PRIVACY POLICY

1. ABOUT USSZ EMPREENDIMENTOS, registered in the CNPJ under No. 28.086.378/0001-79, with headquarters at Rua 284, 660, sala 2, Meia Praia, Itapema, Santa Catarina, CEP 88220-000, hereinafter referred to as " ZAH,” is a real estate developer and builder. We care about protecting the personal data of our customers, website visitors and users of our products (collectively, “Users”). This privacy policy provides details about how your personal data is collected, shared and used by ZAH. For purposes of the General Data Protection Law of Brazil (LGPD), ZAH and our brands that you have contacted to inquire about a product or service is the data controller.

2. DATA COVERED BY THIS PRIVACY POLICYThis privacy policy covers personal data, including any of your data that we collect, use and share, as described below. This privacy policy applies to ZAH websites, our products and services and our mobile applications (collectively, “Services”). This privacy policy does not cover how our Users may use or share data they collect using our services.
When using our website, your personal data will be collected, used and shared in accordance with the provisions of this privacy policy.

3. DATA WE COLLECT FROM YOUWhen you use our website, we gather the following data (described below). We collect this data for the purposes described in “How we use your data.”

3.1. INFORMATION YOU VOLUNTARILY PROVIDE USWe collect the following data when you provide it: Information you provide for any registration process, such as your email address when you provide it; Information you provide in any registration process, including in relation to an offer (such as your name, email address, telephone number, location); Data you provide when you call or email us (for support or otherwise) or when you use our products or services; Data you provide in the course of your relations with us (for example, information about your business); Any other information you voluntarily provide us, such as voluntary survey responses.

3.2. INFORMATION WE COLLECT ABOUT YOUR BROWSING AND DEVICESWe collect data related to your online activities on our websites, including the following:
Network location and IP address; Browser type and version; Type of device you use, operating system version and device identifier; Location; Screen resolution and screen color processing capability; How you came to our Services and any links you click on to leave our Services; When you update your information, you communicate with us; Metadata about your use of our Services and emails that we send you (including clicks and pages visited); Your interactions with the videos we offer you; Problems you encounter that require support or assistance; and Any device or other method of communication that you use to interact with the Services. We store the data we collect in a variety of places in our infrastructure, including system log files, back-end databases and analytic systems.

3.3. INFORMATION WE ACQUIRE FROM OTHER SOURCESWe also collect the following data from other sources:
Data that is publicly available; Data that you allow us to receive from third parties; and we also collect data that you may provide during telephone conversations with us, which we may monitor or record. We may use any data we collect with other information we have about you to help us update, expand and analyze our records, identify new customers or offer products that may be of interest to you. If you provide us with personal data about third parties, or if others provide us with their data, we will only use it for the specific purposes for which it was provided.

4. HOW WE USE YOUR DATAWe use the data we collect, both on its own and in combination with any other data we collect about you, for the following business and company purposes:
To provide you with the products you requested; To provide you with useful content; To offer and improve our products; To provide requested information or technical support; To facilitate the use of our websites; To improve the advertising and marketing of our Services (subject to your consent when required by applicable laws); To advertise and market third-party products (subject to your consent, when required by applicable laws) To communicate with you; To target current or potential customers with products through online advertisements on third-party websites such as Google (subject to your consent when required by applicable laws); To help provide you with a personalized experience or otherwise adapt our products to you; and as described elsewhere in this privacy policy. We also use the data we receive to produce reports on trends and statistics, such as mobile search trends, email open rates by sector, recommended campaign practices, or the number of site visitors or people who clicked on our sites or rated or purchased our products.

5. DATA SHARINGAs described below, we only share certain personal data with:
Other members of our corporate family; Our partners; Authorized users in your organization. We may also share your data in a sale, merger, acquisition or corporate reorganization, or as required by law (e.g. law enforcement).

5.1. DATA SHARING WITH PARTNERSWhen we share your personal data with third-party partners, including marketing and advertising partners, that data includes your name, email address, and other information that allows these partners to:
Help you use our products, communicate offers, services or products that may be of interest to you, and offer your products or services. Our partners may use cookies, web beacons, pixels, tags, scripts and similar technologies for advertising based on your browsing history and interests. If you wish to opt out of interest-based advertising, click here. If this sharing requires your permission, we will do so only with your consent.
In addition, our partners are prohibited from using your contact information without your consent for any purposes other than those described above.

5.2. CORPORATE REORGANIZATIONShould we enter into a merger, acquisition, sale of all or a substantial part of our assets, or other similar sales transaction, your data will be transferred as part of this transaction. We will notify you by email and/or a prominent notice on our website of any transfer and any choices you may have regarding your data.

5.3. LEGAL PROCEEDINGSIf we are legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may share your personal data with courts, public authorities (including to satisfy national security or law enforcement requirements) and other relevant third parties, such as Internet service providers, to conduct an investigation, respond to a third party or subpoena or court order, in a legal case, or to avoid harm to a third party, or to seek other measures when you or a third party undertake the following:
Violate our terms and conditions of use; Cause damages or otherwise violate property or other legal rights, of our company, other users or third parties; or violate federal, state, local or other applicable laws. This disclosure may include the transfer of your data to the United States of America and elsewhere. To the extent that we are legally permitted to do so, we will notify you if we are required to provide your personal data to third parties in connection with a court order.

