LGPD · Law 13.709/2018
Privacy Policy
Last updated: [CONFIRM date]
[CONFIRM — this document is a structural template within the mockup. It must be reviewed by a lawyer and completed with the company's real details before launch. No company name, CNPJ, address, email or period below is real.]
1. Data controller
The controller of personal data processed through this site is [CONFIRM registered company name], CNPJ [CONFIRM], registered office at [CONFIRM full address], Florianópolis — Santa Catarina, Brazil.
Privacy contact: [CONFIRM DPO email]. Data Protection Officer: [CONFIRM name or “not applicable”].
2. What we collect and why
| Data | When | Purpose | Legal basis (LGPD art. 7) |
|---|---|---|---|
| Name | Consultation form | Identify the enquirer | Pre-contractual steps (item V) |
| Consultation form | Respond to the enquiry | Pre-contractual steps (item V) | |
| Phone (with country code) | Consultation form | Return the contact | Pre-contractual steps (item V) |
| Jurisdiction of residence | Consultation form | Assess mandate fit and referral to local counsel | Consent (item I) |
| Market of interest and timeline | Consultation form | Route the enquiry | Pre-contractual steps (item V) |
| Indicative budget band | Consultation form | Qualify the enquiry — sensitive wealth data | Consent (item I) |
| Referral source | Consultation form | Origin of the enquiry | Consent (item I) |
| Analytics cookies | Browsing, if permitted | Measure site usage | Consent (item I) |
| Marketing cookies | Browsing, if permitted | Measure campaigns | Consent (item I) |
Wealth and investment-intent data. The consultation form collects jurisdiction of residence, an indicative budget band and a timeline. We treat this as highly sensitive: restricted access, used only to assess the enquiry. This site never collects CPF, passport numbers, bank details or source-of-funds documentation. [CONFIRM whether any AML/KYC obligation applies to mandate onboarding — if so it stays entirely off the public site.]
3. Cookies
Essential cookies keep the site working and remember your consent choice; they cannot be switched off. Analytics and marketing cookies are off by default and are only enabled if you tick the matching option in the banner. You can revisit your choice at any time by clearing site data in your browser.
| Category | Default | Examples | Retention |
|---|---|---|---|
| Essential | Always on | Consent record (stored in your browser) | [CONFIRM] |
| Analytics | Off | [CONFIRM tool — e.g. Google Analytics 4] | [CONFIRM] |
| Marketing | Off | [CONFIRM tool — e.g. Meta Pixel] | [CONFIRM] |
4. WhatsApp
The buttons on this site open a WhatsApp conversation with a pre-filled message. From the moment you send that message, the processing of your data in that app is also governed by Meta Platforms' privacy policy, over which we have no control.
5. Sharing
We do not sell personal data. We share it only with processors necessary to deliver the service:
- Website hosting — [CONFIRM]
- Analytics tool, if permitted — [CONFIRM]
- WhatsApp / Meta Platforms, when you start the conversation
- Public authorities, where legally required
International transfers: [CONFIRM — likely, if hosting or analytics sit outside Brazil. State the countries and safeguards.]
6. How long we keep it
Contact data and enquiries: [CONFIRM period]. Consent records: [CONFIRM period]. After that, data is deleted or anonymised, unless a legal retention duty applies.
7. Your rights (LGPD art. 18)
At any time, free of charge, you may request:
- confirmation that processing exists;
- access to your data;
- correction of incomplete, inaccurate or out-of-date data;
- anonymisation, blocking or deletion of unnecessary or non-compliant data;
- portability to another provider;
- deletion of data processed on the basis of consent;
- information about who we share your data with;
- information about your right to refuse consent and the consequences;
- withdrawal of consent.
To exercise any of these, write to [CONFIRM email]. We will reply within the statutory period. You may also petition the ANPD, Brazil's data protection authority.
8. Security
We apply technical and administrative measures to protect personal data. [CONFIRM measures — e.g. HTTPS, access control, backups]. In the event of a significant security incident we will notify you and the ANPD under art. 48.
9. Minors
This site is not directed at people under 18 and does not knowingly collect children's data. No image on this site depicts children or minors.
10. Changes
We may update this policy. The date at the top shows the last revision. Material changes will be flagged on the site.
11. LGPD and GDPR
This firm's stated audience is foreign and explicitly includes European family offices. The site is therefore operated under both Brazil's LGPD (Law 13.709/2018) and the EU GDPR (2016/679): granular consent with refusal as accessible as acceptance, non-essential categories off by default, a named controller, a stated legal basis and a working data-subject request channel. [CONFIRM an EU representative, if the processing volume requires one]
12. What this site does not do
This site publishes no return, yield, appreciation, IRR or cap-rate projection, and provides no returns calculator. Angeli Global is a CRECI-registered real-estate advisory (CRECI/SC 37.050-F); it is not a CVM-authorised investment advisor, not a law firm and not a tax advisor. Nothing here is an offer, a recommendation, or investment, legal or tax advice.
13. Advertising and measurement
[CONFIRM active paid campaigns — the current site loads a Google Ads conversion tag. Ad copy repeating the same return claims is subject to the same CDC rules and to Google's own financial-services advertising policies.] No third-party script runs before consent.