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About the Policy

This Policy explains how Moura Dubeux collects, uses, shares and protects data linked to its services and products. This policy may be changed at any time; however, we will inform you of the date of the most recent update.

Moura Dubeux is committed to protecting your privacy, committing to process your personal data in accordance with Brazilian law and best market practices, respecting the principles of purpose, adequacy, necessity, free access, quality, transparency, security, prevention and non-discrimination. It is our hope that this Policy will help you understand our commitments regarding your privacy. For information on how to contact us, in the case of any questions or concerns, please email dpo@mouradubeux.com.br.

If the User does not agree with the content of this Policy, we emphasize that they are free to decide whether they want to have access to Moura Dubeux’s products and/or services, and may even, in some cases, choose not to share certain optional data with us (which may prevent their access to our products and/or services).

Personal Data Processing Guidelines:

• All collection and processing of personal data will be carried out in accordance with this Privacy Policy in order to fulfill the purposes specified herein;
• The data collected will not be sold, transferred, rented, or disclosed in any manner other than that indicated in this Privacy Policy;
• When any personal data is no longer needed and we have no legal obligation to store it, we intend to delete, destroy or anonymize it;
• Our intention is to collect as little personal data as possible. We only intend to collect the data that is necessary to fulfill the purposes described herein.

Your rights

Law No. 13.709/18 (General Data Protection Law) provides for the rights that the User, as the holder of this data, may exercise through the “Use and Privacy” link on our Moura Dubeux websites: (mouradubeux.com.br) and RI Moura Dubeux (ri.mouradubeux.com.br).

See below your principal rights related to your personal data:

• Access to personal data;
• Confirmation of the existence of its processing;
• Correction of incomplete, inaccurate or outdated data;
• Anonymization, blocking, or deletion of data that is unnecessary, excessive, that does not comply with the LGPD;
• Information about the entities with which the controller has shared use of data;
• Portability of data to another service or product provider;
• Information about the possibility of not providing consent;
• Revocation of consent;
• Review of automated decisions;
• Right to object to processing, if irregular;
• Deletion of personal data processed with the consent of the data subject.

In some cases, we may not be able to comply with your request for data deletion, such as:

• Compliance with a legal or regulatory obligation by the controller;
• Existence of a contract that is valid and in effect;
• If the law determines minimum deadlines for data retention.

Purpose of data processing

“Personal Data” is defined as any information relating to an identified or identifiable natural person. The full name, email address, telephone number, location data, online identifier or other characteristic elements that can identify the User are examples of Personal Data.

     a) Data provided by the user

On the Moura Dubeux (www.mouradubeux.com.br) and RI Moura Dubeux (ri.mouradubeux.com.br) websites, the user may voluntarily provide personal data, such as full name, e-mail address, company, type of profile (renter, broker, investor, among other options) to register on the mailing list and receive content related to the selected profile or send a message to answer any questions or suggestions through the Contact Us or Contact IR forms, or even by contacting Moura Dubeux directly by telephone for this purpose.

Moura Dubeux will process the personal data voluntarily provided by the User in accordance with applicable law, considering that the User provides his/her personal data, or the personal data of a third party shared in a legitimate manner. If the User shares personal data of third parties, the User will be the controller of such personal data, in accordance with applicable law, and declares, under penalty of law, to have a legal basis to share such personal data of third parties.

     b) Data Provided by Business Partners/Customers

Business partner and customer data such as name, email and telephone number are required to:

• Grant access to our products and/or services;
• Registration for prospecting new business;
• Develop and improve our communication methods, products and/or services;
• To enable communication when necessary for business purposes and information that may be of interest;
• Ensure the conclusion of a contract or meet the prerequisites for entering into a contract;
• Understand the expectations, desires and interests of Users, aiming to improve our services and products and even to create products and services.
• For other purposes for which we will provide specific notice at the time of collection, or otherwise as authorized or required by law.

Usage and Navigation Data

This means data generated by interaction with the Website which may include IP (Internet Protocol) addresses or domain names used by the User when accessing the Website, URI (Uniform Resource Identifier) addresses, date and time of navigation, method of sending and server, size of the file obtained in response, numerical code indicating the status of the server’s response (successful, error, etc.), country of origin, the characteristics of the browser and operating system used by the User, time periods during the visit (for example, the time spent on each page) and the sequence of pages consulted. The automated systems and software used to operate and manage the Website collect Usage and Navigation Data.

Moura Dubeux collects these types of data for the following purposes:

• Obtain aggregated statistical information about the use of the Website;
• Verify the proper functioning of the Website;
• Allow contact with the User, when requested by him.

Such information is not collected by Moura Dubeux to enable the association with an identified natural person, however, due to the nature of the information, it may allow the identification of the User.

