This Privacy Policy wishes to provide all relevant information on data collection activities and on the processing of your personal data through the usage of this website, including any data that you may provide through this website whilst subscribing our newsletter, whilst asking information on our projects or service or whilst participating in a survey and/or tender to be launched.

This privacy policy must be read together with, and complementary to, other information or privacy notice that we may supply in specific cases.

This website is not intended to children and we do not knowingly collect data from children.

1. WHO WE ARE  

HABITAT VITAE. a joint-stock limited liability company, incorporated under the laws of Portugal, with the single registration and body corporate number 505768216, with registered office at Rua da Moeda, no. 4, 1200-275 Lisbon, parish of Misericórdia, municipality of Lisbon (“HABITAT VITAE”) the object of which is the Purchase and Sale of properties and resale of those acquired for the same purpose, real estate promotion, consultancy, management and support of real estate projects, marketing of real estate products, projects and setting up of real estate investments, as well as the management of own and third parties properties; rentals, management of property communities of owners, exploitation of real estate and tourist developments, local accommodation included.

2. DATA PROCESSING CONTROLLER

HABITAT VITAE is responsible for the processing of your personal data and you may contact us to clarify any doubt you may have or for the exercise of your rights, through the following contacts:

3. WHAT PERSONAL DATA DO WE COLLECT?

Personal data means the information relating to an identified or identifiable living person. Personal data further means all data elements which could serve to identify a given person.

We can collect, use, store and transfer different types of personal data on you, which we have grouped as follows:

1. Identification data, notably and when applicable, name, title, birth date, gender;
2. Contact data, notably, address, e-mail address and telephone numbers;
3. Financial and invoicing data, notably and when applicable, Tax Payer Number and Inter Bank Account Number (IBAN);
4. Technical data, notably and when applicable, IP address, login data, browser type and version, operating system setup and location’s time zone, browser plug-ins types and versions, operating system and platform and other technologies of the devices you are using to have access to this website;
5. Website usage data, notably information on how you use our website, products and services;
6. Data relating to communication and marketing, notably and when applicable, the preferences of the user on communication and marketing.

We do not collect any special categories of your personal data, notably, health data, biometric data, genetic data, data concerning sex life, religious beliefs and political opinions, trade union membership or any data revealing racial and ethnic origin.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?   

Personal data can be collected in different ways, in first place by direct interaction with you, the data subject supplying his/her data when completing any forms or when contacting us by post, telephone, e-mail or other means, notably when requesting information on our real estate products, when subscribing news, newsletters or when requesting the sending of marketing communications or other interactions within the scope of our activity. We can also collect personal data from public sources or from third parties authorised to share such data.

It is also possible to automatically collect data when you interact with this website, notably technical data and website usage data. For further information you are invited to see our Cookies Policy

5. HOW AND FOR WHICH PURPOSES DO WE USE YOUR PERSONAL DATA 

We only process personal data when, primarily, processing is required to meet legal obligations applying to us, or when such processing operation is required for the performance of an agreement or of pre-contractual steps associated to it.

We can, also, process information if we have a legitimate interest for doing it, provided that, in each case, our interest complies with the applicable legislation and with the data subject rights; this can occur, notably, for effects of communication with our customers; recruitment of collaborators; prevention and investigation of fraud, information on investment projects, clarification of additional information, questions or requests of information on investment opportunities.

When none of the other legitimacy conditions are capable of supporting the operation of data processing, we shall only process the information if we have obtained the consent of the data subject to process his/her personal data for specific, explicit and legitimate purposes.

6. INTERNATIONAL TRANSFERS AND ASSIGNMENT OF DATA

Unless expressly stated in this document or in any complementary privacy notice, we shall not transfer your personal data outside the European Economic Area (EEA).

For compliance with legal obligations, we may have to share your personal data with external entities that provide us services, notably, suppliers of systems and IT management services, professional advisors, inter alia, counsellors, auditors and insurers established in the EEA, as well as with public, regulation bodies, Tax and Customs Authority and other entities.

7. DATA SECURITY  

Your personal data are important for us and, for such reason, we have implemented adequate security measures to avoid your personal data to be accidentally lost, used or accessed in a non-authorised manner, modified or disclosed, as well as internal procedures to answer eventual risks associated to the processing of these data.

We have further developed all required efforts to ensure that third entities that cooperate with us as partners or services providers contractually guarantee the appropriate protection of the personal data to which they may eventually have access. We limit the access to personal data to specific employees and only when their contact with such personal data is justified within the scope of their functions.

