Policy on Data Protection and Privacy | QUINTELA e PENALVA – Real Estate |
Commitment on Data Protection and Privacy
QUINTELA e PENALVA – Real Estate complies with all the Community and national legal rules applicable to data protection, privacy and security of information.
QUINTELA e PENALVA – Real Estate is currently implementing a System of Protection of Personal Data and an Information Security System, in order to assure normative compliance and the demonstration or evidence of the institution’s responsibility on matter of data protection and security of information. This involves implementing all the necessary technical and organisational measures, both for compliance with the general legal system of the Data Protection Law in force, and for compliance with the special legal system of the General Data Protection Regulation, applicable from 25 May 2018 onwards.
For any clarification or further information or for exercise of rights in this regard, please contact the Data Protection Office of QUINTELA e PENALVA – Real Estate by electronic mail to dpo@quintelaepenalva.pt .
Definitions
«Personal data»
«Personal data», information relative to an identified or identifiable natural person («data owner»). A natural person is considered identifiable when she/he can be identified directly or indirectly, especially by reference to an identifier. Personal identifiers are considered, for example, a name, an identification number, location data, identifiers via electronic means or to one or elements of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
«Treatment of Personal Data»
«Treatment», an operation or a series of operations conducted on personal data or on personal datasets, by automated or non-automated means, such as the collection, registration, organisation, structuring, conservation, adaptation or alteration, recovery, consultation, use, disclosure by transfer, dissemination or any other form of provision, comparison or interconnection, limitation, deletion or destruction.
«Cookies»
«Cookies» are small text files with information considered relevant which are loaded by the devices used for access (computers, mobile phones or portable mobile devices), through the internet browser when a website online is visited by the Customer or User.
Entity Responsible for the Treatment
“QUINTELA e PENALVA – Real Estate ASSOCIADOS – SOCIEDADE DE MEDIAÇÃO IMOBILIÁRIA, LDA.”, with head office at Rua Rodrigo da Fonseca, n.º 178-A, 1070-243 Lisboa, registered at Lisbon Commercial Register, under the sole registration and legal person number 506.856.364, with share capital of € 43,173.00, hereinafter referred to as QUINTELA e PENALVA – Real Estate, is the entity responsible for the websitedev.quintelaepenalva.pt and for the electronic applications, hereinafter referred to as channels or applications, through which the Users, Service Receivers or Customers have remote access to the services and products of QUINTELA e PENALVA – Real Estate which are presented, marketed or provided to them, at any time, through them.
The use of the channels or applications by any User, Service Receiver or Customer can imply the conduct of operations of treatment of personal data, whose protection, privacy and security are assured by QUINTELA e PENALVA – Real Estate, as the entity responsible for this treatment, pursuant to the terms of this Policy on Data Protection and Privacy.
Contacts of the Managers responsible for the Data Treatment
To contact the Data Protection Office of QUINTELA e PENALVA – Real Estate, please send an email to dpo@quintelaepenalva.pt, describing the subject of the request and indicating an electronic mail address, a telephone contact or a postal correspondence address.
For any other purpose, the following general contacts of QUINTELA e PENALVA – Real Estate may be used:
– Postal address: Rua Rodrigo da Fonseca, n.º 178-A, 1070-243 Lisboa
– Electronic mail: geral@quintelaepenalva.pt
– General telephone: 212 454 059
Collection and Treatment of Personal Data
QUINTELA e PENALVA – Real Estate’s treatment of personal data is strictly in accordance with that required for the provision of information and functioning of its channels, in accordance with the uses made by the Users, Service Receivers or Customers. This includes both the data supplied by the Users, Service Receivers or Customers for purposes of registering requests or obtaining information, or the data supplied by them for effects of subscribing to these channels, or data arising from use of the services provided by QUINTELA e PENALVA – Real Estate, such as accesses, consultations, instructions, transactions and other records relative to their use.
