Privacy Policy

01 Introduction

Trevisani Moveis USA ("we", "us", or "our") is a real estate consultancy incorporated in the United States and Brazil, specializing in helping clients acquire residential and commercial properties in the United States. Our primary website is trevisanimoveisusa.com.

This Privacy Policy describes how we collect, use, store, and disclose personal data obtained through our website, communications, and professional interactions. It applies to all visitors, prospective clients, current clients, and anyone else who engages with our digital or physical touchpoints.

We operate in compliance with the General Data Protection Regulation (GDPR) for individuals located in the European Union or European Economic Area; Brazil's Lei Geral de Proteção de Dados (LGPD — Law 13,709/2018) for Brazilian data subjects; and applicable federal and state privacy statutes of the United States, including the California Consumer Privacy Act (CCPA) where relevant.

By using our website or engaging our services, you acknowledge that you have read and understood this policy. If you do not agree with its terms, please refrain from using our website or providing us with your personal data.

02 Information We Collect

We collect information in two broad categories: data you provide to us directly, and data collected automatically when you visit our website.

Information You Provide Directly

When you contact us by phone, email, WhatsApp, or through any inquiry channel, you may provide personal data that includes, but is not limited to:

• Identity data: full name, nationality, date of birth, passport or government-issued identification number (when required for real estate transactions).
• Contact data: email address, phone number (including international and WhatsApp), mailing address.
• Financial profile data: general budget range, financing preferences, and investment objectives — shared voluntarily during consultation to allow us to make appropriate property recommendations. We do not collect bank account numbers, credit card details, or Social Security Numbers through our website.
• Communication records: the content of emails, messages, or notes generated during meetings and calls with our team, retained to ensure continuity of service.
• Transaction-related data: information required to complete a real estate purchase, lease, or legal process, such as proof of funds, visa status, and power-of-attorney documentation, collected at the appropriate stage and handled with heightened confidentiality.

Information Collected Automatically

When you visit trevisanimoveisusa.com, our servers and third-party analytics tools automatically collect certain technical information:

• Usage data: pages visited, time spent on each page, navigation paths, referring URLs, and exit pages.
• Device & browser data: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, and language settings.
• Cookie data: session cookies, persistent cookies, and similar tracking technologies as described in Section 4 of this policy.
• Advertising interaction data: if you arrive at our site via a paid advertisement (Google Ads, Meta, etc.), we may receive anonymized or aggregated data about which ad you clicked and the general audience segment it was served to.

Automatic collection occurs regardless of whether you submit any contact details. IP addresses are retained in anonymized form for analytics purposes and are not used to personally identify visitors except when required by law enforcement.

03 How We Use Your Information

We process personal data only for specific, legitimate, and clearly defined purposes. We do not sell your personal information to any third party under any circumstances. The legal bases we rely on under GDPR and LGPD include consent, legitimate interests, contractual necessity, and legal obligation.

• Service delivery: To respond to your inquiries, schedule consultations, present property recommendations, and carry out the real estate advisory and transaction services you engage us for. This processing is necessary for the performance of a contract or pre-contractual steps.
• Communication: To send you follow-up information, answer questions, share market updates or investment insights relevant to your stated interests. Where required by law, we obtain your explicit consent before sending marketing communications.
• Legal compliance: To fulfil obligations under anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements applicable to real estate transactions, and any reporting duties imposed by U.S. or Brazilian authorities.
• Website improvement: Aggregated and anonymized analytics data helps us understand which content is most valuable to visitors, optimize page performance, and improve the overall user experience.
• Advertising effectiveness: Anonymized conversion data helps us measure which advertising campaigns generate genuine client interest so we can allocate our marketing budget responsibly and avoid showing you irrelevant ads.
• Security & fraud prevention: To monitor for suspicious access, protect our systems, and detect or prevent fraudulent or unauthorized activity.

We will never use your personal data for purposes that are incompatible with those stated above without first notifying you and, where required, obtaining fresh consent.

04 Cookies & Tracking Technologies

Our website uses cookies and similar technologies (such as pixels and local storage) to operate correctly, analyze traffic, and, where you have given consent, to serve relevant advertising. A cookie is a small text file placed on your device. It cannot execute programs or carry viruses.

