Last updated: May 2026
This policy applies to the Avalon Homes institutional website, related digital experiences (including logged-in areas where applicable), and the Avalon Homes mobile app for investors.
Personal data is processed on behalf of Avalon Homes and, depending on the service, by affiliated companies and contracted processors. This policy covers operations in Brazil and the United States, subject to the laws applicable in each jurisdiction.
This policy applies to website visitors, leads, registered users, active customers, inactive customers, and users of related logged-in experiences and the mobile app.
To exercise privacy rights or submit requests related to this policy: contato@avalonhomes.com.br.
Depending on how you interact with us, we may process categories such as those below (not every item applies to every user):
We process personal data to: (i) provide website/app services; (ii) authenticate users and secure accounts; (iii) comply with legal, regulatory, tax, accounting, and anti-fraud obligations; (iv) communicate operational updates; (v) generate product and service analytics; and (vi) establish, exercise, or defend legal claims.
In Brazil, legal bases under LGPD may include contract performance, pre-contractual steps, legal/regulatory compliance, legitimate interests (with safeguards), regular exercise of rights, credit protection, and consent where required.
In the U.S., processing follows the legal framework applicable to the service context, including state privacy laws where applicable and sector-specific financial privacy rules where applicable.
We may share data with service providers that support our operations (hosting, authentication, communications, analytics, support, push notification infrastructure, among others), subject to confidentiality and security obligations aligned with the purpose.
We may also disclose information when required by competent authorities, court order, or to protect rights in administrative or judicial proceedings.
Part of Avalon Homes’ operations relates to the United States. Data may be processed or stored in Brazil, the U.S., or other countries where our vendors maintain infrastructure, with reasonable contractual and technical safeguards.
We retain personal data for as long as needed for legitimate business purposes and legal/regulatory obligations. After the applicable period, data is deleted or anonymized, except where retention is legally required.
Under Brazil's Marco Civil da Internet, application access logs may be retained for the statutory minimum period and disclosed only under applicable legal process.
Transaction, anti-fraud, and compliance records may be retained for additional periods required by law, audit, or regulatory frameworks.
We adopt technical and organizational measures proportionate to the risk, such as access controls, encryption in transit where applicable, environment segregation, and monitoring. No system is perfectly secure; we recommend strong passwords and device protection.
The website may use cookies and similar technologies for core functionality, preferences, metrics, and security. You can manage preferences in your browser; some features may be unavailable if essential cookies are disabled.
Where applicable, you may request confirmation of processing, access, correction, anonymization/blocking/deletion, portability, information about sharing, review of automated decisions, and withdrawal of consent, in line with LGPD and ANPD rules.
To submit a request, use the email in Section 1. We may ask for additional information to verify your identity before fulfilling the request.
Depending on your U.S. state of residence and the nature of your relationship with Avalon Homes, you may have rights to access, correct, delete, and port your personal information, and in some states rights to opt out of sale/sharing of data for targeted advertising.
The availability and scope of these rights varies by jurisdiction and may be subject to statutory exceptions, including fraud prevention, security, legal compliance, and legal claims.
For Massachusetts (MA) residents, where we maintain U.S. operations, we follow applicable state requirements on data security and incident response and honor data-rights requests when legally applicable to the specific relationship and processing context.
When you request account deletion, we apply deletion and de-identification rules consistent with legal obligations and the contractual/regulatory context of the account. Certain records may be retained where required for compliance, anti-fraud, audit, or legal defense.
In scenarios permitted by our internal rules and applicable law, an account may remain deactivated (soft-deleted) and can only be reactivated after valid re-authentication and explicit user confirmation before access is restored.
We may update this policy to reflect legal, operational, or product changes. The “Last updated” date at the top will be revised when there is a material change. Continued use after publication may constitute notice of changes, subject to any additional legal requirements where applicable.
This policy is intended to provide transparency and legal notice. If a specific contract, regulatory requirement, or mandatory legal rule applies to your relationship with Avalon Homes, that specific rule will prevail to the extent of any conflict.
