Privacy Policy

01Identification of the controller

DAVINOR PARTICIPACOES E CONSULTORIA LTDA, registered under CNPJ 66.255.784/0001-07, with address at Avenida Cristóvão Colombo, nº 2144, Sala 408, Andar 3, Bairro Floresta, Porto Alegre – RS, CEP 90.560-001, Brasil. The company uses the institutional brand Davinor and the registered trade name DAVINOR CAPITAL.

Institutional channel for privacy matters: contato@davinor.com.br. The company has not yet formally appointed a data protection officer, therefore requests are received and handled through this channel.

02Categories of data processed

This is an institutional website with no registration, login or payment area. The personal data processed is the data that the interested party itself provides when contacting Davinor.

• Identification and contact data provided in the forms: name, company or institution, position, e-mail and telephone.
• Descriptive information about the demand or transaction that the interested party decides to present.
• Content of messages exchanged by e-mail or WhatsApp.
• Technical records automatically generated by the hosting server when pages are accessed, such as IP address and the date and time of the request.

03Purposes of processing

• Respond to contact requests and carry out a preliminary scope assessment.
• Conduct institutional and commercial relationships with companies, institutions and investors.
• Organise and coordinate contracted transactions, where an engagement exists.
• Comply with applicable legal, regulatory and contractual obligations.
• Maintain the security, availability and integrity of the website.

04Legal bases

Processing complies with Brazilian Law No. 13,709/2018 (General Personal Data Protection Law). Depending on the situation, the applicable legal bases are: consent of the data subject when sending a message, performance of a contract and preliminary procedures related to a contract, compliance with a legal or regulatory obligation, and legitimate interest for institutional relationships and website security.

05Contact forms

The forms on this website do not perform automatic submission. Once completed, the website prepares a message in the interested party's own e-mail application or WhatsApp, and that person decides whether to confirm sending it. Until the message is sent, the data remains only on the user's device.

The forms expressly request that passwords, banking data, restricted documents or confidential information not be provided.

06Communication by e-mail and WhatsApp

E-mail communication uses Davinor's institutional address and the e-mail service contracted by the company. WhatsApp communication takes place in the application maintained by Meta Platforms and is subject to that application's own policies. By choosing this channel, the interested party shares the telephone number and the content of the conversation with that service.

The choice of channel belongs to the interested party. Sensitive or restricted information should not be sent by message before an appropriate channel is defined with Davinor.

07Hosting and external technology services

The website consists of static files hosted on Hostinger, which acts as hosting operator and may record technical access data in accordance with its own policies.

Typefaces are served from the website's own domain, from files hosted alongside the pages themselves. The browser makes no request to external typography services, and loading the fonts generates only technical hosting records, like any other file on the website.

In this version of the website there are no audience analytics tools, advertising pixels, heat maps, session recording or embedded social networks. Should any of these resources be adopted, this policy will be updated before activation.

08Sharing of information

Davinor does not sell personal data and does not share it for advertising purposes.

• Technology service providers necessary to operate the website and institutional communication, within the limits of the purposes described.
• Qualified professionals and advisors involved in a transaction, where an engagement exists and on a technical need basis.
• Public authorities, where there is a legal or regulatory request.

09Retention of information

Messages and contact data are kept for as long as necessary to handle the request and the institutional relationship, and for the periods required by legal or contractual obligations or for the defence of rights. Specific periods per category of information will be defined in the internal retention policy, currently being prepared, and incorporated into this document after validation.

10Rights of the data subject

Requests may be sent to contato@davinor.com.br, with identification of the data subject so that a response is possible.

• Confirmation of the existence of processing and access to the data.
• Correction of incomplete, inaccurate or outdated data.
• Anonymisation, blocking or deletion of unnecessary data or data processed in breach of the law.
• Portability, under the terms of the applicable regulation.
• Information on sharing and on the possibility of not consenting.
• Withdrawal of consent and deletion of data processed on that basis.

11Information security

Davinor adopts reasonable administrative and technical measures to protect the information it receives, including access control over institutional accounts and document organisation by transaction. No security certification is declared, and Davinor does not claim to hold ISO, SOC 2 or equivalent certifications.

12International transfers

Hosting, e-mail and messaging services may process data on servers located outside Brazil. In such cases, processing observes the situations provided for in Brazilian data protection legislation.

13Updates to this policy

This policy may be updated whenever there is a change in the services used, in the purposes of processing or in the applicable legislation. The version in force will always be available on this page.