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🏠 Maracaju · MS · BrazilPrivacy · LGPD · Real Estate · CRECI-MS · ISS Maracaju

Privacy Policy.

Ltda R2A Imóveis Ltda · CNPJ 48.278.673/0001-34

Company

R2A Imóveis Ltda

CNPJ

48.278.673/0001-34

Last updated

January 2025

Legislation

LGPD · CRECI-MS · Lei 6.530/78 · ISS Maracaju

This Privacy Policy describes how R2A Imóveis Ltda ("we," "our" or "the Company") collects, uses, stores and protects personal data of our clients, website visitors and all persons whose data we process in connection with our real estate brokerage and property valuation activities at Rua Cmte. Camisão, 870, Sala 2, Jardim Guanabara, Maracaju, Mato Grosso do Sul, Brazil.

As a registered limited liability company (Ltda) operating in the real estate sector with a CRECI-MS registered broker, we are committed to full compliance with the LGPD (Lei nº 13.709/2018), the CDC (Lei nº 8.078/1990), Lei 6.530/78 (which governs real estate brokers in Brazil), and the tax obligations of ISS of the Municipality of Maracaju and SEFAZ-MS. Real estate transactions involve some of the most sensitive personal data processed in any sector — CPF, income, financial situation, property ownership history, family composition — and we treat all client data with corresponding care.

01

Introduction and Scope

This Policy applies to all personal data processed in connection with our real estate brokerage and valuation activities — buyers and sellers of residential, commercial and rural properties, clients who commission property valuations, website visitors and any person whose data we process. Real estate brokerage involves access to financial, patrimonial and family data that goes beyond most commercial sectors in its depth and sensitivity.

02

Identity of the Controller

Company name: R2A Imóveis Ltda
Type: Sociedade Limitada (Ltda)
CNPJ: 48.278.673/0001-34
Activity (CNAE): Corretagem na Compra e Venda e Avaliação de Imóveis (6821-8/01)
Address: Rua Cmte. Camisão, 870, Sala 2, Jardim Guanabara, Maracaju — MS, Brazil
CRECI-MS: Registered real estate broker
Email: privacy@r2aimoveis.com.br
03

Personal Data We Collect

  • Identity and fiscal data: Name, CPF or CNPJ, RG, marital status and profession — required for purchase and sale documentation, promissory agreements (compromissos de compra e venda), and NF-e issuance.
  • Financial data: Income range, financial institution, financing pre-approval status — collected from buyers when required for property matching and mortgage eligibility assessment. Never shared with third parties without consent.
  • Property data: Address, registration number (matrícula), IPTU number, area, valuation history and documentation status — for the property being bought, sold or valued.
  • Valuation engagement data: Property description, valuation purpose (financing, legal, insurance, estate), and technical specifications — for ABNT NBR 14653 valuation reports.
  • Website and WhatsApp enquiry data: Name, WhatsApp and property requirement when submitting an enquiry.
  • Technical website data: IP address, browser type and pages visited.
04

Purpose and Legal Basis

PurposeLegal Basis (LGPD)
Real estate brokerage intermediationContract performance (Art. 7º, V)
Property valuation service deliveryContract performance (Art. 7º, V)
Issuing NF-e / RPS per engagementContract performance; Legal obligation (Art. 7º, II)
ISS Maracaju / SEFAZ-MS fiscal bookkeepingLegal obligation (Art. 7º, II)
CRECI-MS regulatory compliance recordsLegal obligation (Art. 7º, II)
ITCD / SEFAZ-MS property transfer documentationLegal obligation (Art. 7º, II)
Website analytics and improvementLegitimate interest; Consent (cookies)
05

