Privacy Policy

1 Introduction

SINAI EMPREENDIMENTOS IMOBILIARIOS LTDA (hereinafter "Sinai Imobiliária", "we", "us" or "our") is a real-estate brokerage and property-development firm registered under CNPJ 49.856.306/0001-33, with registered offices at Rua Vicente Beghelli, 315, Dom Bosco, Juiz de Fora — MG, Brazil. We operate the website imobiliariasinai.site and all associated digital channels through which we offer residential and commercial real-estate services.

We take the privacy and security of your personal information seriously. This Privacy Policy describes how we collect, use, disclose, and safeguard personal data submitted to us — whether through our website, contact forms, telephone, e-mail, or any other interaction — in full compliance with Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD — Law No. 13,709/2018) and, where applicable, the European Union's General Data Protection Regulation (GDPR — Regulation EU 2016/679).

By accessing our website or submitting your personal data through any of our channels, you acknowledge that you have read, understood, and agree to the practices described in this document. If you do not agree with any part of this policy, please refrain from using our website and contact us with any questions before proceeding.

2 Information We Collect

We collect personal data only to the extent necessary to provide our services, respond to enquiries, and improve your experience. The categories of data we may collect include:

2.1 Data you provide directly

When you complete a contact form, request a property valuation, schedule a visit, subscribe to property alerts, or otherwise communicate with us, you may supply:

• Full name and, where relevant, company or business name
• E-mail address and telephone number (including WhatsApp)
• Physical address or city/neighbourhood of interest
• Property preferences (type, size, price range, intended use)
• Financial profile information provided voluntarily (e.g. pre-approval status, payment method preference) to help us make suitable recommendations
• Content of messages, notes or documents you send to us
• Identification documents (CPF, RG, or equivalent) collected only where legally required for property transactions

2.2 Data collected automatically

When you browse our website, our servers and third-party tools automatically record certain technical data, including:

• IP address and approximate geographic location (city/region level)
• Browser type, version, and operating system
• Device type (desktop, tablet, mobile) and screen resolution
• Referring URL and the pages you visit on our site, including time and duration
• Search terms used within the property-search functionality
• Click patterns, scroll depth, and interaction events (collected via analytics scripts)
• Cookie identifiers and session tokens (see Section 4 for full detail)

2.3 Data from third-party sources

We may receive limited data about you from advertising platforms (such as Google Ads or Meta Ads) when you click on one of our paid advertisements. This data is restricted to anonymised or aggregated engagement metrics and does not include your name or contact details unless you subsequently submit a form on our site.

3 How We Use Your Information

We process personal data only for specific, explicit, and legitimate purposes. We will never use your information for purposes incompatible with those for which it was originally collected. Our processing activities and their legal bases are as follows:

• Responding to enquiries and scheduling visits — We use your contact details to reply to messages, book property viewings, and send follow-up information you have requested. Legal basis: performance of a contract or pre-contractual steps (LGPD Art. 7, II; GDPR Art. 6(1)(b)).
• Property matching and recommendations — We analyse your stated preferences to identify listings that match your criteria and communicate relevant options to you. Legal basis: legitimate interests (LGPD Art. 7, IX; GDPR Art. 6(1)(f)) — carefully balanced against your privacy interests.
• Sending property alerts and newsletters — With your prior consent, we send periodic updates about new listings, market reports, and promotional events. Legal basis: consent (LGPD Art. 7, I; GDPR Art. 6(1)(a)). You may withdraw consent at any time.
• Completing real-estate transactions — When a purchase, rental, or leasing agreement proceeds, we process identification and financial data to fulfil our legal and contractual obligations. Legal basis: legal obligation and contract (LGPD Art. 7, II & V; GDPR Art. 6(1)(b) & (c)).
• Improving our website and services — Anonymised analytical data helps us understand how visitors use our site so we can enhance navigation, content, and performance. Legal basis: legitimate interests.
• Measuring advertising effectiveness — We use conversion tracking tools to understand which campaigns bring the most relevant enquiries, enabling us to allocate our marketing budget responsibly. Legal basis: legitimate interests / consent where cookies are involved.
• Compliance with legal obligations — We may process data to comply with tax regulations, anti-money-laundering requirements (applicable to real-estate transactions under Brazilian law), judicial orders, or requests from regulatory authorities. Legal basis: legal obligation.

4 Cookies & Tracking Technologies

Our website uses cookies and similar technologies (pixel tags, local storage identifiers) to deliver a functional, personalised, and measurable experience. A cookie is a small text file placed on your device by a web server. It does not contain executable code and cannot access other information on your device.

4.1 Types of cookies we use

• Strictly necessary cookies — Essential for the website to function. They enable features such as the property search form, session management, and security protections. These cookies cannot be disabled without breaking core functionality.
• Performance & analytics cookies — We use Google Analytics (and may use similar tools) to collect anonymised data on visitor behaviour, page views, and traffic sources. This data is aggregated and does not identify you personally. We have configured IP anonymisation to be active at all times.
• Marketing & advertising cookies — With your consent, we deploy Google Ads conversion tracking and remarketing tags, as well as Meta Pixel (Facebook/Instagram), to measure ad performance and serve relevant advertisements to users who have previously visited our site.
• Functional cookies — These remember choices you make (such as preferred property type or saved search filters) to improve your experience on return visits.

4.2 Managing your cookie preferences

You can manage or withdraw your consent to non-essential cookies at any time through the cookie settings panel available on our website. You may also configure your browser to block or delete cookies; note that doing so may affect some features of our site. For opting out of Google Analytics specifically, you can use the Google Analytics Opt-out Browser Add-on. To manage Google advertising preferences, visit adssettings.google.com.

