Privacy Policy

1. Introduction

This Privacy Policy applies to all personal data processed by REAL CONSULTORIA IMOBILIARIA RJ LTDA ("REAL Imóveis", "we", "us", or "our") in connection with the website realimoveisrj.site and any related services, including property consultancy, brokerage introductions, and market advisory activities carried out from our offices in Barra da Tijuca, Rio de Janeiro.

We act as the data controller for all personal information collected through this website. We are incorporated in Brazil under CNPJ 29.314.297/0001-41 and our operations are primarily governed by Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD — Federal Law no. 13,709/2018). To the extent we interact with individuals located in the European Union or United Kingdom, we also respect the principles of the General Data Protection Regulation (GDPR) and the UK GDPR.

Please read this policy carefully before submitting any personal information to us. By using our website or engaging our services, you acknowledge you have read and understood how we handle your data. If you do not agree with any part of this policy, please discontinue use of our site and contact us at the address below to discuss your options.

2. Information We Collect

We collect personal data in three main ways: information you provide directly, information generated automatically when you browse our site, and information we receive from trusted third-party sources that you have authorized.

2.1 Information You Provide Directly

When you fill in a contact form, request a property valuation, subscribe to our newsletter, or send us a message via WhatsApp or email, we collect the data you choose to share. This typically includes:

• Full name and preferred form of address
• Email address and phone number (including WhatsApp number if provided)
• Property preferences: type (apartment, house, commercial), preferred neighbourhood, budget range, and number of bedrooms
• Whether you are looking to buy, sell, or rent, and an approximate timeline
• Any additional information you include in the free-text "message" field of our forms
• If you are an investor or developer: company name, professional context, and volume requirements you choose to disclose

Providing this information is entirely voluntary; however, certain fields (name, email or phone) are necessary for us to respond to your enquiry at all. Mandatory fields are marked clearly on our forms.

2.2 Automatically Collected Data (Analytics & Browsing)

When you visit our website, our hosting infrastructure and analytics tools automatically collect technical information about your device and browsing behaviour. This includes:

• IP address (stored in anonymized or truncated form where technically possible)
• Browser type, version, and language preferences
• Operating system and device category (desktop, mobile, tablet)
• Referring URL — the page or search result that brought you to our site
• Pages visited, time spent on each page, and navigation path through the site
• Search terms used within any on-site property search functionality
• Date, time, and duration of visit
• Approximate geographic location derived from IP (city/region level only — never precise GPS)

This data is collected in aggregate and used primarily to understand how visitors interact with our site so we can improve content, performance, and user experience. On its own it does not typically identify you as an individual.

2.3 Advertising & Remarketing Data

We use Google Ads to promote our services. When you arrive via a Google ad, or when you subsequently visit Google properties after browsing our site, certain data points (such as your Google advertising identifier or a cookie-based audience segment) may be shared between our website and Google's advertising infrastructure. This allows us to display relevant property listings to people who have already expressed interest. You can opt out of personalized advertising through Google's Ad Settings.

3. How We Use Your Information

We rely on the following legal bases under LGPD and, where applicable, GDPR to process your personal data:

3.1 To Respond to Your Enquiries and Provide Our Services

Legal basis: Performance of a contract / legitimate interest / consent. When you contact us, we use your name, email, phone number, and stated preferences to respond to your enquiry, identify suitable properties, arrange viewings, introduce you to partner brokers or developers, and generally deliver the real estate consultancy service you have requested. Without this data, we are simply unable to help you.

3.2 To Send You Property Updates and Market Insights

Legal basis: Consent. If you have explicitly opted in to receive our newsletters or property alert emails, we will use your email address to send you curated listings, neighbourhood market reports, and investment commentary relevant to the criteria you specified. You may unsubscribe from any such communication at any time using the link included in every email, or by contacting us directly.

3.3 To Improve Our Website and Marketing

Legal basis: Legitimate interest. Aggregated analytics data helps us understand which property categories attract the most interest, which pages perform poorly, and how visitors navigate from first visit to enquiry. We use this to refine our content, improve site speed, and allocate our advertising budget more effectively — all of which ultimately results in a better experience for you and future visitors.

