/ 01 Who we are
MRLLS Assets is a private boutique advisory firm registered in Brazil under CNPJ 59.665.238/0001-89, with operating address in São Paulo, SP. References to "we", "us" or "the firm" in this notice mean MRLLS Assets. This privacy notice describes the practice we follow with respect to any personal information that may reach us through this website, email correspondence, or in the course of an engagement.
/ 02 Information we may collect
We try to collect as little personal information as is reasonably possible. The categories that may apply are:
- Inquiry data: the name, email address, capacity, area of interest, and any free-text message you voluntarily submit through the contact form on this site.
- Direct correspondence: any information you choose to share with us by email, telephone, or other channel.
- Mandate documentation: if you proceed to formal engagement, additional documents required by the mandate (identification, ownership records, provenance, financial references). This information is governed by the specific mandate agreement and confidentiality terms agreed in writing.
- Technical data: when you visit this site, our hosting provider may log basic technical information (IP address, browser type, pages visited) for security and operational purposes only. We do not deploy advertising trackers, analytics that profile individuals, or third-party marketing pixels.
/ 03 How we use your information
We use the information shared with us for the following purposes only:
- To respond to your inquiry and conduct preliminary discussion regarding a possible mandate.
- To carry out the work agreed under a formal mandate, including communication, documentation, and reporting to the principal.
- To comply with legal, regulatory, and tax obligations applicable to the firm in Brazil and, where relevant, in jurisdictions where mandate-related transactions are executed.
- To protect the firm and its principals from fraud, misrepresentation, and other harm.
We do not sell, rent, or share your personal information for marketing purposes — neither to third parties nor between mandates.
/ 04 Confidentiality as a practice
The existence of a relationship is itself confidential. Counterparties, positions, and the identity of principals are not disclosed publicly under any circumstance, except where compelled by law.
For mandates, confidentiality is also enforced contractually through bilateral non-disclosure agreements. The provisions of this privacy notice apply in addition to, not in place of, those mandate-specific agreements.
/ 05 Sharing with third parties
We engage carefully selected third-party service providers in the course of our practice (e.g. legal counsel, custodians, auction houses, despachantes, accountants). When information needs to be shared with such parties to execute a mandate, this is done only to the extent necessary, and under written confidentiality.
The site itself uses minimal infrastructure — hosting and email delivery providers — none of which receive personal data beyond what is technically necessary for operation. We do not use behavioral advertising, retargeting pixels, or social media tracking.
/ 06 Cookies and similar technologies
This site uses minimal essential session storage to remember whether you have already acknowledged this privacy notice. We do not deploy persistent advertising cookies or third-party tracking. If your browser blocks all storage, the site continues to function — you will simply see the privacy banner on each visit.
/ 07 Your rights under LGPD
Brazilian law (Lei Geral de Proteção de Dados, Law 13.709/2018) grants you specific rights with respect to personal data we hold about you. These include:
- Confirmation that we hold personal data about you, and access to that data.
- Correction of inaccurate, outdated, or incomplete data.
- Anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the law.
- Portability of your data to another service provider, where applicable.
- Information on the public and private entities with which we share data.
- Revocation of consent, where consent is the legal basis for processing.
To exercise any of these rights, please contact us at privacy@mrllsassets.com. We respond to verified requests within the timeframes required by applicable law (typically within 15 days).
/ 08 Data retention
Inquiry data that does not progress to mandate is retained for up to 24 months, after which it is deleted unless we have an active legal or regulatory obligation to retain it. Mandate-related data is retained for the duration of the engagement and thereafter for the period required by Brazilian commercial, tax, and anti-money-laundering legislation — typically five to ten years depending on the document type. REVIEW
/ 09 International data transfers
Because we operate global mandates, certain information may be transferred to or processed in jurisdictions outside Brazil — for example, when corresponding with auction houses, custodians, or counsel located abroad. Such transfers are made only when necessary for the engagement and under contractual safeguards consistent with LGPD requirements. REVIEW
/ 10 Security
We apply reasonable administrative, technical, and organizational measures to protect information held by the firm against unauthorized access, loss, or alteration. Despite such measures, no system is entirely immune to compromise; in the event of an incident affecting your personal data, we will notify you and the competent authority as required by applicable law.
/ 11 Children and minors
This site is not directed at, and we do not knowingly collect personal data from, individuals under 18 years of age. If you believe a minor has shared data with us, please contact us so we may delete the information.
/ 12 Changes to this notice
We may update this notice from time to time to reflect changes in our practice, legal requirements, or operational scope. The current version is always available at this URL with the effective date shown above.
/ 13 Contact & Data Protection Officer
For any matter related to this privacy notice or to the personal data we hold about you, please write to:
- Email: privacy@mrllsassets.com
- Postal: MRLLS Assets, São Paulo, SP — Brazil REVIEW
You also have the right to lodge a complaint with the Brazilian National Data Protection Authority (ANPD) at www.gov.br/anpd.