Private Policy

Privacy Policy
  1. Purpose

This Policy aims to demonstrate the commitment of Nexpe S.A. and its subsidiaries*, hereunder referred to as “Grupo Nexpe ” or “We”, to the privacy and protection of your Personal Data, establishing the rules on the Processing of such in the scope of the services of any company of the Grupo Nexpe and the functionalities of its website(s) and application(s), indistinctively referred to as the “Platform”, pursuant to the applicable laws, with transparency and clarity to you and the market in general.

To access and use the exclusive functionalities on the Platform, you declare that you have read this Policy entirely and attentively, being fully aware of its content and confirming, thus, your free and express agreement with the terms stipulated herein, including the collection of the Data mentioned herein, as well as its use for the purposes specified below.

If you do not agree with the provisions of this Policy, you should discontinue your access or use of the Platform and, if applicable, you may contact us through the channels indicated below.

DISCLAIMER FOR CHILDREN AND ADOLESCENTS AGED UNDER 18

Please do not register or use any form and/or service that requires the provision of personal data on the Platform if you are under 18 years old.

DISCLAIMER TO LEGAL REPRESENTATIVES

Legal representatives shall supervise and represent children and adolescents under the age of 16 (sixteen), and assist adolescents over the age of 16 (sixteen) and under the age of 18 (eighteen), whenever applicable..

  1. About the Data We Collect
    • How we Collect Data. We may collect Personal Data about you when you interact with us in any way, whether in person or using our platforms, applications or websites, or when you conduct business with us. These include:
Which data do we collect? What do we collect for?
Registration data
Full name (i)                  Respond to user requests.

 

(ii)                Identify and validate your identity.

 

(iii)              To comply with the requirements arising from our services.

 

(iv)              To expand our relationship, by informing you about news, features, content, news and other events we consider relevant to you.

 

(v)                To enhance your experience with us and promote our products and services.

 

(vi)              To comply with our legal and regulatory requirements.

NATIONAL ID/ SOCIAL
SECURITY NUMBER / NATIONAL DRIVER’S LICENCE
Date of Birth
Gender
Marital Status
Occupation
Education
Contact phone
Address
 Financial Information
Digital Identification Data
Source IP Address and Logical Port (i)                 Identify and validate your identity.

 

(ii)                To comply with legal requirements for records maintenance established by the Brazilian Civil Rights Framework for the Internet (Law 12,965/2014).

 

(iii)              To comply with our legal and regulatory requirements.

 

(iv)              To mantain record of our personal data processing operations, as established by the General Personal Data Protection Law (Law 13,709/2018)

 

(v)                Improve our Platform.

 

(vi)              Perform statistical analysis of our Platform.

 

(vii)            To better know the profile of our public.

 

(viii)          Prevent Fraud and any other related risk.

