Privacy Policy

Privacy Policy & Data Protection Statement

Effective July 2026. Version 1.2. This policy explains how BETS collects, uses, protects, shares, and retains information for website visitors, prospects, clients, course and webinar participants, contractors, partners, portal users, and staff/back-office users.

Our commitment to your privacy

BETS works with sensitive matters: money in escrow, identity documents, property records, source-of-funds information, transaction history, and plans for moving to or investing in Brazil. Protecting that information is built into how we operate.

This Privacy Policy applies to our website, services, forms, calls, webinars, course sign-ups, client portal, document uploads, communications, contractors, and partners. It explains what we collect, how we use it, when we share it, how we protect it, and what choices and rights you have.

1. Information We Collect

  • Identity and contact information: name, email, phone number, WhatsApp number, mailing address, country of residence, preferred language, and related contact details.
  • Identity-verification and KYC data: government ID, passport, CPF or CNPJ, date of birth, proof of address, source-of-funds information, sanctions or anti-money-laundering screening information, and related compliance records.
  • Transaction and property information: property details, parties, purchase or lease terms, compromisso, contracts, registry or matricula records, diligence results, closing status, and escrow instructions.
  • Financial information: bank details, foreign-exchange or cambio information, escrow-account information, proof of funds, payment confirmations, wire information, and billing history. Payment-card details are processed by payment providers; BETS does not store full card numbers.
  • Intake and planning information: goals, residency plans, family or traveler count, timeline, preferred services, risk concerns, and circumstances you provide so we can determine how to help.
  • Website and usage data: IP address, device and browser information, pages visited, referring pages, approximate location derived from IP address, and cookies or similar technologies.
  • Portal, account, and security data: account profile, role and permission records, login attempts, password reset and invitation events, MFA status, session and device identifiers, audit logs, cache and access-control records, support requests, and security alerts.

2. How We Collect Information

We collect information directly from you through intake surveys, forms, calls, webinars, course sign-ups, emails, text messages, WhatsApp, client portal activity, and document uploads; automatically through our website; and from third parties such as banks, escrow providers, notaries, cartorios, foreign-exchange providers, government agencies, attorneys, accountants, inspectors, brokers, and other partners when needed to perform a service or meet a legal obligation.

3. How We Use Your Information

We use your information to deliver and improve services; coordinate escrow, title, due diligence, transaction, rental, relocation, course, portal, and closing support; coordinate with attorneys, notaries, banks, the cambio channel, government offices, and partners on your behalf; verify identity; meet anti-money-laundering, know-your-customer, sanctions-screening, BACEN, COAF, tax, and other legal obligations; communicate with you; administer accounts, billing, permissions, row-level access controls, caching, monitoring, support, incident response, and generic authentication messages; prevent fraud; maintain security; resolve disputes; and operate our business. We do not use your information for unrelated purposes.

5. WhatsApp, SMS & Text-Message Communications

With your opt-in, BETS may use your mobile number and WhatsApp number to send appointment reminders, transaction and escrow updates, document requests, service messages, and, with separate consent, promotional messages up to approximately 4 per month. Consent to marketing messages is not required to purchase or use BETS services.

You may opt in through forms, by messaging us first, by checking a consent box at sign-up, or through an engagement workflow. Service messages related to an active transaction or purchased service are sent as part of the service you engaged us to perform.

You may reply STOP or SAIR to unsubscribe from SMS, reply HELP or AJUDA for help, use WhatsApp's in-app block or report controls, or email support@brasilescrow.com.br. Message and data rates may apply. WhatsApp messages use your data connection.

BETS never sells your phone number or WhatsApp number and does not share those numbers with third parties for their own marketing. BETS follows the LGPD, the WhatsApp Business Messaging Policy, and, for U.S. recipients where applicable, TCPA, CAN-SPAM, and CTIA guidelines.

6. Email Communications & Opt-Out

You may opt out of promotional emails using the unsubscribe link in a marketing email. Even if you opt out of marketing, BETS may continue to send transactional, legal, security, billing, document, service, escrow, or closing-related emails about services you requested or purchased.

7. How We Share Information

  • Escrow and banking partners: client funds and related information are handled through the licensed escrow and banking infrastructure partner named in the applicable escrow instruction agreement.
  • Professionals and partners: attorneys, notaries, cartorios, banks, foreign-exchange providers, inspectors, accountants, insurance partners, brokers, translators, and service providers under confidentiality obligations, only as needed to perform your services.
  • Operational service providers: payment processors, email, SMS and WhatsApp platforms, cloud hosting, analytics, customer relationship management, document management, security, and support tools, each required to protect information and use it only as directed.
  • Government and regulatory filings: Brazilian registries, BACEN/RDE-IED, COAF, tax authorities, immigration or consular offices, and applicable U.S. authorities where required to deliver the services or meet legal obligations.
  • Legal requirements: when required by subpoena, court order, regulator request, law, or legal process, or when needed to protect rights, safety, security, or prevent fraud.
  • Business transfers: in connection with a merger, acquisition, reorganization, financing, or sale of assets under equivalent privacy protections.

