PRIVACY POLICY

At Calper, privacy and security are priorities and we are committed to being transparent when handling your Personal Data. With this in mind, this Privacy Policy establishes how we collect, use and transfer the information of customers and other people who visit our website.

By using our services, you understand that your personal information will be collected and used as set forth herein, and as established by the General Data Protection Regulation (DPPR, Federal Law 13.709/2018) and other applicable rules of the Brazilian legal system.

Therefore, Calper is bound by the provisions of this Privacy Policy.

As a condition for using the exclusive features of our website you are required to read, understand and be aware of the rules established in this Policy. If you continue browsing, we will understand that you will declare the abovementioned to be true.

If you are under 18 (eighteen) years of age, please do not register on our website or fill out any forms that require Personal Data. Remember that your activities must be supervised by an adult and your interests represented or assisted by your legal representative.

1 – Collected data and its purposes

Your Data, including Personal Data, may be collected at different times within the context of our operations. Among them we can mention our sales stands, platforms, applications, websites and when entering into commercial agreements with Calper as well as with the Special Purpose Entities especially created for each project.

The collection of your personal information varies depending on the relationship established with us, that is, whether you are a customer, an investor, a supplier or other, as applicable.

The Data and/or Personal Data may be provided directly by you or collected automatically, as per the non-exhaustive examples indicated below:

A – The personal data provided by the information Owner is registration data, such as: full name; ID number, CPF [Individual Taxpayer Registration Number] or CNH [Driver’s License Number]; Email; Phone number; Date and place of birth; Nationality; Genre; Marital status; Profession; Complete Address; Banking Information; Spouse Information, among others.

They are collected to meet users’ requests; to identify and authenticate users; to fulfill obligations arising from the services we provide; to enrich the experience and promote our products and services; to comply with legal and regulatory obligations; to expand and strengthen our relationship and to keep users informed about news, features, content, news and events that we consider relevant to them.

B – The Personal Information collected automatically is the digital identification data, such as: IP address; Original Logic Gate; Device and Operating System Version; Geolocation; records of date and time of every action performed; Screens accessed; Session ID and Cookies (https://www.calper.com.br/politica-de-privacidade, in the Cookies tab);

They are collected for to identify and protect the individuals visiting our digital channels; to fulfill the record keeping obligation established by the Civil Rights Framework for the Internet (Law No. 12.965/2014); to improve and perform statistical analyses of our Platforms; fulfill our legitimate interest to offer services and products in accordance with your preferences, to comply with legal obligations and prevent fraud and any other associated risk.

• We emphasize that you are fully responsible for the accuracy, or the lack of it, regarding the information you provide, as well as for keeping it up to date. Also, that we may refuse to process any of your Data if we have any reason to believe that such action or data treatment may lead to any type of breach of the applicable law, or in the event it is verified that you are using Calper’s services, products and websites for any illegal, unlawful or immoral purposes.

• It is worth mentioning that many of our services depend directly on some of the Personal Data mentioned above, especially registration data. Therefore, if you choose not to provide some of the Data, we may be unable to provide you the services desired, in whole or in part.

• We process your Data based on your consent. Your consent is a free, informed and unequivocal expression through which you authorize us to process your information. Thus, in line with the Data Protection Law, your Data will only be collected, processed and stored with your prior and express consent.

By using our services and providing your personal data, you are aware and consenting to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

Your consent can be withdrawn at any time and at no cost.

It is important to note that to revoke your data treatment consent could prevent a platform’s functionality to perform appropriately in the event it depended on that operation. Such consequences will be informed in advance.

• Calper uses Cookies on the Platform, and it is up to you to manage your preferences and configure your Internet browser if you wish to block them. However, certain configurations could limit the functionality of the Platform.

• Finally, we emphasize that we do not use any completely automated decision that could impact you, and we are the owner and therefore responsible for the database built based on the processing of the data collected, its use, access and sharing, when necessary, will be carried out within the limits and purposes established herein, with technologies used in accordance with the current legislation and the terms set forth in this Policy.

