Privacy Policy

Introduction

Jan Lechte Negócios Imobiliários Ltda ("Jan Lechte", "we", "our" or "us") is a real estate brokerage and advisory firm established and operating in Brazil. We are committed to protecting the privacy and personal data of every person who visits our website, makes an enquiry, or otherwise interacts with us.

This Privacy Policy explains, in plain language, what personal data we collect, why we collect it, how long we keep it, with whom we may share it, and what rights you hold as a data subject. It applies to the website at janlechte.site and to all associated communications channels operated by Jan Lechte.

Our practices are designed to comply with Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD) — Law No. 13,709/2018, the European Union's General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), and other applicable privacy legislation. Where these frameworks overlap, we apply the more protective standard.

By continuing to browse this website, you acknowledge that you have read and understood this policy. If you do not agree with any part of it, please discontinue use of our site. This policy does not constitute a contract.

Information We Collect

We collect personal data only to the extent necessary to operate our services and respond to your communications. The categories of data we may process are set out below.

Information you provide directly

When you contact us by email, phone, or any other communication channel you choose, you may voluntarily share:

• Your full name and, where applicable, the name of your company or organisation.
• Email address and telephone number so that we can respond to your enquiry.
• A description of your property requirements, preferences, budget range or any other details you choose to include in your message.
• National identification numbers (CPF/CNPJ) or other documentary information when required by Brazilian law to proceed with a real estate transaction or due-diligence process.
• Financial or bank reference information, provided solely when required to assess eligibility for a specific transaction, and only with your explicit consent.

We never solicit sensitive personal data — such as health or biometric information — unless a specific legal requirement compels us to do so, and we will always inform you clearly in that event.

Information collected automatically

When you visit our website, certain technical data is collected automatically by our hosting infrastructure and analytics providers:

• IP address — used for security monitoring, fraud prevention and approximate geolocation (country / city level only).
• Browser type and version, operating system, device type — used to ensure the site renders correctly across different environments.
• Referring URL and exit page — helps us understand how visitors discover our site.
• Pages visited, time on page and click paths — used in aggregate form to improve site structure and content relevance.
• Date and time of access — retained in server logs for security and legal compliance purposes.
• Cookie identifiers — see the Cookies section below for full detail.

Automatically collected data is processed in pseudonymised or aggregated form wherever technically possible. We do not use it to build individual profiles for marketing purposes without your consent.

How We Use Your Information

Every use of your personal data by Jan Lechte is grounded in a lawful basis under the LGPD and GDPR. Below are the specific purposes for which we process personal information, together with the corresponding legal basis.

• Responding to enquiries and providing services — When you contact us, we use the information you supply to reply accurately, assess your property needs, and connect you with the appropriate member of our team. Legal basis: performance of a pre-contractual or contractual relationship (LGPD Art. 7, II; GDPR Art. 6(1)(b)).
• Compliance with legal and regulatory obligations — Brazilian anti-money-laundering regulations (Lei No. 9,613/1998, as amended) and real estate brokerage rules require us to verify the identity of clients involved in property transactions and to keep certain records. Legal basis: legal obligation (LGPD Art. 7, II; GDPR Art. 6(1)(c)).
• Website operation and performance monitoring — We use technical and analytics data to maintain a fast, secure and accurate website, diagnose errors, and understand which content is most useful to our audience. Legal basis: legitimate interest (LGPD Art. 7, IX; GDPR Art. 6(1)(f)).
• Marketing and promotional communications — We may send you information about new property opportunities or market insights if you have given us clear consent. You may withdraw consent at any time. Legal basis: consent (LGPD Art. 7, I; GDPR Art. 6(1)(a)).
• Fraud prevention and site security — Server logs and IP data are reviewed if we suspect unauthorised access, data breaches or other harmful activity. Legal basis: legitimate interest and legal obligation.

We do not sell, rent or otherwise monetise your personal data. We do not use your information to make automated decisions that produce legal or similarly significant effects without human review.

Cookies & Tracking Technologies

Our website uses cookies — small text files stored in your browser — and similar tracking technologies (web beacons, pixels) to make the site function correctly and to help us understand how it is used. The table below describes the categories of cookies we deploy.

Google Analytics: We use Google Analytics 4, configured with IP anonymisation enabled. Anonymised, aggregated usage data may be processed by Google LLC on servers in the United States under the EU–US Data Privacy Framework and Standard Contractual Clauses. You can opt out globally using the Google Analytics Opt-out Browser Add-on.

Google Ads: We use the Google Ads conversion tracking pixel to measure enquiries originating from paid search campaigns. This does not allow Google or Jan Lechte to identify you personally. Remarketing features are only active where you have provided consent.

Managing cookies: When you first visit our site, a consent banner gives you granular control over non-essential cookies. You can change your preferences at any time by clearing your browser cookies and revisiting the site, or by adjusting your browser's cookie settings. Note that disabling certain cookies may affect some features of the website.

