PRIVACY POLICY

IAD Portugal, SA, a public limited company, with its registered office at Avenida da Boavista, no. 934, 4100-112 Porto, registered under the corporate person identification number 513 467 408, holder of License AMI 11220, issued by IMPIC, I.P., hereafter "iad Portugal" or "iad")is, as the data controller, obligated to process your personal data when you browse the website https://www.iadportugal.pt/ website (the “Website”) and interact with it, in particular when you complete an online form.

This data processing can be carried out by iad Portugal depending on the purposes involved:

- As the sole data controller ;

- As a joint controller with an iad agent.

This privacy policy provides you with the information required by the applicable legislation regarding the collection and processing of your personal data, in accordance with Law No. 58/2019, of August 8, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("GDPR") (collectively referred to as "Applicable Legislation").

Furthermore, iad Portugal uses cookies to make the Website work. To find out more, please refer to the “Cookie Management” policy.

For more general information about the protection of personal data, please visit the website of the For more general information on the protection of personal data, you can consult the website of the National Data Protection Commission: www.cnpd.pt.

This privacy policy may be amended. You should therefore consult it regularly.

DATE OF LAST UPDATE OF THIS PRIVACY POLICY: FEBRUARY 2023

1. Categories of data concerned

• Personal data that you directly provide to iad Portugal

You may need to provide iad Portugal, and, where appropriate to agents, with information about you in your various interactions with this company.

This mainly includes contact details such as first name, last name, title, email address and telephone number, as well as data about your project.

• Data that iad Portugal collects indirectly

iad Portugal collects technical browsing and interaction data on the Website (in particular, via cookies), as well as geolocation data if you have accepted this.

2. Purposes, legal basis and retention period

iad Portugal collects and processes your personal data for the purposes identified in the table set out below, which also explains the legal basis for the processing and the retention period for each purpose.

Your data may be retained, at the end of the periods identified below, to allow iad Portugal to fulfil its statutory or regulatory obligations and assert its rights for any appropriate period with regard to the applicable limitation period. In such cases, the processing operations are performed on the basis of compliance with statutory obligations or the legitimate interests of iad Portugal.

	Purposes of the processing operations	Legal basis	Retention period
1.	Creating and managing your account, if you decide to create an account, particularly for managing subscriptions and alerts created by you.	Legitimate interests	3 years from collection or last contact with the data subject.
2.	Responding to your requests to download brochures and guides, as well as for requests for responses to the questionnaire assessing your suitability for the real estate market.	Legitimate interests	3 years from collection or last contact with the data subject.
3.	Responding to requests submitted by you through online forms on the Website and putting you in contact with an iad agent. The functioning of iad Portugal is based, essentially, on its network of agents, as Real Estate Agents. Consequently, any contact request, whatever your intention (to buy or rent a property, become a referrer, become a consultant, etc.), passes through direct contact with an iad consultant. This processing of your personal data is therefore carried out by iad Portugal jointly with our agents.	Legitimate interests	3 years from collection or last contact with the data subject.
4.	Sending newsletters and other commercial materials, as well as managing subscriptions to them, if you sign up for those services.	Consent	3 years from collection or last contact with the data subject.
5.	Monitoring your satisfaction with the use of the services.	Legitimate interests	3 years from collection or last contact with the data subject.
6.	Managing your requests to exercise rights.	Compliance with statutory obligations	Time taken to process the request. Deletion of the proof of identity document, if requested, as soon as the checks have been completed.

3. Recipients of your data

The data collected and processed by iad Portugal for the above-mentioned purposes may be communicated, as needed for your file:

- to its customer, marketing/communication and technical services;

- to its administrative and legal departments if necessary ;

- to iad Portugal agents in the context of responding to requests you have made via online forms on the Site;

- to the administrative or judicial authorities authorised under Portugese law if necessary.

Personal data concerning you may be transmitted to iad Portugal's commercial partners, in connection with your projects, offering in particular services of :

- rental management ;

- home staging ;

- banking and payment services brokerage

- insurance brokerage;

- concierge services.

iad Portugal's commercial partners are contractually obliged to protect the personal data transmitted to them in this context.

iad Portugal also needs to grant access to your data to the service providers it instructs. These service providers may only use the data for the purposes of performing their services and they have a contractual obligation to protect the personal data transmitted to them in this context.

iad Portugal does not sell your information to any business partner or service provider.

4. Transfers outside the European Union

Your data may be sent to some of the iad service providers located outside the European Union.

These transfers are governed by standard contractual clauses or by binding corporate rules (BCR), depending on the provider, and supplemented where necessary by additional measures. You may request additional information and/or a copy of these clauses by emailing iad Portugal at privacy@iadgroup.pt .

5. Your rights

You may change or delete your personal data directly, in your personal area.

You may exercise the following rights for your personal data, on the terms and within the limits set out in the Applicable Regulations:

- right of access and information: you have the right to be informed about how your personal data is processed in a concise, transparent, intelligible and easily accessible form. You also have the right to obtain confirmation as to whether or not your personal data is being processed and, where applicable, access the data by requesting a copy.

- right to rectification: you have the right to have incomplete and/or inaccurate personal data corrected and/or completed.

- right to withdraw your consent: when the processing of your personal data is based on your consent, you may withdraw your consent at any time.

- right to object: you may object to the processing of your personal data for reasons relating to your particular situation.
In some cases, this right cannot be exercised, for example if there are compelling legitimate grounds or for the establishment, exercise or defence of legal claims.

- right to portability: you have the right to receive the personal data you provided to iad Portugal, to allow you to transfer it to another data controller. This right only applies if the processing of your personal data is based on your consent or on the performance of a contract and the processing is performed by automated means.

- right to restrict the processing of your data: in some cases, you may restrict the processing of your personal data. This right allows you to temporarily block the use of some of your data, if the statutory requirements are met.

- right to erasure: in some cases, you may request the erasure of your personal data (for example, if the personal data is too old and is no longer necessary).

- right to obtain human intervention following profiling or an automated decision: when profiling or an automated decision is used, you may request human intervention for the assessment.

- right to give “post-mortem” instructions: you may decide what is to happen to your personal data after your death.

If you wish to exercise one or more of these rights, you should send the corresponding request to the data protection officer using the contact details set out in the “Data protection officer” section below.

Similarly, for any request or complaint concerning the processing of your personal data, please contact the I@D Portugal data protection officer.

If no response is received from iad Portugal or if a dispute persists, you may in any event lodge a complaint with the appropriate supervisory authority (the National Data Protection Commission (CNPD) in Portugal).

6. Data protection officer

You may contact the data protection officer appointed by iad Portugal at the following address:

- By email: privacy@iadgroup.pt

- by post to the following address: iad Portugal, SA, Legal Department, Avenida da Boavista, n.º 934, 4100-112 Porto, for the attention of the Data Protection Officer.

7. Security

iad Portugal implements various measures to protect your data from any misuse. A firewall protects the infrastructure of the public website you access and authentication and passwords are encrypted.

However, please note that, although iad Portugal implements appropriate technical and organisational means to prevent any unauthorised or unlawful processing of personal data and any loss, damage or accidental destruction of personal data, the absolute security of personal data cannot be guaranteed.