2 – Data Sharing

2.1.      The collection of data and the activities mentioned can only be shared as follows:(i) With competent judicial, administrative or governmental authorities, if legally determined, required or requested or via court order;(ii) For credit analysis and granting;(iii) With the real state consultant (realtor), is the purchase is intermediated;(iv) With financial institutions, when requested by you;(v) With the administrator of the condominium, which will provide the project’s management and administration services;(vi) In the event of corporate transactions, such as mergers, acquisitions and incorporations, automatically;(vii) With partner companies, for statistical and analytical purposes);(viii) When needed for the development of commercial activities and services provided through the Platform;(ix) With Calper’s partner organizations, service and/or infrastructure providers, third parties that contribute to the company’s activities;(x) For the protection of Calper’s rights in any type of conflict, including those of legal nature.

2.2.      In order to preserve your privacy, we will not share your Data or Personal Data with unauthorized third parties, other construction companies or companies not part of our economic group. If you are contacted by any unidentified third party claiming to have obtained your data from us, please contact us as soon as possible through the Service Channels described in this Policy.

3 – Shared Data Protection

To keep your personal information secure, we use physical, electronic and managerial tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the treatment and the risks that any violations would generate for the rights and freedom of the person owning the data collected and processed.

Among the measures we have adopted, we highlight the following: (i) only authorized professionals have access to the personal data collected; (ii) access to your personal data is carried out in compliance with the principles of proportionality, necessity and relevance to our business objectives, in addition to the commitment to confidentiality and preservation of your privacy; (iii) your personal data is stored in a safe and suitable environment.

Calper is committed to adopting the best attitudes to avoid security incidents. However, we need to point out that no virtual page is entirely safe and risk-free. It is possible that, despite all our security protocols, there could be problems caused by third parties, such as cyber attacks by hackers, or even as a result of negligent or reckless behavior on the part of the user/customer.

In the event of a security incident that could generate relevant risk or damage for you or any of our users/clients, we will inform the ones affected and the National Data Protection Authority, in line with the provisions of the General Data Protection Law.

4 – Data Storage

Your personal data collected will be used and stored for as long as necessary to fulfill the provision of the service or to achieve the purposes listed in this Privacy Policy, considering the rights of data holders and controllers.

User’s personal data will be excluded from our data base or anonymized at the end of the storage period, or when the user requests their disposal, unless the maintenance of data is expressly authorized by law.

The information may be kept to comply with legal or regulatory obligations; transfer to a third party, provided that the data processing requirements are complied with; for auditing, security, fraud control, credit protection and rights preservation purposes, including those determined by the Brazilian Technical Standards Association (ABNT).

That is, your personal information essential for the fulfillment of legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be kept, despite the exclusion of other data.

The storage of collected data reflects our commitment to the security and privacy of your data. The technical protection measures and solutions we employ can ensure the confidentiality, integrity and inviolability of your data. In addition, we also have risk-appropriate security measures and access control to stored information.

5 – Rights of Data Owners and how to Exercise Them

5.1.      We assure our users, customers and investors the rights of data holders provided for in article 18 of the General Data Protection Law. With this in mind, here is a list of the main rights you are entitled to, and we guarantee that you can exercise them, free of charge and at any time, through the channels indicated in Clause 5.2 below:

• Request confirmation about the existence of Data processing, information about your Personal Data being processed and access to them;
• Request any incomplete, inaccurate or outdated information to be corrected by the means required by the specific regulation, when necessary;
• Request the use of your personal data to be limited;
• Request the anonymization, blocking or deletion of unnecessary, excessive data, or data which may have been treated in violation of the law;
• Request your data to be transferred another service or product provider, if this is done expressly and respecting our intellectual property or business secret;
• Request Personal Data processed with your consent to be deleted.  In the event there may still be a reason for such data to be kept, it may need to be kept for a period longer than the specified in the deletion request.
• Revoke and/or oppose to consent you Personal Data to be used for any purpose you have previously consented to. This act will not consider the previous processing of your data unlawful. If you withdraw your consent for purposes essential to the regular functioning of our environments and services, they may become unavailable to you;
• Request information about third parties with whom we share your Data, limiting such disclosure to information that does not violate our intellectual property or business secret;
• Get information about the possibility of not providing your consent and about the consequences of denial.

5.2.      To exercise your rights as a holder of personal data, send an email to dpo@calper.com.br.

5.3.      In order to ensure your correct identification as the holder of the personal data object of the request, we may request documents or other evidence that can prove your identity, seeking to prevent fraud. In this case, you will be informed in advance.

6 – Cookies or browsing data

Calper uses Cookies, which are text files sent by the Platform to your computer and stored there, containing information related to browsing our website. In short, Cookies are used to improve user experience.

