2PRO COMUNICAÇÃO EMPRESARIAL LTDA (“2PRO”) adopts this Privacy Policy to bring full transparency to you on how we handle personal data, to guarantee safe and correct treatment, in line with the legislation for the protection of personal data and maintaining a relationship of trust.
We understand the importance of adequate, safe, necessary treatment for specific purposes, supported by legal bases. Referred legal bases that justify our treatment are: (i) consent; (ii) compliance with a legal or regulatory obligation; (iii) contract execution; (iv) regular exercise of rights; and (v) legitimate interest.
Please take a few minutes of your time to read this Privacy Policy and make conscious and safe use of our services. You will easily understand what personal data we collect, use, and how the owner of the personal data can exercise their rights.

This Privacy Policy is intended for partners, employees, candidates, customers, suppliers, partners and website users.
It will be disclosed internally to its partners and employees, and externally to candidates, customers, suppliers, partners and website users through the institutional website:

Personal data processed and its purposes
The collection or access to personal data may occur by any of the following means: (i) directly by the holder of the personal data through our institutional website, in the “contact” tab; (ii) mailing list sent by customers and partners or provided by service provider; (iii) directly by the holder of the personal data due to an employment or partnership relationship; (iv) marketing and advertising campaigns carried out exclusively in favor of 2PRÓ and in favor of customers, directly by the holder; and (v) cookies and analytics information when accessing 2PRÓ’s institutional website.
The personal data collected, stored and processed in the event (i) provided directly by the holder of the personal data through our institutional website, in the “contact” tab, are the email and, usually, the name. These personal data are used solely to respond to your request sent to our contact email, according to your interest.
In the event (ii) of access to the mailing list sent by customers and partners, 2PRÓ requires that they only provide personal data treated with full respect for the legislation on privacy and protection of personal data, as well as only processing the personal data strictly necessary for the execution of the contract. Furthermore, 2PRÓ clarifies that it does not enrich the mailing list received without the authorization and request of the client and partner. As for the mailing list provided by a service provider for sending press releases to journalists, 2PRÓ only relates to providers that claim to comply with personal data protection legislation and the guidelines issued by the National Authority for the Protection of Personal Data (ANPD).
In the situation (iii) of collection of personal data provided directly by the holder, due to an employment or partnership relationship, 2PRÓ, respecting and applying labor and other applicable legislation, will process the following data: CPF, name, telephone, address, ID, bank account, PIX key, union membership and health data.
Employees’ sensitive personal data, including union membership information and health-related data, are processed in accordance with the contractual relationship established and in compliance with labor legislation.
In situation (iv) relating to the collection of personal data through marketing and advertising campaigns made exclusively in favor of 2PRÓ and in favor of customers, the processing of personal registration data, provided by its holders, such as: name, e-mail, telephone and position. This data will be used to offer services and prospect customers.
Indirectly, we collect cookies and analytics information through our institutional website. Some of the data collected are important for the functioning of the website, others are used to obtain behavior pattern analysis for the improvement of 2PRÓ’s services.
We only process data for people aging 18 years old or above.

Storage, Sharing and Transfer of Personal Data
2PRO does not sell personal data.
Access to personal data may occur by 2PRÓ employees and service providers that provide us with assistance for the proper performance of our activities.
We emphasize that everyone who has access to the personal data that 2PRÓ handles, whether as a controller or operator, in fact needs access for the development of their activity, however, they only have access to strictly necessary data and under clear guidelines and a duty of confidentiality of all information.
In addition, personal data may be shared with public authorities, regulatory agencies or governmental entities. This is when 2PRO is compelled by legal or regulatory obligation to carry out such sharing.
Furthermore, we inform you that we store personal data on encrypted platforms in the cloud and these operators may be based in other countries. 2PRÓ will adopt the necessary and possible measures to guarantee the correct treatment of personal data by these operators.
Finally, 2PRÓ clarifies that it will adopt adequate information technology and security measures, in accordance with applicable regulations. The measures are: information security policy (PSI), corporate governance, training, storage and access controls to personal data, encryption, delimitation of responsibilities, contractual clauses, confidentiality agreement, among others.
It is essential that the holder of personal data is aware of the risks related to information security incidents, such as the use of illegal means by third parties to obtain stored and transmitted information. In view of this, 2PRÓ cannot guarantee the inviolability of your personal data, but is dedicated to ensuring that privacy is preserved to the fullest.

Personal data storage time
Personal data will be stored for the period necessary and adequate to achieve the purpose for which it was collected or as long as there is a legal basis for its storage.

Rights guaranteed to the owner of personal data
The holder of personal data has the following rights guaranteed by the LGPD:
I – confirmation of the existence of treatment;
II – access to data;
III – correction of incomplete, inaccurate or outdated data;
IV – anonymization, blocking or elimination of unnecessary, excessive or treated data in violation of the LGPD;
V – deletion of personal data;
VI – information on the possibility of not providing consent and on the consequences of denial;
VII – revocation of consent.

All these rights can be exercised by contacting our Person in Charge (or Data Protection Officer – DPO), at the email:
We will respond to your request as soon as possible. However, there may be a delay in responding, for justifiable and duly informed reasons.

Notification of Changes
This Privacy Policy is subject to change without notice. We reserve the right to modify it at any time, without any prior notice, but always making it available on our institutional website. Therefore, we advise you to review it frequently.

This Privacy Policy presents all fundamental and relevant information about the processing of personal data by 2PRÓ.
In the event that there is any doubt about this Privacy Policy or if you want to send a suggestion for change, after reading it in full, you can contact us through our Person in Charge (DPO) Myrian Vallone, e-mail;
We will respond to your request as soon as possible. However, there may be a delay in responding, for justifiable and duly informed reasons.

Privacy Policy Updated: December 23, 2021.