Types of Cookies We Use

• Strictly necessary cookies: Required for the website to function. These enable core features such as page navigation, security checks, and load balancing. They do not collect personal data for marketing purposes and cannot be disabled without breaking site functionality.
• Analytics & performance cookies: We use Google Analytics 4 (with IP anonymization enabled) to collect anonymized data about how visitors interact with our pages — which content is popular, where users drop off, and how they arrive. This helps us continuously improve the site. Data collected through GA4 is governed by Google's privacy policy.
• Advertising & retargeting cookies: We may use Google Ads conversion tracking and the Google Ads remarketing tag to measure ad performance and, with your consent, to show our ads to people who have previously visited our website. The Google Tag Manager container manages these tags in a controlled manner. Meta Pixel may also be in use for similar purposes on the Meta advertising network. These cookies collect a hashed, pseudonymous identifier and are subject to opt-out through the Google Ad Settings and Meta Ads Manager respectively.
• Functionality cookies: These remember your preferences — such as language or whether you have acknowledged our cookie notice — so you do not need to reset them on every visit.

Cookie Consent & Your Choices

When you first visit our website, you will be presented with a cookie consent notice. Strictly necessary cookies are always active. All other cookie categories are activated only upon your affirmative consent. You may withdraw consent at any time by adjusting your browser settings to refuse or delete cookies, or by using opt-out tools provided by:

• Google Analytics: tools.google.com/dlpage/gaoptout
• Google Ads personalization: adssettings.google.com
• Meta / Facebook: your Facebook account's "Ad Preferences" panel
• General opt-out (NAI): optout.networkadvertising.org

Please note that disabling certain cookies may affect website functionality and your browsing experience. Opting out of advertising cookies does not mean you will stop seeing our ads — it means those ads will no longer be personalized based on your visit history.

Do Not Track

Some browsers transmit a "Do Not Track" (DNT) signal. Our website currently does not alter its data collection practices in response to DNT signals, as no universally accepted standard for honoring them yet exists. We encourage you to use the specific opt-out mechanisms listed above.

05 Sharing With Third Parties

We do not sell, rent, or trade your personal information. We share data only in the limited circumstances described below, and always with appropriate contractual safeguards in place.

• Service providers & processors: We engage trusted technology and professional service providers who process data strictly on our behalf and under our instructions — including cloud hosting providers, email delivery platforms, and CRM software vendors. These providers are bound by data processing agreements that prohibit any use of your data beyond what is necessary to deliver their service to us.
• Real estate ecosystem partners: With your explicit knowledge and where required to complete a transaction, we may share relevant data with U.S.-licensed real estate brokerages, title companies, escrow agents, immigration attorneys, and mortgage brokers. Such sharing is governed by contractual confidentiality obligations and occurs only to the extent necessary to fulfill the service you requested.
• Advertising platforms: Hashed or pseudonymized identifiers may be shared with Google LLC and Meta Platforms Inc. for ad measurement and retargeting purposes, subject to your consent as described in Section 4. These platforms act as independent data controllers for the data they subsequently process and are governed by their own privacy policies.
• Legal authorities: We may disclose personal data to law enforcement agencies, courts, regulators (including BACEN, SEC, or COAF), or other public authorities if required to do so by law, court order, or in connection with anti-money laundering, sanctions compliance, or fraud-prevention obligations. We will notify you of such disclosure where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, restructuring, or asset sale involving Trevisani Moveis USA, personal data may be transferred to the relevant successor entity. Affected individuals will be notified prior to any such transfer, and data will remain protected under terms no less stringent than this policy.

International data transfers — in particular, transfers of data from Brazil or the EU to the United States — are conducted under appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms recognized under the LGPD.

