Privacy Policy

Introduction

SILVIO XIMENES IMOVEIS LTDA ("Silvio Ximenes Imóveis," "we," "our," or "us") is a real-estate brokerage company registered under CNPJ 16.669.418/0001-26, with its principal place of business at Rua Alvares Maciel, 362, Sala 204, Santa Efigênia, Belo Horizonte — MG, Brazil. We operate the website silvioximenes.site (the "Site") to provide institutional information about our services to prospective clients, partners, and members of the public.

We take the privacy and security of your personal data seriously. This Privacy Policy explains what information we collect when you visit our Site, why we collect it, how long we keep it, with whom we share it, and what rights you have over it. It has been drafted to comply with Brazil's Lei Geral de Proteção de Dados (LGPD) — Law 13.709/2018 — and, where applicable, the European Union's General Data Protection Regulation (GDPR) and other relevant data-protection legislation.

By continuing to use this Site you acknowledge that you have read and understood this Policy. If you do not agree with its terms, please discontinue use of the Site. This Policy applies only to information collected through our website and does not govern personal data exchanged in the context of any physical meeting, telephone conversation, or service agreement concluded separately.

Information We Collect

We limit data collection to what is genuinely necessary for the operation of this informational website and for maintaining an appropriate commercial dialogue with individuals who choose to contact us. The categories of personal data we may collect are described below.

2.1 — Information you provide directly

When you reach out to us by email, telephone, or through any future contact channel we operate, you may voluntarily share personal data such as your full name, email address, telephone number, and a description of your real-estate needs or enquiry. We collect only what you choose to disclose and use it solely to respond to your request and, if you agree, to keep you informed of services relevant to your stated interests.

2.2 — Technical and usage data collected automatically

When you visit the Site, our hosting infrastructure and third-party analytics services may automatically record certain technical information about your session. This can include:

• Your device's Internet Protocol (IP) address, which may be truncated or anonymised before storage
• The type and version of web browser you are using, your operating system, and device category (desktop, tablet, or mobile)
• Referring URL — the address of the page or search result that brought you to our Site
• Pages visited within the Site, time and date of each visit, and the duration of each page view
• Approximate geographic location derived from IP address (country and city level only — no precise GPS coordinates are collected)
• Aggregate statistics on how visitors navigate the Site, which we use solely to improve content and user experience

2.3 — Cookies and similar technologies

We use cookies and similar tracking technologies (see Section 4 for full detail). Cookies are small text files placed on your browser; they allow us and authorised analytics services to recognise repeat visits and compile aggregate usage statistics. We do not use cookies to build individual advertising profiles or to track your activity across unrelated third-party websites.

How We Use Your Information

We process personal data only for specific, explicit, and legitimate purposes, and we do not use it in any manner that is incompatible with those purposes. Our lawful bases under the LGPD include legitimate interest (Article 7, VI), consent (Article 7, I), and fulfilment of a contract or pre-contractual steps (Article 7, V). Under the GDPR, the equivalent bases apply (Articles 6(1)(a), 6(1)(b), and 6(1)(f)).

The specific purposes for which we use your data are:

• Responding to enquiries: When you contact us, we use the information you provide to reply promptly and accurately to your question or service request.
• Service delivery and pre-contractual steps: If an enquiry leads toward a formal brokerage engagement, we use relevant contact and preference data to take the necessary pre-contractual steps under applicable Brazilian civil and real-estate law.
• Website analytics and improvement: Aggregated, anonymised technical data helps us understand which pages are most useful, identify broken links, and improve overall Site performance and content quality — no individual profiling is involved.
• Legal and regulatory compliance: We may retain and process data to the extent required by Brazilian tax law (including Receita Federal obligations), the Brazilian Civil Code, COFECI/CRECI regulations, anti-money-laundering statutes, and any other applicable legislation.
• Fraud prevention and security: Technical log data may be used to detect, investigate, and prevent security incidents, fraudulent activity, or other misuse of our Site.
• Communication of service updates: Where you have expressly consented, we may send you information about our services or real-estate market insights. You may withdraw this consent at any time by contacting us at the email address in Section 11.

We never sell, rent, or otherwise trade your personal data for commercial gain. We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects on you.

