We, at EMPIRICUS RESEARCH PUBLICAÇÕES S.A., a company registered under CNPJ 11.431.155/0001-07, with headquarters at Av. Brigadeiro Faria Lima No. 3477, 10th Floor, Tower B, Suite 101, Itaim Bibi, São Paulo/SP, ZIP Code 04.538-133 (“EMPIRICUS RESEARCH” or “We”), wish to maintain a relationship of trust and transparency with all our clients, suppliers, and partners (“You”). For this reason, we ensure that all your interactions with us are carried out with the highest level of security and in compliance with the current privacy standards.
Therefore, we ask that you take a few minutes to carefully read our Privacy Policy, which describes the personal data we collect, how it is used, stored, and shared, and how you can exercise your rights, among other details. The rules of this document will apply whenever you browse our website https://www.empiricus.com.br/ (“website”), purchase our products and/or courses.
If you have any questions regarding the terms used, you can consult the glossary at the end of this document or click here to review the General Data Protection Law (“LGPD”), which, in Article 5, provides various definitions and necessary concepts.
I. WHO ARE WE?
We are a financial analysis and content publishing house founded in 2009, with the primary goal of helping our clients invest better by providing strategies as effective as those used by professional investors. We offer investors access to a complete journey: economic and financial news on our portals “Seu Dinheiro” and “Money Times,” portfolio and asset recommendations made by our analysts, as well as the ability to execute our investment ideas on the Empiricus Investimentos platform.
EMPIRICUS RESEARCH is part of the “Empiricus Group,” along with Empiricus Investimentos and Seu Dinheiro. This group is part of the BTG Pactual financial group.
Regarding the processing of your personal data, based on the legal grounds provided by law, we determine the purposes and means of using this information, and thus act as Controllers of your personal data.
II. HOW DO WE COLLECT YOUR PERSONAL DATA?
The information we process about you may have been provided directly by you to EMPIRICUS RESEARCH, by third parties, or even automatically collected through our website and other channels.
Let’s understand these data collection situations in more detail:
a. Information provided directly by You
From the moment you interact with us, you voluntarily provide us with information about yourself. For example, when you purchase our products or contact our support channels through chat, email, or other tools.
b. Information obtained from Third Parties
In specific cases, we may also receive some of your personal data from third parties. For example, information provided by EMPIRICUS RESEARCH contractors, such as consultants, service providers, or suppliers who help us offer better products to you, or data from credit bureaus when a credit analysis is necessary.
c. Automatically obtained information
In some situations, we may also automatically collect personal data through the devices you use to access our website. This information helps us generate access statistics and better understand our audience. This is important so that we can improve our platforms and products and tailor them to diverse audiences. Some of this data may be collected through cookies or similar technologies, as explained in the dedicated section below.
III. WHAT PERSONAL DATA DO WE PROCESS?
EMPIRICUS RESEARCH processes your personal data in accordance with the exact terms defined by the LGPD. To respect your privacy, we understand that any processing of personal data must be limited to the minimum necessary, relevant, and proportionate to achieve the intended purpose.
Therefore, the personal data we collect about you will vary depending on your relationship with us, whether as a client, visitor, partner, or other type of interaction.
You expressly agree to provide only accurate and truthful personal data and not access our platforms using information that alters your identity. You will be responsible for the information entered into our channels, especially if it is false, outdated, or inaccurate.
Below, grouped by category, are the main types of personal data we may process:
a. Registration data: Full name, date of birth, and CPF (Brazilian Taxpayer ID);
b. Qualification data: Residential/commercial address;
c. Contact data: Landline or mobile phone, personal and/or professional email addresses;
d. Payment data: Credit/debit card information, PIX, bank account, and other banking information;
e. Attributes associated with your electronic devices: IP address of the devices used, interactions made, and usage profile of websites, technical data such as URL information, network connection, provider and device data, cookies, device ID, operating system, browser, model, and geolocation data of the device, if you authorize the collection from your device.
