- Introduction and Purpose
AWARE will keep confidential all information related to its clients and investment funds under management, except for information that is already in the public domain by virtue of regulation or even by the information holder’s publicity initiative.
By providing their Personal Data to AWARE, the User accepts the terms and conditions of this Policy and declares that the Personal Data provided is true and accurate, assuming the corresponding responsibility if they are not. AWARE does not assume any responsibility in case of inaccuracy of the Personal Data provided by the User.
For the purposes of this Policy, words and expressions beginning with capital letters, when not defined elsewhere in this Policy, in the singular or plural, shall have the meaning given to them as indicated below:
- “User”: all natural persons who use or visit the AWARE website, over 18 (eighteen) years of age or emancipated and fully capable of performing acts of civil life or those absolutely or relatively incapable duly represented or assisted.
- “Personal Data”: refers to any data that directly identifies the User personally or which, when used in combination with other information, is liable to identify the User, including contact information such as: name, email address, company name, address, telephone number and other information of the User or his company, provided directly or obtained through public information.
- “Browsing Data”: refers to information about the User’s computer and visits to our website, such as their IP address, geographic location, browser type, referral source, length of visit and pages viewed.
- “Sensitive Data”: refers to personal data on racial or ethnic origin, religious conviction, political opinion, membership in a union or organization of a religious, philosophical or political nature, data relating to health or sexual orientation, genetic or biometric data , when linked to a natural person.
Personal Data may be in any media or format, including electronic or computerized records, including Navigation Data where such information is sufficient to identify someone directly or indirectly.
Sensitive Data will not be collected through the AWARE website.
- Data Treatment
When the User visits the AWARE website, he will be free to explore it without providing any Personal Data. However, should you wish to provide it, this Policy clarifies how AWARE will collect, process, use and store this information.
How we use the data we collect:
We use the data we collect only in accordance with this Policy. User’s Personal Data will not be transferred to third parties or used for purposes other than those for which they were collected, except in the case of legal, regulatory or judicial determination.
Access to Personal Data is restricted to authorized AWARE employees, who are subject to applicable legal penalties and their own internal disciplinary penalties, in case of improper use. AWARE may share Personal Data with other market participants, in the following situations and within the limits required and authorized by law:
- with its service providers and partners when necessary and/or appropriate for the provision of related services, including here the transfer of data to the institution responsible for the distribution of investment funds managed by AWARE;
- with AWARE employees who need the User’s Personal Data to carry out their activities and functions;
- with suppliers and partners necessary to carry out the activities developed by AWARE, highlighting information technology, accounting, legal service providers, among others;
- for administrative purposes such as: research, planning, service development, security and risk management;
- when necessary as a result of a legal obligation, a determination by a competent authority or a court decision.
Personal Data may be used exclusively to: (i) improve the User’s own browsing experience; (ii) send the User information or content, if he has chosen to provide his Personal Data in the “Contact” tab of this website; (iii) promote the use of AWARE services and share informational content with the User in accordance with their communication preferences.
In short, the collection and use of Personal Data is justified, depending on the context in which it is inserted, by the legitimate interest of AWARE, provided that it does not harm the interests of data protection or fundamental rights and freedoms of the User, or even when necessary for the execution of a contract signed with the client or due to a legal or regulatory obligation.
Whenever the basis for the collection and use of data does not fit these hypotheses, the User’s express consent will be requested, making clear the possibility of not providing it, as well as the consequences of this refusal. In this sense, AWARE clarifies that the provision of Personal Data by the User on the “Contact” tab of this website is understood, for all purposes, as consent, which may be revoked at any time by the User.
Use of Navigation Data:
Navigation Data is used to operate and improve the website. Browsing Data may also be used alone or in combination with Personal Data to provide the User with personalized information about AWARE, its products and services.
Security of User’s Personal Data:
AWARE uses various security technologies and procedures to help protect User Personal Data from unauthorized access, use or disclosure. All Personal Data is protected by physical, technical and organizational measures.
Media Resources – External Sites:
This website may contain links or frames from other websites, which may or may not be AWARE partners. These links and frames are made available for the sole purpose of facilitating the access of information to Users. It is noteworthy that the inclusion of these links and frames does not mean that AWARE is aware of, agrees with or is responsible for them or their content. Therefore, Wilson Sons cannot be held responsible for any losses or damages suffered as a result of the use of these links or frames.
Retention of Personal Data:
After reaching the purpose for which the collection of information is intended, AWARE will archive such data for a period of 05 (five) years, except in cases where conservation is authorized or mandatory for a longer period. After this period, the information collected will be deleted or anonymized. If requested, the processing of data may be terminated upon the express request of its owner.
Data is not collected or stored through cookies that may eventually be present on our website.
When the User uses the services or views content provided by AWARE, information about the hardware and software of his/her computer is automatically collected. This information may include: IP address, browser type, domain names, Internet service provider (ISP), files viewed on the website (eg HTML pages, graphics, etc.), operating system, clickstream data, time of access and referring website addresses. This information is used by AWARE to generate general statistics regarding Site usage. For these purposes, this collected data is automatically linked to the User’s Personal Data.
Data on minors:
The AWARE website is not intended for or directed at persons under the age of 18, and data from persons under the age of 18 are not knowingly or intentionally collected. If the User suspects that a collection of this nature has taken place, he/she must send an email to [indicate the email of the person responsible for the LGPD] so that AWARE can delete this information from the database.
How to access and control Personal Data:
The User has the following data protection rights:
- may request access, correction, updating, anonymization or deletion of your Personal Data, especially those unnecessary, excessive or treated in disagreement with the LGPD.
- may request information about sharing data with public and private entities.
The User may request confirmation of the existence of the processing of their Personal Data and oppose their processing, request to restrict the processing of their Personal Data or request the portability of their Personal Data.
If AWARE has collected and processed Personal Data with the consent of its owner, the User may revoke his consent at any time. The revocation of your consent will not affect the legality of any processing carried out before the revocation nor will it affect the processing of Personal Data carried out in accordance with the lawful processing independently of the consent.
To exercise any of these rights, please send an email to [indicate LGPD responsible email address]. The Supervisor will respond to your request to change, correct, or delete your data within a reasonable time and we will notify you of the action we have taken..
- General Provisions and Contact of the Supervisor