In particular, the use or activation of certain functionalities of the channels might imply the treatment of various direct or indirect personal identifiers, such as the name, address of residence, contacts, addresses of devices or geographic location, whenever the User, Service Receiver or Customer has explicitly consented such.
In all cases, the Users, Service Receivers or Customers will always be informed of the need for access to such data for use of the functionalities of the channels in question.
The personal data collected by QUINTELA e PENALVA – Real Estate are treated electronically, in certain cases in an automated form, including the processing of files or definition of profiles and in the management of pre-contractual, contractual or post-contractual relations with the Users, Service Receivers or Customers, under the terms of the national and Community standards in force.
Categories of Personal Data Treated
The following categories or types of personal data of the Users, Service Receivers and Customers are subject to treatment:
i. Name;
ii. Telephone of residence and/or workplace;
iii. Mobile telephone;
iv. Address of residence and/or workplace;
v. Electronic mail address.
Legal principles
All the data treatment operations comply with the fundamental legal principles concerning data protection and privacy, namely as to their circulation, lawfulness, loyalty, transparency, purpose, minimisation, conservation, accuracy, integrity and confidentiality, with QUINTELA e PENALVA – Real Estate being willing to demonstrate its responsibility to the data owner or any other third party entity that has a legitimate interest in this matter.
Foundations of legitimacy
All the data treatment operations conducted by QUINTELA e PENALVA – Real Estate are founded on legitimacy, namely due to the fact that consent was given by the data owner for the treatment of her/his personal data for one or more specific purposes, the fact that the treatment is considered necessary for the execution of a contract in which the data owner is a party, or for pre-contractual procedures at the request of the data owner, or due to the fact that the treatment is necessary for compliance with a legal obligation to which the entity responsible for the treatment is subject, or due to the fact that the treatment is necessary for effect of legitimate interests pursued by QUINTELA e PENALVA – Real Estate or by third parties.
Purpose of the Treatment
All the personal data treated within QUINTELA e PENALVA – Real Estate’s channels are exclusively intended for the provision of information to the Users, management of the personal information of the Service Receivers considered necessary for purposes of management of relations or communication, as well as the provision of the services contracted by the Customers and, in general, the management of pre-contractual, contractual or post-contractual relations with the Users, Service Receivers or Customers.
The personal data collected might, also and possibly, be subject to treatment for statistical purposes, for information disclosure or promotional actions and for commercial or marketing actions, namely to promote actions disclosing new functionalities or new products and services, through direct communication, whether by correspondence, by electronic mail, messages or telephone calls or any other electronic communications service, and this data can be conveyed to other companies of the Quintela e Penalva Group for the same purposes.
While the prior information and collection of explicit authorisation for these last purposes is always assured, the Users, Service Receivers or Customers can, at any time, exercise their right to object to the use of the personal data for other purposes that go beyond the management of the contractual relationship. This includes for marketing purposes, for sending informative communications or for inclusion in lists or informative services. To exercise this right, they should send a written request to the Data Protection Office of QUINTELA e PENALVA – Real Estate, in accordance with the procedures indicated below.
Data Conservation Periods
Personal data shall be kept only for the period of time required for the purposes leading to their collection or subsequent treatment, with compliance with all the applicable legal rules on matters of archiving being assured.
Use of Cookies
QUINTELA e PENALVA – Real Estate could possibly use two major categories of cookies: cookies in the context of website online and cookies in the context of direct electronic communication channels, always assuring the respective deactivation by the Users, Service Receivers or Customers.
QUINTELA e PENALVA – Real Estate uses cookies in its websites online in order to improve the browsing performance and experience of the Users, Service Receivers and Customers, on the one hand increasing the speed and efficiency of response, and on the other hand eliminating the need to repeatedly enter the same information.
The use of cookies helps websites online to recognise the devices of the Users and Customers the next time they visit, and in some cases, it is also indispensable for their operation.