06 Data Retention

We retain personal data for no longer than is necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The following general retention periods apply:

• Active client data: Retained for the duration of our professional relationship plus a minimum of five (5) years after the last transaction or interaction, in accordance with U.S. real estate recordkeeping requirements and Brazilian tax law.
• Prospective client inquiries: Contact information and inquiry records are retained for up to two (2) years from the date of last contact if no transaction was initiated. If you request earlier deletion, we will comply unless legal retention is required.
• AML / KYC documentation: Identification and financial due-diligence records related to completed transactions are retained for a minimum of five (5) years from the date of the transaction, as required by COAF regulations in Brazil and FinCEN reporting obligations in the United States.
• Analytics data: Google Analytics data is retained for 14 months under our account settings, after which it is automatically deleted. Aggregate, anonymized reports may be retained indefinitely.
• Cookie consent records: Stored for 12 months or until withdrawn by you.

At the end of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual. You may contact us at any time to request the deletion of your data ahead of schedule, subject to the exceptions described under Section 8.

07 Data Security

Protecting your personal data is a core operational priority. We implement a layered set of technical and organizational measures designed to prevent unauthorized access, disclosure, alteration, or destruction of your information:

• Encryption in transit: All data transmitted between your browser and our website is protected by TLS 1.2 or higher (HTTPS). Email communications containing sensitive documents are conducted over encrypted channels or via secure file-sharing platforms.
• Access controls: Personal data is accessible only to team members and authorized processors who have a legitimate need to access it. Access rights are reviewed periodically and revoked when no longer required.
• Secure storage: Data stored in our CRM and document management systems is hosted on cloud infrastructure that provides redundant backups, role-based access controls, and audit logging.
• Vendor vetting: Third-party service providers are assessed for their security posture before engagement and are contractually required to maintain standards equivalent to our own.
• Incident response: We maintain a data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify the appropriate supervisory authority within 72 hours (as required by GDPR) and affected individuals without undue delay.

While we take every reasonable precaution, no method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of data transmitted to us over the internet, but we commit to responding swiftly and transparently to any security incident that occurs.

08 Your Rights

Depending on your location, you hold specific rights over your personal data. We honor these rights for all individuals regardless of jurisdiction, to the fullest extent permitted by law. Your rights include:

How to Exercise Your Rights

To exercise any of the rights above, please contact our data privacy team at [email protected] with the subject line "Privacy Rights Request." Please include your full name and sufficient information to allow us to identify your records. We will acknowledge your request within 5 business days and respond in full within 30 calendar days (extendable by a further 60 days in complex cases, with prior notice).

We may need to verify your identity before processing your request to protect against fraudulent claims. Verification will involve confirming details we already hold on file — we will not ask for information we do not already possess.

If you are located in the EU/EEA and believe we have failed to address your concern adequately, you have the right to lodge a complaint with the data protection supervisory authority of your member state. Brazilian residents may also direct complaints to the Autoridade Nacional de Proteção de Dados (ANPD).

09 Children's Privacy

Our website and services are directed exclusively at adults — specifically, individuals aged 18 and over who are considering real estate investment or property acquisition. We do not knowingly collect personal data from children under the age of 16 (or such higher age as specified by applicable law in a given jurisdiction).

If we become aware that we have inadvertently collected personal data from a minor, we will delete that data promptly and without further use. If you are a parent or guardian and believe that a child under your care has provided us with personal information, please contact us immediately at [email protected] so we can take appropriate action.

10 Changes to This Policy

We review and update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will update the "Last updated" date at the top of this page and, where the changes significantly affect how we process your data, we will notify you by email (if we hold your email address) or by displaying a prominent notice on our website for a reasonable period.

We encourage you to review this page periodically to stay informed about how we are protecting your information. Your continued use of our website after any changes to this policy takes effect constitutes your acceptance of the revised terms, to the extent permitted by applicable law. If you do not agree with any update, please discontinue use of our website and contact us to have your data removed.

Previous versions of this policy are available upon request by contacting us at the address below.

11 Contact & Data Controller

Trevisani Moveis USA is the data controller responsible for your personal information. If you have any questions about this Privacy Policy, wish to exercise your rights, or want to raise a concern about how we handle your data, please reach out to us through the following channels:

For formal legal notices or regulatory correspondence, please use the subject line "Legal / Privacy Notice — Trevisani Moveis USA" when writing to the email address above, so your message is routed to the appropriate contact without delay.