Privacy Policy

Section 01

Introduction

AM IMOVEIS LTDA ("AM Imóveis", "we", "us", or "our") is a real estate brokerage company incorporated under Brazilian law, registered under CNPJ 23.537.693/0001-51, with its principal office at Rua Washington, 634, Sion, Belo Horizonte – MG, Brazil. We operate the website available at mdimoveis.site and its associated subdomains (collectively, the "Website").

We are committed to protecting the privacy and security of personal information entrusted to us. This Privacy Policy explains what personal data we collect when you visit our Website or get in touch with us, why we collect it, how we use and protect it, and what rights you have over it.

This Policy is written in compliance with Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD — Law 13,709/2018) and, where applicable, the European Union General Data Protection Regulation (GDPR — Regulation 2016/679). It also aligns with the requirements set out by Google LLC for advertisers using Google Ads and related services. By using our Website, you acknowledge that you have read and understood this Policy.

Section 02

Information We Collect

We collect personal information through different channels, only to the extent reasonably necessary to provide our services and communicate with you. The categories of data we may collect include:

2.1 Information you provide directly

When you reach out to us by telephone, email, WhatsApp, or through any contact form published on our Website, you may voluntarily share:

• Your full name
• Email address
• Telephone or mobile number
• The general nature of your real estate enquiry (e.g., buying, selling, or renting)
• Any additional information you choose to include in a message

Providing this information is entirely voluntary. You are never legally required to share personal data with us. However, if you choose not to provide certain details, we may be unable to respond to or assist with your enquiry.

2.2 Information collected automatically

When you browse our Website, our servers and third-party analytics tools automatically collect certain technical and behavioural data. This includes:

• IP address and approximate geographic location (city/region level)
• Browser type, version, and language settings
• Operating system and device type (desktop, tablet, mobile)
• Referring URL (the page you came from before visiting ours)
• Pages visited, time spent on each page, and navigation path
• Date and time of each visit
• Unique identifiers stored in cookies or similar technologies

This data is collected in aggregated or pseudonymised form where possible and is primarily used to understand how visitors interact with our Website so we can improve it. See Section 4 for full details on cookies.

2.3 Information from advertising platforms

We run advertising campaigns on platforms including Google Ads and Meta (Facebook / Instagram). These platforms may share aggregated conversion and audience data with us — for example, reporting that a user clicked an advertisement and later visited a specific page. We do not receive personally identifiable information directly from these platforms in a form that allows us to identify individual users without their prior engagement with us.

Section 03

How We Use Your Information

We process personal data on the following legal bases and for the following purposes:

• Responding to enquiries — to answer your questions, provide information about properties or services you have expressed interest in, and arrange meetings or viewings with our licensed brokers. Legal basis: performance of pre-contractual measures at your request (LGPD Art. 7, II; GDPR Art. 6(1)(b)).
• Providing real estate brokerage services — where you engage us to assist with buying, selling, or leasing property, we process the personal data necessary to execute and manage that engagement. Legal basis: performance of contract (LGPD Art. 7, V; GDPR Art. 6(1)(b)).
• Legal and regulatory compliance — real estate transactions in Brazil are subject to oversight by the Conselho Federal de Corretores de Imóveis (COFECI) and associated regional councils (CRECI). We may be required to retain certain records for inspection or audit purposes. Legal basis: compliance with a legal obligation (LGPD Art. 7, II; GDPR Art. 6(1)(c)).
• Website analytics and performance — to understand how visitors use our site, identify technical issues, and improve user experience. Legal basis: legitimate interest (LGPD Art. 7, IX; GDPR Art. 6(1)(f)), balanced against your privacy rights.
• Advertising measurement — to evaluate the effectiveness of our paid advertising campaigns and allocate our marketing budget responsibly. Legal basis: legitimate interest or, where required, consent.
• Preventing fraud and ensuring security — to detect and prevent misuse of our Website, fraudulent submissions, or security incidents. Legal basis: legitimate interest (LGPD Art. 7, IX; GDPR Art. 6(1)(f)).

Section 04

Cookies & Tracking Technologies

Cookies are small text files placed on your device by a website server. They are widely used to make websites function more efficiently, and to provide reporting information. We use the following categories of cookies on our Website:

4.1 Strictly necessary cookies

These cookies are essential for the Website to function correctly. They enable core features such as page navigation, security, and session management. Because they are indispensable for the site to operate, they do not require your consent and cannot be disabled through our cookie controls.

4.2 Analytics cookies

We use Google Analytics 4 (provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to collect anonymised data on website traffic and user behaviour. Google Analytics sets cookies (including _ga and _ga_*) that allow us to recognise returning visitors and measure how pages are used. We have configured Google Analytics with IP anonymisation enabled, meaning your full IP address is never logged. Data collected by Google Analytics may be transferred to and stored on Google's servers in the United States. Google participates in the EU–US Data Privacy Framework. You can opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on.

4.3 Advertising & remarketing cookies

If you have arrived at our Website through a Google Ads or Meta advertisement, these platforms may set cookies on your device to record that visit for conversion tracking and audience building purposes. Cookies in this category may include those set by Google Ads (DoubleClick / _gcl_au), Meta Pixel, and similar advertising SDKs. These technologies allow us to measure whether our adverts lead to visits to our Website and, in some cases, to show you relevant adverts on other websites you visit.

Because advertising cookies process data in ways that go beyond what is strictly necessary, we rely on your prior informed consent before placing them, in line with LGPD Art. 7, I and ePrivacy requirements where applicable.