Device (operating system version)
Geolocation
Logs date and time each action you perform and Screens you access
Session ID
Cookies
  • Required Data. Many of our services are directly related to some of the data informed in the table above, mainly registration data. Similarly, our Platforms require the provision of some of the above data to admit their use. If you choose not to provide some of this data, we may be unable to provide all or part of our services to you.
  • Data Update and Accuracy. You are solely responsible for the accuracy, truthfulness, or absence thereof, of the data you provide, or for its outdating. Please be aware that it is your responsibility to ensure their accuracy or to keep them up to date.
    • Similarly, We are not required to process or handle any of your Data if there is reason to believe that such processing or handling would cause us to breach any applicable law, or if you are using our Platform for any illegal, unlawful or unethical purpose.
  • Data Base. The database comprised by the collection of information is our property and is held under our responsibility, and its use, access and sharing, when necessary, will be done within the limits and business purposes described in this Policy.
  • Technologies used. We use cookies, pixel tags, local storage and/or other identifiers on our websites for several purposes, which are described in our Cookie Policy. You can manage preferences for cookies and other technologies from your browser or device settings, but this may prevent certain website features from working..
    • You can learn more about cookies by reading our Cookies Policy.
    • All technologies used will always respect the current legislation and the terms of this Policy.
  • We do not use any solely automated decisions that affect You.
  1. How We Share Data and Information
    • Data sharing scenarios. Collect
    • data and recorded activities can be shared:
  • We may share your personal data with competent legal, administrative and government authorities whenever there is a legal determination, request or court order;
  • We may share your personal data when it is required to perform commercial activities and services provided by the Company;
  • We may share your personal data with partner companies, for advertising purposes and statistical analysis at our request; and
  • We may share your personal data automatically in case of corporate changes, such as consolidation, acquisition and merger;
  • We may share your personal data with the other companies in the Grupo Nexpe to offer our services, when authorized.
    • We do not share your Personal Data with furniture manufacturers, appliance suppliers, consortiums, or similar. If you are contacted by an unidentified third party, please contact us through the Communication Channels available in this Policy and we will investigate the matter.
    • Data Anonymization. For the purposes of market intelligence research, disclosure of data to the press, and advertising, the data provided by you will be shared anonymously, that is, in a way that does not allow its identification.
  1. How We Protect Your Data and How You Can Also Protect It
    • Password Sharing. You are also responsible for the confidentiality of your Personal Data and should always be aware that sharing passwords and access data infringes this Policy and may jeopardize the security of your data and that of our Platform.
    • Precautions you should be aware of. It is very important that you protect your Data from unauthorized access to your computer, account, or password, and make sure you always click “logout” when you end your browsing on a shared computer. It is also very important that you know that We will never send electronic messages requesting confirmation of data or with attachments that can be executed (extensions: .exe, .com, among others) or links for eventual downloads.
    • Access to Personal Data, proportionality and relevance. We only access the Personal Data collected internally by duly authorized employees, following the proportionality, demand and relevance standards for our business objectives, in addition to our commitment to confidentiality and protection of your privacy pursuant to this Policy.
    • External Links. When you use our Platforms, you may be conducted through links to other portals or platforms that may collect your information and have their own Data Treatment Policy.
      • It is your responsibility to read the Privacy and Data Processing Policies of such portals or platforms outside our environment and it is your responsibility to accept or reject it. We are not responsible for the Privacy and Data Processing Policies of third parties nor for the content of any websites, content or services linked to environments other than our own.
      • We have business partners who may, from time to time, offer services through functionalities or websites that can be accessed from our Platform. The Data provided by you to these partners will be the responsibility of those partners, and thus subject to their own data collection and use practices.
    • Third-party processing under our directive. If third parties process on our behalf any Personal Data that we collect, they will comply with the conditions set forth herein and with the information security standards, as required.
    • Email communication. To optimize and improve our communication, when we send you an e-mail we may receive a notification when they are opened, provided this possibility is available. Please be aware that the e-mails are only sent from the following domains: @abyara.com.br, @vendasbb.com.br, @bbrk.com.br, @nexpe.com.br, @credimorar.com.br, @desenrola.com.br and @bamberg.com.br.
  1. How We Store Your Personal Data and Log Activities
    5.1 Collected Personal Data and recorded activities are stored in a secure and controlled environment for a minimum period following the table below:
STORAGE PERIOD LEGAL BASIS
Registration data
5 years after termination of the relationship Articles 12, 27 and 34 of the Consumer Protection Code
Digital Identification Data
6 months Article 15 of the Brazilian Civil Rights Framework for the Internet
Other data
During the agreeement and unless you request deletion or revoke consent Article 9, Item II of the Brazilian General Data Protection Law
  • Longer storage periods. For auditing, security, fraud control, credit protection and rights preservation purposes, including those established by the Brazilian Association for Technical Standards (ABNT), we may hold the registration records of your Data for a longer period in cases established by law or regulatory standard, or for rights preservation purposes.