Sharing of Data

Real estate data confidentiality: A client's financial situation, property ownership history and purchase plans are highly sensitive. We never share client financial data, income information or property search preferences with banks, financial institutions, insurance companies, construction companies or any third party without explicit client consent. When a transaction requires sharing data with a notary (cartório), a financial institution or a legal professional, we share only the minimum data necessary and only with the client's knowledge.
  • SEFAZ-MS / Receita Federal: NF-e for the brokerage commission — client CPF or CNPJ, transmitted electronically.
  • ISS / Prefeitura de Maracaju: ISS bookkeeping on services rendered in Maracaju.
  • Cartório de Registro de Imóveis: Property registration documentation as required for completion of purchase and sale transactions — deed execution, property transfer and registration at the notary of Maracaju, MS.
  • SEFAZ-MS (ITCD): Property transfer tax documentation — ITCD (Imposto sobre Transmissão Causa Mortis e Doação) records for estate transfers and donations where applicable.
  • CRECI-MS: Transaction records where required by CRECI-MS audit or regulatory inspection.
  • PROCON-MS / Senacon: When required in consumer disputes.
  • Legal authorities: When required by court order or administrative authority.
06

International Transfers

Our operation is based in Maracaju, MS. All client and property data is processed in Brazil. Tax records (NF-e / RPS) are processed exclusively in systems certified by the Receita Federal and SEFAZ-MS. Communication platforms for WhatsApp enquiries operate under the data transfer guarantees of Art. 33 of the LGPD.

07

Retention Periods

  • Transaction and brokerage records: Retained for 5 years after transaction completion — the standard civil liability prescription period for real estate transactions under the Brazilian Civil Code (Art. 206, §5º, I).
  • Valuation reports: Retained for 5 years — ABNT NBR 14653 valuation reports may be referenced in subsequent transactions, legal proceedings or insurance claims years after issuance.
  • NF-e / RPS (ISS Maracaju / SEFAZ-MS): Minimum 5 years as required by Brazilian federal and Mato Grosso do Sul state tax legislation.
  • CRECI-MS transaction records: Retained in accordance with CRECI-MS regulatory requirements for broker records — typically aligned with the 5-year civil liability period.
  • Enquiries without transaction: Up to 1 year — property search cycles in MS can extend over several months.
  • Website analytics: Aggregated and anonymised after 12 months.
08

Security Measures

  • Client financial and patrimonial data stored in access-controlled systems — not accessible to third parties;
  • Physical documents containing CPF, RG and income data stored in locked filing, accessible only to the broker directly handling the transaction;
  • NF-e / RPS issued using a certified digital certificate (A1/A3) approved by the Receita Federal;
  • Website encrypted (HTTPS);
  • Incident response procedures in accordance with LGPD Art. 48.
09

Your Rights under the LGPD

  • Confirmation and Access (Art. 18, I–II): Confirm what data we hold about your transaction and receive a copy.
  • Correction (Art. 18, III): Correct inaccurate data — particularly important for property data (address, area, registration number) used in valuation reports.
  • Deletion (Art. 18, IV): Request deletion — subject to mandatory retention (5 years for transaction records, NF-e and CRECI-MS compliance records).
  • Portability (Art. 18, V): Receive your transaction data in a structured format — useful for clients who are continuing their property search with another agent.
  • Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.

We respond within 15 business days.

10

Cookies and Tracking

Our website may use cookies for essential functionality and aggregated performance analytics. We do not use behavioural tracking or advertising cookies. Cookie preferences can be managed through your browser settings.

11

Minors

Real estate transactions in Brazil require legal capacity — contracts for property purchase and sale must be executed by adults (18+) or by legal representatives for minors. Where a minor has an interest in a property (inheritance, judicial inventory, donation), the legal representative (parent or guardian) is the data subject for LGPD purposes. We process minors' data only within the scope of transactions where they have a legally recognised property interest, and always with the involvement of the responsible adult.

