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1. About the Policy
This Privacy Policy provides information on how we collect, use, share and protect your personal data.This Privacy Policy are subject to change without prior notice, from time to time, in our sole discretion. However, we will notify you of amendments to this Policy by posting them on the website.
Moura Dubeux is committed to protect your privacy, ensuring that your personal data will be treated in accordance with Brazilian law and best practices, complying with the principles of purpose, adequacy, necessity, free access,data quality, transparency, security, prevention non-discrimination and accountability. We hope this Policy will help you understand our commitments regarding your privacy. For contact information in case of any questions or concerns, please send us an e-mail to dpo@mouradubeux.com.br.
If you do not agree with the content of this Policy, we emphasize that you are free to decide whether to have access to Moura Dubeux products and/or services, and may even, in some cases, choose not to share certain optional data with us (which may prevent your access to our products and/or Services).
2. Guidelines for the processing of personal data
- All collection and processing of personal data will be carried out in accordance with this Privacy Policy and to fulfill the purposes specified herein;
- The data collected will not be transferred, sold, rented or disclosed differently from what we indicate in this Privacy Policy;
- When some personal data is no longer needed and we do not have a legal obligation to store it, our duty is to delete, destroy, or anonymize it;
- Our intention is to collect the minimum personal data as possible – we truly intend to only collect the data that is strictly necessary to fulfill the purposes described herein.
3. Your rights regarding privacy and protection of personal data
Act 13.709/18 (Brazilian General Data Protection Law, also known as LGPD) provides the rights sot you, as data subject, may exercise by the link “Privacy” on our following websites – Moura Dubeux (www.mouradubeux.com.br) and RI Moura Dubeux (ri.mouradubeux.com.br).
LGPD provides the main following rights for data subjects:
- to obtain confirmation as to the existence of personal data processing; to access their personal data; to rectify incomplete, inaccurate, or outdated data; to have unnecessary, excessive or noncompliant personal data anonymized,
- blocked or erased; to be informed about third parties with which their data has been shared; data portability; to have personal data processed under the data subject’s consent erased; to withdraw their consent; to request a review of automated decisions that affect their interest and were solely based on automated processing of their personal data (the review does not need to be necessarily made by a natural person).
- Correção de dados incompletos, inexatos ou desatualizados;
- Anonimização, bloqueio ou eliminação de dados desnecessários, excessivos ou em desconformidade com a LGPD;
- Informação sobre as entidades com as quais o controlador realizou o uso compartilhado de dados;
In some cases, it may occur that we may not be able to fulfill your data deletion request, such as:.
- Compliance with legal or regulatory obligation by the controller;
- execution of a contract or preliminary procedures related to a contract of which the data subject is a party, at the request of the data subject; Data retention periods determined by law;
4. Purpose of data processing
“Personal Data” is defined as any information related to an identified or identifiable natural person. Full name, email address, telephone number, location data, online identifier or other characteristic elements that may identify the User are examples of Personal Data.
4.1. User-provided data
On the Websites Moura Dubeux (www.mouradubeux.com.br) and RI Moura Dubeux (ri.mouradubeux.com.br), the user can voluntarily provide Personal Data, such as full name, email address, company, profile type (renter, broker, investor, among other options) to register in mailing and receive content regarding the selected profile or send a message to ask any questions or suggestions through the Contact Us or Contact RI forms, or even by contacting Moura Dubeux directly through the phones for this purpose.
Moura Dubeux will process the Personal Data voluntarily provided by the User in accordance with applicable regulation, considering that the User provides his Personal Data or Personal Data of a third party shared in a legitimate manner. If the User shares Personal Data to third parties, in accordance with applicable law, the User will be the controller of such Personal Data, and declares, under the penalties of law, to have a legal basis to share such Personal Data of third parties.
4.2. Data provided by business partners/customers
Data from business partners and customers such as name, email, and phone number, is required to:
- Grant access to our products and/or services;
- Registration for prospecting for new business;
- Develop and improve our communication methods, products and/or services;
- Enable communication when necessary for commercial purposes and information that may be of interest;
- Ensure the conclusion of a contract or meet the prerequisites for concluding a contract;
- Understand the expectations, desires and interests of users, aiming to improve our services and products and even create products and services;
And for other purposes for which we shall provide a specific notice, at the time of collection, or else when authorized or required by regulation.
