This policy explains how the institutional website of BY POLO, a technology initiative of POLO Negócios Imobiliários, handles personal data under Brazil’s General Data Protection Law (Law 13,709/2018 — LGPD). It applies only to this website; the BY POLO platform will have its own terms and policy.
1. Data controller
The data controller is POLO Negócios Imobiliários, headquartered in Uberlândia, Minas Gerais, Brazil, which runs the BY POLO initiative.
2. What we collect
Browsing: the hosting server logs technical data such as IP address, browser and pages visited, for security and operation.
Audience measurement: when enabled, we use a cookieless statistics tool that does not identify visitors. Tools that use cookies only load after you accept them in the on-site notice.
The site has no forms or sign-ups, does not use advertising cookies and does not collect sensitive data.
3. Purposes and legal basis
Keeping the site secure and preventing abuse — based on legitimate interest (art. 7, IX).
Understanding site usage in aggregate — legitimate interest for cookieless statistics, or consent when measurement cookies are used.
4. Sharing
Data may be processed by vendors acting as processors on our behalf — website hosting and measurement tools — limited to the contracted purpose.
We do not sell or rent personal data.
Some vendors may store data outside Brazil; in such cases we apply the safeguards required by the LGPD.
5. Retention
The site keeps no visitor records. Technical access logs are kept for the period required by law, and measurement data is used only in aggregate.
6. Your rights
You may at any time confirm whether we process your data, access, correct, anonymize, port or delete it, learn about sharing and withdraw consent (LGPD art. 18). You may also file a complaint with Brazil’s data protection authority (ANPD).
To exercise your rights, contact POLO Negócios Imobiliários through its official channels. We respond within the legal deadline.
7. Security
The site is served only over encrypted connections (HTTPS) with security headers. Access to technical logs is restricted.
8. Changes
This policy may be updated. The date of the latest version is always shown at the top of the page.