PRIVACY POLICY
1.WHO WE ARE
Decisões e Soluções – Mediação Imobiliária, Lda and Decisões e Soluções – Intermediários de Crédito, Lda jointly use the DS Private brand, a brand of the DS Group, which currently includes several companies and brands linked to the exercise of credit intermediation activities and the provision of consultancy services related to credit contracts, insurance brokerage activities, real estate brokerage activities, construction and building work brokerage activities, buying and selling real estate for resale and renting it out, trading in light motor vehicles and other motor vehicles and motorcycles, new or used, imported or domestic, maintenance and repair of motor vehicles and motorcycles and trading in parts and accessories for motor vehicles and motorcycles, and the (short and long-term) rental of light motor vehicles and motorcycles, without a driver, the provision of travel agency services and management activities, tourism consultancy and travel agency and the provision of organized training activities, constituting itself as a Business Group comprising the controlling company – Decisões e Soluções Holding, Lda, and the controlled companies: Decisões e Soluções – Mediação Imobiliária, Lda; Decisões e Soluções – Intermediários de Crédito, Lda; Decisões e Soluções – Viagens e Turismo, Lda; Decisões e Soluções – Compra e Venda de Automóveis, Lda; Decisões e Soluções – Investimentos Imobiliários, Unipessoal; Decisões e Soluções II – Gestão de Investimentos, Lda; Decisões e Soluções – Formação, Lda.
2. PERSONAL AND MATERIAL SCOPE OF THIS PRIVACY POLICY
With the definition of this Policy, DS Private intends to make known the general rules for the processing of personal data, which are collected and processed in strict respect and compliance with the provisions of the personal data protection legislation in force at all times, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (“GDPR”) and Law 58/2019 of August 8, which ensures the implementation of the GDPR in the national legal order.
This Privacy Policy applies exclusively to the collection and processing of personal data on which Decisões e Soluções – Intermediários de Crédito, Lda, and Decisões e Soluções – Mediação Imobiliária, Lda, assume the role of responsible for the respective processing, within the scope of the pursuit of their corporate purpose and in all situations in which personal data is processed by the DS Group brands, namely through social intervention and development support actions.
The DS Private website may include links to other websites that are not related to it. The provision of such links is made in good faith and in the interest of the user, and DS Private cannot be held liable in any way for the collection, processing and destination of data on these websites, nor for the reliability, accuracy, lawfulness and functionalities available therein, and therefore this Privacy Policy does not apply to them.
The rules set out in this Privacy Policy complement the provisions on the protection and processing of personal data set out in the contracts that Customers/Users enter into with the Group Companies, as well as the rules set out in the terms and conditions governing the offer of the various goods and services and which are duly advertised on the respective websites.
3. CONCEPT OF PERSONAL DATA
Personal data means any information or record of any nature and regardless of its support or format, namely sound, image, writing, chirograph or characteristic relating to an identified or identifiable natural person.
An identifiable person is one who can be directly or indirectly identified by reference to one or more specific personal data, considered alone or in combination with each other, in particular their physical, physiological, psychological, economic, ethnic, cultural, geographical, social identity or their location
4. THE PROCESSING OF PERSONAL DATA
The processing of personal data consists of an operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, namely collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, restriction, erasure or destruction.
5. THE DATA CONTROLLER
The entity responsible for collecting and processing personal data is Decisões e Soluções – Intermediários de Crédito, Lda, NIPC 506742199, and Decisões e Soluções – Mediação Imobiliária, Lda, NIPC 510011519, both private limited companies, with registered offices at Avenida Sacadura Cabral, n.º 3812 4410-099 São Félix da Marinha, which, in the context of its relations with the holder of the personal data, establishes, always on lawful and legitimate grounds, what data is collected, the means of processing and the purposes of such collection and processing.
6. THE DATA PROTECTION OFFICER
The DS Group has appointed a Data Protection Officer (DPO) who is responsible, among other things, for verifying this Privacy Policy, keeping the rules for processing personal data clear and communicating with the supervisory authorities, guaranteeing that all those who entrust DS Private with the processing of their personal data are effectively aware of how it processes them and what rights they have in this regard.
The Data Protection Officer can be contacted directly by letter sent to the following postal address:
- A/C Data Protection Officer DS Group,
Avenida Sacadura Cabral, n.º 3812
4410 – 099 São Félix da Marinha
or to the email address:
7. CATEGORIES OF PERSONAL DATA PROCESSED
Within the scope of its activities, DS Private processes the personal data necessary for the provision of services and/or the supply of goods, or within the scope of social intervention projects, processing data of various categories, according to more detailed information made available in each context, to the holders of personal data, namely through privacy notices and data collection statements. Electronic identifiers may be processed as part of the use of the website, but if they constitute personal data, they will only be processed after informed consent has been given.
If the Client/User has given their prior consent, this may be revoked at any time, without, however, compromising the lawfulness of the processing carried out on the basis of the consent previously given.