It is important to note that EMPIRICUS RESEARCH does not collect sensitive personal data. These include racial or ethnic origin, religious beliefs, political opinions, union membership, or data related to health, sexual life, genetic or biometric data.
EMPIRICUS RESEARCH does not process personal data from individuals under 18 years of age, whether children or adolescents, as our websites and publicly available features are not intended for this group. Therefore, individuals under 18 should not provide their personal data to EMPIRICUS RESEARCH under any circumstances. Any registrations or records involving data from children or adolescents may be canceled or deleted from the systems at any time, at the sole discretion of EMPIRICUS RESEARCH.
IV. HOW DO WE USE YOUR PERSONAL DATA?
We may process your personal data for multiple purposes, including:
| Category of Personal Data | Purposes |
|---|---|
Registration Data Qualification Data Payment Data | To enable a service requested by You • We will process your Personal Data to facilitate your identification and registration process on our website, enabling access to our products. • We also use your Personal Data to enable the processing of payments that You make on our platforms. |
Registration Data Qualification Data Payment Data | Fraud Prevention • We may process your Personal Data to ensure your security (and that of Third Parties) and to prevent fraud in payments, especially in the purchase of our products. |
Registration Data Contact Data Qualification Data | Communication/Advertising • We may process your Personal Data to communicate with You and send you information by email, letter, telephone (including pre-programmed or pre-recorded calls), text messages, or other means, regarding our products, including new works carried out, to customers, and other institutional information about the company, unless You expressly instruct us not to contact you regarding our promotional communications. • To send you advertising and marketing content, unless You expressly instruct us not to contact you in this regard. • To send You invitations to events and surveys conducted by EMPIRICUS. |
Registration Data Qualification Data Attributes associated with your electronic devices | Facilitate EMPIRICUS's necessary activities • Based on our legitimate interest, we may also process your Personal Data in activities such as: improving our products, building relationships with our customers and partners, conducting company performance analyses and reports, and performing internal reviews. In activities supporting the interests of EMPIRICUS RESEARCH, we will always respect the limits of your expectations, and the processing of Personal Data will not prejudice your interests, rights, or fundamental freedoms. • We also process your Personal Data to help us manage and improve our website, events, experiences, and products, whether personalised or not. • Personal Data may also be processed for market and demographic research purposes. • To prevent and resolve technical and security issues, whenever necessary. |
Registration Data Qualification Data Contact Data | To comply with our legal or regulatory obligations • Your Personal Data may be used to fulfil our obligations under the law and/or regulations of governmental bodies and orders or requests from tax authorities, the Judiciary, and/or other competent authorities. For example, we may process personal data for the issuance of invoices. |
Registration Data Qualification Data Contact Data | To allow the regular exercise of our rights • Even after the termination of your relationship with us, we may process some of your Personal Data to exercise our rights guaranteed by law, including as evidence in judicial, administrative, or arbitration proceedings, when necessary. |
Registration Data Qualification Data Contact Data Payment Data | To enable credit protection • In the event of non-payment for products purchased, we may use your Personal Data to contact you, as well as to register you with credit protection agencies if necessary. |
V. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
It is possible that EMPIRICUS RESEARCH may share your Personal Data, in which case it will be restricted to the minimum appropriate and necessary for the fulfilment of one of the specific purposes previously informed to You in this Policy.
Below are some situations in which we may share your Personal Data:
• With Group companies – We may share your Personal Data with other companies in our Group, such as Empiricus Investimentos, Seu Dinheiro, Banco BTG Pactual, among others. This sharing may be necessary for the operation of our website, to provide our products, to comply with legal or regulatory obligations, and/or to enable an optimised and integrated consumer experience of our products for our users. Sharing may also occur if EMPIRICUS RESEARCH undergoes corporate changes, such as share transfer, restructuring, merger, demerger, or any other operation that results in a change in corporate control. In these situations, the data You provide may be transferred as part of the operation, always in compliance with the provisions of this Policy.