Cookies & Tracking Technologies

Cookies allow the Site to function correctly and help us understand how visitors engage with our content. We use a limited set of cookie types, described below. You can control or delete cookies at any time through your browser settings; however, disabling all cookies may affect some basic Site functionality.

Strictly necessary cookies

These are essential for the Site to load and operate correctly. They do not collect any information about you that could be used for marketing purposes and cannot be disabled without impacting Site functionality. No consent is required for these cookies under applicable law.

Analytics and performance cookies

We use Google Analytics 4 (operated by Google LLC) to collect aggregated, anonymised statistics about visitor behaviour — for example, which pages are visited most often and from which geographic regions our audience originates. Google Analytics is configured on our Site with IP anonymisation enabled, meaning the final octet of each visitor's IP address is masked before any data is stored. This data is used solely to improve the Site and is not linked to any identifiable individual. Google's own privacy policy and terms govern how Google processes this data: policies.google.com/privacy.

We may also use tracking pixels or tags from Google Ads for the purpose of measuring the effectiveness of our advertising campaigns (conversion tracking). These technologies do not enable us to identify you personally; they allow us to count aggregate actions such as a click from an advertisement followed by a visit to the Site. Google's advertising policies and data-processing terms apply to this technology.

Managing your cookie preferences

Most browsers allow you to view, block, or delete cookies via their privacy or security settings. You may also opt out of Google Analytics measurement across all websites by installing the Google Analytics Opt-Out Browser Add-on (available at tools.google.com/dlpage/gaoptout). To opt out of personalised Google advertising, visit adssettings.google.com. These opt-out mechanisms are operated entirely by Google; we have no control over their technical implementation.

Sharing with Third Parties

We do not sell, share, or disclose your personal data to third parties for their own marketing or commercial purposes. We may, however, share limited data with the following categories of recipients, and only to the extent strictly necessary:

• Technology and hosting providers: Our website is hosted by a third-party infrastructure provider. Server logs, including IP addresses, are retained on their systems under data-processing agreements that bind them to confidentiality and appropriate security standards compatible with this Policy.
• Analytics service providers: Google LLC processes anonymised analytics data on our behalf as described in Section 4. Google acts as a data processor under a Data Processing Addendum, not as an independent controller of the data we generate.
• Professional advisors: Lawyers, accountants, and auditors engaged by Silvio Ximenes Imóveis may have access to personal data on a strictly need-to-know basis and are bound by professional and statutory confidentiality obligations.
• Regulatory and law-enforcement authorities: We may disclose personal data to the Receita Federal do Brasil, COFECI/CRECI regional bodies, or other competent authorities where we are legally required to do so, or where such disclosure is necessary to protect our legal rights or comply with a binding judicial order.
• Corporate transactions: In the event of a merger, acquisition, or sale of substantially all of our business assets, personal data may be transferred to the relevant parties under appropriate confidentiality undertakings. We will notify you of any such change if it materially affects how your data is used.

Whenever we engage a third-party data processor, we enter into a data-processing agreement (DPA) or equivalent contractual safeguard that requires the processor to handle your data only on our documented instructions, to implement appropriate technical and organisational security measures, and not to transfer your data outside agreed jurisdictions without adequate safeguards in place.

Where data is transferred outside Brazil or the European Economic Area — for example, to Google's infrastructure — we rely on standard contractual clauses approved by the relevant supervisory authority and/or the data-transfer mechanisms recognised under LGPD Article 33.

Data Retention

We retain personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by law. Our standard retention periods are as follows:

• Enquiry correspondence: Contact messages and related correspondence are retained for up to 5 years from the date of last interaction. This period reflects the general limitation period under the Brazilian Civil Code (Article 205) for any claims that might arise from a pre-contractual relationship.
• Brokerage transaction records: Where an enquiry leads to a formal brokerage agreement and subsequent property transaction, records are retained for a minimum of 5 years after conclusion of the transaction, in accordance with Receita Federal requirements and CRECI professional obligations, which may in some circumstances extend to 10 years for anti-money-laundering compliance purposes under Law 9.613/1998.
• Website analytics data: Aggregated Google Analytics data is retained in our Google Analytics account for 14 months before automatic deletion (as configured by our account settings). Server access logs are retained for up to 90 days and then purged unless a security investigation requires otherwise.
• Marketing communications consent records: Where you have given consent to receive marketing communications, we retain the record of that consent for the lifetime of our marketing relationship and for 2 years after you withdraw consent, to demonstrate compliance.

