Property Management application (widget) for Kommo · Version 2.0 · Last updated: July 19, 2026
The Property Management application ("Application" or "widget") is operated by Crescer Assessoria Performance LTDA, operating under the Crescer Flow brand, Brazilian corporate taxpayer ID (CNPJ) 61.917.521/0001-00, headquartered at Avenida Deputado Jamel Cecílio, No. 2929, Quadra B27, Lote Área, Sala 1618-TA, Edifício Brookfield Towers, Jardim Goiás, ZIP Code 74810-100, Goiânia/GO, Brazil ("Crescer" or "we"). The Application is distributed through the Kommo Marketplace and provides property management integrated with Kommo CRM.
Data Protection Officer (DPO): suporte@crescerflow.com · Support: suporte@crescerflow.com.
This Policy observes Brazilian Law No. 13,709/2018 (LGPD). The roles are:
Roles are assessed for each processing operation. Crescer may act as an independent Controller for data strictly necessary for contract management, security, fraud prevention, compliance with legal obligations, and the exercise of rights. Details of the Controller–Processor relationship are set out in the Data Processing Addendum.
| Category | Examples | Source |
|---|---|---|
| Installation and account data | Kommo account ID and subdomain, user ID, and account access tokens (OAuth) | Kommo OAuth during installation |
| Property catalog | Code, type, address, prices, features, photos, and links | Entered by the real estate agency manually, by import, or through the API |
| Third-party personal data | Name, telephone, email, CRECI registration, and notes concerning property owners and agents linked to properties | Entered by the real estate agency |
| Lead relationships | Kommo lead ID, linked properties, interest status, completed custom fields, and scheduled visits | Use of the widget on the lead card or API |
| Responsible person's contact data | Name, email, and telephone entered in the settings panel | Application form |
| Usage data | Property search, view, and linking events, including property code and date | Generated through use |
| Subscription/payment data | Plan, status, and billing history when a paid plan is available. We do not store full card numbers or security codes. | Checkout or payment provider identified at purchase |
The Application does not perform advertising tracking or use marketing cookies. We use only a short-lived session token required for operation.
| Purpose | Legal basis (LGPD) |
|---|---|
| Provide the service: catalog, search, linking, visits, field synchronization, and automations | Performance of a contract (Art. 7, V) |
| Provision the account and authenticate access through Kommo | Performance of a contract |
| Billing, subscription control, and fraud prevention | Performance of a contract / legal obligation / legitimate interest |
| Usage metrics to operate and improve the product | Legitimate interest (Art. 7, IX) |
| Support and operational communications | Performance of a contract / legitimate interest |
Property owner, agent, and lead data is processed only as necessary for the real estate agency's operation within the Application. The real estate agency (Controller) is responsible for having an appropriate legal basis to collect and enter this third-party data.
We do not sell personal data. We share data only with:
No method is completely infallible, but we adopt technical and organizational measures appropriate to the risk.
We retain data while the account is active and for as long as necessary for the stated purposes. When the Application is uninstalled or the service is terminated, the account and integration keys are disabled. Associated data is deleted or anonymized within 90 days, except where an earlier return was requested or retention is required by law, for fraud prevention, for the regular exercise of rights, or in restricted-access backups subject to their own deletion cycle.
The real estate agency may request export, correction, or deletion through the contact provided in this Policy. Deletion will be performed when there is no legal basis to retain the data and subject to applicable technical limitations.
Under Article 18 of the LGPD, a data subject may request confirmation of processing, access, correction, anonymization, blocking or deletion, portability, information about sharing, and withdrawal of consent. Because we act as Processor, requests from data subjects concerning data entered by the real estate agency should generally be directed to that agency (Controller); we support it in responding.
Some providers or integrations, including Kommo, may maintain infrastructure or teams outside Brazil. When an operation constitutes an international transfer of personal data, we will adopt a valid mechanism under Articles 33 to 36 of the LGPD and ANPD regulations, including an adequacy decision or ANPD standard contractual clauses, as applicable.
The Application is intended for real estate professionals and is not directed to persons under 18 years of age.
We may update this Policy to reflect legal, technical, or operational changes. Material changes will be communicated through product channels with reasonable advance notice, except in legal or security emergencies, and will always state a new update date. Where the law requires new consent, it will be requested specifically.