Privacy Policy

This is a courtesy translation. The Portuguese version of this policy is the official one and prevails in the event of any divergence.

1. Who is the controller

DNA3 Incorporadora Ltda, Brazilian company registry (CNPJ) 57.388.637/0001-14, is the controller of the personal data processed on this website, under the Brazilian General Data Protection Law — Law No. 13.709/2018 (LGPD).

2. What we collect

There are three sources of data, and they work differently:

• Updates form — the data you type yourself: first name, last name, city, state, phone with country code and e-mail. It is optional: the site works normally without filling it in.
• Meta advertising cookie — activated only if you accept it in the cookie banner.
• Server technical logs — generated automatically on any visit: IP address, date and time, browser and page accessed. They keep the site secure and available.

There is no login, customer area or payment. We do not collect sensitive data (LGPD, art. 5, II) and we do not ask for tax IDs, identity documents or financial data.

3. Cookies we use

We use no analytics cookies, no content personalisation cookies and no third-party cookies other than Meta's.

With the Pixel active, your IP address, browser (user agent), page address and the event that occurred are also transmitted to Meta — for example, the page view, the click on the WhatsApp button or the form submission.

4. What we use this data for

From the form:

• Sending updates: launches, available lots and construction progress
• Contacting you through the channels you authorised
• Understanding which cities and states the interest comes from, to plan our communication

From the advertising cookies:

• Measuring how many people saw our ads and reached the site
• Building audiences to show ads to people with a similar profile
• Avoiding showing the same ad too many times to the same person

We do not use this data for automated decisions affecting you, we do not profile beyond what is described above, and we do not sell or transfer your data to anyone.

5. Legal basis

The form and the Pixel rely on your consent (LGPD, art. 7, I), collected separately for each purpose:

• One acceptance in the banner, for the advertising cookie
• One permission to receive updates by e-mail, in the form
• A separate, optional permission to receive them on WhatsApp

None of them comes pre-ticked, and all of them can be withdrawn later. The e-mail permission is required because it is the very object of the subscription: without it there are no updates to send.

The server technical logs rely on the legitimate interest of keeping the site secure and available (LGPD, art. 7, IX).

6. Two-step confirmation

After submitting the form, you receive an e-mail with a confirmation link. Only after you click it does your subscription take effect and the updates begin. The link is valid for 48 hours and can be used only once.

This protects you from being subscribed by someone else typing your e-mail address, and gives us evidence that the consent was yours.

7. Who we share it with

• Cloudflare, Inc. — hosts the site and stores the subscription list, acting as a processor on our behalf and instruction. It also delivers the confirmation e-mail.
• Meta Platforms, Inc. — operates the Pixel and the Facebook and Instagram platforms, and receives the data described in item 3, only if you accept cookies.

Both cases involve an international transfer of data to the United States, under art. 33 of the LGPD. We share it with no one else.

8. How long we keep it

• Confirmed subscriptions: for as long as you want to receive the updates. When you leave the list, we keep only the record of the unsubscription, so that we do not contact you again by mistake.
• Unconfirmed subscriptions: discarded if the link is not used within the deadline.
• _fbp and _fbc cookies: about 90 days in your browser.
• Events sent to Meta: according to Meta's own retention periods.
• Server technical logs: for the legal period applicable to access logs.

9. How we record your consent

So that we can prove the permission was given, we store alongside your subscription: the date and time, the IP address the submission came from, the browser used, the version of the text you accepted, and the date of the e-mail confirmation. This data exists solely as evidence of consent and is not used for anything else.

10. Your rights

Art. 18 of the LGPD grants you, at any time, the right to request:

• confirmation that we process your data, and access to it
• correction of incomplete, inaccurate or outdated data
• anonymisation, blocking or deletion of unnecessary or excessive data
• portability to another provider
• deletion of data processed on the basis of your consent
• information about who we share your data with
• information about the option not to consent, and what follows from that
• withdrawal of consent

11. How to exercise your rights

Write to contato@dnaaocubo.com.br. DNA3 qualifies as a small-size processing agent (ANPD Resolution No. 2/2022), a situation in which appointing a data protection officer is not mandatory; we keep this channel open to handle data subject requests.

12. How to leave the list

Every updates e-mail carries an unsubscribe link. You can also ask to leave by writing to contato@dnaaocubo.com.br, or by replying to any message of ours. Leaving applies to all channels, unless you ask to keep one.

13. Withdrawing cookie consent

You can withdraw the consent given in the cookie banner. That erases your choice and makes the banner appear again, without activating the Pixel. It does not affect the updates subscription, which has a permission of its own.

Review my cookie consent

14. Changes to this policy

We may update this text as the site evolves. The effective date at the top indicates the last change. Relevant changes in purpose or sharing will be communicated to everyone on the list.