Privacy Policy

PRIVACY POLICY This Privacy Policy is intended to provide you with all relevant information about the data collection activities and processing of your personal data through the use of this website, including data that may be provided to us through this website when you subscribe to our newsletter, when you request information about our projects or services or when you participate in a survey and/or contest that may be launched. This privacy policy should be read in conjunction with, and in addition to, other information or privacy notice that is provided by us in specific cases. This website is not intended for children and we do not knowingly collect data from children.

1. WHO WE ARE

DITADOS MILIONÁRIOS UNIPESSOAL, LDA., a private limited company incorporated under the laws of Portugal, with registered office at Rua da Moeda, n.º 4, 1200-275 Lisbon, registered with the Lisbon Commercial Registry Office under the single registration and legal person number 516 693 140, with a share capital of € 100.00 (“MILLIONAIRE SAYINGS“) whose corporate purpose is the Purchase and Sale of real estate and resale of those acquired for the same purpose, real estate development, consultancy, management and support of real estate projects, marketing of real estate products, projects and implementation of real estate investments, as well as the administration of own and third-party properties; rental, condominium management, operation of real estate and tourist developments, including local accommodation.

ALVORADA IMACULADA UNIPESSOAL LDA, A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE LAWS OF Portugal, with registered office at Rua da Moeda, n.º 4, 1200-275 Lisbon, registered with the Lisbon Commercial Registry Office under the single registration and legal person number 516 694 677, with a share capital of € 100.00 (“ALVORADA IMACULADA“) whose corporate purpose is the Purchase and Sale of real estate and resale of those acquired for the same purpose, real estate development, consultancy, management and support of real estate projects, marketing of real estate products, projects and implementation of real estate investments, as well as the management of own and third-party properties; rental, condominium management, operation of real estate and tourist developments, including local accommodation.

CODES & GUIDELINES – UNIPESSOAL LDA, A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE LAWS OF Portugal, with registered office at Rua da Moeda, n.º 4, 1200-275 Lisbon, registered with the Lisbon Commercial Registry Office under the single registration and legal person number 516 253 611, with a share capital of € 100.00 (“CODES & GUIDELINES“) whose corporate purpose is the Purchase and Sale of real estate and resale of those acquired for the same purpose, real estate development, consultancy, management and support of real estate projects, marketing of real estate products, projects and implementation of real estate investments, as well as the management of own and third-party properties; rental, condominium management, operation of real estate and tourist developments, including local accommodation.

INCOGNITEMBRACE, S.A., a private limited company incorporated under the laws of Portugal, with registered office at Rua da Moeda, n.º 4, 1200-275 Lisbon, registered with the Lisbon Commercial Registry Office under the single registration and legal person number 515 141 461, with a share capital of € 50,000.00 (“INCOGNITEMBRACE“) whose corporate purpose is the Purchase and Sale of real estate and resale of those acquired for the same purpose, real estate development, consultancy, management and support of real estate projects, marketing of real estate products, projects and implementation of real estate investments, as well as the management of own and third-party properties; rental, condominium management, operation of real estate and tourist developments, including local accommodation.

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

2. ENTITY RESPONSIBLE FOR DATA PROCESSING

Among the companies indicated in the previous clause, the responsible entity will be the one identified in the Customer’s Identification Document, and this entity will be responsible for the processing of the personal data it collects, and the subjects of the same may contact us, to clarify any doubts they may have or to exercise their rights, through the following contacts:

MILLIONAIRE SAYINGS
Registered Office: Rua da Moeda, 4, 1200 – 275 Lisboa
VAT number: 516 693 140
Phone: (00 351) 213461024
Email: info@habitatinvest.pt

IMMACULATE DAWN
Registered Office: Rua da Moeda, 4, 1200 – 275 Lisboa
VAT number: 516 694 677
Phone: (00 351) 213461024
Email: info@silvia-lopes

CODES AND GUIDELINES
Registered Office: Rua da Moeda, 4, 1200 – 275 Lisboa
VAT number: 516 253 611
Phone: (00 351) 213461024
Email: info@habitatinvest.pt

INCOGNITEMBRACE
Registered Office: Rua da Moeda, 4, 1200 – 275 Lisboa
VAT number: 515 141 461
Phone: (00 351) 213461024
Email: info@habitatinvest.pt

3. WHAT PERSONAL DATA DO WE COLLECT?

Personal data means information relating to an identified or identifiable living person. Personal data also means all elements of the data that can be used to identify a particular person. We may collect, use, store and transfer different types of your personal data, which we have grouped as follows:

a. Identification data, namely and, where applicable, name, title, date of birth, gender;
b. Contact details, such as address, email address and telephone numbers;
c. Financial and billing data, namely and, where applicable, Tax Number and International Bank Account Number (IBAN);
d. Technical data, in particular and, where applicable, IP address, login data, browser type and version, operating system and platform and other technologies of the devices used to access the website;
e. Website usage data, such as information on how our website, products and services are used;
f. Data relating to communication and marketing, namely and, where applicable, the user’s preferences in relation to communication and marketing.