4.3 Cookie retention periods

Session cookies are deleted when you close your browser. Persistent cookies remain for varying durations: analytics cookies typically persist for up to 24 months; advertising cookies for up to 90 days; functional preference cookies for up to 12 months. We review and update these periods periodically.

5 Sharing With Third Parties

We do not share your personal data with third parties except in the following carefully controlled circumstances:

• Service providers and technology partners — We engage trusted suppliers to host our website, send transactional e-mails, provide CRM and property-management software, and support marketing activities. These providers act as data processors under written agreements that prohibit them from using your data for any purpose other than delivering services to us. Examples include cloud hosting providers, Google Workspace, WhatsApp Business API, and e-mail marketing platforms.
• Real-estate partners — Where a property of interest is co-listed with a partner developer or cooperating broker, we may share your name and contact details with that partner solely for the purpose of arranging a visit or providing specific property information. We will inform you at the point of referral.
• Legal and regulatory authorities — We may disclose personal data when required by law, court order, anti-money-laundering regulations, or to protect the rights, property, or safety of Sinai Imobiliária, our clients, or the public.
• Business transfers — In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred as part of that transaction. We will notify affected data subjects before any such transfer takes effect and ensure the receiving party provides equivalent privacy protections.
• Aggregated, anonymised data — We may share statistical, non-identifiable data with research organisations, industry bodies, or in published market reports. Such data cannot be linked back to any individual.

All third parties with whom we share personal data are contractually bound to treat it in accordance with applicable data protection legislation and to implement appropriate security measures.

6 Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, to comply with our legal obligations, resolve disputes, and enforce our agreements. Our standard retention periods are as follows:

• Enquiries and contact-form submissions — Retained for up to 2 years from the date of last interaction, after which they are securely deleted or anonymised unless a transaction is in progress.
• Completed real-estate transactions — Transaction records, including identification documents and contracts, are retained for 10 years in compliance with Brazilian civil and tax law (Código Civil, Art. 205; Lei 5.172/1966 — CTN).
• Marketing communications — If you subscribe to our property alerts or newsletter, we retain your contact preferences until you unsubscribe, after which we hold a minimal suppression record to ensure we do not contact you again.
• Website analytics data — Anonymised usage data is retained for up to 26 months as configured in Google Analytics, consistent with that platform's data-retention settings.
• Cookie and device identifiers — As described in Section 4 above, depending on cookie type.

When retention periods expire, personal data is securely deleted or rendered permanently anonymous using industry-standard methods. Paper documents containing sensitive data are shredded; digital records are overwritten or cryptographically erased.

7 Data Security

We implement a range of organisational and technical measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Transmission of data over our website is protected by TLS/SSL encryption (HTTPS), ensuring that information travels between your browser and our servers cannot be read in transit.
• Access to personal data within our organisation is granted on a need-to-know basis. Staff who handle client data receive privacy and security training and are bound by confidentiality obligations.
• Our CRM and property-management systems are password-protected with multi-factor authentication and hosted by reputable cloud providers with ISO 27001 certification or equivalent.
• We perform regular security reviews of our website and third-party integrations to identify and remediate vulnerabilities promptly.
• Physical access to our offices, where paper records may be stored, is restricted to authorised personnel.

Despite our rigorous precautions, no method of data transmission over the internet or electronic storage is 100% secure. In the event of a personal-data breach that is likely to result in risk to your rights and freedoms, we will notify the Brazilian National Data Protection Authority (ANPD) within 72 hours of becoming aware, as required by LGPD Art. 48, and will notify affected data subjects without undue delay where the breach poses a high risk.

8 Your Rights

You have meaningful rights over your personal data. Under the LGPD and, where applicable, the GDPR, you are entitled to the following:

To exercise any of these rights, please contact our Data Protection Officer (see Section 11) with a written request identifying yourself and the right you wish to exercise. We will respond within 15 business days (as required by LGPD) or within 30 days under GDPR, and may ask you to verify your identity before we proceed. We will not charge a fee for reasonable requests.

9 Children's Privacy

Our website and services are directed exclusively at adults aged 18 years or older. We do not knowingly collect, process, or store personal data from children under the age of 18. Real-estate transactions, by their legal nature, require parties to be of legal age to enter binding contracts.

If we become aware that we have inadvertently received personal data from a minor, we will take immediate steps to delete that information from our records. If you are a parent or legal guardian and believe that your child has submitted personal data to us, please contact us immediately at contato@imobiliariasinai.site so we can investigate and act accordingly.

10 Changes to This Policy

We review and update this Privacy Policy periodically to reflect changes in our business practices, applicable legislation, regulatory guidance, or evolving industry standards. When we make material changes — those that meaningfully affect how we handle your data or your rights — we will:

• Update the "Last updated" date at the top of this page;
• Post a prominent notice on our website homepage for at least 30 days;
• Send a notification by e-mail to subscribers on our mailing list, where the change directly affects their data or our use of it.

We encourage you to review this policy whenever you use our services to stay informed about how we protect your information. Your continued use of our website after changes are posted constitutes acknowledgment of the revised policy. If you disagree with any update, you have the right to contact us to discuss your options or to exercise your rights as described in Section 8.

Previous versions of this Privacy Policy are available upon written request to our Data Protection Officer.

11 Contact & Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or the way in which we handle your personal data, please do not hesitate to get in touch. We are committed to resolving any privacy-related concern you may have promptly and transparently.

If you are located in the European Economic Area and believe your GDPR rights have not been adequately addressed by us, you retain the right to lodge a complaint with the data protection supervisory authority in your member state of habitual residence or place of work.

For users located in Brazil, complaints may be submitted to the Autoridade Nacional de Proteção de Dados (ANPD) via the official government portal at www.gov.br/anpd.