Privacy Policy.

This Policy applies to all personal data processed by our company — including prospective buyers who enquire about our properties, parties involved in active purchase and sale transactions, individuals whose data appears in property transaction documentation, and website visitors.

As a company that buys and sells its own properties — not acting as an agent or broker — we are the seller or buyer in every transaction. This Policy covers data processing in both roles: as a seller (processing buyer data) and as a buyer (processing seller data in acquisition operations).

• Buyer identification data: Full name, CPF or CNPJ, address, nationality, marital status, phone number and email — collected when a prospective buyer expresses interest in a property and advances toward a transaction. These details are required for escritura preparation and property registration.
• Financial qualification data (where applicable): Information about financing arrangements, bank institution and financing approval status — collected only to the extent necessary to assess the viability of a transaction. We do not collect income statements or full financial profiles beyond what is required for the specific transaction.
• Transaction documentation data: Data contained in property transaction documents — purchase promises (promessa de compra e venda), receipts, ITBI declarations, escritura data and all documentation required by the Cartório de Registro de Imóveis and São Paulo municipal and state authorities.
• Spouse and co-buyer data: Where a buyer is married or purchasing jointly, the personal data of the co-buyer or spouse is collected as required by Brazilian property law for joint purchase transactions.
• Contact and enquiry data: Messages via WhatsApp, telephone or online form — name, phone and property interest.
• Technical website data: IP address, browser type, pages visited and access times.

• Cartório de Notas / Cartório de Registro de Imóveis: Buyer and transaction data required for escritura de compra e venda preparation and property title registration — shared only as required by Brazilian property law for the specific transaction.
• Prefeitura de São Paulo (ITBI): Data required for ITBI (Imposto de Transmissão de Bens Imóveis) declaration and payment to the Municipality of São Paulo.
• SEFAZ-SP / Receita Federal: Tax data for NF-e issuance and applicable federal and state tax compliance.
• Financing banks (buyer-directed): Where a buyer is financing the purchase, the bank may require property and transaction documentation — shared only with the buyer's nominated financial institution and only as required for the financing process.
• PROCON-SP: When required in a consumer dispute mediation under the CDC.
• Legal authorities: When required by a competent judicial or administrative order.

Our real estate operations are exclusively in São Paulo, Brazil. All transaction data, property records and client data are stored in Brazil. Any technology platforms used for communication or document management that operate on international servers do so only under the guarantees of Art. 33 of the LGPD or recognised adequacy mechanisms.

• NF-e and fiscal records: Minimum 5 years under federal and state tax legislation (CTN, Art. 174; SEFAZ-SP).
• Property transaction records (escritura, ITBI, registration): Indefinitely — or for as long as the legal effects of the transaction persist. Property transaction documents are records of title transfer and may be required at any time for legal, tax or dispute purposes. We retain complete transaction records for all completed property deals.
• Pre-transaction enquiry data (no deal completed): Up to 1 year from last contact if no transaction was concluded.
• Buyer identification data (completed transactions): As required by the mandatory retention period for property transaction records — minimum 10 years from transaction completion for CPF/CNPJ and identification data associated with escritura records.
• Website analytics: Aggregated and anonymised after 12 months.

• Buyer identification and transaction data accessible only to company management and authorised transaction staff;
• Property transaction documents stored securely — both physical and digital copies of escritura and registration records maintained;
• WhatsApp and email communications handled with discretion — financial and personal details not transmitted via insecure channels without buyer consent;
• Encryption in transit (HTTPS) for website and digital communications;
• PCI-DSS certified payment platforms — card data never retained by the company;
• As a Ltda, formal internal data handling protocols maintained;
• Incident response procedures and breach notification per LGPD Art. 48.

• Confirmation and Access (Art. 18, I–II): Confirm whether we hold your data and receive a copy — including records of any property transaction you were involved in.
• Correction (Art. 18, III): Request correction of inaccurate data.
• Anonymisation / Blocking / Deletion (Art. 18, IV): Request restriction or deletion — subject to the mandatory retention of property transaction records under Brazilian property and tax law.
• Portability (Art. 18, V): Receive your data in a structured format.
• Deletion of consent-based data (Art. 18, VI): Request deletion of data processed by consent.
• Information on sharing (Art. 18, VII): Find out which authorities or entities your data was shared with in connection with a property transaction.
• Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time for consent-based processing.
• Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.

We respond within 15 business days. Deletion of property transaction records is subject to mandatory legal retention requirements that apply to Brazilian property registration and fiscal records.

Our website may use cookies for essential functionality and aggregated performance analysis. We do not use behavioural tracking cookies for advertising without prior consent. Preferences can be managed through browser settings.

Property transactions are conducted with adults of legal capacity. We do not sell property directly to minors. Where a property is being purchased by adults on behalf of or jointly with a minor — for example in inheritance or guardianship situations — the data of the minor is processed only as required by Brazilian property law for the specific transaction, and solely under the direction of the responsible legal guardian or court order.

Property transactions require the processing of certain personal data that, while not classified as sensitive under LGPD Art. 5º, II, is financially and personally significant — CPF, full name, address, marital status and nationality of buyers. We handle all such data with the discretion appropriate to its significance.

All transaction data — buyer identification, financial qualification, escritura content and registration records — is treated as strictly confidential and shared only with the authorities and parties legally required for the specific property transaction.

This Policy may be updated to reflect changes in our activities, the LGPD, ANPD guidance, property transaction law or applicable tax legislation. Material changes will be communicated via our website or directly to active transaction parties by WhatsApp or email.

All privacy requests, questions and complaints should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):