  • Your personal data under our control will be deleted when the purpose for which it was processed has ended and it is no longer necessary to comply with any legal requirement or when the data subject requests its disposal, unless the data storage is expressly authorized by law.
  • The Data collected will be stored on our servers located in Brazil, as well as in a cloud computing environment, which may require transfer and/or processing of this Data outside Brazil.
  1. Your Rights and How to Exercise them
    • Your Basic Rights. You may request our Personal Data Officer/DPO to confirm the existence of Personal Data processing, and to display or amend your Personal Data, through our Communication Channels.
    • Restriction, objection and deletion of data. Using the Communication Channels, you can also:
  • Request a limitation on the use of your Personal Data;
  • Express its objection and/or revoke the consent to the use of its Personal Data, only and exclusively when granted; or
  • Request the deletion of your Personal Data that has been collected by Us.
    • If You request the deletion of Your Personal Data or the revoking of Your consent for purposes fundamental to the regular operation of our Platform and its services, such environments and services may become unavailable to You.
    • If you request deletion of your Personal Data, it is possible that the Data may need to be stored for a period longer than the request for deletion, pursuant to article 16 of the General Personal Data Protection Law, in order to (i) meet a legal or regulatory requirement, (ii) study by a research body, and (iii) transfer to a third party (subject to the data processing requirements set out in the same Law). Whenever possible, we will proceed with the anonymization of your Personal Data.
    • Once the maintenance period has expired and there is a legal need, Personal Data will be deleted using secure disposal methods, or used in an anonymized form for statistical purposes.
  1. Miscellaneous Information about our Policy
    • Amendment and update of the content. You agree that we have the right to change the contents of this Policy at any time, as the purpose or need may require, such as to adapt and legally conform to a provision of law or regulation having equivalent legal force, and it is your responsibility to check it whenever you access the Platform or use our services.
      • If there are updates to this document that require new consent collection, you will be notified through the contact channels you inform.
    • Should any part of this Policy be held to be inapplicable by a Data Authority or court, the remaining terms will remain in full force and effect.
    • Electronic Communication. You agree that all communication made by e-mail (to the addresses informed in your registration), SMS, instant messaging applications or any other digital form, are also valid, effective and adequate for the disclosure of any matter relating to the services we provide, your Data, as well as the conditions of its provision or any other subject addressed therein, being exception only what this Policy provides as such.
    • Service Channels. If you have any questions regarding the provisions contained in this Privacy and Data Processing Policy, you may contact us through the DPO/Service Channel.
      • DPO: dpo@nexpe.com.br
  • Applicable law and jurisdiction. This Policy will be enforced according to the Brazilian legislation, in the Portuguese language, being elected the jurisdiction of your domicile to decide any dispute involving this document, unless specific personal, geographical or functional competence is reserved by the applicable legislation.
    • You, if not domiciled in Brazil, and due to the services offered by Us only in national territory, are subject to the Brazilian legislation, agreeing, therefore, that in case of dispute to be resolved, the lawsuit must be filed in the Court of Rio de Janeiro/RJ.
  1. Glossary
    • For the purposes of this Policy, the following definitions and descriptions are required for better understanding:
  • Data: Any information inserted, processed or transmitted through the Platform.
  • Personal Data: Data related to an identified or identifiable individual.
  • Anonymization: Use of reasonable and available technical means at the time of Processing, whereby a data loses the possibility of association, directly or indirectly, with an individual.
  • Data Protection Officer (DPO): Individual designated by Us to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).
  • Cloud Computing: Cloud computing is a service virtualization technology built from the interconnection of more than one server through a common information network (e.g. the Internet), aiming to reduce costs and increase the availability of sustained services.
  • Access Account: Credential required to use or access the exclusive features of the Platform.
  • Cookies: Small files sent by the Platform, stored on your devices, which store your preferences and little other information, with the purpose of personalizing your browsing according to your profile.
  • Sessions: sessions are small files stored on our servers, which communicate with cookies saved on your devices, to validate your usage session on our Platform.
  • Subsidiaries: (Abyara Brokers Intermediação Imobiliária Ltda., trade name (“Abyara”); Bamberg Brokers Assessoria Imobiliária Ltda., trade name (“Bamberg Imóveis Únicos”); Basimóvel Consultoria Imobiliária Ltda., trade name (“BBRJ”); Morumbi Brokers Administração de Bens e Serviços Ltda., trade name (“Morumbi Brokers”); Niterói Administradora de Imóveis Ltda., trade name (“BB Niterói”); Rede Morar Ltda., trade name (“Credimorar”); Tropical Corretora e Consultoria Imobiliária Ltda., trade name (“Desenrola”, “Convivera” and “Tropical”).
  • IP: Abbreviation for Internet Protocol. It is an alphanumeric code that identifies the users’ devices on the Internet;
  • Logs: Activity logs of any users who use the Platform.
  • Session ID: Identification of the user session when accessing the Platform.
  • Automated decisions solely: These are decisions which impact a user that have been programmed to work automatically, without the need for a human intervention, based on automated processing of personal data.
  • Processing: Any operation performed with Personal Data, such as those regarding including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

