Privacy Policy

Brazilian General Data Protection Law (LGPD) — Law No. 13,709/2018

Last updated: April 2026

1. Data Controller

The IVALION by Imersa VRTOOLS AI ("IVALION", "we", "our") is the data controller for personal data processed through this platform, pursuant to the Brazilian General Data Protection Law (Law No. 13,709/2018 — LGPD). IVALION is a global AI-powered sales infrastructure platform for real estate, operating under Imersa VRTOOLS AI Tecnologia Ltda., headquartered in São Paulo, SP, Brazil.

For privacy and data protection inquiries, contact our Data Protection Officer (DPO) at: [email protected].

2. Personal Data Collected

IVALION collects and processes the following personal data, according to the purpose and applicable legal basis:

Category	Data	Purpose
Identification	Full name, corporate email, position, company	Registration, communication and service delivery
Professional	Company, position, real estate launch size	Lead qualification and experience personalization
Browsing	IP address, cookies, session data, device	Usage analysis, security and platform improvement
Behavioral	Immersive environment interactions, heatmaps, dwell time	Data intelligence (GENESIS) and reports for developers

3. Legal Bases for Processing

Personal data is processed based on the following legal bases under Art. 7 of the LGPD:

I. Consent (art. 7º, I): for marketing communications and the "The Future of Real Estate AI" newsletter.
II. Contract performance (art. 7º, V): for delivering contracted real estate sales infrastructure services.
III. Legitimate interest (art. 7º, IX): for aggregated behavioral analysis, AI algorithm improvement and commercial intelligence reports.
IV. Legal obligation (art. 7º, II): for compliance with competent authorities and tax obligations.

4-11. Additional Provisions

For complete information about data sharing, international transfers, data retention, data subject rights, security measures, cookies, policy changes, and contact information, please contact us at:

IVALION by Imersa VRTOOLS AI

Data Protection Officer (DPO)

E-mail: [email protected]

São Paulo, SP — Brasil