By accessing our website and consenting to the use of Cookies, you declare to be aware of and accept the use of a browsing data collection system with the use of Cookies in your device.

We use the following Cookies:

You may, at any time and at no cost, change the permissions, block or refuse Cookies. However, revoking your consent for certain Cookies may prevent some Platform features to work correctly.

For more information about the Cookies we use and how they work, please access our Cookies Policy, available at https://www.calper.com.br/politica-de-privacidade.

7 – General Provisions

7.1.      This Privacy Policy may be amended at any time, according to the purpose or need, such as for legal adequacy and compliance with a law or rule with equivalent legal force, and it is up to you to check it whenever you access the Platform or use our services. If this document is updated with information that requires your consent, you will be notified through the contact channels you make available.

7.2.      You acknowledge that all communication carried out by email (to the addresses informed in your registration), SMS, instant communication applications or any other digital form, are also valid, effective and sufficient for the dissemination of any matter in reference to the services that we provide, to your Data, as well as to the conditions of its provision or to any other subject addressed therein, the only exception being as expressed in this Policy.

7.3.      Calper has business partners that may eventually offer services through features or websites indicated on the Platform. If you provide any information to such partners, the responsibility for the Treatment of such information rests exclusively with the partner.

7.4.      If, when accessing the Platform, you are led, via a link, to other portals or platforms that may collect and/or process your Data or Personal Data, check if there is a privacy and data processing policy available; you are fully responsible for accepting or rejecting the conditions set out there, and be aware that we are not responsible for conditions imposed by third parties, content on their websites or services offered in environments other than our own.

7.5. If you have any questions regarding the provisions set forth herein, please contact our DPO/Personal Data Protection Officer directly by email at: dpo@calper.com.br.

Cookie Policy

This Cookies Policy is an addition to Calper’s Privacy Policy available at: (https://www.calper.com.br/politica-de-privacidade). The purpose of this document is to demonstrate the company’s commitment to the privacy and protection of your Data, as well as to establish the rules for the Treatment of such data in accordance with the laws in force.

Here you will find clear and objective information about what Cookies are, which Cookies we use in our applications, what role they play and how to set them.

1.     Definitions

Cookies are small text files or pieces of information that are downloaded into your computer, smartphone, or any other internet-enabled device when you visit our Platform. They contain information about your navigation on our pages and retain only information related to your preferences. Cookies can be classified in terms of ownership, time, and purpose:

By accessing our Platforms, you consent to the use of cookies in accordance with this Policy. In case you do not agree to the use of Cookies in this manner, you should adjust your browser settings as to not to allow their use, or not access the Platforms. Disabling the use of cookies may impact your user experience when visiting the Platform.

2. Why do we use Cookies?

The use of cookies is common on any digital platform these days. They enhance the user experience by making our applications easier and more personalized, based on your choices and browsing behavior.

Hence, we seek to understand how you use our applications and adjust the content to make it more relevant to you, in addition to remembering your preferences.

Cookies participate in this process as they store, read, and execute the necessary data to fulfill our purpose. Cookies may also be used to compile anonymous, aggregated statistics which allow us to understand how users utilize our Platform and improve its structure and content.

3. What kind of Cookies do we use? 

The Cookies below may be used on the Platform. It is important to remember that you can manage the permission granted for each Cookie in your browser.

Also, since Cookies capture data about you, we encourage you to read our Privacy Policy, available at (https://www.calper.com.br/politica-de-privacidade).

4. Cookie Management

The installation of cookies is subject to your consent. Although most browsers are initially set up to automatically accept cookies, you can review your permissions at any time to block them, accept them, or turn on notifications for when certain cookies are sent to your device.

Currently, the first time you access our applications, you will be required to agree to their installation. Only after your acceptance they will be activated.

As previously mentioned, at any time and without charge, you can change permissions, block, or refuse Cookies. You can also configure them on a case-by-case basis. However, revoking a consent for certain Cookies may prevent some platform features to function properly.

If you use different devices to access our Platform (computer, smartphone, tablet, etc.), you should ensure that each device’s browser is adjusted to meet your preferences regarding Cookies.

You can manage your browser’s cookies at the Cookie management area of the browser.

5. Final Provisions

If you have any questions about the information contained herein, you can reach us through the Contact Us portal (https://www.calper.com.br/contato/), the Calper Relationship Center (crc@calper.com.br) or by contacting our DPO/Personal Data Protection Officer directly (dpo@calper.com.br).