We do not collect any particular categories of your personal data, such as health data, biometric data, genetic data, data relating to sex life, religious beliefs and political beliefs, 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, who provides his or her data when filling in forms or contacting us by post, telephone, e-mail or by other means, namely, when requesting information about our real estate products, subscribing to our news, newsletters or requesting marketing communications or other interactions within the scope of our activity. We may also collect personal data from public sources or from third parties authorized to share such data.

It is also possible to collect data automatically in the context of interaction with this website, such as technical data and website usage data. For more information, the data subjects should consult clause below 11. COOKIES.

5. HOW AND FOR WHAT PURPOSE WE USE YOUR PERSONAL DATA

We only process personal data when the processing is first required for compliance with legal obligations applicable to us, or where the processing operation is required for the performance of a contract or pre-contractual steps associated with it.

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, in particular, for the purposes of communicating with our customers; employee recruitment; fraud prevention and investigation, information on investment projects, clarification of additional information; questions or requests for information about investment opportunities.

Whenever none of the other conditions of legitimacy is capable of supporting the data processing operation, we shall only process the information if we have obtained the consent of the data subject for the processing of their personal data for specific, explicit and legitimate purposes.

6. INTERNATIONAL TRANSFERS AND ASSIGNMENT OF DATA

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

In order to comply with legal obligations, we may have to share your personal data with external entities that provide services to us, namely, providers of IT administration systems and services, professional consultants, among others, consultants, auditors and insurers established in the EEA, as well as with public, regulatory, Tax and Customs Authority and other entities.

7. DATA SECURITY

Your personal data is important to us and, for this reason, we have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, as well as internal procedures to respond to possible risks associated with the processing of this data.

We also make every effort to ensure that third parties cooperating with us as partners or service providers contractually guarantee adequate protection of the personal data to which they may have access. We limit access to personal data to specific employees/employees and only when their contact with 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 meet the purposes for which it was collected, including for the purposes of complying with legal, tax and accounting requirements.

To determine the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the possible risk of harm 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 the applicable legal requirements.

More specifically, and without limitation, we must retain basic information about our customers (including contact, identification, financial, and transaction information) for tax, financial, auditing, and recordkeeping 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 his or her data.

9. RIGHTS OF THE DATA SUBJECT AND THEIR EXERCISE

In certain circumstances and under data protection law, the data subject has rights in relation to his or her personal data. For your 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 Data Processing Entity:

a) Submitting a request for access to this information, the data subject has the right to obtain confirmation as to whether or not his or her data is being processed and, if this is the case, the data subject must have access to his or her personal data and the information provided for by law.
b) Submit a request for rectification of the data held concerning the data subject if such data is inaccurate or incomplete;
c) Submit a request for deletion of your personal data, without undue delay, where one of the following grounds applies:
- i. The personal data is no longer necessary for the purposes for which the collection or processing was justified;
- ii. Objection to processing or lack of overriding legitimate interests justifying the processing; or
- iii. Withdrawal of consent by the data subject for the processing of the data (in cases where the processing is based on consent) and no other reason for the aforementioned processing.
d) Submit a request for the limitation of the purposes of the processing of your personal data, if one of the following occurs:
- i. Contesting the accuracy of the personal data for a period sufficient to allow its accuracy to be verified;
- ii. The data processing is legitimate and the data subject objects to the deletion of the personal data and requests, instead, the limitation of the use of the data;
- iii. We no longer need your personal data for the purposes of processing, but this data is necessary for the data subject to establish, exercise or defend a right in connection with a legal claim;
- iv. When the data subject has objected to the processing, until it is perfectly clear that all the legitimate grounds of the responsible entity prevail over those of the data subject.
e) Object to the processing of your personal data, 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 you wish to exercise any of the above rights, please contact us using the contact information set out above. We would like to emphasise 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 it.

All requests are answered within one month, unless the complexity of the request submitted is particularly complicated, or if the data subject has submitted several requests. Without prejudice to the above, we will always keep the data subject informed in the event that the response time is extended.

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

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

10. UPDATING AND LINKS TO THIRD-PARTY WEBSITES

This privacy policy may be updated at any time, the latest version being the version that is 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 attributed to us. Therefore, we recommend that you read the privacy policy of all websites you visit in addition to this website.

11. COOKIES

This website uses cookies. When you visit the website, we may install small pieces of information on your computer, called “cookies”. Cookies are stored by the browser on the hard drive.
Within the scope of this website, we distinguish between two types of cookies:

a) Technical cookies, i.e. cookies that are necessary for the proper performance of this website;
b) Performance and tracking cookies, i.e. cookies that collect information about the user and improve performance, but are not necessary for proper operation

In general terms, cookies help us in several ways: we use cookies to be able to better organize the website or information about our products and to have this information adapted to the user’s interests or preferences. Cookies allow us to know who has visited these pages and what content they have visited, to evaluate the frequency of visits to certain pages, to determine favourite areas of the website and to guide their use in general terms.

The user has the option to manage cookies by selecting the corresponding option in their browser. However, we take the liberty of advising you that if you disable or refuse cookies, some parts of this website may be inaccessible or not operate properly.