We, at Thomaz Bastos, Waisberg, Kurzweil Advogados Associados (“TWK” or “Firm”), wish to maintain a relationship of trust and transparency with all users of our services (“You”). For this reason, we ensure that your navigation on https://www.twk.com.br/ is conducted with the highest level of security and in compliance with all current privacy standards.
We have prepared this Privacy Notice (“Notice”) to help You understand how TWK processes your information and how You can exercise your rights related to such information.
Our priority is to safeguard the privacy and security of your personal data. Therefore, any information You provide us will be treated within the limits set forth herein and in accordance with applicable laws.
Whenever we process personal data of individuals under 18 years old (children and adolescents), we will do so considering the best interests of the data subject.
For any questions related to the protection of your personal data and/or this Privacy Notice, we provide an appropriate contact channel: lgpd@twk.com.br. Please do not hesitate to contact us.
1. HOW ABOUT A SUMMARY OF THE MOST RELEVANT INFORMATION?
To facilitate your understanding of this Notice, we provide a summary of the key information that will be presented to You in this document:
| WHO WILL PROCESS YOUR PERSONAL DATA? MEET TWK! | THOMAZ BASTOS, WAISBERG, KURZWEIL ADVOGADOS ASSOCIADOS (“TWK”), registered with CNPJ/MF under No. 26.325.143/0001-67, headquartered at Avenida Brigadeiro Faria Lima, No. 3311, 13th floor, Itaim Bibi, São Paulo, SP, ZIP Code 04538-133, is a law firm specialized in debt restructuring and insolvency, complex judicial and arbitration litigation, corporate and financial transactions, offering personalized services. You can learn more about us by visiting our website: https://www.twk.com.br/. TWK is the entity responsible for processing personal data and determining the respective purposes and means of processing. |
| HOW DO WE COLLECT YOUR PERSONAL DATA? | The information we process about you may have been provided directly by You to TWK, obtained from third parties, or automatically collected through our Platform and other channels. |
| WHAT DATA WILL BE PROCESSED? | Personal Data: driver’s license, citizenship, CNPJ, CPF, CTPS, vehicle data, unique personal identifier, nationality, name, username, internal registration number, passport, PIS/INSS, RG, military service, signature, photos, videos, marital status, parentage, dependent’s age, dependent’s name, parents/guardians’ names, dependent’s relationship, criminal records, previous address, previous phone number, date of birth, gender, age, social media profile, coverage, policy data, insurance information, social media history, postal code, city, email, address, state, country, phone number, mobile number, messaging app username, investments and assets, personal property records, public property records, agency, bank, statement, account information, bank details – account number, history, score, benefit data, payment history, bonus payment, income tax return, card number, job title, hiring date, professional email, company/entity/organization, professional address, function, professional identification, profession, remuneration, salary, education. Sensitive Personal Data: diagnoses, current illnesses (e.g., medical certificates and reports), medical history, medical records, test results, disabilities. |
| WHY DO WE NEED YOUR PERSONAL DATA? | We use your personal data to fulfill specific purposes: To provide a requested service/product; To communicate with You; To comply with our legal or regulatory obligations; To enable the exercise of our rights; To support activities necessary for our Firm; To execute a contract You have entered into with us or perform pre-contractual due diligence; and Recruitment and selection. |
| HOW LONG WILL YOUR DATA BE RETAINED? | We store your personal data for as long as necessary to achieve the purposes for which they were collected. Whenever possible, we will keep personal data anonymized, maintaining the highest level of market security and care. |
| WHEN CAN YOUR PERSONAL DATA BE SHARED? | We may share your personal data with third parties to achieve the purposes for which they were collected. Additionally, sharing may occur when necessary to comply with judicial authority requests or fulfill legal or regulatory obligations. |
| HOW TO EXERCISE YOUR RIGHTS AS A DATA SUBJECT? | We are committed to ensuring all your rights as a data subject. Therefore, we provide a communication channel to address any questions, suggestions, or requests related to the processing of collected personal data. Contact our Data Protection Officer via email: lgpd@twk.com.br. |
2. HOW DO WE COLLECT YOUR PERSONAL DATA?
The information we process about You may have been provided directly by You to TWK, obtained from third parties, or automatically collected through our Platform and other channels.