The cookies used by QUINTELA e PENALVA – Real Estate, in all the channels, do not collect personal information that enable identifying the Users, Service Receivers or Customers, keeping only the general information, namely the form or geographic location of access and the way that the channels are used, among others. The cookies only retain information related to the preferences of the Users and Customers, with personal identifies not being recorded.
The Users, Service Receivers and Customers can, at any time, through the computer application used to browse the internet (browser), decide to be notified of the reception of cookies, as well as block their entry into their system.
In relation to the intended type of purposes, QUINTELA e PENALVA – Real Estate can, whenever justified, use three different types of cookies, in accordance with the following specifications:
(i) essential cookies – some cookies are essential to access specific areas of the channels online, enabling the browsing and use of their applications, such as access to secure areas of the websites, by registering the user – without these cookies, the services requiring them cannot be provided;
(ii) functionality cookies – these cookies enable recalling the user’s preferences in browsing websites online, thus implying that it is not necessary to reconfigure and personalise it each time the user visits;
(iii) analytical cookies – these cookies are used to analyse the way that the users use the websites online, enabling the highlighting of articles or services that could be of interest to the users, monitoring website performance, and knowing which are the most popular pages, what is the most effective method of connection between pages to determine the reason why some pages are receiving error messages – these cookies are used only for purposes of creation and statistical analysis, never collecting information of personal nature.
To these ends, QUINTELA e PENALVA – Real Estate can provide a high quality experience to the Users, Service Receivers or Customers, personalising the information and offers and identifying or correcting any problems that might arise during use.
In relation to the type of validity, there are two types of cookies:
(i) permanent cookies – these cookies are stored in the devices used to access the channels (computers, mobile telephones, etc.), in terms of the electronic application used to browse the internet (browser), being used whenever the Users or Customers revisit any channel – in general, they are used to direct the browsing according to the User or Customer’s interests, enabling QUINTELA e PENALVA – Real Estate to provide a more personalised service;
(ii) session cookies – are temporary cookies, which are generated and only available up to the closing of the session, because the next time the Customer/User accesses her/his browser, the cookies will no longer have been stored – the information obtained enables managing the sessions, identifying problems and providing a better browsing experience.
The Users, Service Receivers and Customers can deactivate part or all the cookies at any time. To do so, they should follow the instructions available on any of the electronic applications used to browse the internet (browser), although the deactivation may imply loss of some website functionalities.
In the context of the direct electronic communication channels, QUINTELA e PENALVA – Real Estate can also use cookies upon the opening of the different electronic communications sent, such as for example newsletters and electronic mail for statistical purposes. These cookies enable knowing if these communications are opened and checking the clicks through links or advertisements within these communications.
Also in this category of cookies, the Users, Service Receivers and Customers can always deactivate the sending of electronic communications through the specific option in their footnote.
Communication of Data to Other Entities
The provision of information or services by QUINTELA e PENALVA – Real Estate to its Users, Service Receivers or Customers through the channels could possibly imply the use of services of outsourced third parties, including entities based outside the European Union, to provide certain services. This could imply the access, by these entities, to the personal data of the Users, Service Receivers or Customers.
Under these circumstances and whenever necessary, QUINTELA e PENALVA – Real Estate will only use outsourced entities that present sufficient guarantees of execution of appropriate technical and organisational measures for the treatment to meet the requirements of the applicable standards. In this case, these guarantees will be formalised in a contract signed between QUINTELA e PENALVA – Real Estate and each of these third party entities.
Data Receivers
Except under compliance with legal obligations, under no circumstances whatsoever will there be communication of personal data of Users, Service Receivers or Customers to third parties that are not outsourced entities, companies of the Quintela e Penalva Group or legitimate receivers. Likewise, no other communication will be made for purposes other than those referred to above.
International Data Transfers
Any transfer of personal data to a third party country or international organisation will only be done in compliance with the legal obligations or assuring conformity with the applicable Community and national legal rules on this matter.