3.4 To Comply With Legal Obligations

Legal basis: Legal obligation. Brazilian real estate brokerage activities are regulated under Federal Law 6,530/1978 and supervised by COFECI/CRECIs. We are required to maintain certain transaction records and, in some cases, to share information with public authorities (tax, anti-money laundering, or judicial orders) when legally compelled to do so.

3.5 To Prevent Fraud and Ensure Site Security

Legal basis: Legitimate interest / legal obligation. We may process IP addresses and session data to detect and block automated abuse, spam submissions via our contact forms, and other fraudulent activity that could harm the integrity of our platform or the security of our clients.

4. Cookies & Tracking Technologies

Our website uses cookies — small text files placed on your device — as well as similar technologies such as web beacons and pixel tags. Below is a breakdown of the categories of cookies we use:

4.1 Strictly Necessary Cookies

These cookies are essential for the website to function. They enable you to navigate between pages, use the property search filter, and submit contact forms securely. Because they are required for basic functionality, they cannot be disabled. They do not collect any information that could be used for marketing purposes.

4.2 Performance & Analytics Cookies

We use Google Analytics 4 (GA4) to collect anonymous information about how visitors interact with our site. GA4 cookies track which pages you view, how long you stay, and what actions you take. All data is transmitted to Google servers and processed in accordance with Google's Privacy Policy. We have enabled IP anonymization on our GA4 configuration. These cookies are only placed with your prior consent, where required by applicable law.

4.3 Advertising & Remarketing Cookies

We use Google Ads conversion tracking tags and remarketing lists to measure the effectiveness of our paid search and display campaigns, and to show property ads to people who have previously visited our site. The Google Ads tag reads the gclid parameter from your URL and writes it to a first-party cookie for up to 90 days. Google's DoubleClick cookie may also be present when remarketing is active.

We do not use any social media tracking pixels (such as Facebook/Meta Pixel) on this website at this time. Should this change, we will update this policy and our consent mechanism accordingly.

4.4 Managing Your Cookie Preferences

When you first visit our site, you are presented with a cookie consent banner that allows you to accept or decline non-essential cookies. You can change your preferences at any time by clearing your browser cookies and revisiting our site, or by adjusting your browser's cookie settings. Popular browsers handle this as follows:

• Google Chrome: Settings → Privacy and security → Cookies and other site data
• Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
• Apple Safari: Preferences → Privacy → Manage Website Data
• Microsoft Edge: Settings → Cookies and site permissions → Cookies and site data

Note that disabling certain cookies may affect the functionality of our property search and contact forms.

5. Sharing Your Information With Third Parties

We do not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share information only in the following specific, limited circumstances:

5.1 Technology Service Providers

We use a small number of carefully selected third-party technology providers who process data on our behalf as data processors. These include our website hosting provider, email delivery infrastructure, and analytics platform (Google Analytics). All such providers are bound by data processing agreements that prohibit them from using your data for any purpose beyond providing the service to us, and require them to maintain appropriate security standards.

5.2 Partner Brokers and Developers

In the context of a specific property transaction you have requested, we may share your contact details and stated preferences with a licensed broker (Corretor de Imóveis registered with CRECI-RJ) or a property developer whose project matches your criteria. We will only make such an introduction where it is reasonably expected and necessary in the context of the service you have asked for. We will always tell you about any introduction of this kind, and we will not share your data with any party who has not been vetted by our team.

5.3 Legal and Regulatory Disclosure

We may disclose personal data to courts, regulators, tax authorities, or law enforcement bodies where we are required to do so by a binding legal obligation, court order, or regulatory requirement under Brazilian law. In such cases we will disclose only the minimum amount of data strictly required and, where legally permissible, will notify you of the disclosure.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business assets, personal data we hold may be among the assets transferred to the acquiring entity. In such circumstances we would notify you by email and/or a prominent notice on our website in advance of any transfer, and the acquiring entity would be required to honour the commitments set out in this privacy policy or obtain your fresh consent.