• Business partners – We may share Personal Data with other business partners for the purpose of offering courses, events, and sweepstakes. In such cases, measures will be taken to ensure that the data is processed only for the intended purpose.
• Service providers – We may share your Personal Data with service providers hired to facilitate, promote, and optimise the activities and functionalities of our website and products or to prevent and resolve technical or security issues. These companies include, but are not limited to, information technology providers, customer service, communication, statistical services, research, marketing, payment service providers, cloud services, among others. In all cases of sharing your data with service providers, the information will be used exclusively for the purpose agreed with EMPIRICUS RESEARCH, and the providers will be required to comply with the guidelines of this Policy.
• With public authorities – We may share information, including Personal Data of Data Subjects and third parties, with public authorities and/or government agencies, regulatory authorities, legal authorities (e.g. regional police stations), consumer protection bodies, and government and judiciary bodies, in the following cases: (a) to comply with court orders or government requests; (b) to allow the regular exercise of our rights and to prevent liabilities of EMPIRICUS RESEARCH; (c) to investigate, prevent, or take action regarding illegal activities, suspected or actual, or to cooperate with public authorities; (d) to investigate possible violations of the rights of EMPIRICUS RESEARCH and/or third parties; and (e) to comply with legal and/or regulatory obligations applicable to our products.
• With external law firms – We may share your Data for handling extrajudicial, judicial, administrative, or arbitration claims or proceedings when necessary to safeguard our rights, prevent or suppress fraud, and comply with legal obligations.
Any company, public or private entity, authority, body, agency, and/or individual who has access to the Personal Data of Data Subjects and/or third parties, in accordance with the situations outlined in the chapter on personal data sharing, will assume the role of data controller and will be required, under the applicable law and/or contracts signed with EMPIRICUS RESEARCH, to adopt best security and governance practices regarding the protection and processing of the Personal Data to which they have access.
In situations where the sharing of Personal Data is with a third party located outside of Brazil, in addition to ensuring the security and protection of Personal Data through a contract, EMPIRICUS RESEARCH will use one of the legal bases for international data transfers.
VI. WHAT ARE COOKIES? HOW DO WE USE THEM?
EMPIRICUS is committed to providing the best possible browsing experience, and for this purpose, we use cookies. Below, we explain in detail how this type of feature may be used.
What are cookies?
Cookies are small text files containing information that can be stored on your electronic devices when You visit our website. Cookies can, for example, remember your language preferences, authenticate your access to restricted areas when applicable, and provide us with statistics about your access.
We use cookies to better understand your behaviour on our website and, as a result, to tailor it to your interests and needs, improving the efficiency, speed, and presentation of future content for You.
We may also use this information for audits, statistical analyses to study preferences, data science, and the development and improvement of products offered by EMPIRICUS.
Grouped into categories, below are the types of cookies used and their purposes:
| Cookie Type | What do they do? |
|---|---|
Necessary/Essential | These cookies are essential for the proper functioning of our website and allow You to use all the available functionalities. |
Performance/Analytics | These cookies help us understand how visitors interact with our website by providing information about the areas visited, the time spent on the website, and any issues encountered. |
Functional | These cookies allow us to remember your previous choices, such as your language preference. They are responsible for providing a personalised experience. |
Marketing/Advertising | These cookies are used to deliver more relevant and specific content tailored to your interests. They can also be used to present targeted advertising or limit the number of times it is displayed. Additionally, they enable the measurement of the effectiveness of a launched campaign. |
We highlight that essential cookies are necessary for the normal functioning of our website. This means that, should You oppose the use of this tool, it may result in the unfeasibility of your experience or the suspension of your access.
It is also worth noting that our website may contain cookies directly installed by EMPIRICUS (first-party cookies) or those linked to third-party domains (third-party cookies). The latter, although installed by other companies, offer certain functionalities on the website, especially related to advertising.
