Privacy and Data Protection Policy

The General Data Protection Regulation (GDPR) enforces the application of the transparency principle. Within the framework of existing contractual or commercial relationships, we provide information to the data subject about the processing. In this context, it is up to FPE (PT)3 Residential, S.A. to provide you, in your capacity as data subject, with the following information in relation to the processing of your personal data.

1. Context in which the processing of Personal Data takes place:

This Privacy and Data Protection Policy, hereinafter “Privacy Policy” or just “Policy”, applies generically to the collection and processing of personal data provided by users who access the “Entrecampos Residences” landing page or other means of collection, namely, data collected through forms, documents or other means intended to allow contact with the FPE (PT) 3 RESIDENTIAL, S.A., a Portuguese company, legal person no. 516 243 519, registered at the Companies’ Registry Office of Lisbon under the same number, with registered office at Largo do Calhariz, nr 30, 1249-001 Lisbon, Portugal, with the share capital of 2.000.000,00 EUR, hereinafter referred to as FPE (PT)3, also applying to the exercise of rights, by the user, in relation to this data, under the terms of the applicable legislation.

This Policy is of a general nature, so the information provided in it may be complemented or removed, in whole or in part, by other policies, notices or more specific information that may have been or will be made available in the context of certain types of processing of personal data.

2. Controller and Data Protection Officer:

Controller: FPE (PT) 3 RESIDENTIAL, S.A.

The Data Protection Officer appointed by FPE (PT)3 may be contacted, in writing, at:

Data Protection Officer – Largo Calhariz 30, 1200-086 Lisboa;
epdp@fidelidade.pt

3. Processing of personal data

The data provided in the relationship established with FPE (PT)3 are treated in accordance with the legally applicable precepts, namely:

processed lawfully, fairly, and in a transparent manner;
collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

4. Purposes and legal basis for processing personal data and criteria for setting the respective retention periods

Personal Data is processed for the following purposes based, in each case, on the grounds indicated in the table below and are kept for the time strictly necessary to pursue the same purposes, according to the deadlines (or criteria adopted to define them) indicated in the same table:

Purpose	Legal Basis	Storage Period
Business relationship management	Necessary for taking steps prior to entering into a contract Legitimate interests within the scope of the development of commercial activity	12 months after last communication
Marketing	Consent	Up until the end of a period of one year following the end of the contractual relationship.
Compliance with Legal Obligations, including in relation to the Authorities (namely supervisory, regulatory, fiscal and court authorities), management control and actions to prevent and combat fraud.	Compliance with a legal obligation Legitimate interests of controlling the activity of the data controller, including prevention of losses due to fraud For the declaration, exercise or defence of rights in judicial proceedings	Legal time limit applicable at any time for each Legal obligation to be complied with Up until the end of the limitation period or until the exercise of rights expires

5. Data communication

The Personal Data will be processed by real estate brokers to which FPE (PT)3 has outsourced its processing, who contact the data subjects through the contacts provided by themselves on this landing page or other means of collection.

6. Rights of the data subject

The Data Subject is entitled to request from the FPE (PT)3, by means of a written request sent to the Data Protection Officer:

Access, in the terms and conditions provided in law, to Personal Data relating to him which is processed by FPE (PT)3;
Correction or updating of Personal Data relating to him which is incorrect or out of date;
Processing of missing Personal Data when that data proves to be incomplete;
Deletion, in the cases specifically provided for in law, of Personal Data relating to him;
Restriction, once the conditions provided for in law have been confirmed, of processing of Personal Data relating to him.

The Data Subject is also entitled to submit a written request to the Data Protection Office in order to:

Withdraw the consent provided, when the processing of data is based only on consent;
Oppose processing for reasons related with his particular situation, when the processing of data is based on a legitimate interest of the controller.
Receive from the FPE (PT)3, in a commonly used machine-readable digital form, the personal data relating to him and which has been supplied by him, processed by automatic means on the basis of:

(a) consent provided by the data subject or, (b) a contract entered into,

and may request, in writing, its transmission directly to another controller, whenever this proves technically possible.

The Data Subject may also request more detailed information from the Data Protection Officer, namely on the purposes, grounds of lawfulness and storage periods, and may also present complaints about the way his Personal Data is processed, without prejudice to also being entitled to do so to the competent Authority.

7. Personal data security

FPE (PT)3 adopts appropriate technical and organizational measures to protect Personal Data against accidental or unlawful loss, destruction, or damage, as well as to ensure that the data provided is protected against access or use by unauthorized third parties.

8. Changes to the Privacy and Data Protection Policy

The present Privacy Policy may be amended periodically, through publication on the Landing page, without the need for prior and express consent from the data subject.

Any significant changes will be announced with the degree of publicity corresponding to their relevance, either by highlighting in the online publication, or, if the relevance justifies it, by means of individual communication to the data subjects.