4.3. Usage and Navigation Data
Usage and Navigation data refers to website interaction data, that may include Internet Protocol (IP) addresses or domain names used by the User when accessing the Website, URI (Uniform Resource Identifier) addresses, date and time of navigation, shipping method and server, file size obtained in response, numeric code indicating the status of the server response (successfully, error, etc.), country of origin, the characteristics of the browser and operating system used by the User, time lapses of the visit (for example, the time spent on each page) and sequence of pages consulted. Automated systems and software, used to operate and manage the Website, collect Usage and Navigation Data.
Moura Dubeux collects Usage and Navigation data for the following purposes:
- Obtain aggregate statistical information about Website use;
- Check the proper functioning of the Website;
- Allow contact with the User, when requested.
Such information is not collected by Moura Dubeux to enable the association with an identified natural person. However, by the very nature of the information, it may allow the identification of the User.
The Usage and Browsing Data may also be processed for the purpose of determining and assessing the authorship of cybercrimes against the Website, in accordance with applicable laws
Moura Dubeux reserves the right to refuse noncompliant data processing or any other attempt to use the website for any illegal or unlawful purposes.
5. Data transfers to third parties
Your personal data may be shared with:
- Third parties whose access and intervention are necessary to execute and to provide services offered on this Website, for example, the operational analysis of the Website;
- Moura Dubeux employees committed to confidentiality or legally obliged to maintain confidentiality of information (e.g., employees and companies providing services for the benefit of the Controller);
- Judicial, administrative or governmental authorities, whenever there is legal determination, request, or court order;
- Institutions responsible for charging the credit arising from the acquisition of the real estate unit(s) that you purchased;
- The realtor, when the purchase is brokered;
- Real Estate line credit provided by Financial institutions;
- Condominium Management Company, which will provide the management and administration services of the enterprise; and
- Automatically, in case of corporate transactions, such as merger, acquisition and incorporation.
- Securitization of receivables;
- Service providers in charge to accomplish polls/ surveys, events and others, always with the prior consent of the data subject.
We will always guide these third parties on how to process your data, keeping it safe and complying with the law. The indicated personal data will not be transferred, sold, rented, or disclosed in any manner that is not described in this Privacy Policy.
6. International Data Transfers
There is no international transfer of personal data.
7. Data Retention
Personal data will not be used for any purpose that is not described in this Policy. In cases that you need to use your data for other purposes, we will seek for your consent before proceeding, unless for complying with legal obligations or accomplishing our legitimate interests, such as conducting internal investigations, fraud prevention, among other illegalities that may occur in our system. In addition, your personal data will be held in our system only as necessary to fulfill the purposes described.
8. Controller and Processor
We have tools to protect your personal data from malicious or unauthorized third parties. We take appropriate security measures to protect us from unauthorized access, alteration, disclosure or destruction of data. These measures include internal analyses of our data collection, storage, and processing practices.
We guarantee that your personal data protection is one of our priorities and, in case of an incident, we will take all possible measures to minimize possible harm.
9. Controlador e Operador
The Controller of Personal Data is Moura Dubeux, based at Av. Eng. Domingos Ferreira, 467 – Pina, Recife – PE. All user requests involving personal data should be forwarded to the address above or to the@mouradubeux.com.br dpo email, or through the Contact Us or Contact RI forms on our websites. The Personal Data Processor is a natural or legal person, under public or private law, who carries out the processing of personal data on behalf of the Controller. Moura Dubeux may hire third parties to support its operational activity that will have access to Personal Data as Operators. Likewise, Moura Dubeux may share data with third parties, who will also become Controllers of Personal Data.
10. General Provisions
10.1. Change of content and update.
You acknowledge our right to change the content of this Policy at any time, as required or necessary, such as for adequacy, complying with the law or regulation. You are responsible for checking this notice whenever you access to the platform or use our services. In the event of updates to this document that require new consent collection, you will be notified through the contact channels you provide.
10.2. Electronic Communication.
You acknowledge that all communication made by e-mail (to the addresses provided in your registration), SMS, instant communication applications or any other digital form, are valid, effective, and sufficient for the disclosure of any matter that refers to the services we provide, your personal data.
10.3. Service Channels.
If the User becomes aware that his/her Personal Data is not being processed in accordance with applicable laws, the User may submit a request to the National Data Protection Authority (ANPD).
In case of any doubt regarding the provisions contained in this Privacy Policy, you may contact us through the service channels indicated below:
Customer Relationship Center;
Moura Dubeux Group Complaint Channel;
E-mail of the Person responsible for the Protection of Personal Data / DPO: dpo@mouradubeux.com.br.