CHOICE is defined by the highest standards of privacy and security, and we want to ensure that we can rely on your confidence in the use of your personal data.
In compliance with Regulation (EU) no. 679/2016 of April 27th, referred to hereafter in abbreviation as GDPR, we inform you that the treatment of personal data collected for the purposes of contact or in the CHOICE consent form for commercial and MARKETING purposes is the responsibility of “CHOICE II – Sociedade de Mediação Imobiliária, Lda.”, a limited liability commercial company, legal person number 514067209, registered under the same number in the Commercial Registry of Lisbon, with a share capital of €5,000.00 (five thousand euros), with main office at Avenida da Boa Esperança, Loja 4B, 1990-305 Lisbon, referred to hereinafter as CHOICE.
CHOICE respects the privacy of all its customers and undertakes to protect the personal data that each customer decides to share.
We advise you to read the following information carefully and in full.
▪ Personal data – Personal data means any information that, relating to one other, allow identifying or making identifiable a live individual. Different types of information that relate to one other to identify an individual also constitute personal data. Any personal data that has been anonymised, encrypted or pseudonymised that may, in any way, be identifiable again constitutes personal data. An identifiable natural person is one that can be identified, directly or indirectly, in particular by referencing an identifier such as a name, an identification number, location data, an online identifier, or one or more specific factors of the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
▪ Data subject – The data subject is any identified or identifiable natural person whose personal data is processed by the controller.
▪ Data treatment – treatment is any operation or set of operations that is performed on personal data or sets of personal data (whether or not by automated means), such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, dissemination by transmission, disclosure or availability, alignment or combination, restriction, erasure or destruction, regardless of the way it is performed (digital and/or hard copy).
▪ Treatment restriction – The restriction of treatment consists of the identification of personal data stored with the aim of limiting treatment thereof in the future.
▪ Pseudonymisation –Pseudonymisation is the treatment of personal data in such a way that personal data can no longer be attributed to a specific data subject without using supplementary information, provided that such supplementary information is kept separately and is subject to technical and organisational measures to ensure that personal data cannot be attributed to an identified or identifiable natural person.
▪ Controller – the Controller is the person, natural or legal, public or private, public authority, agency or other body that, individually or jointly, determines the purposes and means of treatment of personal data; where the purposes and means of such treatment are determined by Union or Member State law, the controller or the specific criteria applicable to their nomination may be provided for by Union or Member State law.
▪ Subcontractor – The Subcontractor is a natural or legal person, public or private, public authority, agency or other body that treats personal data in the name and on behalf of the data controller.
▪ Cross-border treatment – cross-border treatment of personal data occurs when a data controller or subcontractor treats data in a number of Member States or is likely to affect data subjects in more than one Member State.
▪ Consent – The consent of the data subject is a freely given, specific, informed, and unequivocal manifestation of the will of the data subject – by means of a statement or unequivocal positive act – that the personal data relating to them should be the object of treatment.
DATA COLLECTION METHOD
CHOICE may collect personal data in the context of online service, and personal data may be collected through the contact form.
Personal data may also be requested when telephone or in-person contact is established.
The collection of personal data for the purposes of MARKETING and/or sending a newsletter and/or sending communications of commercial and/or promotional nature by CHOICE is carried out by completing the form available on the website, via personal or telephone contact.
BASIS FOR THE USE OF PERSONAL DATA
In accordance with the GDPR, the collection of personal data is considered lawful only if it is carried out on one of the following grounds:
▪ Consent has been given to the treatment of personal data;
▪ Treatment is necessary for the conclusion of a contract or for its performance;
▪ The treatment is necessary to comply with the legal obligations that CHOICE is subject to;
▪ Treatment is necessary to achieve a legitimate interest that prevails over the right to protection of personal data;
▪ Treatment is necessary so that we can declare, enforce or defend a right in judicial proceeding against them, us or a third party.
As such, CHOICE, in strict compliance with the GDPR, may collect personal data to sign and perform a contract, namely, purchase, sale or lease of property or mediation services.
For the purposes of MARKETING and/or sending a newsletter and/or sending communications of a commercial and/or promotional nature, CHOICE only treats personal data with prior, free and informed consent.
CONSENT OF MINORS
CHOICE may only process the personal data of individuals under the age of 13 (thirteen) years, when prior consent of the holders of parental responsibilities of the minor has been procured.
The identification of the quality of the holder of parental responsibilities of the minor will be investigated by the management/administration of CHOICE, or by whom the latter appoints, through verification and review of relevant documentation and using the technology available.
Upon prior, free and informed consent, the CHOICE website shall create and write to the data subject’s computer text files (cookies), for the purpose of greater ease and speed of use of the site to customise the data subject’s preferences.
The use of cookie technology is accepted by most browsers, but the data subject can erase them or automatically block them.
The data subject may configure the browser in the “Help” menu.
Restricting the use of this technology may limit the access and functionality that exist on the CHOICE website.
CHOICE advises you to check the privacy policies of these sites before disclosing any personal data.