BETS does not sell personal information and does not share personal information for cross-context behavioral advertising.

8. How We Protect Your Information

BETS maintains a written information-security program consistent with the LGPD and good industry practice. Safeguards include encryption of sensitive data in transit and at rest, role-based least-privilege access, multi-factor authentication, secure one-time links for credentials and sensitive documents, no retention of plaintext financial passwords, password reset on first login where applicable, vendor due diligence, staff training, access logging, and a documented incident-response process.

Portal and back-office data must be protected by row-level or equivalent per-user access controls, storage policies, service-role secret separation, audit trails, secure session handling, and private API responses that avoid shared caching. User-specific pages, documents, and portal endpoints should use no-store or user-segmented cache behavior and should be invalidated on logout, role change, file revocation, or account closure.

BETS also maintains a security-testing program for authentication flows, account lockouts, rate limits, row-level security rules, storage buckets, private documents, cache behavior, secrets, forms, APIs, dependency vulnerabilities, and production configuration. Login, signup, password reset, invite, MFA, upload, export, payment, webhook, messaging, AI, email, SMS, and other expensive or abuse-prone routes should be rate-limited, throttled, queued, challenged, suspended, or blocked according to risk. Logs, exports, support tickets, screenshots, analytics, AI traces, and test fixtures should be scrubbed, masked, or minimized before review or sharing. Authentication errors are intentionally generic and do not disclose whether an email, username, password, account existence, MFA factor, or permission state caused the failure.

No method of storage or transmission is perfectly secure, but we use commercially reasonable measures appropriate to the sensitivity of the information we hold.

9. Contractors & Independent Professionals

Any contractor, attorney, notary, accountant, translator, broker, inspector, or partner who accesses client information is bound by written confidentiality and data-protection obligations at least as protective as this Policy, must use the information only to perform assigned work, must follow our security program, and must return or securely destroy information when the work is done unless retention is legally required.

BETS also protects contractors' own personal information, including identity, payment, tax, credentialing, and compliance records, with appropriate safeguards and does not sell or misuse it.

10. Data Retention

BETS retains information as long as needed to provide services, manage the client relationship, resolve disputes, maintain security, and meet legal, tax, anti-money-laundering, escrow, title, banking, regulatory, and recordkeeping obligations. Transaction and KYC records are generally retained for the periods required by Brazilian and U.S. law, and escrow records are retained for the life of the file plus the applicable limitation period. When information is no longer needed, BETS securely deletes or anonymizes it.

11. Your Rights & Choices

  • Under the LGPD: you may confirm processing, access, correct, anonymize, block, delete, request portability, obtain information about sharing, review automated decisions where applicable, and withdraw consent. You may also contact our Encarregado/Data Protection Officer through the contact address below and may petition the ANPD.
  • Under the GDPR or UK GDPR: where applicable, you may have rights of access, correction, erasure, restriction, objection, portability, withdrawal of consent, and complaint to a supervisory authority.
  • For U.S. residents: where applicable under CCPA/CPRA or similar laws, you may have rights to know, access, delete, correct, opt out of sale or sharing, limit certain sensitive information uses, and not be discriminated against for exercising rights. BETS does not sell personal information or share it for advertising.

All rights are subject to legal, tax, anti-money-laundering, escrow, property, and regulatory retention requirements. To protect privacy and security, BETS may need to verify your identity before responding to a request.

12. International Data Transfers

Because BETS serves clients relocating to or investing in Brazil, coordinates with Brazilian notaries, banks, counsel, and registries, and operates through a U.S. entity, your information may be transferred across borders, including between Brazil and the United States. Where required, BETS uses appropriate safeguards for transfers under the LGPD, GDPR, UK GDPR, and other applicable law.

13. Cookies & Tracking

Our website uses cookies and similar technologies for functionality, analytics, performance, fraud prevention, and service improvement. You can control cookies through browser settings. Disabling some cookies may affect site functionality.

14. Do Not Track

Some browsers offer a Do Not Track signal. Our website does not currently respond to DNT signals. BETS will update this Policy if that changes.

16. Children's Privacy

BETS services and website are intended for adults 18 and older and are not directed to children. BETS does not knowingly collect personal information from minors. If you believe a minor has provided personal information, contact us so we can review and take appropriate action.

17. Data-Breach Notification

If a data incident affects your personal information, BETS will notify you and appropriate authorities, including the ANPD where required by the LGPD, within timeframes required by applicable law and will take prompt steps to contain, investigate, remediate, and reduce recurrence.

18. Changes to This Policy

BETS may update this Policy from time to time. Material changes will be posted on this page with a new effective date, and where required by law or contract, BETS will provide additional notice.

19. Contact Us

Questions or requests about this Policy or your information, including LGPD rights requests and requests to contact our Data Protection Officer/Encarregado, may be sent to support@brasilescrow.com.br or to Brasil Escrow & Title Services, LLC. BETS responds to verified rights requests within the timeframes required by applicable law.