Privacy Policy

Property owned by Real Estate Trancoso Real Estate Investment Fund
(CNPJ/MF No. 43.565.147/0001-31, the “Fund”)

Fund Administration: Trustee Distribuidora de Títulos e Valores Mobiliários Ltda. (CNPJ/MF No. 67.030.395/0001-46)
Fund Management: Vila Rica Capital Gestora de Recursos Ltda. (CNPJ/MF No. 14.751.574/0001-06)
Intermediation and Sales: Bossa Nova Sotheby’s International Realty – Alameda Gabriel Monteiro da Silva, 2,027 – Jardim Europa – ZIP Code 01441-001 – Tel.: +55 (11) 3061-0000 – São Paulo (SP). CRECI: 27212J

1. PURPOSE

The purpose of this Privacy Policy is to demonstrate the commitment of the Real Estate Trancoso Real Estate Investment Fund to the privacy and protection of your data, as well as to establish rules for how it is processed.

2. ABOUT THE DATA COLLECTED

2.1 How Data is Collected

Data, including Personal Data, may be collected when you visit our stands, interact with our platforms, applications, or websites, or enter into commercial agreements with the Real Estate Trancoso Real Estate Investment Fund. The personal information we collect about you varies according to the relationship you choose to have with us (for example: client, investor, supplier, or another applicable status).

Note: This data may be shared with Bossa Nova Sotheby’s International Realty, responsible for intermediation and sales, as well as with the Fund’s other service providers.

2.2 What Data We Collect and Why We Collect It

During your relationship with the Real Estate Trancoso Real Estate Investment Fund, you may provide us with some personal information, as illustrated by (but not limited to) the non-exhaustive examples below:

A) Data collected to meet user requests, to enrich the experience, and to promote products and services:

Full Name, CPF (Brazilian Individual Taxpayer Registry), Email, and Telephone Number

B) Data collected for specific requests (in addition to those listed in item A):

Address of the bank where you purchased the shares (Investors)
Bank Details, Contract Information (Suppliers and Business Partners)
Professional Experience (Job Applicants)

C) Data collected for contractual obligations (in addition to those listed in item A):

Gender, Marital Status, Date and Place of Birth, RG (ID), CPF, Driver’s License (CNH), Nationality, Addresses (personal and professional), Mother’s Name, Spouse and Dependent Information, Education, Job Title, Income and Credit Information, Consumption and Payment Profile, Bank Details, and Health Data that may be requested for proposal evaluation and, subsequently, for the process of transferring the property unit to you, through the completion of forms and health declarations required by the financial institutions partnered with the Real Estate Trancoso Real Estate Investment Fund.

D) Data collected to identify and protect visitors on our digital channels, to fulfill our legitimate interest in providing services and products according to your preferences, to comply with legal obligations, and to prevent fraud or any other associated risk:

IP Address, Source Port, Device and Version, Geolocation, Date and Time Logs of Actions, Accessed Screens, Session ID, and Cookies (according to our Cookie Policy)

In specific situations, such as in the case of resettlement of people, neighbor removal, or accidents, we may also collect health data required by insurance companies contracted by the Real Estate Trancoso Real Estate Investment Fund to cover construction works and projects.

2.3 Required Data

Many of the Real Estate Trancoso Real Estate Investment Fund’s services depend directly on some of the data mentioned above, especially registration data. If you choose not to provide certain Data, we may be unable to fully or partially provide our services to you.

2.4 Accuracy of the Data

You are responsible for the accuracy of the data you provide—and for any lack thereof.

2.4.1

Similarly, the Real Estate Trancoso Real Estate Investment Fund is not required to process or handle any of your data if there is reason to believe that such processing or handling could result in a violation of any applicable law, or if you are using the Fund’s services, products, and websites for any illegal, unlawful, or immoral purposes.

2.5 Database

The database formed through the collection of Data is the property and under the responsibility of the Real Estate Trancoso Real Estate Investment Fund. Its use, access, and sharing, when necessary, will be carried out within the limits and purposes of the businesses described in this Policy.

2.6 Technologies Employed

The Real Estate Trancoso Real Estate Investment Fund uses the following technology(ies):
(i) Cookies, and you may configure your Internet browser if you wish to block them. In this case, some features may be limited.

2.6.1

All technologies used will always comply with current legislation and the terms of this Policy.

2.6.2

No type of exclusively automated decision that impacts you is used.