Safety Measures
In view of the more advanced techniques, the costs of application and the nature, scope, context and purposes of the treatment, as well as the risks, of variable probability and severity, for the Users, Service Receivers or Customers, QUINTELA e PENALVA – Real Estate and all their outsourced entities apply the appropriate technical and organisational measures to assure a security level that is adequate to the risk.
For the effect, diverse security measures are adopted, in order to protect the personal data against its dissemination, loss, improper use, alteration, treatment or access in an unauthorised manner, as well as against any other form of unlawful treatment.
The Users, Service Receivers or Customers are exclusively responsible for keeping access codes secret, not sharing them with third parties. They should also, in the particular case of the electronic applications used to access the channels, maintain and conserve the access devices in secure conditions and follow the security practices recommended by the manufacturers and/or operators, namely as to the installation and updating of the necessary security applications, especially, among others, antivirus applications.
When it is necessary to outsource services to third parties that might have access to the personal data of the Users or Customers, the outsourcers of QUINTELA e PENALVA – Real Estate will be obliged to adopt security measures and protocols at the level of the organisation and the necessary technical measures to protect the confidentiality and security of the personal data, as well as prevent unauthorised accesses, losses or the destruction of personal data.
Exercise of the Rights of Ownership of Personal Data
The Users, Service Receivers and Customers of QUINTELA e PENALVA – Real Estate can, as owners of personal data, at any time, exercise their rights of data protection and privacy, namely the rights of access, rectification, deletion, portability, limitation or objection to the treatment, under the terms and with the limitations established in the applicable standards.
Any request of exercise of data protection and privacy rights should be addressed, in writing, by the respective owner, to the Data Protection Office of QUINTELA e PENALVA – Real Estate, pursuant to the procedure and contact described below.
Complaints or Suggestions and Communication of Incidents
The Users, Service Receivers or Customers of QUINTELA e PENALVA – Real Estate have the right to file a complaint, either by recording it in the Complaints Book or by submitting it to the regulatory authorities.
The Users, Service Receivers or Customers of QUINTELA e PENALVA – Real Estate can also send suggestions by electronic mail to the Data Protection Office of QUINTELA e PENALVA – Real Estate.
Communication of Incidents
QUINTELA e PENALVA – Real Estate has implemented an incident management system concerning data protection, privacy and security of information.
If any User, Service Receiver or Customer wishes to communicate the occurrence of any situation of breach of personal data, which cause, in an accidental or unlawful manner, the unauthorised destruction, loss, alteration, disclosure or access to personal data conveyed, kept or subject to any other type of treatment, the person concerned can contact the Data Protection Office of QUINTELA e PENALVA – Real Estate or use the general contacts of QUINTELA e PENALVA – Real Estate described above.
Alteration of the Privacy Policy
In order to assure updating, development and continued improvement, QUINTELA e PENALVA – Real Estate can, at any time, make the alterations deemed appropriate or necessary, to this Policy on Data Protection and Privacy. All alterations are published in the different channels in order to assure transparency and information to the Users, Service Receivers and Customers.
Explicit Consent and AcceptanceThe terms of the Policy on Data Protection and Privacy are supplementary to the terms and provisions, on matters of personal data, established in any specific campaigns for communication and/or disclosure of products or services of QUINTELA e PENALVA – Real Estate that may be carried out.
The free, specific and informed provision of personal data by their owner implies knowledge and acceptance of the conditions contained in this Policy, where it is considered that, due to the fact of using the channels or providing their personal data, the Users, Service Receivers and Customers are explicitly authorising their treatment, in accordance with the rules defined in each of the applicable channels or collection instruments.
Data Protection Office
To exercise any type of data protection and privacy rights or for any issue concerning data protection, privacy and security of information, the Users, Service Receivers and Customers of QUINTELA e PENALVA – Real Estate can contact the Data Protection Office by email to dpo@quintelaepenalva.pt, describing the subject of the request and indicating an electronic mail address, a telephone contact or a postal correspondence address for the answer.