Privacy

1. Legal Concepts:
The following legal concepts and definitions are applicable together with other defined terms to be used by the Parties and are in accordance with the provisions of the General Data Protection Law (Law 13.709/18), namely:

“Modo Construção e Desenvolvimento Imobiliário SA” or “MCDI”: Modo Construção e Desenvolvimento Imobiliário SA, a legal entity governed by private law, regularly registered with the CNPJ/MF under n. 28.758.679/0001-00.

“Personal data”: information related to an identified or identifiable individual;

“Sensitive personal data”: personal data about racial or ethnic origin, religious belief, political opinion, membership of a trade union or information about religious, philosophical or political organization affiliation, data referring to health, sexual life, genetics or biometrics data, when linked to the individual;

”Holder” or “user”: natural person to whom the personal data object of processing refers to;

”Processing”: refers to any operation performed on the personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification , communication, transfer, broadcast or extraction;

“Shared use of data”: communication, dissemination, international transfer, interconnection of personal data or shared processing of personal databases by public agencies and entities in the fulfillment of their legal jurisdictions, or between these and private entities, mutually, with specific authorization, for one or more types of processing allowed by these public entities, or between private entities;

“Anonymization”: process in which data loses the possibility to be directly or indirectly associated to an individual, using reasonable technical means that are available at the time of processing;

“National Data Protection Authority (ANPD)”: public administration body responsible for overseeing, implementing and supervising the compliance to this Law throughout the national territory.

2. the Sources of Personal Data, what is the Personal Data collected by us and how it is collected:
We collect Personal Data from Holders through the following sources:

2.1 MCDI website
MCDI website may collect Personal Data from users through an online form on the contact pages, to register suppliers, to offer land or even to register those interested in taking part in candidate selection for a position at MCDI.

2.1.1 Online Forms
The user, when accessing the “contact” page, must provide Personal Data in order to send a message to MCDI team.

The Personal Data required may be: (I) Full name (II) E-mail (III) Landline number (IV) Mobile number.

The user can also register as a supplier through the “Become a supplier” page, and must also provide their Personal Data in order to register.

The Personal Data required may be: (I) Full name (II) E-mail (III) Landline number (IV) Mobile number.

The user may register to offer land to MCDI through the “Offer a land” page, and must provide some of their Personal Data to register.

The Personal Data required may be: (I) Full name (II) E-mail (III) Landline number (IV) Mobile number.

2.1.2 Customer Restricted Area
MCDI website offers a restricted for its customers, suppliers, service providers and other third parties through which they may have access to files eventually shared by MCDI.

Access to the restricted are requires prior registration performed by MCDI itself.

In order to register, it will be necessary to provide the following Personal Data: (I) Full name (II) E-mail.

2.2 Cookies
Cookies: These are small text files that can be placed on your computer or mobile device by websites or web services you use. They are used to ensure proper functioning of websites and other online services.

As for the Personal Data collected through the use of cookies, all information can be found under the section “About the use of Cookies, log and similar files”.

3. Sensitive Personal Data:
MCDI does not carry out any collection of Personal Data considered sensitive under the General Data Protection Act (LGPD), therefore we do not intend to collect or process sensitive personal data in the normal course of your interactions with the website.

4. About the use of Cookies, log and similar files:
Cookies are small text files that can be placed on your computer or mobile device by websites or web services that you use. They are used to ensure the proper functioning of websites and other online services, as well as to provide information to the owners of the website or online service.

Cookies are used to improve the use and functionality of the websites and other compatible web services and to better understand how our visitors use our websites, online services, the tools and services they offer. For navigation on the website, MCDI only uses cookies from third parties, such as Google, to monitor the activity of the website itself, so MCDI does not collect any Personal Data through its own cookies.

It is important to remember that it is up to you to ensure that your computer or mobile device settings reflect whether you consent to accept Cookies or not.

MCDI uses the following types of Cookies on its websites:

Necessary Cookies: Necessary cookies help make a website usable by allowing basic functions such as page navigation and login to protect areas of the website. The website cannot function properly without these cookies.

Session Cookies: These are temporary use cookies, which are deleted as soon as the user closes their browser.

Persistent Cookies: Persistent cookies are those that remain stored in the user’s browser until their manual deletion or until the duration of the cookie.

Cookies that share user information to third parties: These are cookies used by third parties that collect and share user information to MCDI partners and help to understand how users interact with the website, anonymously collecting and reporting information, as well as displaying advertisements that are relevant to the user.

Most browsers allow you to set rules to warn you before accepting Cookies or simply rejecting them. You do not need to have all Cookies enabled to use or browse the MCDI website, only on those that are strictly necessary. We recommend that You see the “help” button on your browser how to perform this type of configuration. Remember that if you use different browsers, or even different computers and/or handheld devices in different locations, you will need to ensure that each device and browser is set to your personal Cookies preferences.

In addition, we store some information that we automatically receive every time a customer interacts with the MCDI website. Internet Protocol (IP), browser type and pages viewed on our website are some examples of this collection, which is carried out using Cookies.

