Privacy Policy - Samauma

1. OBJECTIVE OF THE PRIVACY POLICY

1.1 - Samauma Empreendimentos Imobiliários S.A. (“Samauma”) values transparency and is committed to the privacy and protection of data for all our partners and clients. Therefore, this Privacy Policy (“Policy”) has been created to clarify how we collect, use, store, process, and protect the personal data of users and visitors to our website (www.samauma.com) or anyone who interacts with Samauma through LinkedIn, Instagram, or any other social media or email.

1.2 This Policy is an internally developed document by Samauma and may be updated from time to time, always aiming to comply with the applicable regulations, especially Brazilian Law No. 13.709 of August 14, 2018 (“LGPD”).

2. DEFINITIONS

2.1 - To help understand the applicability of this Policy, we highlight below some relevant concepts:

- Personal Data: Any information that identifies or allows the identification of a person, such as full name, CPF (Brazilian individual taxpayer registry), email, phone number, address, among others.

- Third Parties: Refers to any individual or legal entity that interacts with Samauma, whether as a client, service provider, supplier, consultant, partner, contracted third party, or subcontractor, among others.

- Processing of Personal Data: Any operation such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, or control of information, modification, or communication carried out with Personal Data.

3. HOW IS PERSONAL DATA COLLECTED?

3.1 - For us at Samauma, it is very important that you understand how we collect your information. Personal Data may be collected through the following means:
- Samauma Website: Samauma’s website, managed by Samauma (www.samauma.com), including messages received through our “Contact Us” form.

- Social Media/LinkedIn/Instagram: Any pages maintained on third-party social media networks or apps managed by Samauma, such as LinkedIn and Instagram.

- E-mail, Text Messages, and/or Other Electronic Messages: Any interaction through electronic communications sent by Samauma group companies based on the communication data we have in our database.

- Samauma Whistleblower Channel: Communications through our whistleblower channel (https://canal.aliant.com.br/samauma).

4. WHICH PERSONAL DATA IS COLLECTED?

4.1 - Samauma may collect various types of information provided through the means described in item 3.1 above, such as:

- Registration and Contact Information: Any information provided that allows us to contact or verify your registration, such as your full name, RG (Brazilian identity card), CPF, date of birth, gender, address, ZIP code, email, social media details, phone number, etc.

- Technical Information about Electronic Devices: Any information about electronic devices used to access one of our sites or applications, such as IP address, operating system type, and browser type and version

- Website/Communication Usage Information: As users interact on our site, we may use automated data collection technologies to gather information such as which links are clicked, which pages are accessed, how long they are viewed, download errors, etc. This information is captured through automated technologies like Cookies, web beacons, and third-party tracking.

- Content Generated by Partners and Clients on Social Media: Any content created and shared with Samauma on third-party social media networks (such as LinkedIn or Instagram) or through posts and comments on our sites or applications may be used by Samauma.

5. COOKIES/SIMILAR TECHNOLOGIES/LOG FILES AND WEB BEACONS

5.1 - A cookie is a small file added to your computer, mobile phone, or other device by visited websites. They are used to make websites work, or work more efficiently, as well as to enable a personalized access experience and provide information to the site owners. Samauma’s sites may use cookies or other tracking technologies.

6. HOW AND FOR HOW LONG IS PERSONAL DATA STORED?

6.1 - We use appropriate technical and organizational measures to keep your Personal Data confidential and secure. However, it is important to note that we cannot guarantee the security of information that the individual has made publicly accessible, such as social media shares.

6.2 - We will use your Personal Data for the time necessary to achieve the purposes for which it was collected or to comply with legal obligations, protect our rights, or fulfill judicial or extrajudicial agreements.

6.3 - Additionally, Personal Data may be retained after the end of its processing in the situations provided for in Article 16 of the LGPD.

7. IS PERSONAL DATA SHARED?

7.1 - Samauma may share the received data with other people and companies such as:

- Other companies in the Samauma group;
- Service providers who assist us in operating Samauma’s business, only as authorized and for specific task.

7.2 - Samauma does not transfer or sell Personal Data to third-party companies for any purpose, including marketing.

8. YOUR RIGHTS

8.1 - The holder of Personal Data may, at any time, contact us through the channels provided at the end of this Policy to:

a) Confirm the existence of Personal Data and access it;
b) Correct Personal Data;
c) Request anonymization, blocking, or deletion od Personal Data.

8.2 - Samauma will respond to requests as far as we can meet and comply with our obligations under law, contract, or necessity. Additionally, when it comes to third-party social media, we may be unable to act on the request made.

9. CHANGES TO OUR POLICY

9.1 - In the event of changes in the manner of collecting and processing Personal Data, this Policy will be updated.

9.2 - Samauma reserves the right to update the Policy at any time. Please check the Policy from time to time to review any updates.

10. CONSENT

10.1 - By providing your Personal Data through any of the means described in this Policy, you agree to this Privacy Policy and all its terms, as well as acknowledge that you have the right to contact us to withdraw your consent at any time, through the channels indicated below.

11. CONTACT

11.1 - For any questions about this Policy and our privacy practices, please contact us through our website (www.samauma.com) or send a correspondence with proof of identity to Samauma’s address:

Address: Rua Doutor Eduardo de Souza Aranha, 153, 6o andar – São Paulo/SP.

12. APPLICABLE LAW AND JURISDICTION

12.1 - This Policy is governed by the laws of the Federative Republic of Brazil, and any disputes must be resolved in the court of São Paulo, State of São Paulo.

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