Is it safe to have my information stored in cookies?
Yes, it is safe. All the information collected on our website is protected by our certified information security controls. However, if the user does not feel comfortable with the use of this tool, cookies can easily be disabled by configuring the browser. In such cases, the website may not function correctly or may take a long time to load content.
For more information on how to manage cookies in browsers, we provide the links below:
VII. HOW DO WE PROTECT YOUR PERSONAL DATA?
All Personal Data that You send to us via the internet through our website forms will be transferred via encrypted protocol and stored in databases that cannot be accessed externally. In other words, all and any Personal Data that You send us will be properly encoded so that it cannot be decrypted and read by any malicious agents. Our firewall is a mechanism that prevents access to our servers by individuals who are not part of the EMPIRICUS RESEARCH staff and is active continuously.
EMPIRICUS RESEARCH does not sell or rent your contacts to anyone. Access to the information provided is restricted to our employees and contracted service providers, as established in this Policy.
Unsolicited Emails
All email content sent by You to EMPIRICUS is confidential. We will not add your email address to our distribution lists without your prior permission. For security reasons, if your request concerns only one of our newsletters, we may request additional information beyond what has already been provided to verify your identity. It is important to note that in this case we will only confirm information that You have previously provided.
We have a policy against promoting our Site, products, and content using unsolicited emails. We require that all emails promoting EMPIRICUS or its products be sent only to individuals who have previously agreed to receive such content. Any promotion of the EMPIRICUS brand or our website through unwanted emails is expressly prohibited. Non-compliance with this policy will result in the cancellation of partnerships and/or termination of affiliate accounts.
VIII. HOW LONG DO WE STORE YOUR PERSONAL DATA?
We will retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected, unless a longer retention period is required to comply with legal obligations, safeguard our rights, fulfil judicial/extrajudicial agreements, or for audit purposes.
To determine the retention period of your Personal Data, we rely on the following criteria:
• If we have a legal, contractual, or other obligation to retain Personal Data, or if it is necessary for investigation or litigation purposes; and
• If it is necessary to maintain accurate commercial and financial records.
Once the purpose or legal necessity has expired, the data will be deleted using secure disposal methods or anonymised for statistical purposes only.
The Personal Data of users will be stored on cloud computing servers located in Brazil or abroad. For this, all requirements established by current legislation will be observed, and best practices for security and privacy will be adopted to ensure the integrity and confidentiality of the Personal Data.
IX. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM WITH EMPIRICUS?
Regardless of the relationship you choose to establish with EMPIRICUS, You are guaranteed all rights regarding your personal data as provided by law. These rights include:
• Confirmation that your data is being processed by us;
• Access to the collected data;
• Correction of your data if it is incomplete, outdated, or inaccurate;
• Request that the stored data be transferred to another institution (data portability);
• Request deletion, blocking, elimination, or anonymisation of your data if it is unnecessary, excessive, or processed in a manner contrary to what the law guarantees;
• Request deletion of data processed with consent;
• Be informed about the possibility of consenting to the use of data and the consequences of not consenting;
• Withdraw permission for the Processing of your Personal Data (revoke consent);
• Receive information about the public or private entities with which we share your Personal Data;
• Request a review of fully automated decisions that affect your interests.
To exercise your rights, You may contact our Data Protection Officer at the following email: privacidade@empiricus.com.br.
In specific circumstances, your request may not be fulfilled. In these cases, we will explain the reasons for the non-fulfilment.
Your request should include: (a) the identification of the Data Subject (full name and email), along with an identification document; (b) the specification of the action the Data Subject intends regarding their personal data; and (c) if applicable, the specification of the data that is the subject of the request.
Within 15 days, unless the law or regulation stipulates a different period, the Officer will respond to the personal data subject's request by: (a) communicating the fulfilment of the request; (b) providing justification if it is not possible to comply with the request; or (c) estimating a new timeframe for fulfilling the request and justifying the extension.