Our Platforms, its Terms of Use and our Cookie Policy are subject to continuous improvement. They may be updated at any time, subject to the absence of any legal restrictions, and you are required to check them periodically. If this Privacy Policy is substantially amended, we will notify you through the communications channels provided, to request that you become aware of its new content.

The Company’s DPO is responsible for amending this Policy whenever necessary.

Cookies Policy
  1. Purpose

This Policy aims to demonstrate the commitment of Brasil Nexpe Participações S.A. and its subsidiaries*, jointly referred to as “Nexpe Group” or “Company”, with your privacy within the scope of the services and functionalities of our websites, in compliance with the applicable laws, with transparence and clarity for you and for the market in general.

  1. Introduction

Our websites use cookies to enable some features, to improve your browsing experience, and to allow us to offer you a more customized and unique experience.

We seek to explain in a transparent way how, when and why we use such resources.

By accessing our website, we ask you whether you consent to the use of cookies, which are subject to the terms of this Policy.

If you do not agree with the use of cookies in this form, depending on the Nexpe Group website you may: (i) refuse to accept them by clicking “I do not accept” on the notice appearing on your screen when you access our website, (ii) adjust your browser settings to not allow the use of cookies or (iii) not access our website.

We remind you that rejecting the use of cookies or disabling them in your browser may impact your experience when browsing our websites and restrict some of their purposes.

For any questions or concerns regarding this Cookie Policy, you may contact us at: dpo@nexpe.com.br.

  1. What are cookies?

Cookies are digital files with small pieces of data (usually with a unique identification) that are stored on your device through your browser or application and which store information related to your preferences.

  1. What are cookies used for?

Cookies are used to enhance your experience, both in terms of performance and usability, since the content made available will be targeted to your needs and expectations.

They also allow our websites to store information about your visit, your preferred language, your location, the frequency of your sessions, and other parameters we consider relevant to improving your experience.

In addition, cookies may be used to collect anonymous, aggregated statistics that allow us to understand how users use and interact with our websites and to improve their structure and content. Since these statistics are anonymous, we cannot identify you personally from them.

The use of cookies is standard on any website nowadays. Their use does not damage in any way the devices (computers, smartphones, tablets, etc.) on which they are stored.

  1. What kind of cookies we use?

We use two types of cookies on our website: session cookies and persistent cookies.

  • Session Cookies: are temporary cookies that remain stored until the user quits the website or closes the browser.
  • Persistent Cookies: these are cookies stored on the user’s device until they are deleted (the period during which the cookie remains on the device depends on its “lifetime” and browser settings).

Cookies (session or persistent) can be classified according to their purpose:

  • Strictly Mandatory Cookies: allow you to navigate and access the safe areas of the website. These cookies will ensure that our website will operate correctly.
  • Analytics Cookies: these cookies collect anonymous statistical data to analyze website usage and performance.
  • Functionality Cookies: these are used to ensure that additional functionality is available on the website or to store the preferences defined by the user, whenever they use the same device.
  • Advertising-Specific Cookies: target advertising based on user interests, helping to determine the success of applications and the effectiveness of third-party advertising.
  1. What do we use cookies for?