6. Data Retention

We retain your personal data only for as long as is necessary for the purposes described in this policy, and no longer than is permitted or required by applicable law. Our general retention periods are as follows:

• Contact form enquiries that did not result in a transaction: 24 months from the date of your last interaction with us, after which all personally identifiable information is deleted or anonymized.
• Client records relating to a completed property transaction: 5 years from the date of completion, in line with Brazilian civil law requirements for contract records and anti-money laundering obligations (COAF rules).
• Newsletter subscription records: For as long as you remain subscribed, plus 6 months following an unsubscribe request (to process the opt-out and maintain a suppression record).
• Analytics data (Google Analytics): Configured to a 14-month retention window within GA4, after which event-level data is automatically deleted. Aggregated, anonymized reports may be retained indefinitely.
• Server access logs: Up to 12 months for security and abuse-prevention purposes.
• Legal obligation records (tax, regulatory): As mandated by Brazilian legislation, which in most cases requires financial records to be retained for a minimum of 5 years.

When your data reaches the end of its retention period, it is securely deleted or irreversibly anonymized so it can no longer be associated with you as an individual.

7. Data Security

We take the security of your personal information seriously and implement a range of technical and organizational measures proportionate to the nature of the data we process. These include:

• HTTPS encryption: All data transmitted between your browser and our website is encrypted using TLS 1.2 or higher, indicated by the padlock icon in your browser's address bar.
• Access control: Access to personal data held in our systems is restricted to authorized staff members who require it to perform their role. We enforce strong password policies and use multi-factor authentication on administrative accounts.
• Secure email handling: Enquiry notifications are transmitted to our internal team via encrypted email channels. We do not discuss sensitive personal or financial details over unencrypted platforms.
• Form security: Our contact forms use CSRF protection tokens and server-side validation to prevent automated spam submissions and injection attacks.
• Regular reviews: We periodically review our data handling practices, update software dependencies, and assess our security posture in line with current best practices.

Despite these measures, no method of electronic transmission or storage is completely secure. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that poses a high risk to your rights and freedoms, we will notify you and the relevant authorities (ANPD in Brazil) in accordance with our legal obligations and within the timeframes required by law.

8. Your Rights

Depending on your country of residence, you have a number of rights with respect to your personal data. Under Brazil's LGPD (Article 18) and, where applicable, the GDPR (Article 15–22), these rights include:

How to Exercise Your Rights

To exercise any of the above rights, please contact our data protection point of contact by email at contato@realimoveisrj.site, including the subject line "Data Rights Request" and clearly describing the right you wish to exercise and any relevant details (such as the email address you used when contacting us). We will respond within 15 business days for requests under LGPD, and within 30 calendar days for requests under GDPR, in both cases extendable by a further 30 days in complex cases with notice to you.

We may need to verify your identity before processing a data subject request in order to protect the security of your information. We will not charge a fee for exercising your rights unless a request is manifestly unfounded, excessive, or repetitive, in which case we reserve the right to charge a reasonable administrative fee or decline the request.

If you believe your rights have been infringed and you are located in Brazil, you may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd. EU residents may also contact their national data protection supervisory authority.

9. Children's Privacy

Our website and services are directed exclusively at adults who are legally capable of entering into real estate transactions or enquiring on behalf of an entity with authority to do so. We do not knowingly collect personal data from individuals under the age of 18 (or under 16 in certain EU jurisdictions).

If you are a parent or guardian and have reason to believe that a child under the relevant minimum age has submitted personal data to us through our website or contact forms, please contact us immediately at contato@realimoveisrj.site. We will investigate promptly and, if confirmed, delete the information without undue delay.

10. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, service offerings, applicable law, or regulatory guidance. When we make material changes, we will take reasonable steps to draw these to your attention. Depending on the nature of the change, this notification may take the form of:

• A prominent notice on our homepage or a banner within the site for a minimum of 30 days following the update;
• An email notification to individuals on our mailing list where the change materially affects how we use their data; or
• A request for renewed consent where the new processing requires it.

The "Last updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this policy periodically. Your continued use of our website after any updated policy has been posted (with sufficient notice having been given) constitutes your acceptance of the revised terms, to the extent permitted by applicable law.

Archived versions of this policy are available on request by contacting us at the address below.

11. Contact & Data Controller Details

All questions, requests, or complaints relating to this Privacy Policy or our data handling practices should be addressed to us directly. We are the data controller for all personal data collected through this website.