Privacy Policy

Introduction

Grupo Dls/ — D'Lázari & Spinelli Ltda, registered under CNPJ 18.632.961/0001-84, headquartered in Birigui, São Paulo, Brazil — brings together three units: Dls/ Comunicação, Elleven Digital and Metrik.

This Privacy and Data Protection Policy demonstrates the Group's commitment to the privacy and personal data of its clients, partners, candidates and visitors, under Brazil's General Data Protection Law (Law 13,709/2018 — LGPD), and describes how and for what purpose this information is collected and used.

This Policy applies to all Data Subjects whose data is processed, directly or indirectly, by Grupo Dls/ through grupodls.com.br and the forms published on this website, and must be observed by its employees, clients and service providers.

Definitions

• Data Subject: the natural person to whom the personal data processed by Grupo Dls/ refers.

• Personal Data: any information that identifies, or can be used to identify, a natural person — in any format, electronic or on paper.

• Processing: every action performed with personal data, from collection to storage, use and deletion.

• Purpose: the objective for which the personal data will be used.

• Consent: the informed, express and unequivocal authorization given by the Data Subject for a specific purpose.

• Controller: the one who decides on the processing — here, Grupo Dls/. Processor: the one who processes data on behalf of the Controller, such as the hosting and e-mail services.

• Security Incident: any occurrence related to the leak or misuse of personal data.

• ANPD: Brazil's National Data Protection Authority, the body responsible for enforcing the LGPD in the country.

Data subjects' rights

Grupo Dls/ guarantees Data Subjects the following rights, as provided by the LGPD:

1. Protection and confidentiality of the personal data processed;

2. Confirmation that their personal data is being processed;

3. Access to their processed personal data;

4. Correction of incomplete, inaccurate or outdated data;

5. Anonymization, blocking or deletion of unnecessary or excessive data, or data processed in violation of the LGPD;

6. Portability of data to another service or product provider, upon express request and subject to trade and industrial secrets;

7. Deletion of data processed with their consent, except where retention is required under art. 16 of the LGPD;

8. Information about the public and private entities with which the data has been shared;

9. Information about the possibility of not giving consent and the consequences of refusal; and

10. Withdrawal of consent, where consent is the legal basis for the processing.

Any question about these rights can be addressed to Grupo Dls/ through the channels listed in the Contact section.

Processing of personal data

Grupo Dls/ processes only the personal data strictly necessary for its activities. On this website, that means one simple rule: we only collect what you type. We don't buy lists, we don't enrich records with third-party databases and there are no hidden forms.

What the forms ask for

The contact form, published on the home page, on /grupo and on /contato, receives name, company, e-mail and message — required — plus phone and fronts of interest, optional.

The job application, on /trabalhe-conosco, receives name, e-mail and message — required — plus phone, LinkedIn profile, area of interest and resume, all optional. Resumes are accepted in PDF, DOC or DOCX, up to 5 MB.

Your resume may contain data you chose to include that we did not ask for — photo, marital status, age, address. Send only what you consider necessary: none of it is required to apply.

What is recorded with the submission

When a form is received, we record the visit's origin: campaign parameters (UTM), Google ad click identifier (gclid), the page and button the submission came from, the referring site reported by the browser, the IP address, and the date and time. It serves to know which channel brought the contact and to reply knowing where the person came from.

This data is only recorded when you submit a form. Browsing the site without submitting anything creates no record of ours.

Cookies

This website does not set cookies — no analytics tool, social network pixel or third-party tracker is loaded on the pages. The only record kept in your browser is the button through which you reached the form, stored in sessionStorage and deleted when you close the tab. Videos hosted on Vimeo only load after you click play; before that, nothing is sent to them.

Purpose and legal basis

• Replying to your sales inquiry — carrying out preliminary contract procedures at your request (art. 7, V).

• Evaluating your application — carrying out preliminary contract procedures at your request (art. 7, V).

• Understanding where contacts come from — legitimate interest in knowing which channels work (art. 7, IX).

• Recording IP, date and time — compliance with legal obligation and security of the record itself (art. 7, II and VI).

How long we keep it

Personal data processed under this Policy will be deleted within a maximum of 6 (six) months after its processing by Grupo Dls/ ends, unless current legislation requires longer retention.

You can request deletion before that period at any time, through the channels in the Contact section.

Disclosure of personal data

Grupo Dls/ may disclose the personal data it processes to third parties only in the following situations and within the limits of the law:

1. to its employees, when necessary to achieve the purpose of the processing;

2. to service providers, when necessary for the provision of the related services — which includes the website hosting and the e-mail service through which messages travel; and

3. when necessary due to legal obligation, order from a competent authority or court decision.

The Group may also disclose data as necessary to defend itself against third-party claims or to protect the safety and rights of its employees, clients and service providers.

Grupo Dls/ does not sell personal data and does not hand it over for third-party advertising use. If an unplanned disclosure becomes necessary, the Data Subjects involved will be informed, unless such communication is restricted or forbidden by law or court decision.

Security incidents

Data sent through this website travels over an encrypted connection. The forms limit the size of each field, refuse files that are not PDF, DOC or DOCX, and store resumes outside the website's public folder — no one reaches them through a guessed address.

Upon identifying a security incident, whether in its own processing or in a third party's, Grupo Dls/ will immediately investigate to identify the origin, which data was affected and the resulting risks. Based on the investigation, it will take the necessary measures to reverse or mitigate the effects and, if it finds relevant risk or damage to Data Subjects, will notify the ANPD and the Data Subjects involved, as required by law, stating the nature of the affected data, the protection measures used, the related risks and what will be done about it.

Contact

Questions, communications or requests related to the processing of personal data by Grupo Dls/ can be addressed to:

• E-mail: contato@grupodls.com.br

• Letter addressed to Grupo Dls/, Av. João Cernach, 2605, Centro, Birigui/SP, Brazil.

We reply within 15 days. For deletion or access requests, we may ask for identity confirmation — not to make it harder, but to avoid handing your data to someone else.

Validity and changes

This Policy is available for consultation at any time, with a permanent link in the footer of every page on the site.

When it changes, the update date at the top changes with it and the version moves forward. Relevant changes in purpose or legal basis are announced before taking effect.