Let’s better understand each of these data collection scenarios:
a) Information provided directly by You
From the beginning of your interaction with us, You voluntarily provide information about Yourself. For example, when You contact us via email or our service channels, interact with us through our website or other tools, or register to participate in a selection process.
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 TWK’s clients, such as consultants, service providers, suppliers who help us offer better products and services to You, or even as a result of financial or legal sector activities.
c) Automatically obtained information
In some situations, we may also collect personal data automatically through the devices You use to access our Platform. This information helps us generate access statistics and better understand our audience. This is important so we can improve our Platforms and services and tailor them to various audiences. Some of this data may be collected through cookies or similar technologies, as we will explain in a separate section below.
d) Publicly available information
There is also the possibility of collecting publicly available information about You that is available on social media (such as Instagram and Facebook) and in public databases (such as court records).
3. WHAT PERSONAL DATA DO WE PROCESS?
To respect your privacy, we understand that all processing of personal data must be limited to the minimum necessary, in a relevant and proportional manner, to fulfill the intended purpose.
Therefore, the personal data we collect about You will vary depending on the relationship You choose to have with us, whether as a client, consumer, visitor, partner, among others.
Below, grouped into categories, we present the main personal data that may be processed by us:
- Identification and qualification data: driver’s license, citizenship, CNPJ, CPF, CTPS, vehicle data, unique personal identifier, nationality, name, username, internal registration number, passport, PIS/INSS, RG, military service, signature, photos, videos.
- Qualification data: marital status, parentage, dependent’s age, dependent’s name, parents/guardians’ names, dependent’s relationship, criminal records, previous address, previous phone number, date of birth, gender, age, social media profile, coverage, policy data, insurance information, social media history.
- Contact data: postal code, ZIP code, city, email, address, state, country, phone number, mobile number, messaging app username.
- Financial data: investments and assets, personal property records, public property records, agency, bank, statement, account information, banking details – account number, history, score, benefit data, payment history, bonus payment, income tax return, card number.
- Professional data: job position, hiring date, professional email, company/entity/organization, professional address, role, professional identification, profession, remuneration, salary, education.
- Behavioral data: consumer or professional profile, social media usage pattern.
- Sensitive personal data: diagnoses, current illnesses (e.g., medical certificates and reports), medical history, medical records, test results, disability.
- Attributes associated with your electronic devices: internet provider, operating system, browser (type, version, enabled options, and installed plug-ins), video settings (size/resolution and color depth), access date and time, and pages viewed through cookies.