12

CRECI-MS, Real Estate Law and ISS Maracaju

CRECI-MS and Lei 6.530/78 — what the broker registration means for client data: Every real estate broker operating in Brazil must be registered with the CRECI (Conselho Regional de Corretores de Imóveis) of their state. R2A Imóveis Ltda operates with a CRECI-MS registered broker in compliance with Lei 6.530/78, which establishes the legal framework for the real estate brokerage profession in Brazil. The CRECI-MS registration creates specific obligations that intersect with client data: (a) Transaction records — CRECI-MS may audit broker transaction records as part of regulatory oversight; brokers must maintain records of intermediation engagements; (b) Client identification — the broker is legally responsible for verifying the identity and capacity of the parties in a transaction; CPF and RG verification is a professional obligation, not merely a commercial convenience; (c) Commission documentation — the brokerage commission must be documented and invoiced with ISS correctly applied. The CRECI-MS audit right over transaction records creates a regulatory retention obligation that parallels (and overlaps with) the tax retention obligation for NF-e/RPS records.
Real estate data sensitivity — financial and patrimonial information under LGPD: Real estate brokerage collects data that, while not classified as "sensitive" under LGPD Art. 5º, II (which lists health, genetic, biometric, racial, religious, political and sexual data), is economically sensitive in ways that require heightened protection. A client's income range, mortgage approval status, maximum budget and urgency to sell constitute a financial profile that could be exploited if disclosed to wrong parties — other buyers, sellers, competing agents or financial institutions seeking to offer products. The LGPD's general framework protects this data through the legitimate interest and contract performance legal bases — but the real protection comes from the professional ethics obligations of the CRECI-regulated broker, which are more stringent than the LGPD's baseline. R2A Imóveis Ltda treats financial and patrimonial client data with the confidentiality standard of the CRECI code of conduct, which prohibits the use or disclosure of client information for any purpose beyond the brokerage engagement.
ISS Maracaju and ITCD-MS for real estate transactions: Real estate brokerage services (intermediação imobiliária) are subject to ISS (Imposto Sobre Serviços) under the Municipal Services Tax framework (LC 116/2003, item 21 — "Serviços de intermediação e congêneres"). ISS is levied by the municipality where the brokerage service is provided — for services provided from Maracaju, ISS Maracaju applies. The NF-e or RPS for each brokerage commission is issued with the client's CPF or CNPJ and ISS Maracaju applied. Separately, property transfers in Mato Grosso do Sul may be subject to ITBI (Imposto de Transmissão de Bens Imóveis) levied by the municipality for inter vivos transfers, and ITCD (Imposto sobre Transmissão Causa Mortis e Doação) levied by SEFAZ-MS for estate and donation transfers. While the ITBI and ITCD are the buyer's/heir's fiscal obligation rather than the broker's, R2A Imóveis Ltda assists clients in understanding and documenting these obligations as part of the transaction support service. For rural properties in the Maracaju region, the ITR (Imposto Territorial Rural) status and the NIRF (Número de Imóvel Rural na Receita Federal) registration are additional documentary requirements that the valuation report and brokerage documentation must address.
13

Updates to this Policy

This Policy may be updated to reflect changes in our activities, in the LGPD, in ANPD guidance, in CRECI-MS regulatory requirements, in Lei 6.530/78 or its implementing regulations, in ISS Maracaju / SEFAZ-MS legislation, or in ITCD-MS property transfer tax rules. Material changes will be communicated by email or WhatsApp to active clients.

14

Contact and Data Protection Officer

All privacy requests should be directed to our Data Protection Officer (LGPD Art. 41):

🏠

Privacy — R2A Imóveis Ltda

CompanyR2A Imóveis Ltda
CNPJ48.278.673/0001-34
AddressRua Cmte. Camisão, 870, Sala 2, Jardim Guanabara, Maracaju — MS, Brazil
WhatsApp+55 (67) 9 0000-0000
HoursMon–Fri: 08:00–18:00 · Sat: 08:00–12:00
ResponseWithin 15 business days of receipt.
You also have the right to lodge a complaint with the Brazilian national data protection authority:
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd