This Privacy and Personal Data Protection Policy of overA Capital ("Policy") governs the processing of personal data received or collected through this website, by email, through the valuation simulator and through any other contact channel maintained by overA, in accordance with Brazil's General Data Protection Law (Lei nº 13.709/2018, "LGPD").
1. Institutional commitment
overA is committed to protecting the security and privacy of the personal data it processes, to communicating its processing activities transparently, and to maintaining mechanisms through which data subjects can exercise their rights. Confidentiality is how the firm works: the same care we devote to the information of a company in a sale process applies to the data of those who reach out to us.
2. Who processes the data
overA Capital Assessoria Financeira Ltda. (CNPJ 49.274.375/0001-39), with its registered office at Rua Hungria, 1240, 5th floor, suite 51, Jardim Europa, São Paulo, SP, CEP 01455-000, acts as the controller of the personal data processed under this Policy, that is, it is the one that decides the purposes and the means of processing. Service providers engaged by overA (for example, hosting, email and analytics tools) act as processors, processing data on overA's behalf and in accordance with its instructions.
3. What data we collect and how
We collect personal data in three ways:
- Data you send us. When you write to contato@overacapital.com.br, apply through the Careers page or speak with a partner: name, email, LinkedIn profile, résumé and the content of your message, plus any other data you choose to include, such as phone number, company or position. The applications form is processed by Netlify's forms service, which stores the submissions on overA's behalf.
- Data you enter in the valuation simulator. Your company's website address, location, revenue, earnings and growth, and the work email address to which the analysis is sent. The simulator also looks up public information about the company from the address provided and records where the visit came from, such as campaign parameters and referring page. The answers are stored in a database operated by Supabase on overA's behalf.
- Data collected automatically. As you browse, the site may record your IP address, browser and device type, pages visited and the date and time of access, through cookies and similar technologies, described in section 8.
We do not knowingly collect sensitive personal data or data from anyone under 18. If you believe you have sent us data of this kind, write to the contact in section 13 so that it can be deleted.
4. How we use the data
- To respond to your inquiry and manage your relationship with overA, including the preliminary assessment of a possible deal.
- To prepare and perform contracts, such as advisory mandates, and fulfill the obligations arising from them.
- To assess applications and run recruitment processes.
- To comply with legal and regulatory obligations, including anti-money laundering requirements, and respond to authorities when required.
- To exercise rights in judicial, administrative or arbitration proceedings.
- To record and summarize meetings and calls: overA may use AI-assisted transcription and summary tools. If you would rather this did not happen, just let us know before the conversation.
- To keep overA's website and systems secure and prevent fraud.
- To understand how the site is used and improve the browsing experience.
- To prepare and send the valuation simulator analysis to the email address provided and, on that basis, present overA's services.
- To measure the performance of our marketing campaigns, when you accept the advertising cookies described in section 8.
5. Legal bases
We process personal data on the grounds provided for in the LGPD, as applicable: performance of a contract or of preliminary procedures at the data subject's request; compliance with a legal or regulatory obligation; the regular exercise of rights; overA's legitimate interest, always weighed against the data subject's rights and expectations; and consent, where applicable, as in the case of analytics cookies. Where processing is based on consent, you may withdraw it at any time, without affecting the processing carried out until then.
6. Who we share it with
overA does not sell personal data. We may share it, to the extent necessary and with contractual safeguards, with:
- service providers that support the operation (website and form hosting by Netlify, the valuation simulator database by Supabase, email, cloud storage, productivity tools and the measurement and advertising tools described in section 8);
- legal, accounting and financial advisors, where necessary to carry out a mandate or fulfill obligations;
- potential buyers and investors, only in the context of a sale process you have authorized and under a confidentiality agreement;
- public authorities, regulators and courts, where there is a legal obligation or an order to that effect.
7. International transfers
Some of the data is processed in Brazil and some on servers abroad, mainly in the United States: this is the case for the hosting of the site and of the applications form, for the valuation simulator database and for the measurement and advertising tools. In these cases, the transfer takes place only with providers that offer an adequate level of protection or under contractual clauses ensuring compliance with the LGPD.
8. Cookies
Cookies are small text files stored on your device when you visit a website. They make it possible to remember preferences and understand how the site is used. This site uses the following categories:
| Category | Purpose | Duration | Consent |
|---|---|---|---|
| Essential | Required for the site to work: security, correct page loading and recording your cookie choice. | Session, or up to 12 months to record your choice | Not required |
| Preferences | Remember browsing choices, such as the site language. | Up to 12 months | Not required |
| Analytics | Measure which pages are visited, for how long and from what type of device, in order to improve the site. When active, this measurement uses Google Analytics. | Up to 24 months | Only with your consent |
| Advertising | Measure how our ads perform and show overA ads to people who have already visited the valuation simulator. Uses Google Ads, LinkedIn Insight Tag and Meta Pixel, and currently runs only on the simulator page. | Up to 13 months | Only with your consent |
When you first enter the site, a box asks whether you accept or reject analytics and advertising cookies. Your answer is kept for 12 months in your browser's local storage. Essential cookies work regardless of your choice. You can change your mind at any time through the Cookie preferences link in the footer of every page, or through your browser settings (Chrome, Firefox, Safari and Edge all allow you to block or delete cookies; blocking the essential ones may affect how the site works). To turn Google Analytics off across all websites, Google offers an opt-out add-on.
9. Your rights
Under the LGPD, you may request the following from overA at any time: confirmation that processing exists; access to your data; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law; portability; information about sharing; information about the possibility of withholding consent and about the consequences of refusal; withdrawal of consent; and review of decisions taken solely on the basis of automated processing. To exercise these rights, use the contact in section 13. We will respond within the period set out in the legislation, and may ask you to confirm your identity before acting on the request. You may also petition Brazil's National Data Protection Authority (ANPD) directly.
10. How long we keep it
We keep personal data only for as long as necessary for the purposes for which it was collected, to comply with legal and regulatory obligations and for the regular exercise of rights, taking into account the nature of the data and the applicable limitation periods. At the end of that period, the data is deleted or anonymized.
11. Security
We adopt technical and administrative measures to protect personal data against unauthorized access and accidental or unlawful destruction, loss, alteration, disclosure or dissemination, such as access controls, encryption in transit and restricting access to those who need the data for their work. No transmission over the internet is entirely secure; should an incident occur that may pose a material risk to you, overA will notify the data subjects and Brazil's National Data Protection Authority (ANPD) as required by law.
12. Updates to this Policy
This Policy may be updated to reflect changes in the law, in overA's services or in overA's practices. The version in force will always be published on this page, with the date of the last update at the top.
13. Contact us
Questions, requests and complaints about this Policy or about the processing of your personal data may be addressed to overA's data protection officer:
Data Protection Officer (DPO)
overA Capital
Rua Hungria, 1240, 5th floor, suite 51, Jardim Europa, São Paulo, SP, CEP 01455-000
contato@overacapital.com.br