Requests involving personal data and/or documents of other subjects will not be fulfilled, except by proxy, parental authority, or other circumstances that authorise you to exercise another subject's rights.
There are situations where EMPIRICUS will need to retain or may not be able to alter personal data and, for that reason, may not fully meet the requests made by a Data Subject, even while following the rules above (e.g. when the retention of personal data is necessary to fulfil legal obligations or to comply with a court order).
We may occasionally use your name and email address to send you information related to Group content that may interest you. If at any time you wish to be removed from our free content distribution list or if you believe you have mistakenly received an unsolicited message from EMPIRICUS RESEARCH, please contact us via the following channel: privacidade@empiricus.com.br.
EMPIRICUS uses the WhatsApp Business tool as a sales channel and for informational communications with subscribers and readers. If you no longer wish to receive communications through these means, please send us your request via email at privacidade@empiricus.com.br.
X. LINKS TO THIRD-PARTY SITES
We may provide links to other websites/platforms that are not operated and controlled by us. We have no control over the content of these websites/platforms or how the Third Parties responsible for them collect and use your personal information. We do not promote third-party sites or make any statements about them.
Third-party websites may have their own privacy notices regarding the use and sharing of your personal information. Therefore, we recommend that you carefully read these privacy notices to ensure that you are aware of how your personal information is being collected and shared by these Third Parties.
XI. GENERAL QUESTIONS
If you have any questions, complaints, or wish to exercise your rights regarding your Personal Data, you can contact EMPIRICUS RESEARCH through our official channels, or send an email to privacidade@empiricus.com.br.
XII. CHANGES TO THIS PRIVACY POLICY
EMPIRICUS RESEARCH may amend this Privacy Policy at any time. Whenever a relevant condition of this Privacy Policy is altered, these changes will be valid, effective, and binding once the new version is published on our website.
We always prioritise transparency: whenever a significant change is made, we will send you a notification on the website and/or through the contact channels you provided at the time of registration, indicating the new version in effect.
Last updated on 16 August 2023.
XIII. GLOSSARY
To help you fully understand this Policy, we provide below some important terms and concepts:
| Term/Expression | Meaning |
|---|---|
National Data Protection Authority (ANPD) | It is the federal public administration body responsible for ensuring the protection of Personal Data and for regulating, implementing, and supervising compliance with the General Data Protection Law (Federal Law No. 13,709/2018) in Brazil. |
Personal Data | These are any information related to an identified or identifiable natural person, either directly or indirectly. In addition to basic identification information, such as name, identification number, or location data, Personal Data also includes other information related to a natural person, such as consumption habits, appearance, and aspects of personality. |
Sensitive Personal Data | Any Personal Data relating to racial or ethnic origin, religious beliefs, political opinions, union membership or membership in religious, philosophical, or political organizations, as well as data concerning health, sex life, genetic or biometric data. |
Data Protection Officer (DPO) | the Data Protection Officer (DPO) is the professional responsible for acting as a communication channel between EMPIRICUS, Data Subjects, and the ANPD. One of their main objectives is to ensure that EMPIRICUS complies with laws and regulations related to privacy and Personal Data protection. |
Third Parties | Refers, but is not limited, to any and all natural or legal persons that EMPIRICUS has or will have relationships with, including service providers, suppliers, consultants, partners, contracted or subcontracted third parties. |
Data Subject | A natural person to whom the Personal Data refers. |
Processing | It is any operation performed with Personal Data, such as collection, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of the information, modification, updating, communication, transfer, sharing, and extraction. |
You or User | Natural persons who use the website and the products provided by EMPIRICUS. |
EMPIRICUS RESEARCH | EMPIRICUS RESEARCH PUBLICACOES S.A., a company registered under CNPJ 11.431.155/0001-07, headquartered at Av. Brigadeiro Faria Lima nº 3477, 10th Floor, Tower B, Suite 101, Itaim Bibi, São Paulo/SP, ZIP Code 04538-133. |