4. WHY DO WE USE YOUR INFORMATION?
The personal data we collect may be used as described in the table below:
| Category of Personal Data | Purpose |
| Identification Data; Contact Data; Financial Data. | To provide a requested service/product. We will process your data to deliver the service/product you have acquired. |
| Identification Data; Contact Data. | Communication. We may process your personal data to respond to your requests or other interactions with us, such as via email, chat, or through our website. We may also send updates that impact your relationship with us in respect of transparency, such as updates to this Privacy Notice. |
| Identification Data; Contact Data. | To comply with our legal or regulatory obligations. Your personal data may be used to fulfill our legal obligations set forth by law and/or regulations of governmental bodies, orders, or requests from tax authorities, the Judiciary, and/or other competent authorities. For example, we may process personal data for issuing invoices. |
| Identification Data; Contact Data. | To enable the regular exercise of our rights. Even after the end of your relationship with us, we may process some of your personal data to exercise our legally guaranteed rights, including as evidence in judicial, administrative, or arbitration proceedings. |
| Identification Data; Contact Data; Behavioral Data. | To enable necessary activities for our Firm. Based on our legitimate interest, we may also process your personal data in activities such as internal banking reconciliation or internal purchases. In supporting TWK’s interests, we will always respect the limits of your expectations, and the processing of personal data will not infringe upon your interests, rights, or fundamental freedoms. |
| Identification Data; Contact Data; Financial Data. | To execute a contract you have entered into with us or conduct pre-contractual due diligence. If you are part of a contract with TWK or represent a company in a contractual agreement, we will process your data for the execution of the contract to ensure the performance of the work and respective payment. |
| Identification Data; Contact Data; Professional Data | Recruitment and selection. We publish our job openings on specialized websites and social networks, such as LinkedIn. We also receive resumes via email, employee referrals, and physical submissions at our office locations. In these cases, we will process your personal data to analyze your resume, verify your skills and professional information, and assess whether you meet the specific requirements for the position for which you applied. We may also proceed with the selection process through phone or email contact and interview scheduling. |
| Identification Data; Contact Data; Behavioral Data; Device Attributes. | Marketing. We may use your personal data to create audience segmentations and thus promote updated marketing campaigns from TWK more effectively. In this case, the option to unsubscribe from our database will always be available at the end of each communication we send, allowing you to choose whether to receive information about offers and updates on TWK’s latest trends. We may also use your personal data to participate in market research (e.g., Chambers and Partners, Legal 500, etc.), always requesting your consent. |
5. WHAT ARE COOKIES AND HOW DO WE USE THEM?
Cookies are text files that can be stored on your electronic devices when You visit our Platform. TWK uses this tool for different purposes, such as generating access statistics and improving your experience on our website.
Below, we list the types of cookies used and their purposes:
| Type of Cookie | What They Do |
| Necessary/Essential | These cookies are essential to ensure the proper functioning of our Platform, as well as to allow You to use all available features. |
| Performance/Analytics | These cookies help us understand how visitors interact with our Platform by providing information about visited areas, the time spent on the Platform, and any encountered issues. |
| Functional | These cookies allow us to remember your previous choices, such as browsing language. They are responsible for providing a personalized experience. |
| Marketing/Advertising | These cookies are used to deliver more relevant content tailored to your interests. They may also be used to present more targeted advertising or limit the number of times an ad is displayed. Additionally, they allow us to measure the effectiveness of a campaign. |
We emphasize that necessary cookies are essential for the normal operation of our website. This means that if You oppose the use of this tool, it may result in an impaired experience or restricted access.
However, You do not need to worry, as cookies do not damage your equipment and/or electronic device and can be easily disabled by configuring your browser to reject cookies. In such cases, the website may not operate correctly or may take longer to load content.
For more information on managing cookies in browsers, we provide the following links:
You may also choose to block the use of Google Analytics cookies at the following link: https://tools.google.com/dlpage/gaoptout.
6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
TWK may share your personal data, but only in the minimum scope necessary to fulfill specific purposes previously disclosed to You in this Notice.
Thus, we may share your data with third parties in the following situations:
- Business partners and service providers, to facilitate communication and marketing channels, as well as to provide the necessary structure for our services;
- In the case of corporate transactions, such as mergers, acquisitions, spin-offs, or incorporations;
- With administrative and judicial authorities, when necessary to comply with legal obligations or assist in the investigation of suspected illegal activities; and
- With other law firms, advisory services, and legal representatives, when necessary to defend TWK’s interests in administrative, arbitration, or judicial proceedings.
Whenever we share your personal data in these situations, we use contractual instruments to ensure that any third party receiving your data guarantees adequate protection.
In cases where data sharing occurs with a third party located outside Brazil, in addition to ensuring security and protection through contractual means, TWK will rely on one of the legally authorized mechanisms for international data transfer.
7. HOW LONG DO WE STORE YOUR PERSONAL DATA?
We will not retain your personal data for longer than necessary to achieve the purposes stated above, nor will we use your data for other purposes, except as authorized by law.
If it is necessary to retain personal data after fulfilling its intended purpose, the retention period will be determined based on the following criteria:
- If we have a legal, regulatory, contractual, or authority-imposed obligation to retain personal data; and
- If the data is necessary to maintain accurate historical, commercial, and financial records or to comply with internal determinations of our Firm.
8. HOW DO WE PROTECT YOUR PERSONAL DATA?
We have internal policies and procedures that define how personal data should be handled at TWK. These guidelines aim to ensure the appropriate and lawful processing of the personal data we collect.
In addition to these organizational and governance measures, we adopt various technical measures that further enhance the security of your personal data, such as:
- Strict control over the processing of personal data, including access limitation and password-protected access;
- The implementation of an information security program;
- Segmentation of access to personal data;
- Guidelines for password protection; and
- Access to services exclusively through secure networks.
9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM WITH TWK?
Regardless of your relationship with TWK, You have all the rights regarding your personal data as provided by law, including:
- Knowing whether we process any of your personal data;
- Knowing which personal data of yours we process;
- Correcting incomplete, inaccurate, or outdated data;
- Requesting anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
- Requesting the portability of data to another service or product provider;
- Requesting a review of solely automated decisions that affect your interests;
- Requesting the deletion of data processed with your consent;
- Obtaining information about the public or private entities with whom we share your data; and
- If processing requires your consent, You may refuse to give it. In this case, we will inform You of the consequences of not carrying out the requested activity. If You give consent, You may revoke it at any time.
You may exercise your rights at any time. To do so, You may contact our Data Protection Officer via email at lgpd@twk.com.br. We request that You identify yourself and indicate which right You wish to exercise.
TWK may request additional information and/or documents to confirm identity or verify the authenticity of the request.
Requests involving personal data and/or documents of other data subjects will not be fulfilled, except in cases of power of attorney, parental authority, or other situations that authorize the exercise of another data subject’s rights by You.
In specific circumstances, Your request may not be fulfilled. In such cases, we will explain the reasons that justified the non-compliance.
10. QUESTIONS?
If You have any questions, You may contact our Data Protection Officer via email at lgpd@twk.com.br.
11. UPDATES
Some of the information provided here may be updated or changed. Therefore, we advise You to periodically review this Privacy Notice. Whenever there is a change, we will inform You on our homepage.
Last updated: January 8, 2025.
12. UNDERSTANDING KEY TERMS
To help You better understand this Privacy Notice, we provide definitions of some technical terms used in this document:
| Term/Expression | Meaning |
| National Data Protection Authority (ANPD) | Public administration body responsible for overseeing compliance with the provisions of the LGPD throughout Brazil. |
| Personal Data | Any information capable of identifying a natural person, directly or indirectly. |
| Sensitive Personal Data | Any personal data related to racial or ethnic origin, religious beliefs, political opinions, membership in a union or organization of a religious, philosophical, or political nature, as well as data concerning health, sex life, genetic, or biometric data. |
| Data Protection Officer (DPO) | Professional responsible for acting as a communication channel between TWK, data subjects, and the ANPD. Their main objective is to ensure TWK’s compliance with privacy and data protection laws and regulations. |
| LGPD | General Data Protection Law (Federal Law No. 13.709/2018). |
| Third Parties | Any individual or legal entity that TWK interacts with or may interact with. This includes service providers, suppliers, consultants, partners, subcontracted third parties, tenants, space assignees, whether formally contracted or not, including those who use the Firm’s name, supply materials, interact with public officials, government entities, or other third parties on behalf of TWK. |
| Data Subject | The natural person to whom the personal data refers. |
| Processing | Any activity performed with personal data, such as collection, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation, or information control, modification, updating, communication, transfer, sharing, and extraction. |