1. WHO WE ARE & OUR POLICY PURPOSE
Private Luxury Collection is wholly owned and licensed by Centelha D’Exito Unipessoal Lda. An established and experienced real estate agency based in Portugal.
Centelha D’Exito Unipessoal LDA., consists of the following trade names.
Private Luxury Collection www.privateluxurycollection.com
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this policy. If you have questions, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Private Luxury Collection
DPO: Linda Capel
Email: email@example.com, Subject DPO
Registered address: Caminho das Searas 50, 8125-417, Vilamoura
Telephone number: (+351) 915471151
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us at: firstname.lastname@example.org subject: Personal Data
Centelha D’Exito Unipessoal LDA’s websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. HOW YOUR PERSONAL DATA IS COLLECTED
To ensure we can provide you the best services, information and value with your property needs. We use different methods to collect data from and about you through:
a. Direct interactions. You may give us data through a personalised consultation, through completing forms at events and exhibitions or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Request information about a property(s) or service(s) through completing a form online, during events, seminars and exhibitions.
- Select us as your mediation or marketing partner
- Request property and supporting marketing to be sent to you
- Book tickets for an event or an exhibition hosted by us or our strategic partners
- Subscribe to our services or publication
- Enter a competition, promotion or survey ot
- Provide us feedback
b. Automated technologies, interactions and cookies. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites utilising our cookies.
c. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:
- Analytics providers such as Google based outside the EU
- Social media services
- Advertising networks or
- Search information providers
3. DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information which can directly and personally identify an individual data subject. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a. Identity Data - first name, maiden name, last name, username or similar identifier, marital status, title
b. Contact Data - billing address, delivery address, email address and telephone numbers
c. Marketing and Communications Data - preferences in receiving marketing from us and our third parties and your communication preferences
d. Transaction Data - details about payments to and from you and other details of products and services you have purchased from us
e. Technical Data - internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to interact with or access this website
f. Profile Data - your client identification number, purchases or orders, interests, preferences, feedback and survey responses
g. Usage Data - information about how you use our website, products and services.
We may also collect, use and share Aggregated Data such as statistical or demographic data to aid in improving the products and services we provide you. Aggregated Data may be derived from your personal data but when sanitised for aggregation purposes will not include detail which would directly or indirectly reveal your identity and so is not considered personal data.
Failure to provide personal data - where we need to collect personal data by law, or under the terms of a contract we have with you where by you fail to provide that data when requested, may result in us not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may need to cancel a service you have with us, we will however notify you should this the case.
4. HOW WE USE YOUR PERSONAL DATA
We may use your personal data in the following circumstances:
- Where we need to perform a contract we enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
We rely on consent as a legal basis for processing your personal data in relation to contacting you via telephone or sending direct marketing communications to you via email or other means. Where you have placed a request with us by completing a form at events, seminars and exhibitions or purchased our services we consider that you have an interest in those products or services and similar products or services offered by or through us or our partners, and we are permitted under data protection legislation to send those communications to you.
We comply with data protection legislation in our electronic marketing and you have the right to withdraw consent to marketing at any time by emailing us at: email@example.com Subject: Unsubscribe.
Our aim is to provide you with the best options possible when purchasing your property in Portugal. Our tailored model for work includes purchasing service which ensures you are able to invest with supports and strives to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us - we may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (Known as marketing).
You will receive marketing communications from us if you have requested information from us, placed a request with us, purchased goods or services from us, if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing - When you request information on products, services or properties provided by our commercial partners, we will pass your personal data on to them and they may contact you regarding those products, services or properties. We will get your express opt-in consent before we share personal data provided for that purpose with any other company or organisation (other than ourselves) for marketing purposes.
Opting out - At any time you can request that we, or third parties, stop contacting you, sending you marketing messages or material. When you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose - We will only use your personal data for the purposes for which we collected it, unless we reasonably consider it useful or compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Internal Third Parties
- External Third Parties
- Specific third parties such as commercial partners and legal entities
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
If you enquire about a product or service located outside the European Economic Area (“EEA”) – for example, Cape Verde, your personal data may be provided to our commercial partner. We may also from time to time offer information, products or services from partners outside the EEA in relation to products or services in their country or location related to your investment needs and interests. In each case, this will involve transferring your data outside the European Economic Area (EEA).
In many cases where you submit an enquiry about products, services or properties offered by a commercial partner (such as a real estate professional) outside of the EEA, we may be unable to ensure a similar degree of protection for your personal data as exists within the EEA. In these situations, we transmit your personal data directly to the commercial partner at your request and on your behalf.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
7. DATA SECURITY
We continually endeavour to ensure security measures are in place to prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we are required to keep information on our clients for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
9. YOUR LEGAL RIGHTS
You have the right to:
- Access - to your personal data. This enables you to receive a copy of the personal data we hold about you and to check it is correct and we are lawfully processing it. For security purposes you may be asked to verify your identity before your data is released.
- Correction - of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. Verification of your identity and accuracy of the new data you provide to us may be required.
- Erasure - of your personal data. Enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object - to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restrict processing - this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Transfer - your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent - at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
To find out more about these rights, please refer to paragraph 10. If you wish to exercise any of the rights set out above, please contact us at: firstname.lastname@example.org
Data access fees
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with requests under abusive circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
Time to respond will be dependant on the request and urgency of the situation. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In the event of an urgent situation or breach we will endeavour to inform or respond to you within 72 hours or as soon as practicable.
10. LAWFUL BASIS
Legitimate Interest means the interest of the business(s) and in conducting and managing the business to provide you the best service/product and experience to facilitate your property search, purchase and investment(s). We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Brands/trade names controlled by Centelha D’Exito Unipessoal LDA., acting as joint controllers.
External Third Parties
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities, who may act as processors or joint controllers, based in Portugal (or abroad, in relation to properties, products or services located abroad) who require reporting of processing activities in certain circumstances.
- Commercial partners providing processing, technical and security services or products, services or information related to properties, including real estate agents, property developers, private sellers, lawyers and notaries, mortgage and financial services companies, event organisers, media and marketing companies.