are a party;
c. where the transfer is necessary for the regular exercise of rights in judicial, administrative, or arbitration proceedings;
d. where the transfer is necessary to protect life or physical safety;
e. where the transfer is authorized by the ANPD;
f. where the transfer results from an international cooperation agreement;
g. where the transfer is necessary for the execution of a public policy or a legal attribution of public service; or
h. where the transfer otherwise complies with the mechanisms and requirements permitted under the LGPD.

Where required, RemoFirst will adopt appropriate safeguards and measures for international transfers of Personal Data in accordance with applicable law.

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