Privacy Policy for El Peñon Investimentos Effective Date: 01/01/2025 1. Introduction El Peñon Investimentos ("we," "us," or "our") is committed to protecting the privacy of your information. This Privacy Policy explains how we collect, use, and share your personal information when you visit or use our website, https://www.elpenoninvestimentos.com (the "Site"), and our services.   2. Information We Collect We collect several types of information from and about users of our Site, including: * Personal Information: This may include information that can be used to identify you, such as your name, email address, phone number, postal address, and login credentials. We collect this information when you register for an account, subscribe to our services, or contact us.   * Usage Information: We collect information about how you use our Site, such as the pages you visit, the searches you conduct, the links you click, and the time you spend on our Site. This information may be collected through cookies, web beacons, and other tracking technologies.   * Device Information: We collect information about the device you use to access our Site, such as your IP address, browser type, operating system, and device identifiers.   * Location Information: With your permission, we may collect information about your location. * Real Estate Preferences: We collect information about your real estate interests, such as preferred locations, property types, and price ranges. This helps us personalize your experience and provide relevant information. 3. How We Use Your Information We may use your information for the following purposes: * Provide and Improve Services: To provide you with access to our Site and services, personalize your experience, and improve the functionality of our Site. * Account Management: To create and manage your account, verify your identity, and process your requests. * Communication: To contact you with updates, newsletters, marketing materials, and other information related to our services. You can opt-out of receiving marketing communications at any time. * Customer Support: To provide you with customer support and respond to your inquiries. * Legal Compliance: To comply with applicable laws and regulations. * Analytics: To analyze how our Site is used and identify trends. * Marketing: To personalize and deliver targeted advertising. (Explain your advertising practices clearly.) 4. How We Share Your Information We may share your information with the following third parties: * Service Providers: We may share your information with third-party service providers who assist us with website hosting, data analysis, email delivery, marketing, and other services. We require these service providers to protect your information.   * Business Partners: We may share your information with business partners who offer products or services that may be of interest to you. We will only do this with your consent. (Be very specific about who these partners are and what information is shared.) * Legal Authorities: We may disclose your information to legal authorities if required by law or legal process. * Affiliates: We may share your information with our affiliates for the purposes described in this Privacy Policy. * Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.   5. Your Choices   * Access and Correction: You may access and update your personal information through your account settings or by contacting us.   * Marketing Communications: You can opt-out of receiving marketing communications from us by clicking the unsubscribe link in our emails or by contacting us.   * Cookies: You can control the use of cookies through your browser settings. However, disabling cookies may affect the functionality of our Site.   6. Data Security We take reasonable measures to protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.   7. Children's Privacy Our Site is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13.   8. Changes to this Privacy Policy   We may update this Privacy Policy from time to time. We will post any changes on our Site and notify you as required by law. 9. Contact Us If you have any questions about this Privacy Policy, please contact us at: info@elpenoninvestimentos.com 10. GDPR Compliance: Lawful Basis for Processing: We process your personal data based on the following lawful bases: * Contract: For the performance of our contract with you when you create an account and use our services. This includes processing your registration details, providing access to the members-only area, and facilitating communication related to your account. * Consent: For marketing communications, personalized recommendations, and certain types of data collection (e.g., location data). We will obtain your explicit consent before processing your data for these purposes. You have the right to withdraw your consent at any time. * Legitimate Interests: For our legitimate interests in operating and improving our website, ensuring security, preventing fraud, and analyzing website usage. We have carefully balanced our legitimate interests with your rights and freedoms. (Be very specific about what these legitimate interests are. Vague claims won't suffice.) * Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject. 11. GDPR Compliance: Data Subject Rights: You have the following rights regarding your personal data: * Right of Access: You have the right to access the personal data we hold about you. * Right to Rectification: You have the right to correct any inaccurate or incomplete personal data we hold about you.  * Right to Erasure ("Right to be Forgotten"): You have the right to request that we delete your personal data under certain circumstances (e.g., if the data is no longer necessary for the purpose for which it was collected, if you withdraw your consent, or if you object to the processing).   * Right to Restriction of Processing: You have the right to restrict the processing of your personal data under certain circumstances (e.g., if you contest the accuracy of the data or if you object to the processing).   * Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.   * Right to Object: You have the right to object to the processing of your personal data based on our legitimate interests.   * Right to Withdraw Consent: You have the right to withdraw your consent to processing at any time. * Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in the EU if you believe that our processing of your personal data infringes GDPR.   

To exercise these rights, please contact us at info@elpenoninvestimentos.com 12. GDPR Compliance: International Data Transfers: If we transfer your personal data outside the EU, we will ensure that appropriate safeguards are in place to protect your data, such as: * Adequacy decisions by the European Commission. * Standard contractual clauses adopted by the European Commission. * Binding corporate rules. We will provide you with further information about the specific safeguards used in any transfer upon request. 13. GDPR Compliance: Data Retention: We will retain your personal data for as long there is activity and/or up to a year of inactivity. This is necessary to fulfill the purposes for which it was collected, including for as long as you have an active account with us, and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. We will regularly review our data retention policies and delete data that is no longer necessary. Our Data Protection Officer (DPO) can be contacted at [DPO Contact Information, if applicable]. You can also contact us at info@elpenoninvestimentos.com