Privacy Policy

Introduction

LPS Brasil - Consultoria de Imóveis S/A. ("LPS Brasil", "we", "us" or "our") operates this institutional website and related digital channels to provide information about our real estate consultancy services. We are a company incorporated under the laws of Brazil, registered under CNPJ 08.078.847/0001-09, with registered offices at Rua Estados Unidos, 2000, Jardim América, São Paulo – SP.

This Privacy Policy explains what personal data we collect when you visit our website or reach out to us through any of our contact channels, how we use and protect that data, and what rights you have in relation to it. We have written this document to comply with Brazil's Lei Geral de Proteção de Dados (LGPD — Law No. 13,709/2018) and, where applicable, the European Union's General Data Protection Regulation (GDPR — Regulation 2016/679) and other relevant privacy legislation.

Please read this policy carefully. By continuing to use our website, you acknowledge that you have read and understood these practices. If you do not agree with any part of this policy, you should discontinue use of our site. This policy applies exclusively to information collected through this website and our official contact channels; it does not govern third-party websites that may be linked from our pages.

Information We Collect

We collect personal information only to the extent necessary to provide our services and maintain an effective, reliable website. The categories of data we may collect are described below.

Information you provide directly

When you contact us by telephone, email or through any messaging channel listed on this site, you may voluntarily provide us with information such as your name, email address, telephone number, and the substance of your enquiry. This information is used solely to respond to your communication and, where relevant, to follow up in the course of a professional relationship.

Information collected automatically

When you browse this website, our hosting infrastructure and analytics tools collect certain technical data automatically. This may include:

• Your Internet Protocol (IP) address and approximate geographic location derived from it (city or country level — we do not access precise GPS location).
• The type and version of the browser and operating system you are using.
• The pages of our site you visit, in what order, and for how long.
• The URL of the website that referred you to ours, or the search query that led you here.
• The date and time of each page request.
• Device identifiers and screen resolution, used solely for rendering optimisation.

This data is collected in aggregated or pseudonymised form and is used to understand how visitors use our site so that we can improve navigation, content and performance. It is not used to identify you as a named individual unless you have separately provided us with identifying information.

Cookies and similar technologies

We use cookies, local storage and similar tracking technologies. Full details are provided in Section 4 of this policy. Cookies may collect identifiers that, when combined with other data, could constitute personal data under applicable law.

Data we do not collect

This website does not contain any online forms that collect personal data, nor does it operate any user account, client portal, property-search tool, booking engine or e-commerce feature. We do not collect sensitive personal data (such as health, financial, ethnic or biometric data) through this site.

How We Use Your Information

LPS Brasil uses personal data only for specific, explicit and legitimate purposes. We never sell personal data to third parties, and we do not use it for automated decision-making or profiling that produces legal or similarly significant effects on individuals.

• Responding to enquiries: When you contact us via email or telephone, we use the details you provide to handle your enquiry, answer your questions, and, if appropriate, establish a commercial relationship with you.
• Service delivery: If you engage LPS Brasil's consultancy services, we use your contact and professional information to perform those services, communicate progress, and fulfil our contractual obligations.
• Website operation and improvement: Automatically collected technical data and analytics help us ensure the site functions correctly, identify and fix errors, and understand which content is most useful to visitors.
• Marketing communications: Where you have given explicit consent, we may send you updates about our services, market analyses or relevant news. You may withdraw this consent at any time by contacting us at contato@lopes-us.site.
• Legal and regulatory compliance: We may process data where necessary to comply with Brazilian laws (including the LGPD, tax legislation and sector-specific real-estate regulation), court orders, or requests from competent public authorities.
• Legitimate interests: We may use data for fraud prevention, network and information security, internal record-keeping, and the exercise or defence of legal claims.

Cookies & Tracking Technologies

A cookie is a small text file placed on your device by a website you visit. Cookies serve a variety of purposes, from keeping a site functional to providing usage statistics. Below we explain the types of cookies this site may use.

Strictly necessary cookies

These cookies are essential for the website to function. They enable basic features such as page navigation, security, and performance. Without them, parts of the site would not work correctly. They do not require your consent and cannot be switched off in our systems.

Analytics and performance cookies

We may use Google Analytics (operated by Google LLC) to collect aggregated statistics about how visitors interact with our site — for example, which pages are visited most often and where visitors come from. Google Analytics uses its own cookies. We have configured our implementation to anonymise IP addresses before they are stored. The data is used solely to improve site performance and user experience.

You can opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on.

Advertising and remarketing cookies

If we run advertising campaigns through Google Ads or similar platforms, those platforms may place cookies on your device to measure campaign effectiveness, such as whether someone who clicked on an advertisement subsequently visited our site. These cookies do not personally identify you to us, and we do not combine ad-measurement data with your contact details. Where required by law, we will seek your consent before placing these cookies.

Third-party embedded content

Some pages may include embedded content from third parties (for example, maps or video players). These third parties may place their own cookies on your device. We recommend reviewing the privacy policies of those third-party providers for further information.

Managing cookies

Most browsers allow you to refuse or delete cookies through their settings. Blocking certain cookies may affect your experience of this website, but will not prevent you from accessing its core informational content. For guidance on cookie management, visit the help pages of your browser provider.

Sharing With Third Parties

LPS Brasil does not sell, rent or trade your personal data. We share data with third parties only in the limited circumstances described below, and always subject to appropriate safeguards.

