Last updated: 3 October 2026 (awaiting final legal review)
This policy explains how Exclusive Realty Brasil collects and uses personal data when you visit our website, send us an enquiry or work with us to buy or sell a property. It is written to meet the Brazilian General Data Protection Law (LGPD, Law 13.709/2018) and, for visitors in the European Economic Area, Switzerland and the United Kingdom, the General Data Protection Regulation (GDPR).
1. Who we are
The controller of your personal data is Exclusive Realty Empreendimentos Imobiliários Ltda, trading as Exclusive Realty Brasil, CNPJ 10.861.511/0001-51, Fazenda Taípe, km 18, nº 6 A, Trancoso, Porto Seguro, Bahia, CEP 45818-000, Brazil. Registered real estate broker, CRECI RJ-065884/O.
For any privacy question or request, contact our data protection officer (encarregado): Edmond van Wijngaarden, [email protected].
2. What data we collect
- Details you give us: your name, email address, phone or WhatsApp number, country, budget and currency, when you plan to buy, the properties you are interested in and anything you write in your message. If you want to sell, we also collect details about your property.
- Conversations: emails, WhatsApp messages and call notes when you contact us or we reply to you.
- Transaction documents: if you go ahead with a purchase or sale, identification and other documents needed for the deed and for legal checks.
- Technical data: IP address, browser and device type, the pages you visit, the website that sent you to us and campaign codes in the link (for example from an advert). Analytics and advertising cookies are only used if you accept them (see section 8).
3. Why we use it, and on what legal basis
| Purpose | Legal basis |
|---|---|
| Replying to your enquiry, sending you property information you asked for, arranging viewings | Steps you asked us to take before a contract (GDPR art. 6(1)(b); LGPD art. 7, V) |
| Following up on your search and suggesting suitable properties after you contacted us | Our legitimate interest in serving enquirers (GDPR art. 6(1)(f); LGPD art. 7, IX). You can object at any time. |
| Sending our newsletter and new listings by email | Your consent, given by ticking the optional box or signing up to the newsletter (GDPR art. 6(1)(a); LGPD art. 7, I). You can unsubscribe at any time. |
| Handling a purchase or sale, including due diligence and the deed | Performance of a contract (GDPR art. 6(1)(b); LGPD art. 7, V) |
| Record keeping required by law, including anti-money-laundering rules for real estate | Legal obligation (GDPR art. 6(1)(c); LGPD art. 7, II) |
| Keeping the website secure, preventing spam and measuring visits | Our legitimate interest (GDPR art. 6(1)(f); LGPD art. 7, IX), and your consent for analytics and advertising cookies |
Sending an enquiry does not sign you up to marketing. We only send newsletters or promotional emails if you ask for them.
4. Who we share it with
We never sell your data. We share it only where needed, with:
- Service providers who work for us under contract: HubSpot (our customer database and email platform, data stored in the EU), our website host, Cloudflare (website security and speed), Google (Analytics, Tag Manager, Ads and email), Meta (advertising measurement and WhatsApp, when you choose to message us there).
- People involved in your transaction, with your knowledge: the property owner or seller, partner brokers, lawyers, notaries and registry offices.
- Authorities, when the law requires it.
5. International transfers
We work from Brazil, and some of our providers store data in the European Union or the United States. When data leaves Brazil or the EEA, we rely on adequacy decisions or standard contractual clauses (GDPR art. 46; LGPD art. 33).
6. How long we keep it
- Enquiries: up to 3 years after our last contact, unless you ask us to delete them sooner.
- Transactions: for as long as the law requires (usually at least 5 years after the deal).
- Newsletter: until you unsubscribe.
- Analytics: up to 14 months.
7. Your rights
You can ask us to confirm whether we hold your data, give you a copy, correct it, delete it, restrict or object to its use, transfer it to another provider, or tell you who we have shared it with. You can withdraw consent at any time, for example with the unsubscribe link in any email. To make a request, email [email protected]. We reply within 15 days.
You can also complain to the Brazilian data protection authority (ANPD, gov.br/anpd) or, if you live in Europe, to your local data protection authority.
8. Cookies
Some small files are needed for the website to work, for example to remember the currency you chose and to protect our forms from spam. Analytics cookies (to understand how the site is used) and advertising cookies (to measure our adverts on Google and Meta) are only set if you accept them in the cookie banner. You can change your choice at any time with the “Cookie settings” link at the bottom of every page.
9. Security
We use encrypted connections, access controls, login protection and regular backups, and we only give our team access to the data they need.
10. Children
Our services are meant for adults. We do not knowingly collect data from anyone under 18.
11. Changes
We may update this policy. The date at the top shows the latest version. If we make important changes, we will say so on this page.