Privacy Policy

1. Data Controller

InnCorporate Desenvolvimento Imobiliário Participações Ltda., CNPJ 67.606.802/0001-10, headquartered in São Paulo, Brazil, is the data controller responsible for processing personal data collected through this website and InnovaSphere platform services, under Brazil's General Data Protection Law (Lei nº 13.709/2018 — LGPD).

2. Personal Data Collected

We collect the following categories of personal data, limited to what is strictly necessary:

3. Purposes of Processing

• Respond to contact requests and initiate qualified commercial relationships
• Assess profile suitability for developments under InnovaSphere management
• Send institutional communications and portfolio updates, with prior consent
• Improve browsing experience and website performance
• Comply with applicable legal and regulatory obligations
• Produce aggregated and anonymized analytical reports on website usage

4. Cookies and Tracking Technologies

You can manage your cookie preferences at any time through the consent banner at the bottom of the site or through your browser settings.

5. Data Sharing

Your personal data may be shared exclusively with:

• InnCorporate ecosystem subsidiaries — for service coordination relevant to your profile and stated interest
• Cloudflare, Inc. (USA), processor: site hosting and delivery, abuse protection and cookieless aggregate audience measurement
• Supabase, processor: database receiving the form, hosted in São Paulo, Brazil
• Competent authorities — when required by law, regulation or court order

InnovaSphere does not sell, rent or make personal data available to third parties for marketing, advertising or any purpose not described in this policy.

6. International Data Transfer

Personal data may be processed on servers located outside Brazil, in countries offering adequate protection or through standard contractual clauses, in accordance with LGPD Chapter V and ANPD guidelines.

7. Retention and Deletion

Personal data is retained for the time strictly necessary. Contact data: up to 5 years after last interaction. Analytics data: anonymized after 26 months.

8. Your Rights

Under the LGPD (Art. 18), you have the right to:

• Confirmation and access — know whether we process your data and obtain a full copy
• Correction — request update of incomplete, inaccurate or outdated data
• Anonymization, blocking or deletion — of unnecessary, excessive or non-compliant data
• Portability — receive your data in a structured and interoperable format
• Deletion — of personal data processed based on consent
• Withdrawal of consent — at any time, without retroactive effect
• Objection — to processing based on legitimate interest
• Information about sharing — know the entities with which we share your data

To exercise any of these rights, contact our Data Protection Officer through the channel indicated in section 10. We will respond within 15 business days.

9. Information Security

We adopt appropriate technical and organizational measures including TLS 1.3 encryption, role-based access control (RBAC), continuous security monitoring, geo-redundant backups, and periodic vulnerability assessments.

10. Data Protection Officer (DPO)

11. Changes to this Policy

This policy may be updated periodically. Substantial changes will be communicated through a prominent notice on this website. Continued use constitutes acceptance of updated terms.

12. Applicable Law and Jurisdiction

This policy is governed by Brazilian law, particularly the LGPD (Lei nº 13.709/2018), the Marco Civil da Internet, and the Consumer Protection Code. Jurisdiction: Balneário Camboriú, Santa Catarina, Brazil.