3. HOW WE SHARE DATA AND INFORMATION

3.1 Situations in Which Data May Be Shared

The Data collected and activity logs may be shared:

With judicial, administrative, or governmental authorities whenever there is a legal requirement, request, demand, or court order;
With institutions responsible for charging the credit resulting from the purchase of the real estate unit(s) you have acquired;
With the real estate agent, when the purchase is brokered;
With financial institutions or advisors for real estate financing;
With the condominium manager, which will provide management and administrative services for the development, including access to its facilities;
Automatically, in case of corporate transactions such as mergers, acquisitions, or incorporations;
For the securitization of receivables;
With partner organizations of the Real Estate Trancoso Real Estate Investment Fund, service and/or infrastructure providers, and third parties that contribute to the Fund’s activities, provided they have been duly approved through security processes;
With service providers for conducting surveys/polls, events, and others, always with the prior consent of the data subject.

3.2 Non-Sharing

We do not share your Personal Data with furniture manufacturers, suppliers of appliances, or other developers not involved. If you are contacted by unidentified third parties, please contact us through the service channels made available in this Policy, and we will help investigate the matter.

4. HOW WE PROTECT YOUR DATA AND HOW YOU CAN ALSO PROTECT IT

4.1 Access to Personal Data, Proportionality, and Relevance

Internally, the Personal Data collected is accessed only by duly authorized professionals, respecting the principles of proportionality, necessity, and relevance to our business objectives, as well as the commitment to confidentiality and the preservation of your privacy under this Policy.

4.2 External Links

When using our Platforms, you may be redirected via links to other portals or platforms that may collect your information (which will then be processed according to the respective Data Policies of those portals and platforms).

4.2.1

Outside our environment, you are responsible for reviewing and becoming aware of the Privacy Policies of the portals and platforms mentioned in item 4.2 above, and it is your responsibility to accept or reject them. The Real Estate Trancoso Real Estate Investment Fund is not responsible for the Privacy Policies of third parties or for the content of any websites or services linked to environments not under its responsibility.

4.2.2 Partner Services

Business partners of the Real Estate Trancoso Real Estate Investment Fund may occasionally offer services through features or websites that may be accessed from our Platforms. These partners will be subject to their own data collection and use practices, which are their sole responsibility.

4.3 Processing by Third Parties Under Our Direction

If third-party companies process any personal data we collect on our behalf, they must necessarily comply with the conditions set forth herein and with information security regulations.

5. HOW WE STORE YOUR PERSONAL DATA AND ACTIVITY RECORDS

Any information provided will be collected and stored in accordance with best security practices. To that end, the Real Estate Trancoso Real Estate Investment Fund takes the necessary precautions, in compliance with security standards established by the applicable laws and regulations.

Your personal data will be discarded by the Fund when its purpose has been fulfilled and when it is no longer required to comply with any legal obligation or when you request its deletion, except where the retention of such data is expressly authorized by law.

Information may be retained to comply with a legal or regulatory obligation or may be transferred to a third party, always respecting data processing requirements.

5.1 Longer Retention Periods

For the purposes of auditing, security, fraud control, credit protection, and safeguarding rights, we may retain the history of your data records for a longer period in cases where the law or regulatory norms so require or to preserve our rights.

5.2

The Data collected will be stored on our servers located in Brazil, as well as in a cloud computing environment (cloud servers).

6. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM

6.1 Your Basic Rights

You may request the following rights from our Personal Data Officer (DPO) at the email address ri@vilarica.capital:

The restriction of the use of your Personal Data;
To object and/or revoke consent regarding the use of your Personal Data;
To know which personal data of yours the Real Estate Trancoso Real Estate Investment Fund processes;
To correct incomplete, inaccurate, or outdated data, by the means required by the specific regulation, when necessary;
To request the anonymization, blocking, or deletion of unnecessary or excessive data or of data that may have been processed in violation of the law;
To request the portability of data to another service or product provider, if expressly done so;
To request the deletion of data processed with your consent;
To obtain information about public or private entities with which we share your data;
When the processing activity requires your consent, you may refuse to give consent. If requested, we will inform you of the consequences of not performing such activity;
When the processing activity requires your consent, you may revoke it at any time.

6.1.1

If you withdraw your consent for purposes that are fundamental to the normal operation of the Platforms and services, these environments and services may become unavailable to you.

6.1.2

If you request the deletion of your personal data but there is still an active purpose for the data, it may need to be retained for longer than requested.

6.1.3

All requests will be offered free of charge and submitted to a form of identity validation (so that the Real Estate Trancoso Real Estate Investment Fund ensures it is responding exclusively to the data subject).

6.1.4

To exercise your rights as the data subject, please send an email to ri@vilarica.capital, as mentioned in item 6.1 above.

7. GENERAL PROVISIONS

7.1

To ensure compliance with the law and full transparency, this document may be amended at any time. In the event of changes and/or updates, the document will be updated on this page.

7.2

If you have any questions regarding the provisions of this Privacy Policy, you may contact us at the Data Protection Officer / DPO email: ri@vilarica.capital.

8. REFERENCES

Law No. 13,709/18 — General Personal Data Protection Law (LGPD).

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