La Guarita Riviera Private Club

1. Who we are

La Guarita Riviera Private Club is a private leisure destination under development, designed to bring together fractional ownership, a private water park, a dining village, a cable car, a sunset lookout, hospitality, leisure, retail and experiences in Bragança Paulista, São Paulo, Brazil.

For the purposes of this Policy, the party responsible for processing the personal data collected through this website is:

2. Which personal data we may collect

We may collect personal data provided directly by users when they fill in forms, join interest lists, ask to be contacted, download materials or interact with our channels.

The data collected may include:

• full name;
• e-mail address;
• phone or WhatsApp number;
• city and state;
• profile of interest in the project;
• interest in fractional ownership, founding membership, stays, the village or other parts of the destination;
• messages sent by the user;
• browsing data on the website;
• IP address;
• type of device;
• browser used;
• pages visited;
• date and time of access;
• traffic source, such as Instagram, TikTok, Facebook, Google, ads or other channels.

On this website we do not request sensitive data such as racial origin, religion, political opinion, health data, biometrics or similar information.

3. How we collect data

Data may be collected when the user:

• visits the website;
• fills in an interest form;
• asks to be contacted;
• joins a private list or waiting list;
• clicks WhatsApp buttons;
• downloads institutional materials;
• answers surveys or questions;
• interacts with ads, pages or official social media profiles;
• accepts the use of cookies and similar technologies.

We may also collect data automatically through cookies, tracking pixels, analytics tools and similar technologies, as explained in this Policy.

4. Purposes for which we use the data

Personal data may be used to:

• answer requests sent by the user;
• register interested parties on private lists;
• send institutional information about the project;
• present information about the Founding Members phase;
• send communications about events, presentations, meetings or launches;
• get in touch by e-mail, phone or WhatsApp;
• group users according to the interest they have shown;
• improve the browsing experience on the website;
• measure the performance of marketing campaigns;
• analyse traffic sources, conversions and browsing behaviour;
• prevent fraud, unauthorised access and abusive use of the website;
• comply with legal, regulatory or contractual obligations;
• protect the rights of La Guarita Riviera Private Club, of RAC CONSTRUCOES E INCORPORACOES LTDA and of third parties.

5. Legal bases for processing

Personal data may be processed on the legal bases set out in Brazil's General Data Protection Law (LGPD), Law No. 13,709/2018, including:

• consent, when the user agrees to receive communications or registers voluntarily;
• preliminary procedures related to a contract, when the user requests information about membership, participation or acquisition;
• legitimate interest, for institutional communications, website improvement, security and relationships with interested parties;
• compliance with a legal or regulatory obligation, when necessary;
• regular exercise of rights, in administrative, judicial or arbitration proceedings.

6. Data sharing

Personal data may be shared with third parties only when necessary for the purposes described in this Policy, such as:

• website hosting platforms;
• marketing automation tools;
• CRM systems;
• e-mail, SMS or WhatsApp messaging tools;
• advertising platforms, such as Meta, Google, TikTok or similar;
• technology and data analysis companies;
• providers of commercial customer service;
• legal, accounting, administrative or commercial advisers;
• partners involved in structuring the project, when necessary;
• public authorities, under a legal obligation or valid request.

Whenever possible, sharing will be limited to the minimum necessary for the intended purpose.

7. Cookies and tracking technologies

This website may use cookies, pixels, tags and similar technologies to improve browsing, understand user behaviour and optimise marketing campaigns.

These technologies may be used to:

• remember user preferences;
• measure visits to the website;
• identify the most visited pages;
• understand where visits come from;
• measure conversions;
• create remarketing audiences;
• improve ads and communications;
• enhance the user experience.

Users may at any time set their browser to block or delete cookies. However, some features of the website may be affected.

8. Data storage and security

We adopt reasonable technical and administrative measures to protect personal data against unauthorised access, loss, alteration, improper disclosure or inappropriate processing.

The measures that may be adopted include:

• restricted access to data;
• use of platforms with security controls;
• storage in protected environments;
• use of passwords and authentication;
• access monitoring;
• periodic review of tools and suppliers;
• internal guidance on data protection.

9. Retention period

Personal data will be stored for as long as necessary to fulfil the purposes for which it was collected, including relationships with interested parties, sending information, compliance with legal obligations, exercise of rights and keeping commercial records.

Data may be deleted or anonymised when:

• it is no longer necessary;
• the data subject requests deletion, where applicable;
• consent is withdrawn;
• there is no legal, regulatory or legitimate obligation that justifies keeping it.

10. Rights of data subjects

Under the LGPD, the data subject may request:

• confirmation that processing takes place;
• access to their personal data;
• correction of incomplete, inaccurate or outdated data;
• anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in breach of the law;
• data portability, where applicable;
• information about data sharing;
• withdrawal of consent;
• deletion of data processed on the basis of consent, where applicable;
• objection to processing in certain cases;
• review of automated decisions, if any.

To exercise these rights, the data subject may write to: contato@laguarita.com.br.

We may ask for additional information to confirm the identity of the requester and keep the request secure.

11. Communications by e-mail, phone and WhatsApp

By providing contact details, the user may receive institutional, commercial or informative communications about La Guarita Riviera Private Club, including news, presentations, events, list openings, materials and information about the phases of the project.

The user may ask to stop receiving these communications at any time, through the channels indicated in the message itself or through the privacy e-mail.

12. Third-party links

The website may contain links to social media, external platforms, forms, WhatsApp, partner pages or other websites.

This Privacy Policy applies only to the official environment of La Guarita Riviera Private Club. We are not responsible for the privacy practices, content or security of third-party websites and platforms.

We recommend that users read the privacy policies of external platforms before providing their data.

13. Data of minors

This website is not aimed at children or adolescents and does not seek to collect personal data from minors.

If improper processing of data of minors is identified, the data may be deleted, unless there is an appropriate legal basis or authorisation from their legal guardians.

14. International data transfer

Some tools used on the website, such as hosting, analytics, CRM, marketing automation or advertising platforms, may store or process data outside Brazil.

In such cases, we will seek to use suppliers that adopt appropriate standards of security and data protection, in accordance with the applicable legislation.

15. Changes to this Policy

This Privacy Policy may be updated at any time to reflect changes to the website, the tools used, data processing practices or legal requirements.

The updated version will always be available on this page, with the date of the last update.

16. Contact

If you have any questions about this Privacy Policy or about the processing of personal data, please get in touch:

Additional notice for forms

Recommended text for use below registration, private list, waiting list or information request forms.