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1. Purpose of Processing

The Company processes personal data strictly for the purpose of performing its contractual obligations related to global mobility and relocation services. Such processing activities may include, but are not limited to:

  • Immigration and visa procedures

  • Customs clearance and logistics coordination

  • Housing and relocation support services

  • Insurance and ancillary services

Processing is limited to what is necessary for the execution of the contracted services.

2. Categories of Personal Data

The Company collects and processes only the personal data that is strictly necessary for the intended purposes, which may include:

  • Identification and contact information

  • Personal and professional details

  • Official documentation required for service execution

  • Financial and operational data related to relocation services

3. Legal Basis for Processing

Personal data is processed on the basis of one or more of the following legal grounds:

  • Consent of the data subject

  • Necessity for the performance of a contract or pre-contractual measures

  • Compliance with legal or regulatory obligations

All processing activities are carried out in accordance with the applicable legal framework.

4. Data Sharing and International Transfers

Personal data may be shared with third parties only where necessary to:

  • Comply with applicable legal or regulatory requirements; or

  • Enable the provision of contracted services, including through service providers, agents, and partners.

Where personal data is transferred internationally, the Company ensures that such transfers are conducted in accordance with applicable legal requirements and are subject to appropriate safeguards, including contractual protections where required.

5. Data Security Measures

The Company implements appropriate technical and organizational measures to safeguard personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Access controls and role-based permissions

  • Use of secure systems and encrypted communication protocols

  • Monitoring, auditing, and periodic review of security practices

  • Training and awareness programs for personnel

6. Data Retention

Personal data is retained only for the period necessary to fulfill the purposes for which it was collected, or as required to comply with legal or regulatory obligations. Upon expiration of the applicable retention periods, personal data is securely deleted, anonymized, or otherwise disposed of in accordance with established procedures.

7. Data Subject Rights

In accordance with applicable data protection laws, data subjects have the right to:

  • Request access to their personal data

  • Request correction, update, or deletion of their data

  • Withdraw consent, where processing is based on consent

  • Request information regarding the processing and sharing of their data

Requests may be submitted using the contact details provided below.
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8. Contact Information

For any inquiries regarding this Policy or to exercise data subject rights, please contact:

Data Protection Officer (DPO): Richard Ian Gerson
Email: richard@gersonandgrey.com.br
Telephone: +55 (11) 3811-1616

ENG

Personal Data Protection Policy

Gerson & Gray is committed to ensuring the protection, confidentiality, and lawful processing of personal data, in accordance with applicable data protection laws and regulations worldwide, including, but not limited to, the Brazilian General Data Protection Law (Law No. 13,709/2018 – LGPD) and the General Data Protection Regulation (EU) 2016/679 (GDPR).

1. Purpose of Treatment

The Company processes personal data strictly for the performance of its contractual obligations related to global mobility and relocation services, including, but not limited to:

  • Immigration procedures and obtaining visas

  • Customs clearance and logistics coordination

  • Housing support and relocation services

  • Contracting insurance and related services

Treatment is limited to what is necessary for the provision of the contracted services.

2. Categories of Personal Data

The Company collects and processes only the personal data strictly necessary for the fulfillment of its purposes, which may include:

  • Identification and contact information

  • Personal and professional information

  • Official documents required for the execution of services.

  • Financial and operational data related to relocation services.

3. Legal Basis for Treatment

The processing of personal data is carried out based on the following legal grounds:

  • Data subject consent

  • Requirement for the execution of a contract or preliminary procedures.

  • Compliance with legal or regulatory obligations [PDprotection]

4. International Data Sharing and Transfer

Personal data may be shared with third parties only when necessary to:

  • Compliance with legal or regulatory obligations; or

  • Execution of contracted services through service providers, agents, or partners.

International data transfers are carried out in accordance with applicable legislation and with the adoption of appropriate data protection safeguards.

5. Security Measures

The Company adopts appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or improper disclosure, including:

  • Access control and restriction by permission levels.

  • Use of secure systems and encrypted communications.

  • Monitoring and periodic review of security practices.

  • Employee training and awareness programs

6. Data Retention

Personal data is stored only for the period necessary to fulfill the purposes for which it was collected or to comply with legal and regulatory obligations.

After this period, the data is deleted, anonymized, or securely disposed of, in accordance with the procedures established by the Company.

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7. Rights of Data Subjects

Under applicable law, the data subject may, at any time:

  • Request access to your personal data.

  • Request the correction, update, or deletion of data.

  • Revoke consent, where applicable.

  • Request information about the processing and sharing of your data.

8. Contact

For clarifications or to exercise rights related to the protection of personal data, the data subject may contact:

Data Protection Officer (DPO): Richard Ian Gerson
Email: richard@gersonandgrey.com.br
Telephone: +55 (11) 3811-1616

POR

Personal Data Protection Policy

Gerson & Grey (“Company”) is committed to ensuring the protection, confidentiality, and proper handling of personal data, in accordance with applicable local and international legislation, including, but not limited to, the General Data Protection Law (Law No. 13.709/2018 – LGPD) and the General Data Protection Regulation of the European Union (GDPR).

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