PRIVACY POLICY AND PERSONAL DATA PROCESSING
INTRODUCTION
The purpose of this Policy is to demonstrate our commitment to the privacy and protection of personal data collected from our clients, 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, depending on the specific case, for example, Lei Geral de Proteção de Dados Pessoais – LGPD for Brazilian residents -, EU General Data Protection Regulation 2016/679 (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA” as amended by the California Privacy Act of 2020 (“CPRA”) or other US state applicable law, and the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”)
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 to us on our website or personally.
We solicit personal information which is critical to provide our services. We do so by legal methods/means with your consent and knowledge. We also will inform you of the reason for requesting such information and how it will be used. When and if we store information, we fully protect it according to robust security protocols to avoid unauthorized access for whatever use.
We intend to process personal data for the following purposes:
• To enable us to supply professional services to you as our client.
• To fulfil our obligations under relevant laws in force.
• To comply with professional obligations.
• To use in the investigation and/or defense of potential complaints, disciplinary proceedings and legal proceedings.
• To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
• To contact you about other services we provide which may be of interest to you if you consented to us doing so or if there is a legitimate interest in processing your personal data for such purpose.
• To investigate any tax planning requirements where you ask us to do so under present and any future change in laws.
Our intended processing of personal data has the following legal bases:
• At the time you instruct us to act, you agree to our processing your personal data for the purposes listed above.
• The processing is necessary for the performance of our contract with you.
• The processing is necessary for compliance with legal obligations to which we are subject.
• The processing is necessary for the legitimate interests which we pursue.
• To comply with professional obligations.
• To use in the investigation and/or defense of potential complaints, disciplinary proceedings and legal proceedings.
• To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
• To contact you about other services we provide which may be of interest to you if you consented to us doing so or if there is a legitimate interest in processing your personal data for such purpose.
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 Passport No., Country of Issue and Expiration Date ID No. and Country Marital status Employer Name (when applicable) Position (when applicable) Origin of Funds and Professional Activity |
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 send a request to change the consent granted for the processing of your data, to obtain the information we have stored about you, or to cancel receiving communications from Dartmouth, by contacting: dpo@dartmouthinternational.com.
We may share information about you between our offices, or with third parties, as necessary for any of the purposes necessary to provide our services. We do not sell personal information obtained and only share personal information when regulated(required) by law.
The data collected and the activities recorded may be shared or obtained from:
• Dartmouth Group of Companies.
• Competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or court order.
• Our database and official government channels in case of corporate transactions such as mergers, acquisitions and incorporations.
• Commercial credit rating or scoring agencies.
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 for at least five years after termination of our services.
REQUEST, RECTIFICATION, LIMITATION AND OPPOSITION
You have the right to request access to your personal data that we hold; to obtain the rectification of any inaccurate personal data concerning you; to have any incomplete personal data about you completed; to have the personal data that we hold about you erased, “blocked” or suppressed, in certain circumstances.
To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:
• Your date of birth.
• Previous or other name(s) you have used.
• Your previous addresses int the past five years.
• Personal reference number(s) that we may give you.
• What type of information do you want to know.
• Copy of passport
• A recent utility bill
You can request by email at dpo@dartmouthinternational.com the confirmation of the existence of personal data processing, its display, rectification or erasure, 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. We do not use automated decision-making systems in relation to your personal data.
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 or dartmouthinternational.com domains.
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@dartmouthinternational.com. It is a requirement of our contract with you that you provide us with the personal data that we reasonably request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.
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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