At the end of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to any identified or identifiable individual. We review our retention schedules annually to ensure they remain proportionate and legally justified.

Data Security

Silvio Ximenes Imóveis implements a range of technical and organisational measures to protect the personal data in our custody against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit via TLS 1.2 or higher (HTTPS) across all pages of the Site
• Access controls that restrict internal access to personal data on a strict need-to-know basis, with unique credentials required for each user
• Regular review of third-party data processors to verify that their security certifications and practices remain adequate
• Periodic software updates and patch management applied to server and application infrastructure
• Secure email practices for handling correspondence containing personal information, including discouraging the transmission of highly sensitive documents over unencrypted channels

Despite these measures, no method of transmission over the Internet is completely secure. We cannot guarantee absolute security of data transmitted to or from our Site. If you become aware of any vulnerability or security incident involving our Site or your personal data held by us, please notify us immediately at contato@silvioximenes.site so that we can take prompt corrective action.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and, where required by the LGPD or GDPR, notify the relevant supervisory authority (the Autoridade Nacional de Proteção de Dados — ANPD — in Brazil) within the legally prescribed timeframe.

Your Rights

Under Brazil's LGPD (Article 18) and, where applicable, the EU GDPR (Articles 15–22), you have a number of important rights regarding the personal data we hold about you. These rights are summarised below. We will respond to all verified requests within 15 business days, consistent with the LGPD's maximum response timeframe, and within 30 calendar days as required by the GDPR.

To exercise any of the rights listed above, please contact our designated data-protection point of contact by email at contato@silvioximenes.site with the subject line "Data Rights Request." We may ask you to verify your identity before processing your request to protect against fraudulent or unauthorised access to your data. Identity verification typically involves confirming information you have previously shared with us; we will not ask you to provide unnecessary additional personal data for this purpose.

We will never charge a fee for handling a legitimate data rights request unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or decline to act, with written justification provided to you.

Children's Privacy

This Site is intended for use by adults and is not directed at children under the age of 18. We do not knowingly collect personal data from minors. Our real-estate brokerage services involve transactions governed by Brazilian civil law which require legal capacity, and therefore our services are inherently directed at adults of full legal age (18 years or older, or legally emancipated minors as applicable under Brazilian law).

If we become aware that we have inadvertently received personal data from a person under the age of 18 without appropriate parental or guardian consent, we will take prompt steps to delete that data from our records. If you believe that a minor's data has been submitted to us in error, please contact us immediately at contato@silvioximenes.site and we will act without delay.

Changes to This Policy

We review this Privacy Policy at least annually and whenever there are material changes in applicable law, our data-processing activities, or the technologies we use. When we make changes that affect your rights or the way we handle your data in a meaningful way, we will update the "Last updated" date at the top of this page and, where the change is substantial, we will make reasonable efforts to draw it to your attention — for example, by a prominent notice on the Site homepage.

We encourage you to review this Policy periodically so that you remain informed about how we protect your personal data. The version of the Policy bearing the most recent "Last updated" date supersedes all prior versions. Your continued use of the Site after an update is posted constitutes your acknowledgement of the updated Policy, to the extent permitted by applicable law. Where LGPD or GDPR requires fresh consent for a changed processing purpose, we will obtain that consent before proceeding.

Previous versions of this Policy are available on request by contacting us at the address below.

Contact Us

All privacy-related enquiries, data rights requests, or questions about this Policy should be addressed to our data-protection contact. We are committed to resolving any concern promptly, fairly, and transparently. Our full legal and contact details are:

If you are not satisfied with our response to your privacy concern, you have the right to contact the Autoridade Nacional de Proteção de Dados (ANPD) — Brazil's national data-protection supervisory authority — at www.gov.br/anpd. EU/EEA residents may also contact the data-protection authority in their country of habitual residence.