Sharing With Third Parties

Jan Lechte does not sell, trade or otherwise transfer your personal data to third parties for their own commercial purposes. We may, however, share data in the following limited and controlled circumstances:

• Service providers and data processors — We engage carefully selected third-party vendors who process data on our behalf under written data processing agreements: web hosting providers, analytics platforms (Google LLC), email delivery services and IT security partners. These parties are contractually prohibited from using your data for any purpose other than providing the service.
• Real estate co-brokers — In the course of a property transaction it may be necessary to share limited client information with other CRECI-registered brokers or partner agencies. This occurs only with your prior knowledge and only to the extent required to complete the transaction.
• Legal authorities — We may disclose personal data to courts, regulators or law enforcement agencies where we are legally compelled to do so — for example, in response to a lawful court order, or to comply with anti-money-laundering reporting obligations under Brazilian federal law.
• Business transfers — In the event of a merger, acquisition, restructuring or sale of assets, personal data may be transferred to the acquiring entity. We will notify you via a prominent notice on this page or by direct communication before any such transfer takes effect, and you will retain your rights over your data.

Where personal data is transferred outside Brazil or the European Economic Area, we ensure adequate protections are in place — such as Standard Contractual Clauses approved by the European Commission, or equivalent mechanisms recognised by Brazil's National Data Protection Authority (ANPD) — before any cross-border transfer proceeds.

Data Retention

We keep personal data for no longer than is necessary to fulfil the purpose for which it was collected, unless a longer period is required by law. Our standard retention periods are:

• General enquiry records — Correspondence and contact details are retained for up to 3 years following the conclusion of our last meaningful interaction, enabling us to provide continuity of service and to respond to any subsequent questions you may raise.
• Transaction records — Where a property transaction completes, the associated documents and client identification data are retained for a minimum of 5 years as required by Brazil's anti-money-laundering framework (COAF / Lei 9,613/1998).
• Marketing consent records — Records of consent to receive marketing communications, together with any withdrawal of that consent, are kept for 5 years to demonstrate regulatory compliance.
• Website server logs — Access logs containing IP addresses and technical request data are kept for 6 months for security and troubleshooting purposes, then securely deleted.
• Analytics data — Aggregated and anonymised usage statistics (Google Analytics) are retained for up to 26 months, the default maximum for GA4, after which they are automatically purged.

When personal data is no longer needed and no legal basis for further retention exists, it is securely deleted or irreversibly anonymised. Backups are purged on a rolling cycle consistent with these retention periods.

Data Security

We take the security of your personal data seriously. Jan Lechte and its hosting providers maintain a range of technical and organisational measures to protect data against unauthorised access, accidental loss, destruction or alteration:

• All data transmitted between your browser and our web server is encrypted using industry-standard TLS 1.2 / 1.3 (HTTPS). Our domain maintains an active SSL certificate at all times.
• Access to systems holding personal data is controlled by role-based permissions, strong password policies and, where available, multi-factor authentication.
• Our web hosting infrastructure is operated by providers that maintain international security certifications. Physical access to data centres is restricted and monitored.
• We conduct periodic reviews of our data handling practices and update security controls in response to emerging threats.
• Staff with access to personal data receive training on data protection obligations and are bound by confidentiality undertakings.

No method of electronic transmission or storage is 100% secure. While we apply commercially reasonable measures, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority (ANPD in Brazil; the competent data protection authority in EU/EEA member states) within the timeframes required by applicable law, and we will inform affected individuals without undue delay where the breach is likely to result in a high risk to them.

Your Rights

Depending on your jurisdiction, you hold a number of rights regarding your personal data. The LGPD (Art. 18) and the GDPR (Arts. 15–21) grant data subjects substantive rights, summarised below. Jan Lechte respects and facilitates the exercise of all of these rights:

How to exercise your rights: Submit a written request to contato@janlechte.site with the subject line "Data Subject Request". Please include your full name and enough identifying detail to allow us to locate your records. We will acknowledge your request within 5 business days and provide a substantive response within 15 days (extendable to 30 days in complex cases, with prior notice). Identity verification may be required before we release or amend data, to prevent unauthorised access to your information.

Children's Privacy

Our website and services are directed exclusively at adults and are not designed to attract or be used by children under the age of 18. We do not knowingly collect, store or process personal data from anyone under 18 years of age.

If you are a parent or guardian and you believe your child has provided us with personal information without your consent, please contact us immediately at contato@janlechte.site. Upon verification, we will promptly delete such information from our records. Given the nature of real estate transactions, all interactions with Jan Lechte must involve an individual who has reached legal majority under applicable Brazilian law.

Changes to This Policy

We review this Privacy Policy regularly and may update it in response to changes in applicable law, our data processing activities, or best practice guidance issued by data protection authorities. The "Last updated" date at the top of this page reflects when the most recent revision was made.

Where changes are significant — for example, if we introduce a new purpose for processing that requires your consent — we will bring this to your attention via a prominent notice on the website homepage or, where we hold your contact details and it is lawful to do so, by direct communication. We encourage you to review this policy periodically so that you are always informed about how we handle your information.

Your continued use of the website after changes are posted constitutes acceptance of the revised policy, to the extent permitted by applicable law. If you do not accept the updated terms, you should discontinue use of the site and may exercise your data rights as described above.

Contact Us

For any question, concern or request relating to this Privacy Policy or to the personal data we hold about you, please reach out to our data privacy team. We are committed to resolving privacy-related matters promptly and transparently.

This policy was prepared in good faith to reflect our current data practices as of the date shown at the top. It does not constitute legal advice. If you have specific concerns about your rights under Brazilian or international privacy law, we recommend consulting an independent legal professional.