5. About the use of Personal Data:
The following items describe the purposes for which MCDI handles the processing of Personal Data of the holders, and the different types of Personal Data that we collect for each purpose.

Consumer Services: Users’ Personal Data are used for the purpose of providing services to users, including registration of people interested applying for positions, as well as answering their complaints, questions and suggestions. This usually requires certain personal contact information and information about the reason for your complaint, question or suggestion.

Legal reasons or merger/acquisition: If MCDI or its assets are acquired by, or merged with, another company, including by reason of bankruptcy, we will share your Personal Data with our legal successors, respecting the requirements of current legislation. We will also disclose the Personal Data of the holders to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from the competent legal authority; (iv) to protect our rights, privacy, safety or property; or (v) to enforce the terms of any agreement or the terms of our website, products and services, pursuant to applicable law.

Other purposes and situations in general: In accordance with current legislation, MCDI uses the Personal Data of users for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of our advertising campaigns . MCDI may also use Users’ Personal Data to manage and operate their communications, IT and security and data protection systems.

6. About Sharing Personal Data:
We may share Users’ Personal Data with the following third party organizations:

Service Providers: These include partners that are used by MCDI to help operate its business. Service Providers may only access Personal Data on behalf of MCDI for specific tasks that have been requested directly by MCDI.

7. About the retention and termination of the processing of Personal Data:
In respect of the General Data Protection Law (Law nº 13.709/18), as well as other applicable legislation, MCDI will use Personal Data for as long as it is necessary to satisfy the purposes for which the Personal Data was collected, as described in this policy, or to comply to the requirements applicable laws.

The request for deletion of Personal Data after the end of its respective treatment will be subject to its possibility, as well as the technical limits of the activity.

Thus, upon termination of the processing of the Personal Data of its users, they will continue to be kept for the regular fulfillment of legal or regulatory obligations and the regular exercise of rights in judicial, administrative or arbitration proceedings which are or may be submitted to MODO CONSTRUÇÃO E DESENVOLVIMENTO IMOBILIÁRIO S.A.

You can obtain further details about the retention of Personal Data through the communication channels detailed in this policy.

8. About sharing, storing or transferring Personal Data:
MCDI always seeks to adopt adequate measures to ensure that any and all Personal Data is kept confidential and secure. However, these protections do not apply to information you have chosen to share in public areas such as third-party social networks.

Persons Authorized to Access Users’ Personal Data: Any and all Personal Data will be processed by our employees or authorized agents, as long as they need to have access to such information, depending on the specific purposes for which the Personal Data have been collected.

Measures taken in operational environments: We store any and all Personal Data in operational environments that count on reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to ensure protection of Personal Data.

9. About the rights of the holder regarding Personal Data:
The holder of personal data has the right to confirm the existence, access, review, modify and/or request an electronic copy of the information in their Personal Data file that is processed by MCDI.

The holder is also entitled to request details about the origin of his Personal Data or the sharing of this data with third parties.

At any time, the holder of personal data may also limit the use and disclosure, or revoke consent to any of the processing activities of their Personal Data by MCDI, except in situations required by the current legislation.

These rights may be exercised through the communication channels described in this policy.

MCDI will make every effort to ensure that any questions you may have about the way in which your Personal Data will be processed are regularly addressed. Furthermore, the user has the right to complain to the competent data protection authorities.

10. Applicable law and competent jurisdiction:
Any conflicts arising from the use of the application will take into account the legislation and jurisdiction of the territory of collection and processing of the data regarding the data protection law, and, in the absence or omission of this, the parties declare that they will be subject to the legislation of the headquarters of MODO CONSTRUÇÃO E DESENVOLVIMENTO IMOBILIÁRIO S.A.

11. Changes to our Privacy Policy:
Whenever MCDI decides to change the way Personal Data is handled, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, as long as we maintain compliance with current legislation.

We recommend that users access this policy frequently, or whenever there is any doubt, to check for updates or changes made to this Privacy Policy.

12. How to contact us:
The HOLDER of Personal Data may use the communication channels to:

• Asking questions or comments about this Policy and our privacy and Personal Data protection practices;
• Complain;
• Confirmation of the existence of processing of Personal Data;
• Obtain information on how to access Personal Data;
• Correcting incomplete, inaccurate or outdated Personal Data;
• Request the deletion of personal data processed with your consent, except in the cases provided for in current legislation;
• Request details of the public and private entities with which we share Personal Data;
• Other rights of the holder of personal data, according to the General Data Protection Law (Law n. 13.709/18).

For this, we ask that you contact us using the following channels:

Responsible for the Processing of Personal Data:

William Tadeu Domingues
Contact: dpo@mcdi.com.br

Privacy Portal:
www.mcdi.com.br/privacidade

MCDI will receive, investigate and respond, within a reasonable period of time, to any request or complaint about the processing of Personal Data, including complaints about breaches of the rights of the holders under the current laws of privacy and protection of Personal Data.