Privacy Policy

This Privacy Policy aims to provide all relevant information on data collection activities and the processing of your personal data when using this website, including data that may be provided to us when subscribing to our newsletter, by requesting information about our projects or services, or by participating in a survey and/or competition that may be launched.

This privacy policy should be read in conjunction with, and in addition to, other information or privacy notices that we provide in specific cases.

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

1. WHO ARE WE?

CEDILHA GENTIL – UNIPESSOAL LDA., a limited liability company incorporated under Portuguese laws, with registered office at Rua da Moeda, n.º 4, 1200-275 Lisbon, registered at the Conservatória do Registo Comercial Lisboa under the registration and legal person number 516117564, with a share capital of € 100.00 (“CEDILHA GENTIL”) whose corporate purpose is the purchase and sale of properties and resale of those acquired for the same purpose, real estate development, consultancy, management and support of real estate projects, real estate product marketing, projects and implementation of real estate investments, as well as the management of own and third-party properties; rental, administration of condominiums, exploration 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

CEDILHA GENTIL is the entity responsible for processing the personal data it collects, and the data subjects may contact us to clarify any doubts they may have or to exercise their rights through the following contacts:

CEDILHA GENTIL

Registered Office: Rua da Moeda, 4, 1200 – 275 Lisboa

NIPC: 516117564

Phone: (00 351) 213461024

E-mail: cp@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 data elements that can identify a specific person.

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

Identification data, namely and, where applicable, name, title, date of birth, and gender;
Contact details, namely, address, email address and telephone numbers;
Financial and billing data, namely and, when applicable, Taxpayer Number and International Bank Account Number (IBAN);
Technical Data, namely 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;
Website usage data, namely, information on how our website, products and services are used;
Communication and marketing data, namely and, where applicable, the user’s preferences concerning communication and marketing.

We do not collect any particular categories of your personal data, namely health data, biometric data, genetic data, data relating to 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 can be collected in different ways, firstly, by direct interaction with the data subject, providing his or her data by filling out forms or by contacting us by post, telephone, email or by other means, namely, when requesting information about our real estate products, when subscribing to our news, newsletters or when requesting marketing communications or other interactions within the scope of our activity. We may also collect personal data from public sources or third parties authorized to share such data.

It is also possible to collect data automatically as part of the interaction with this website, namely technical data and website usage data.

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

Personal data is only processed when it is necessary for us to fulfil legal obligations that apply to us or for the performance of a contract or pre-contractual steps.

If we have a legitimate interest in processing information, we may do so, provided that, in each case, we comply with applicable law and the rights of the data subject; this may occur, namely, to communicate with customers; recruitment of employees; fraud prevention and investigation; information on investment projects; clarification of complementary information; inquiries regarding investment opportunities.

Whenever none of the other conditions of legitimacy can support the data processing operation, we shall only process the information if we have obtained the data subject’s consent to process their personal data for specific, explicit and legitimate purposes.

5. A. Follow-up contacts after form submissions When you complete forms on this website and request information (for example, about projects, services, visits or proposals), we may contact you to follow up on your request using the contact channels you provide — email and/or phone call. This processing is necessary for pre-contractual steps and/or is based on our legitimate interest in responding to requests and providing information, under Article 6(1)(b) and (f) GDPR. These contacts are not promotional in nature and will cease once your request has been concluded or upon expiry of the applicable retention period.

5. B. Marketing communications CEDILHA GENTIL will only send electronic direct marketing communications (for example, newsletters, campaigns or invitations) if we have your prior, specific and informed consent, collected separately from the rest of the form content (for example, via an unticked opt-in checkbox). You may withdraw your consent at any time via the unsubscribe link included in every communication or by contacting us using the details in Section 2. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

6. INTERNATIONAL TRANSFERS AND DATA ASSIGNMENT

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

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

7. DATA SECURITY

Your personal data is important to us, and for that reason, we have implemented adequate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed, 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 that 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 and only where their contact with personal data is justified within the scope of their functions.

8. MAXIMUM RETENTION PERIOD OF PERSONAL DATA

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

To determine the appropriate period for retaining personal data, we consider the amount, 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 them and whether we can achieve these purposes by other means, and the 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 details) for tax, financial, auditing and record–keeping purposes for a minimum period of 10 years from the moment 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 HOLDER AND RESPECTIVE EXERCISE

In certain circumstances and under data protection law, the data subject has rights concerning his or her personal data.

For your information, the data subject may, at any time, but always considering the actual situation and the respective legal limits, exercise the following rights with any Data Controller:

Submit a request for access to that information. The data subject has the right to obtain confirmation that their data is, or is not, being processed and, if this is the case, the data subject must have access to their personal data and the information provided for by law.
Submit a request for rectification of data held concerning the data subject if these data are inaccurate or incomplete.
Submit a request for deletion of your personal data, without undue delay, whenever one of the following reasons applies: Personal data are no longer necessary for the purposes that justified the collection or processing; or Objection to processing or lack of overriding legitimate interests justifying processing; or Withdrawal of consent by the data subject for data processing (in cases where processing is based on consent) and no other legal basis for processing.
Submit a request to restrict the processing of your personal data if one of the following situations occurs: Contesting the accuracy of personal data for a period sufficient to allow verification of its accuracy; or The processing of data is lawful and the data subject opposes the deletion of personal data and requests, instead, restriction of use; or 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 the context of legal action; or Where the data subject has objected to processing, until it is verified whether the legitimate grounds of the controller override those of the data subject.
Object to the processing of your personal data in cases where data processing is carried out for the legitimate interests pursued by us, or when data is processed for direct marketing purposes.

If the data subject intends to exercise any of the above rights, he or she must contact us using the contact information previously indicated. We 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 those 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 submitted request is particularly high or if the data subject has submitted several requests. Without prejudice to the foregoing, we will always keep the data subject informed if the response time is extended.

The exercise of your rights does not involve the payment of any fee. However, if your request is unfounded, repetitive, or excessive, we reserve the right to charge a reasonable fee or, alternatively, refuse your request.

Addition — Right to object to direct marketing: You also have the right to object, at any time, to the processing of your data for direct marketing purposes, in which case we will cease processing your data for that purpose. We provide simple mechanisms to exercise this right in every communication.

We remind you that you have the right, at any time, to file a complaint with the Portuguese Data Protection Authority (CNPD), 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. UPDATE AND LINKS TO THIRD-PARTY WEBSITES

This privacy policy can be updated at any time, the latest version being the version 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 other than this website.

11. Cookies.

This website uses cookies. When you visit the website, we may place small pieces of information called “cookies” on your device. Cookies are stored by the browser on the hard drive.

Within the scope of this website, we distinguish two types of cookies:

Technical cookies, i.e., cookies that are necessary for the proper performance of this website; and Performance and tracking cookies, i.e., cookies that collect information about the user and improve performance, but which are not necessary for proper operation (to be reviewed before the site goes live and to create a cookie policy depending on the cookies used – we also recommend a pop–up control for managing cookie settings).

In general terms, cookies help us in several ways: we use cookies to better organise the website or information about our products and to have this information adapted to the interests or preferences of the user. Cookies allow us to know who has visited these pages and what content has been visited, to assess the frequency of visits to certain pages, to determine favourite areas of the website and to direct its use in general terms.

The user can manage cookies by selecting the corresponding option in their browser. However, we warn you that, in the event of deactivating or refusing cookies, some parts of this website may become inaccessible or not operate correctly.