Usage and Navigation Data may also be processed for the purpose of determining and confirming the authorship of a cybercrime committed against the Website, under the terms of the applicable laws.

Moura Dubeux reserves the right not to process or treat any data if there is reason to believe that such processing or treatment may impute any infringement of any applicable law, or if there is an attempt to use the platforms for any illegal, unlawful or immoral purpose.

Data Sharing With Third Parties

Your data may be shared with:

• Third parties whose access and intervention are necessary for the execution and provision of the services offered on this Website, for example, the operational analysis of the Website;
• Moura Dubeux employees committed to confidentiality or legally obliged to maintain the confidentiality of information (e.g. employees and service providers for the benefit of the Controller);
• With competent judicial, administrative or governmental authorities, whenever there is a legal determination, requirement, requisition, or court order;
• With institutions responsible for collecting the credit resulting from the acquisition of the real estate unit(s) that the user has acquired;
• With the real estate broker, when the purchase is intermediated;
• Financial institutions for real estate financing
• With the condominium administrator, who will provide the management and administration services for the project; and
• Automatically, in case of corporate transactions, such as a merger, acquisition or incorporation.
• Securitization of receivables;
• With service providers to carry out polls/surveys, events and others, always with the prior consent of the owner.

We will always advise these third parties on how to treat your data, keeping it secure and complying with the law.

The personal data indicated will not be sold, transferred, rented or disclosed in any way that is not described in this Privacy Policy.

International Transfer

Personal data processed as a result of our services may be stored on our servers located in Brazil, as well as in an environment using resources or servers in the cloud (cloud computing), which may require a transfer of personal data outside Brazil.

Only in this case will there be an international transfer of personal data, and we will inform you which countries are receiving your personal data.

Data Retention

Your personal data will be kept for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of complying with any legal, contractual, accountability or requisition obligations from competent authorities.

After this period, we may store your personal data for an additional period for audit purposes or to enable us to comply with legal or regulatory obligations. We will retain your data for the necessary period, respecting the time periods established in the applicable legislation.

Information Security

Moura Dubeux has tools to protect your personal data from malicious or unauthorized third parties. We have put in place appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of data. These measures include internal reviews of our data collection, storage, and processing practices. We assure you that the protection of your personal data is one of our priorities and that, in the event of an incident, we will take all possible measures to minimize possible damage.

We assure you that the protection of your personal data is one of our priorities and that, in the event of an incident, we will take all possible measures to minimize possible damage.

Controller and Operator

The Controller of Personal Data is Moura Dubeux, headquartered at Av. Eng. Domingos Ferreira, 467 – Pina, Recife – PE. All requests or requests from users involving personal data should be directed to the address above or to the email address: dpo@mouradubeux.com.br or through the Contact Us or Contact IR forms on our websites. The Personal Data Operator is the natural or legal person, under public or private law, who processes personal data on behalf of the Controller. Moura Dubeux may hire third parties to support its operational activity who will have access to Personal Data as Operators. Likewise, Moura Dubeux may share data with third parties, who will become Controllers of Personal Data.

General Provisions

Alteration of Content and Update

The User acknowledges our right to change the content of this Policy at any time, according to the purpose or need, such as for the adaptation to and legal compliance with a provision of law or rule that has equivalent legal force, and it is the User’s responsibility to verify this whenever accessing the Platform or using our services.

Electronic Communication

The User acknowledges that all communication made by e-mail (to the addresses informed in their registration), SMS, instant communication applications or any other digital form, are also valid, effective and sufficient for the disclosure of any matter that refers to the services we provide, to their Data, as well as the conditions of their provision or any other matter addressed therein, the only exceptions being those provided for in this Policy.

Service Channels

If the User becomes aware that his/her Personal Data is being processed in violation of applicable laws, the User may submit a request to Moura Dubeux. If you are not satisfied with the answer or lack thereof, you can contact the National Data Protection Authority (ANPD).

In case of any doubt regarding the provisions contained in this Privacy Policy, the User may contact us through the service channels indicated below:

1. Moura Dubeux Privacy Portal;
2. Moura Dubeux Transparency Channel;
3. Personal Data Protection Officer/DPO: dpo@mouradubeux.com.br.

In addition, if the User wants to make use of any of their rights, we have the exclusive Privacy Portal for this through the link: Privacy Request Fulfillment Portal.

Data Officer

The Data Protection Officer, also called DPO (Data Protection Officer), is the person appointed to act as a communication channel between Moura Dubeux and the owners of the Data.

Data Officer: ICTS GLOBAL SERVIÇOS DE CONSULTORIA EM GESTÃO DE RISCOS LTDA – CNPJ 08.226.125/0001-46.

Contato: dpo@mouradubeux.com.br