This privacy policy is intended to provide all relevant information about the data collection activities and the processing of your personal data through the use of this website, including data that you may provide us through this website when subscribing to our newsletter, requesting information about our projects or services, or participating in any survey and/or competition that may be launched.

This privacy policy should be read in conjunction with, and in addition to, other privacy information or notices that are provided by us in specific instances.

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

  1. 1. WHO WE ARE

HABITAT VITAE – Sociedade de Investimentos Imobiliários, S.A., a public limited company incorporated under the laws of Portugal and registered with the Commercial Registry Office of Lisbon (2nd Section), under the single registration and legal person number 505768216, with its registered office at Rua da Moeda, 4, 1200-275 Lisbon.

2. ENTITY RESPONSIBLE FOR DATA PROCESSING

HABITAT INVEST

is responsible for processing the personal data it collects. Data subjects may contact us to clarify any doubts they may have or to exercise their rights through the following channels:

3. WHAT PERSONAL DATA DO WE COLLECT?

Personal data means information relating to an identified or identifiable living person. Personal data also includes all data elements that can be used to identify a specific person.

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

  • Identification data, namely, and where applicable, name, title, date of birth, sex;
  • Contact information, namely address, email address and telephone numbers;
  • Financial and billing data, namely, and when applicable, tax number and International Bank Account Number (IBAN);
  • Technical data, namely, and where applicable, IP address, login details, browser type and version, operating system and platform and other technologies on the devices used to access the website;
  • Website usage data, namely information about how our website, products and services are used;
  • Communication and marketing data, namely, and where applicable, user preferences regarding communication and marketing.

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

4. HOW DO WE COLLECT PERSONAL DATA?

Personal data may be collected in different ways. Firstly, by direct interaction with the data subject, such as when they provide their data when filling in forms or contacting us by post, telephone, email or other means, particularly when requesting information on our real estate products, subscribing to our newsletters or requesting the sending of marketing communications or other interactions within the scope of our activity. We may also collect personal data from public sources or from third parties authorised to share such data.

5. HOW AND TO WHAT END DO WE USE YOUR PERSONAL DATA?

We only process personal data when, firstly, the processing is required for compliance with legal obligations applicable to us, or, secondly, when the processing operation is required for the fulfilment of a contract or pre-contractual diligence associated therewith.

We may also process information if we have a legitimate interest to do so, provided that, in each case, our interest is in accordance with applicable law and the rights of the data subject. The foregoing may occur, inter alia, for the purposes of communicating with our customers, recruiting employees, fraud prevention and investigation, information on investment projects, clarification of further information, and questions or requests for information on investment opportunities.

Where none of the other conditions of legitimacy are capable of supporting the data processing operation, we shall only process the information if we have obtained the data subject’s consent to the processing of their personal data for specified, explicit and legitimate purposes.

6. INTERNATIONAL TRANSFERS AND DATA TRANSFER

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

To comply with legal obligations, we may need to share your personal data with external parties who provide services to us, including providers of IT systems and administration services; professional advisers, among others; consultants; auditors and insurers based in the EEA, as well as with public entities, regulators, the Tax and Customs Authority, and other entities.

7. DATA SECURITY  

Your personal data are important to us. For this reason, we have implemented appropriate security measures to prevent accidental loss, unauthorised use or access to your personal data, or alteration or disclosure, as well as internal procedures to respond to any risks associated with the processing of this data.

We also make every effort to ensure that third parties who cooperate with us as partners or service providers contractually guarantee the adequate protection of the personal data to which they may have access. We limit access to personal data to specific employees/workers and only when their contact with the personal data is justified within the scope of their duties.

8. MAXIMUM RETENTION PERIOD FOR PERSONAL DATA

Your personal data will only be retained for the period necessary to fulfil the purposes for which they were collected, including for compliance with legal, fiscal and accounting requirements.

In determining the appropriate period for which to retain personal data, we take into account the quantity, nature and sensitivity of the personal data, the possible risk of damage caused by unauthorised use or disclosure of your personal data, the purposes for which we process it and whether we can achieve these purposes by other means, and applicable legal requirements.

More specifically, and without limitation, we are required by law to retain basic information about our customers (including contact, identification, financial and transaction data) for tax, financial, audit and record-keeping purposes for a minimum period of 10 years from the time our customers cease to be our customers.

In certain circumstances, the data subject may request the deletion of their data.

9. RIGHTS OF THE DATA SUBJECT AND HOW TO EXERCISE THEM

Under certain circumstances and under data protection law, the data subject has rights in relation to their personal data.

For their information, the data subject may, at any time, but always taking into account the actual situation and the respective legal limits, exercise the following rights with any Entity Responsible for Data Processing:

  1. Submit a request for access to that information. The data subject shall have the right to obtain confirmation as to whether or not their data is being processed and, if so, the data subject shall have access to their personal data and information as provided for by law.
  2. Submit a request for rectification of data held on the data subject, in case the data is inaccurate or incomplete;
  3. Submit a request for the deletion of personal data, without undue delay, whenever one of the following reasons applies:
      1. The personal data are no longer necessary for the purposes that justified their collection or processing;
      1. Objection to the processing or absence of overriding legitimate interests justifying the processing; or
      1. Withdrawal of consent by the data subject to the processing of the data (in cases where the processing is based on consent) and no other reason for the mentioned processing.
  4. Submit a request for the limitation of the processing of your personal data, if one of the following situations occurs:
      1. Contestation of the accuracy of personal data for a period sufficient to allow their accuracy to be verified;
      1. The data processing is legitimate and the data subject objects to the deletion of the personal data and instead requests limitation of the use of the data;
      1. We no longer need your personal data for processing purposes, but such data is necessary for the data subject to establish, exercise or defend a right in legal proceedings;
      1. Where the data subject has objected to processing, until it is perfectly clear that all legitimate reasons of the responsible entity outweigh those of the data subject.
  5. Oppose the processing of your personal data, in cases where the data processing is carried out for the purposes of the legitimate interests pursued by us, or where the data is processed for direct marketing purposes.

If the data subject wishes to exercise any of the rights referred to above, they should contact us using the contact information above. We would like to underline that it may be necessary to request specific information so that we can confirm the identity of the data subject and guarantee their legitimacy to exercise these rights, as well as to ensure that we do not provide data to third parties who are not entitled to receive them.

All requests are answered within one month, unless the complexity of the request submitted is particularly burdensome, or the data subject has made several requests. Notwithstanding the above, we will always keep the data subject informed in case the response time is extended.

Exercising your rights does not involve the payment of any fees. However, in the event that your request is unfounded, repetitive or excessive, we will, at our discretion, charge a reasonable fee or refuse your request.

We would like to remind you that you have the right to lodge a complaint at any time with the National Data Protection Commission (CNPD), whose contact information is available at www.cnpd.pt. We would also like to ask you to give us the opportunity to answer your questions before contacting the CNPD.

10. UPDATES AND LINKS TO THIRD-PARTY WEBSITES

This privacy policy may be updated at any time, the latest version of which is the version made available on this page.

This website may include links to third-party websites, plug-ins and applications. Clicking on these links or activating these links may allow third parties to collect or share your data, which is not controlled by us and cannot be imputed to us. We therefore recommend that you read the privacy policy of every website you visit, in addition to this one.

11. COOKIES

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