8. MAXIMUM PERIOD FOR PERSONAL DATA TO BE RETAINED

Your personal data shall only be retained for the period required to comply with the purposes for which they have been collected, including for the effects of compliance with legal, tax and accounting requirements.

To determine the adequate retention period of personal data, we take into account the quantity, the nature and the sensitivity of the personal data, the eventual risk of damages caused by a non-authorised usage or disclosure of your personal data, the purposes for which we process your personal data and if we can achieve these purposes by other means, and the applicable legal requirements.

More specifically, and without limitation, we have to retain, under law, basic information on our customers (including contact, identification, financial and transaction data), for a minimum period of 10 years upon customers are no longer our customers, for tax, financial, audit and record keeping purposes.

Under given circumstances, you may request erasure of your data.

9. RIGHTS OF THE DATA SUBJECT AND RESPECTIVE EXERCISE

In certain circumstances and under data protection law, you have rights in what regards your personal data.

For your information you may, at any time, however always taking into account the real situation and the respective legal limits, exercise the following rights before any Data Processing Controller:

1. Request access to the information, the data subject being entitled to obtain confirmation that his/her data are, or not, being processed and, if such is the case, the data subject shall have access to his/her personal data and to the information laid down in law.

1. Request the rectification of the data held on the data subject, in the event such data are inaccurate or incomplete;

1. Request the erasure of your personal data, without unjustified delay, when one of the following motives applies:

1. Personal data are no longer required for the purpose that has justified the collection or processing;
2. Opposition to processing and inexistence of legitimate prevailing interests justifying processing; or

• Withdrawal of consent by the data subject for the processing of data (in the cases when processing is based on consent) and the inexistence of other grounds for the mentioned processing.

1. Request the purpose limitation of your personal data processing, in the event one of the following situations occurs:
2. Contesting of the accuracy of the personal data for a period sufficient to allow the checking of their accuracy;
3. The processing of data is legitimate and the data subject opposes to the erasure of the personal data and requests, in return, limitation of data usage;

• We no longer need your personal data for processing purposes, but such data are required by the data subject to establish, exercise or defend a right in a legal claim;

1. When the data subject has opposed to processing until it becomes clear that all legitimate motives of the controller prevail over those of the data subject.

1. Oppose to the processing of your personal data, in the cases where the data processing is carried out for the effects of the legitimate interests pursued by us or when data are processed for direct marketing purposes.

If you wish to exercise any of the hereinabove referred rights, kindly contact us using the hereinabove-mentioned contact information. We would like to advise you that it may be necessary to request specific information so that we can confirm your identity and guarantee that you have the legitimacy to exercise such rights, as well as to guarantee that we do not provide data to third parties who are not entitled to receive them.

All requests are answered within one month, save as if the complexity of your request is particularly complex or if you have made several requests. Notwithstanding the above, we shall always keep you informed in the event the time to reply is extended.

The exercise of your rights shall not involve the payment of any fee. However, in the event your request is unfounded, repetitive or excessive, we are allowed to charge a reasonable fee or, alternatively, to refuse your request.

We would recall that you will have the right to, at any time, submit a complaint to the Portuguese Data Protection Authority [Comissão Nacional de Protecção de Dados (CNPD)], contact information available at www.cnpd.pt. We would however kindly ask you to give us the opportunity to answer your questions before you contact CNPD.

10. UPDATING AND LINKS TO THIRD PARTIES WEBSITES

This privacy policy can be updated at any time, the last version of which shall be made available on this page.

This website may include links to third parties websites, plug-ins and applications. To click on these links or to activate such links can allow third parties to collect or to share your data, what is not controlled by us and cannot be attributed to us. We, thus, recommend, that you read the privacy policy of all websites you visit other than this website.

11. COOKIES

This website uses cookies. When you visit the website, we can install small pieces of information on your computer, known as “cookies”. The cookies are stored by the browser in the hard disk.

Within the scope of this website we distinguish two types of cookies:

1. Technical cookies, i.e. cookies that are necessary for the good performance of this website;
2. Performance and tracking cookies, i.e. cookies that collect information on the user and improve performance, but which are not necessary for an appropriate operation

In general terms, cookies help us in several ways: we use cookies to be able to better organize the website or the information on our products and to have this information adapted to the interests or preferences of the user. Cookies allow us to know who has visited these pages and which contents, to assess the frequency of the visits to certain pages, to determine the favourite areas of the website and direct in general the use of same.

The user has the option to manage the cookies through the selection of the corresponding option in his/her browser. However, we advise you that in case you opt to deactivate or refuse cookies, some parts of this web site can be inaccessible or not correctly operational.