Service providers (data processors)

We engage trusted service providers to help us operate our business and this website. These include hosting and infrastructure providers, email service providers, and analytics platforms. When these providers process personal data on our behalf, they do so only on our documented instructions and are contractually obliged to implement appropriate security measures and to keep your data confidential.

Google LLC

We use Google services including Google Analytics and, potentially, Google Ads. Google may process data on servers located in the United States and other countries. Google LLC is certified under the EU–US Data Privacy Framework and has entered into standard contractual clauses for international transfers. For further information, see Google's Privacy Policy at policies.google.com/privacy.

Legal and regulatory disclosure

We may disclose personal data to government authorities, regulators, courts or law enforcement agencies where we are required to do so by law, regulation, court order, or in connection with legal proceedings. We will notify affected individuals of any such disclosure where we are legally permitted to do so.

Corporate transactions

In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction. In such circumstances, we will ensure that appropriate privacy protections accompany the transferred data and will notify you of any change in data controller as required by law.

What we will never do

• We will never sell your personal data to data brokers, advertisers or other third parties for their own marketing purposes.
• We will never share your data with parties based in countries that do not offer an adequate level of data protection, without implementing appropriate safeguards such as standard contractual clauses.
• We will never disclose your data to a third party based solely on that party's commercial interest in obtaining it.

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 applicable law. Our general retention criteria are as follows:

• Enquiry and contact data: Information exchanged in the course of an initial enquiry that does not lead to a service engagement is retained for up to 24 months from the date of last contact, after which it is securely deleted or anonymised.
• Service-related data: Data processed in connection with an active service engagement is retained for the duration of that engagement and for a period of up to 5 years thereafter, in accordance with Brazilian civil and commercial law obligations regarding contractual records.
• Accounting and financial records: Where required by Brazilian tax law (Lei No. 9.430/1996 and related regulations), financial records may be retained for up to 5 years from the end of the relevant fiscal year.
• Website analytics data: Aggregated and pseudonymised analytics data collected through tools such as Google Analytics is retained in accordance with the configuration of those tools, typically not exceeding 26 months of user-level data.
• Legal claims: Where data is relevant to pending or anticipated legal proceedings, we may retain it beyond the standard periods until the proceedings are finally resolved.

When the retention period expires, data is securely deleted, anonymised or — where physical media is involved — destroyed in a manner that prevents reconstruction or retrieval. We review our retention schedules periodically to ensure they reflect current legal requirements and business needs.

Data Security

LPS Brasil applies technical and organisational measures proportionate to the risk associated with processing personal data. These measures are designed to protect data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

• Encryption in transit: All data transmitted between your browser and our web server is encrypted using TLS (Transport Layer Security). Pages are served exclusively over HTTPS.
• Access controls: Access to systems that hold personal data is restricted to authorised personnel on a need-to-know basis. We use role-based access controls and require strong authentication credentials.
• Vendor security: We select hosting and service providers that maintain recognised security certifications and conduct due diligence before engaging them.
• Internal training: Staff who handle personal data receive training on data protection obligations and our internal privacy procedures.
• Incident response: We maintain an internal procedure for identifying, containing and responding to personal data breaches. Where required by the LGPD or GDPR, we will notify the relevant supervisory authority and affected individuals within legally mandated timeframes.

Despite these measures, no transmission of data over the internet and no method of electronic storage is completely secure. We cannot guarantee absolute security, but we take the obligation to protect your data seriously and continually review our practices as threats evolve.

Your Rights

Under the LGPD (Article 18) and, where applicable, the GDPR, you have a number of rights in relation to personal data that we hold about you. These rights are not absolute and may be subject to exceptions, but we are committed to honouring them promptly and transparently. Your rights include:

How to exercise your rights

To exercise any of the rights described above, please contact us in writing at contato@lopes-us.site, clearly identifying yourself and specifying the right you wish to exercise. We will respond within 15 business days of receipt of a valid request, as required by the LGPD. Where a request is complex or we have received a large number of requests, we may extend this period by an additional 15 business days, in which case we will notify you accordingly.

We may need to verify your identity before fulfilling a request, to ensure that personal data is not disclosed to, or altered at the direction of, an unauthorised party. We will ask for the minimum information necessary to confirm your identity. We will not charge a fee for handling your request unless it is manifestly unfounded or excessive, in which case we will notify you before proceeding.

Children's Privacy

This website is intended for adults and is not directed at children under the age of 18. LPS Brasil does not knowingly collect personal data from minors. The services we provide — commercial real estate consultancy — are by nature directed at adults with legal capacity to enter into contracts.

Under the LGPD (Article 14), the processing of personal data of children requires the specific and prominent consent of at least one parent or legal guardian, and must be in the child's best interest. We do not solicit such data and have no operational reason to process it.

If you believe that a minor has provided us with personal data without appropriate parental consent, please notify us immediately at contato@lopes-us.site and we will take prompt steps to delete the data from our records.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, applicable legislation, or guidance issued by supervisory authorities such as the ANPD. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, draw attention to the changes on our homepage or notify you directly if we hold your contact details.

We encourage you to review this page periodically to stay informed about how we protect your information. Your continued use of this website after any changes become effective constitutes your acknowledgement of the updated policy. If changes require your renewed consent under applicable law, we will request it before those changes take effect.

Archived versions of this policy are available on request by contacting us at the details below, so that you may compare current and previous versions at any time.

Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your rights under the LGPD or GDPR, or have concerns about how we handle your personal data, please contact us. In accordance with Article 41 of the LGPD, LPS Brasil has designated a responsible person for privacy matters (Encarregado de Proteção de Dados) who can be reached through the contact details below.