PURPOSES OF PERSONAL DATA
The personal data provided by the data subject in connection with the conclusion of a contract or its performance may be used for the following purposes:
▪ Establishing contact;
▪ Sending e-mails related to real estate mediation services;
▪ Signing contracts for purchases, sales and/or leasing of real estate;
▪ Responding to requests or questions.
▪ Requesting opinion on CHOICE through satisfaction questionnaires in the scope of the service provided;
The personal data provided by the data subject for MARKETING purposes, obtained upon prior, free and informed consent, may be used for the following purposes:
▪ Communication of special offers, events and commercial promotions;
▪ Sending newsletters.
TYPES OF DATA COLLECTED
Through the contact form, CHOICE proceeds to the treatment of the following personal data:
▪ Telephone/Mobile phone;
For the purposes of MARKETING and/or sending a newsletter and/or sending communications of commercial and/or promotional nature, CHOICE proceeds to the treatment of the following personal data:
▪ Telephone; and
Only the data referred to above will be used for MARKETING purposes and/or for sending a newsletter and/or sending communications of commercial and/or promotional nature by CHOICE.
SECURITY OF YOUR PERSONAL DATA
CHOICE uses authentication and encryption methods and tools to ensure that it helps protect and maintain your data safe, and the integrity and availability of your personal data.
Although it is impossible to ensure full security of data transmitted via the Internet or website, CHOICE works hard for personal data to be kept as secure as possible.
Personal data is protected and maintained in physical, digital and procedural security.
To safeguard the integrity and security of personal data, CHOICE uses the following security measures:
▪ Access log;
▪ Access limitation;
▪ Access passwords;
TIME OF PRESERVATION OF YOUR PERSONAL DATA
CHOICE may only process personal data for the period necessary for the purpose for which it was collected.
The personal data collected in completing the online contact form or when made by telephone or in-person contact may be handled by CHOICE during the entire period of communication in the legitimate interest of CHOICE and/or performance of the contract and/or when necessary for the fulfilment of legal obligations.
For the purposes of MARKETING and/or sending a newsletter and/or sending communications of a commercial and/or promotional nature, personal data will be processed up to a maximum of 4 (four) years, counted from the collection of your consent.
With the approximation of the deadline for the use of this personal data, CHOICE may report the situation and request new consent.
DESTRUCTION OF PERSONAL DATA
Once the maximum period of treatment has been reached, personal data will be safely destroyed, and data recovery is impossible.
Once you have exceeded the maximum period of treatment of personal data provided in the scope of MARKETING and/or sending a newsletter and/or sending communications of commercial and/or promotional nature, CHOICE will proceed to total destruction of personal data.
SHARING PERSONAL DATA
Personal data made available to CHOICE by the data subject may, in certain circumstances, be shared with subcontractors. These service providers are hired for limited purposes, in particular as regards online platform, computer technical support, MARKETING, communications through e-mail.
Consent may be withdrawn or amended at the request of the data subject.
This process does not involve costs and can be carried out at any time.
After consent is withdrawn, CHOICE shall carry out no further communication for the purpose of MARKETING and/or sending a newsletter and/or sending communications of commercial and/or promotional nature.
The personal data will be destroyed, with no possibility of recovery.
If you wish to withdraw consent submitted to CHOICE, please send an e-mail to firstname.lastname@example.org with your request.
The last statement of consent (either withdraw or amend) will prevail over all others previously submitted.
RIGHTS OF DATA SUBJECTS
CHOICE, in accordance with the GDPR, informs that the data subject has, depending on the context, the right to information, the right to access data, the right to consult the data collected, the right to rectification of the data collected, the right to restriction of treatment, the right to erasure of data, the right to oblivion, the right to data portability and the right to oppose the collection of data.
The exertion of these rights by the data subject in respect of personal data processed in the context of drafting a contract and/or during its performance, when its treatment is necessary to comply with the legal obligations that
CHOICE is subject to or when it is intended to safeguard the public interest, may be limited.
Therefore, the data subject may ask CHOICE for:
▪ Additional information on the use we make of your personal data;
▪ A full or partial copy of any personal data submitted by you;
▪ That your personal data be provided to another controller, at your request;
▪ That changes or corrections be made to the personal data submitted by you;
▪ Deletion of any personal data submitted by you;
▪ That the use of your personal data be limited or suspended until the complaint submitted to the Data Protection Authority is
The data subject may exert their rights by written contact with CHOICE by completing the contact form available on the website or through any other means provided by CHOICE, namely through the e-mail email@example.com.
CHOICE undertakes to proceed swiftly in the review of your application and respond within 1 (one) month.
Address: Avenida da Boa Esperança, Loja 4B, 1990-043 Lisbon
Telephone: (+351) 210 970 617
If the data subject is dissatisfied with the use of their personal data by CHOICE or for the exertion of a right, the data subject has the right to submit their complaint to their Data Protection Authority (DPA):
National Data Protection Commission
Rua de São Bento, 148, 3º, 1200-821 Lisbon
Tel.: +351 213,928,400 | Fax: + 351 213,976,832 | E-mail: firstname.lastname@example.org