6. DATA SECURITYWe take customer data security seriously. We employ internal policies and controls to try to ensure that customer data is not lost, accidentally destroyed, misused or shared, and that it is only accessed by employees who reasonably require access based on their responsibilities.
We address security on several levels, including physical security, network security, host security, software security and user account security. We have internal security policies to support these areas.
The sharing of data via internet, e-mail or text message is not completely secure. While we do our best to protect your personal data, we cannot guarantee the security of data transmitted through our Services or by email. Any transmission is at your own risk. Once we have received your data, we take appropriate technical and organizational measures to protect your personal data from loss, theft or unauthorized use, access or modification.

7. TRACKING TECHNOLOGY AND ONLINE ADVERTISINGWe use cookies and other tracking technology to make our websites easier to use and to better adapt them to your interests and needs. We use the data we obtain from cookies and other tracking and profile creation technologies to learn more about you and provide you with personalized advertising based on your behavior on our websites. We also use this technology to compile data that allows us to better understand our customers and visitors.
In addition to our primary cookies, we also allow third parties to use cookies or related technologies on our websites. For example, paid sponsors or affiliates may use third-party cookies to identify you as a referral so that they can be compensated if you sign up for our services.
We perform cross-device tracking which allows us to deliver more relevant advertising to multiple devices.
We also use Google Analytics to track user interactions to compile reports that improve our websites. These reports disclose website trends without identifying individual visitors.

8. CHOICE/OPTION TO NOT PARTICIPATE8.1 MARKETING COMMUNICATION FROM OUR COMPANY 8.1.1. E-MAIL You always have the choice to opt out of our marketing communications or change your preferences by clicking on the link in the footer of all non-transactional email messages we send. Some of our communications are considered transactional or product communications (for example, important purchase notifications and billing information). You agree to receive these transactional and product communications. You must request an opt-out if you do not wish to receive any transactional or product communications. You will still be able to receive marketing communications from us even after you cancel your account, unless you also choose to opt out of our marketing communications, as described above.

8.2. COOKIESYou can select your preferences on your first visit to our website. If you want to change your preferences, you can do so at any time by clicking on the "Cookies Preferences" link at the bottom of the website homepage.
Please note that when you choose not to accept cookies, you exclude all unnecessary cookies. You cannot opt out of necessary cookies, as these cookies and tracking technologies are necessary to help our websites function properly. These cookies allow you to browse our website and use essential features.
You can choose not to use Google cookies or device identifiers without affecting how you visit or use our website. For more information on how to opt out of using Google cookies on all the websites you visit, go to this Google page. To give you more choices on how your data is collected by Google Analytics, Google has developed a browser opt-out add-on available at https://tools.google.com/dlpage/gaoptout that allows you to not be tracked by Google Analytics.

8.3. THIRD PARTY DATATo manage the data we receive about you from social media or third party sites (if applicable), you will need to follow that party's instructions to update your data and change your privacy settings, when available. The data we collect is covered by this privacy policy and the data that third parties collect is subject to the search privacy policies of these parties. The privacy choices you make on any third party website will not apply to our use of data collected directly through our products.

9. RETENTION OF PERSONAL DATAWe retain your personal data to provide you with products and, if necessary, to comply with our legal obligations, settle disputes and enforce our agreements.

10. LEGAL BASIS FOR PROCESSING YOUR DATADepending on the type of data and how we collect it, we have various motives to use your data, including the following:
In order to administrate our contractual relationship, including the establishment of your purchased products, payments, renewals and processes; Because it is in our legitimate interest to run a successful and efficient business and provide you with products and other useful content; In order to comply with legal obligations, we may have to collect this data from you; and/or because you gave your consent for us to do so.

11. YOUR RIGHT TO CONTROL HOW YOUR PERSONAL DATA IS USEDYou have the right to make requests regarding your personal data. You may:
Ask whether we process your personal data and, if we do, access your data we retain and certain information on how we use it and with whom we share it. Ask to update or correct personal data that is inaccurate, incomplete or out of date; Ask to maintain confidential, block or delete unnecessary or excessive data that is not being processed in compliance with data protection laws; Request that we transfer your data to another service or product provider, upon request; Request that we provide information about the possibility of denying consent and the consequences of this denial; and withdraw or revoke your consent.

12. THIRD PARTY LINKS AND DATA COLLECTION AND USE BY OUR USERSSome of our services provide links to other websites. Because we do not have control over the data policies or practices of these third-party sites, you should review their privacy policies to learn how they collect and use personal data.

13. CHILDRENOur services are not intended for people under the age of 18. We do not knowingly collect personal data from people under the age of 18. If you are a parent or guardian of a child and you become aware that your child has provided us with personal data, please contact us as described in this Privacy Policy so we can take reasonable steps to immediately remove this data.

14. DATA TRANSFERIn order to offer you products and comply with our legal obligations, the personal data you provide us and the data we collect about you, your usage and devices will be transferred, stored and processed on our servers in Brazil or in the United States of America. We will take all reasonably necessary steps to ensure that your personal data is secure and used in accordance with this notice.

15. CHANGES IN THE PRIVACY POLICYWe reserve the right to alter this privacy policy at any time. Should we change this privacy policy in any significant way, we will notify you here, by email, or by means of a notice on our website. In any case, your continued use of any of our products constitutes acceptance of these changes.

16. COMPLAINTSIf you have any doubts about this privacy policy or our data use practices, please send your questions to MARKETING@ZAHEMPREENDIMENTOS.COM.BR.

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