Data and privacy

Privacy Policy

Last updated: 2026-08-15. How Clivon handles data from Growth and Launch diagnosis forms, contracting, onboarding, operations and support.

What data can be collected

Clivon provides assisted automation, governance and operations solutions for the real estate market.

  • Customer contact, identification and commercial information.
  • Property materials, files, links, notes and flow usage data.
  • Information needed for diagnosis, contracting, onboarding, service delivery and support.
  • Technical navigation data and attribution parameters present in the access, such as UTM, fbclid and gclid.

Growth and Launch diagnosis forms

The /growth and /launch pages provide a public diagnosis form. This is a commercial prospecting flow started by the visitor, who voluntarily requests contact.

  • Growth data: company, name, WhatsApp number, main operational bottleneck, desired time window and, optionally, preferred contact date and time.
  • Launch data: company, development, WhatsApp number, launch stage, decision to unlock and, optionally, city, preferred date and time.
  • Campaign attribution: only utm_source, utm_medium, utm_campaign and utm_content are recorded with the submission. The complete URL and other navigation parameters are not recorded with the diagnosis.
  • Purpose of commercial data: to allow Clivon's team to contact the visitor about the requested diagnosis. The four UTM parameters are used exclusively to attribute and measure the source of that contact request.
  • Legal basis: legitimate interest under Brazilian Law 13,709/2018, article 7, IX, because the data subject initiated and requested the B2B commercial contact. The data subject may object at any time.
  • Retention criterion: each submission records a 12-month expiration date. Automated deletion is not active yet; until it is implemented, removal after that date depends on an operational review or a data-subject request, subject to applicable legal retention grounds.
  • Processor: data is stored by a cloud database provider contracted by Clivon, which may process and store information outside Brazil. We treat this as an international transfer even though the specific project region is not published here.
  • Meta: Growth and Launch currently do not load Meta Pixel or CAPI. This section will be updated before any future public activation involving those pages.

Contracting and transaction records

  • Payment terms and methods are defined in the proposal and contract accepted by the customer.
  • When an external provider is used, it processes the required data under its own rules and applicable obligations.
  • Clivon does not store full card details on its public pages.
  • References and records from transactions completed through the prior flow may continue to be processed for support, reconciliation, fraud prevention, compliance and the regular exercise of rights.

Use of data

  • Public-form data is used to address the requested diagnosis and conduct the corresponding commercial contact. If a contract is signed, the required data may also be used for onboarding, contracted services and support, subject to the proposal and contract.
  • The four UTM parameters recorded with the diagnosis are used to attribute and measure the source of that request. Navigation events on the routes described in the next section may measure journey continuity.
  • Customers must provide information and materials they are authorized to use.

Cookies, local storage and integrations

  • Local storage may keep the visual theme preference. Historical return and intake routes may also keep a prior transaction's external reference to recover status and service continuity.
  • Technical routes from the prior checkout may use session storage, IndexedDB and essential cookies for bootstrap identity, attribution and duplicate-action prevention. These identifiers are not full card details.
  • Attribution parameters present in the access may accompany the journey. Growth and Launch diagnosis forms record only the four UTM parameters listed above.
  • Growth and Launch currently do not load Meta Pixel or CAPI.
  • The current public configuration keeps Meta Pixel disabled on every page, including the Trust Center at /trust and the historical confirmation, pending, failure and intake routes. While this configuration remains disabled, the integration code does not request the external script or forward events to Meta.
  • Any future activation of Meta Pixel or CAPI will require a specific decision and configuration. This policy will be updated before any future public activation.

Data Protection Officer and exercising your rights

  • Controller: CLIVON TECNOLOGIA E PROMOÇÃO DE VENDAS LTDA, Brazilian registry CNPJ 40.284.458/0001-34, at Rua Alferes Frazão, 11, suite 604, Chácara Califórnia, São Paulo, SP, ZIP 03405-050, Brazil.
  • Data Protection Officer and data-subject contact: contato@clivonapp.com.br.
  • You may request access, correction or deletion, or object to processing based on legitimate interest, including the Growth and Launch diagnosis forms. See Data Deletion.
  • We respond to data-subject requests through the channel above within 15 days.