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 | Contact form | Identify who got in touch | Pre-contractual steps (item V) |
| Phone / WhatsApp and email | Contact form | Reply to the enquiry | Pre-contractual steps (item V) |
| Property of interest | Contact form | Route the enquiry | Pre-contractual steps (item V) |
| Budget band / search profile | Contact form | Qualify the search — sensitive wealth data | Consent (item I) |
| Documents required to let or buy | At contracting, off the website | Formalise the contract | Legal obligation (item II) |
| Analytics cookies | Browsing, if permitted | Measure site usage | Consent (item I) |
| Marketing cookies | Browsing, if permitted | Measure campaigns | Consent (item I) |
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.
Controller
The data controller is the legal entity named in the site footer — Personal Empreendimentos Imobiliarios Ltda, CRECI 2910J, Avenida Pequeno Príncipe, 2020 — Loja 2, Campeche, Florianópolis/SC, Brazil. [CONFIRM whether this is the correct contracting entity and its CNPJ].
Financial-intent data
The forms on this site collect an intended budget band and an interest in financing. That data is processed to find matching properties and to take a credit conversation forward, on the basis of pre-contractual dealings and legitimate interest (LGPD, art. 7, V and IX). It is not used for marketing without separate consent and is not sold or passed to third parties for commercial purposes. [CONFIRM correspondente bancário status and which institutions receive the data].
Property requests
When you describe the property you are looking for, we keep that description so we can tell you when a match appears. You can ask for that record to be deleted at any time, and it then stops generating contact. [CONFIRM retention period].
WhatsApp is Habiflex’s main service channel. Conversation history sits on the company device and on WhatsApp’s own servers, subject to Meta’s privacy policy. We use the channel only to handle your enquiry.
Listing platform
Part of the property content on Habiflex’s current site is served by a third-party real-estate portal platform. [CONFIRM which platform, who operates the lead data it generates, and who owns the listing database] — in a migration that is the first contractual question, ahead of any technical change.