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.
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.
Identity of the Controller
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
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.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Real estate brokerage intermediation | Contract performance (Art. 7º, V) |
| Property valuation service delivery | Contract performance (Art. 7º, V) |
| Issuing NF-e / RPS per engagement | Contract performance; Legal obligation (Art. 7º, II) |
| ISS Maracaju / SEFAZ-MS fiscal bookkeeping | Legal obligation (Art. 7º, II) |
| CRECI-MS regulatory compliance records | Legal obligation (Art. 7º, II) |
| ITCD / SEFAZ-MS property transfer documentation | Legal obligation (Art. 7º, II) |
| Website analytics and improvement | Legitimate interest; Consent (cookies) |
Sharing of Data
- 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.
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.
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.
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.
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.
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.
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.
CRECI-MS, Real Estate Law and ISS Maracaju
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.
Contact and Data Protection Officer
All privacy requests should be directed to our Data Protection Officer (LGPD Art. 41):
Privacy — R2A Imóveis Ltda
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd