Brazil Privacy Notice
ComPsych along with its partner in Brazil, Carevolution, is a leading provider of Employee Assistance Program (“EAP”)services in Brazil. We create and maintain records that contain individually identifiable health information about clients. This notice concerns the privacy and confidentiality of those records and the information contained therein.
ComPsych and Carevolution comply with the Lei Geral de Proteção de Dados No. 13,709/2018 or General Data Protection Law (“LGPD”).
We may collect, process, store and use certain information about you to ensure effective service provision.
Personal data collected on or about individuals located in Brazil is collected on the following lawful bases for processing:
Consent: Where you have provided your consent for us to provide services to you, we may need to process your personal data. (You acknowledge your consent for us to provide services to you and process your personal data for the purpose of providing such services when you request services).
Comply with Legal or Regulatory Obligations: Where we are required to comply with laws, legal obligations, or regulations.
Necessary for Execution of a Contract: If we or our affiliates have entered into a contract with you, or your employer, who may be a customer, partner, supplier or other third party with whom we have a relationship, we may need to process your personal data.
Legitimate Interest: We may need to process your personal data where we have a legitimate interest in doing so, such as (1) to provide services to you; (2) to communicate with you; (3) to assess and improve the quality of our website, products, services and business operations; (4) in limited circumstances, to address security, health, and safety concerns; or (4) or other business-related purposes permitted or required under applicable local laws and regulations.
Individuals located in Brazil may have certain rights under the LGPD related to the processing of their personal data as set forth below:
- You have the right to request that we confirm whether we process your personal data.
- You have the right to request access to the personal data we have collected about you and the right to request additional information about the processing of that data.
- You have the right to request we correct incomplete, inaccurate, or out-of-date personal data.
- You have the right to request that we anonymize, block (restrict) from processing, or delete unnecessary or excessive personal data or personal data processed in violation of the LGPD.
- You have the right to request that your personal data be transferred to another service provider, subject to protection of any ComPsych or Carevolution confidential or proprietary information.
- You have the right to request deletion of your personal data that we process with your consent, subject to certain exceptions.
- You have the right to request information about the third parties with whom we shared your personal data.
- You have the right to information regarding not providing consent to processing your personal data where we seek your consent, and the consequences of declining consent.
- You have the right to revoke consent you granted to us.
- You have the right to request for the review of decisions made solely based on automated processing of your personal data affecting your interests, including decisions intended to define your personal, professional, consumer and credit profile, or aspects of your personality.
Your rights above may be subject to certain limitations and we may not be required to fulfill all requests in all circumstances.
To exercise your rights, please contact:
+55 11 3199-8918
If we experience a security incident which may create risk or relevant damage to you, we will notify you and the Brazilian Data Protection Authority (ANPD) as required by LGPD.