We are responsible for processing your personal data
PRIMOSFERA INVESTIMENTOS IMOBILÁRIOS, LDA. (hereinafter “PRIMOSFERA”), based in Rua do Alecrim, n.º 26, 2.º Esq., 1200-018 Lisbon and registered with corporate identification number 505785129, is responsible for processing your personal data.
What personal data do we collect about you?
Personal data is any information of any kind, regardless of media, that relates to an identified or identifiable person. According to the GDPR, an identifiable person is any person who can be directly or indirectly identified, whether by name, ID no., location data, electronic identifiers or one or more specific physical, physiological, genetic, mental, cultural or social features.
We only collect data considered essential for browsing our website, providing you with the services requested and informing you about our news, if an interest has been shown. To consult the purposes and reasons for processing your data, please see the section below entitled “WHAT DO WE USE YOUR PERSONAL DATA FOR?”
To be specific, we process the following personal data:
ID data: name, tax identification number (NIF), date of birth.
Contact details: email address, telephone number.
Connection and location data: IP address, type of device and country in which the website is accessed.
How do we collect your personal data?
We collect your personal data when you browse our website, and when you contact us. Under no conditions whatsoever will your data be used for a purpose other than that for which it was collected.
Who do we share your personal data with?
As a rule, we do not share your data with other entities. In exceptional situations, while supplying our services, we may need to use service providers and intermediaries who may need to access to some of your personal data. However, this information is shared solely and exclusively to fulfil the purposes for which the data is collected and in accordance with our instructions, in strict compliance with the rules on personal data processing and data security. Whatever the case, you will be informed about all information shared.
We may also share your personal data with third parties when your express consent has been given or to fulfil a legal obligation or court order.
We will not transfer your personal data outside the European Union or European Economic Space, i.e. to a third country. However, if necessary, we will ensure strict compliance with European legislation on transferring data to third countries and we will provide all necessary information, namely guarantees concerning this transfer.
How long do we keep your data?
Your personal data is only kept for the time necessary to achieve the purposes for which it was collected or for the time required by law.
What are your rights as the personal data holder?
The holder has the right to access, rectify, limit and erase their personal data, the right to oppose its use, without compromising the lawfulness of the data processed on these legal grounds, and the right to portability, according to the GDPR.
If the processing is based on your legal consent, you have the right to withdraw it at any time without compromising the lawfulness of the data processed based on prior consent.
As the personal data holder and with a view to exercising your rights, please contact us at the email addresses or telephone numbers shown in the preceding section “WE ARE RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA”.
How do we ensure the data shared is secure?
To ensure your personal data is kept confidential, we take technical and organisational measures to protect it from accidental or unlawful destruction, loss, amendment, dissemination and unauthorised access, and other illegal forms of data processing. For example, the following measures are employed:
The pseudonymisation and encryption of personal data;
The capacity to ensure the permanent confidentiality, integrity, availability and resilience of the processing systems and services;
The capacity to detect a personal data breach and to resolve and report it;
The capacity to re-establish the availability and access to the personal data in a timely manner in the event of a physical or technical incident;
The implementation of a process to test, evaluate and assess the effectiveness of the technical and organisational measures regularly to ensure data is processed securely;
The identification, dissemination and documentation of the duties and obligations of staff with access to personal data;
The maintenance of a written record of all data processing activities performed as required by GDPR;
The defining and implementation of a procedure to record all incidents in writing;
The appointment of a person responsible for security or, where appropriate, a Data Protection Officer who must be designated whenever obliged by law;
The defining and implementation of physical access controls;
The application of security policies and procedures;
The adoption of a code of conduct for personal data protection in accordance with the GDPR;
The defining and implementation of a procedure to destroy or return personal data and documents securely and confidentially (ensuring it cannot be retrieved later and certifying no copies exist) when the contractual relationship ends (except when obliged to keep the data for an additional period, in the event that the data and documents must be blocked).
Any entity we subcontract is bound to equivalent security measures and is permanently obliged to act under our documented instructions.
Who is responsible for handling complaints concerning the processing of your personal data?
If you are not satisfied about the way we collect and process your personal data, you may send a complaint directly to the relevant authority: National Committee for the
Protection of Data (CNPD). All information can be found here.
Bearing in mind that personal data processing practices can change from time to time, this Policy will be updated to comply with them and at the same regular intervals.
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