4.4 Managing your cookie preferences

You can manage or withdraw your consent to non-essential cookies at any time through our cookie preference centre (accessible via the banner displayed on your first visit) or by adjusting your browser settings. Please be aware that disabling certain cookies may affect the functionality and appearance of our Website. Most web browsers allow you to view, block, or delete cookies through the browser's privacy settings. For guidance, consult the help documentation for your specific browser.

Section 05

Sharing With Third Parties

We do not share your personal data with third parties except in the following circumstances, and always subject to appropriate safeguards:

• Service providers and operators — we engage trusted companies to help operate our Website and business, including web hosting providers, email delivery services, and customer relationship management tools. These providers process personal data only on our behalf and under our instructions, and are prohibited from using it for any other purpose. We enter into data processing agreements with each provider as required under the LGPD.
• Analytics and advertising platforms — as described in Section 4, we use Google Analytics and Google Ads, which involve data being processed by Google LLC. We also use Meta Business Suite to manage our social media presence and paid advertising on Facebook and Instagram. Each platform's own privacy policy governs how they handle data received through their respective tools.
• Real estate partners — in the course of facilitating a property transaction, it may be necessary to share information with property owners, legal representatives, notaries, or financial institutions strictly as required to progress the transaction you have instructed us to assist with.
• Legal and regulatory obligations — we may disclose personal data when required to do so by law, court order, or at the legitimate request of a public authority, including the CRECI-MG (Conselho Regional de Corretores de Imóveis de Minas Gerais), tax authorities, or law enforcement agencies.
• Business transfers — in the event that AM IMOVEIS LTDA undergoes a merger, acquisition, or sale of all or part of its business assets, your personal data may be transferred to a successor entity. We will notify you of any such change and of any choices you may have regarding your data.

Whenever we transfer personal data to countries outside Brazil or the European Economic Area, we ensure that appropriate safeguards are in place — including standard contractual clauses, adequacy decisions, or participation in recognised cross-border frameworks — to maintain an equivalent level of protection.

Section 06

Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention principles are:

• Enquiry and contact data — records of enquiries that do not proceed to a formal engagement are retained for up to 24 months from the date of last contact, after which they are securely deleted or anonymised.
• Brokerage transaction records — documents and communications relating to completed or attempted property transactions may be retained for up to 5 years following the conclusion of the transaction or the end of our engagement, in accordance with Brazilian civil law obligations (Código Civil, Art. 205) and real estate regulatory requirements.
• Analytics data — pseudonymised website analytics data is retained in Google Analytics for a maximum of 14 months, as configured in our account.
• Legal hold — where personal data is the subject of an ongoing legal dispute, regulatory investigation, or audit, we will retain the relevant records until the matter is resolved, regardless of the standard retention period.

Upon expiry of the applicable retention period, personal data is either securely deleted, destroyed, or irreversibly anonymised so that it can no longer be associated with any individual.

Section 07

Data Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Our security practices include:

• Encryption of data in transit using TLS (Transport Layer Security) 1.2 or higher
• Access controls ensuring that only authorised personnel can access personal data, on a need-to-know basis
• Use of reputable, security-audited hosting infrastructure with regular software patching
• Internal policies governing the handling, storage, and disposal of personal information
• Regular review of our data processing activities and security posture

While we take these precautions seriously, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security, but we are committed to promptly addressing any security incidents and notifying affected individuals and relevant authorities where required by law. Under the LGPD, we will notify the Autoridade Nacional de Proteção de Dados (ANPD) and affected data subjects of any security incident that may result in relevant risk or harm within a reasonable timeframe.

Section 08

Your Rights

Depending on your jurisdiction and the legal basis on which we process your data, you may have the following rights. Brazilian residents are entitled to these rights under the LGPD (Art. 18); EEA residents are entitled to equivalent rights under the GDPR:

To exercise any of these rights, please contact our data protection point of contact using the details set out in Section 11 below. We will respond to all valid requests within 15 business days (LGPD standard) or within one calendar month (GDPR standard), depending on which framework applies to your request. We may need to verify your identity before processing certain requests to prevent fraudulent or unauthorised access to personal data.

We will not discriminate against you for exercising any of the rights described in this section. Exercising your rights will not affect the quality of any service we provide to you, nor impose any charge unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act.

Section 09

Children's Privacy

Our Website and services are directed exclusively to adults. We do not knowingly collect personal data from individuals under the age of 18. Real estate transactions in Brazil require the capacity to enter into legally binding contracts, which generally requires full legal majority.

If we become aware that we have inadvertently collected personal data from a minor without verifiable parental or guardian consent, we will take prompt steps to delete that information from our records. If you are a parent or legal guardian and believe that your child has provided personal data to us, please contact us immediately at contato@mdimoveis.site so we can investigate and take appropriate action.

Section 10

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, the services we offer, or evolving legal requirements. When we make changes, we will revise the "Last updated" date displayed at the top of this page and, where the changes are material, we will take reasonable steps to notify you — for example, by posting a prominent notice on our homepage or, where we hold your contact details and the change significantly affects how we process your data, by reaching out directly.

We encourage you to review this page periodically to stay informed about how we protect the personal information we hold. Your continued use of our Website after any changes are posted constitutes your acceptance of the updated Policy, to the extent permitted by applicable law. For substantive changes that require renewed consent, we will seek that consent before continuing to process your data under the new terms.

Section 11

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact our data protection point of contact using the details below. We take all privacy enquiries seriously and will do our best to address your concern promptly and thoroughly.

If you are an EEA resident and are not satisfied with our response to your privacy concern, you have the right to escalate the matter to your local data protection supervisory authority. Brazilian residents may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).