The following are details of the cookies we use on our website and the respective purpose for which they are used:

  • Strictly Mandatory Cookies
Cookie’s Name Provider Expiration Purpose
Urlcookie Nexpe When the browsing session is ended It saves searching settings in cookie.
UrlInicial Nexpe When the browsing session is ended It sets initial URL of the campaign in a cookie.
Campaign Nexpe When the browsing session is ended Campaigns are similar to search pages, but include pre-selected listings. Cookies are used to record what users are browsing in a respective campaign, the stored information is useful to inform the user if they are misusing the campaign due to changes in the filters.

 

  • Analytics Cookies
Cookie’s Name Provider Expiration Purpose
Google Cookies Google When the browsing session is ended Google Analytics Features
Facebook Cookies Facebook When the browsing session is ended Facebook Analytics Features
LinkedIn Cookies LinkedIn When the browsing session is ended Facebook Analytics Features

 

  • Feature Cookies
Cookie’s Name Provider Expiration Purpose
Io googlespeech.nexpe .com.br When the browsing session is ended Voice search feature
LgpdNexpe nexpe.co When the browsing session is ended It records the cookie warning notification
BbrkForm_nome Nexpe When the browsing session is ended It records the user’s name after submitting a contact form to be available in future mailings using a previously filled out field
BbrkForm_e_mail Nexpe When the browsing session is ended It records the user’s email after submitting a contact form to be available in future mailings using a previously filled out field.
BbrkForm_celular Nexpe When the browsing session is ended It records the user’s phone number after submitting a contact form to be available in future mailings using a previously filled out field.

 

  • Advertising Cookies
Cookie’s Name Provider Expiration Purpose
Google Cookies Google When the browsing session is ended Support for Google advertising services
Facebook Cookies Facebook When the browsing session is ended Support for Facebook advertising services
LinkedIn Cookies LinkedIn When the browsing session is ended Support for LinkedIn advertising services

 

  1. Is it possible to control or delete cookies?

Most Internet browsers are configured to automatically accept cookies.

You can change the settings to block the use of cookies or to notify you when a cookie is being sent to your device. There are several methods for managing cookies.

By disabling cookies, you may not be able to access some areas of our website, or you may not receive customized information when you visit a page.

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

To enable you to simply and intuitively manage your cookie preferences from your browser, you can use one of the links below:

  • For more information on “Private Browsing” and cookie management in the Firefox browser, click here;
  • For more information on “Browsing as Incognito” and cookie management in the Chrome browser, click here;
  • For more information on “Private Browsing” and cookie management from your Internet Explorer browser, click here;
  • For more information on “Private Browsing” and cookie management from your Safari browser, click here;
  • For more information on “Private Browsing” and cookie management in the Opera browser, click here;

We hope we have clarified this issue for you, and as mentioned before, we do consider it safer to enable cookies on demand, to ensure proper performance and interaction with the features you use on our websites.

Our websites, this Cookies Policy and our Privacy Policy contents are subject to continuous improvement. They may be updated at any time, subject to the absence of any legal restrictions, and you are required to check them periodically.

The Company’s DPO is responsible for amending this Policy whenever necessary.

*Subsidiaries: (Abyara Brokers Intermediação Imobiliária Ltda., trade name (“Abyara”); Bamberg Brokers Assessoria Imobiliária Ltda., trade name (“Bamberg Imóveis Únicos”); Basimóvel Consultoria Imobiliária Ltda., trade name (“BBRJ”); Morumbi Brokers Administração de Bens e Serviços Ltda., trade name (“Morumbi Brokers”); Niterói Administradora de Imóveis Ltda., trade name (“BB Niterói and Desenrola”); Rede Morar Ltda., trade name (“Credimorar”); Tropical Corretora e Consultoria Imobiliária Ltda., trade name (“Desenrola”,  “Convivera” and “Tropical”).

 

Last update: March 30, 2022