8. WHEN AND HOW PERSONAL DATA IS COLLECTED
Processing takes place, as a rule, when the relationship between the data subject and DS Private begins. This relationship may begin with the network of partners with whom the company has contractual relations, and the data subject will be duly informed.
Data may also be collected in the context of browsing DS Private’s website, guaranteeing, where necessary, the prior consent of the data subject, if this is the appropriate basis.
DS Private offers a range of simulators through which you can obtain financial and tax information, including property valuations, and other requests related to the services provided. By submitting a request, you authorize DS Private to process your personal data, including sending it to a partner in order to meet your needs.
DS Private sends newsletters on the basis of the data subject’s consent, proven by a positive and informed act. The sending support service may be provided by a subcontractor located in a third country. However, only if the country has been subject to an adequacy decision or the subcontracting company adopts standard data protection clauses.
Some personal data is indispensable for the performance of the contracted services and if it is missing or insufficient, the product or service in question cannot be provided.
9. PURPOSES OF PROCESSING PERSONAL DATA AND RESPECTIVE LEGAL GROUNDS
In general, the purpose of processing personal data is the implementation of pre-contractual steps and subsequent management of the provision of services, under the contractual relationship established, subsequent compliance with legal obligations arising therefrom and, if necessary, for the purposes of investigation, detection and prosecution of serious crimes.
If personal data is submitted via online forms, DS Private will process the data contained therein on the basis of the data subject’s consent.
Without prejudice to the additional information provided at the time of data collection, DS Private may also, provided it is legally permissible, use the personal data provided by the data subject for other purposes, such as social intervention actions, managing complaints and suggestions, disseminating institutional information and/or publicizing campaigns, promotions and news about products and/or services, as well as conducting market research or satisfaction surveys. In order to fulfill these complementary purposes to the services provided, DS Private may, as appropriate, use informed and free consent or its legitimate interest, taking into account the pre-existing relationship without affecting the rights or freedoms of the data subjects. Whenever DS Private uses its legitimate interest to process personal data, it will inform the data subject in advance, who may exercise their right to object to the processing of their data.
10. SENDING DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
As a rule, DS Private does not send personal data outside the European Economic Area. However, whenever there is such a need, we will only send data to third countries or organizations that have been subject to an adequacy decision by the European Commission. DS Private may also send data to entities located in third countries if these entities adopt the standard data protection clauses adopted by the Commission in force at any given time.
11. DATA RETENTION
The length of time for which personal data is stored and retained varies according to the purpose for which the information is processed. In fact, there are legal requirements that oblige data to be kept for a minimum period of time. Therefore, and whenever there is no specific legal requirement, the data will only be stored and kept for the minimum period necessary for the pursuit of the purposes for which it was collected or subsequently processed, under the terms defined by law.
If DS Private processes personal data based on the consent of the data subject, the data will be kept for as long as the purpose for which consent was given persists or until the data subject revokes consent for the processing of the data for a specific purpose.
12. SECURITY MEASURES
DS Private observes the best security practices, adopting the technical and organizational measures appropriate to the risk, in the field of security and protection of personal data, having for this purpose approved and implemented a demanding plan of compliance with the objectives, the Law and the interest of the holders of personal data, capable of safeguarding the protection of the data that are made available by all those who in any way relate to DS Private, in order to protect them against misuse, disclosure, loss, alteration, unauthorized processing or access, as well as against any other form of illicit processing.
13. EXERCISE OF RIGHTS
DS Private grants all data subjects the right to access, rectify, update, limit and erase their personal data (except when the data is indispensable for compliance with legal obligations to which the data controller is subject), the right to object to its use for commercial purposes and to withdraw consent, without this compromising the lawfulness of the processing carried out under that consent. If you consider it appropriate, you can lodge a complaint with the National Data Protection Commission – Av. D. Carlos I, 134 – 1.º, 1200-651 Lisboa – Tel.: +351 213928400 – Fax: +351 213976832 – e-mail: geral@cnpd.pt.
The owner of the personal data may exercise their rights upon request, supported by a letter sent to the postal address:
- A/C Encarregado de Proteção de Dados Grupo DS,
Avenida Sacadura Cabral, n.º 3812
4410 – 099 São Félix da Marinha
or to the email address:
14. COMMUNICATION OF DATA TO THIRD PARTIES
As part of its business, DS Private may use third parties to provide certain services. Sometimes, the provision of these services implies that these entities process the personal data of Clients/Users on behalf of DS Private. Whenever this occurs, they are contractually obliged to provide a guarantee of reputation and an obligation to develop the appropriate technical and organizational measures to protect the data and ensure that the rights of the data subjects are upheld. In certain circumstances determined by law, certain personal data may have to be communicated to public authorities, such as tax authorities, courts and security forces.
15. USE OF COOKIES
When browsing the DS Private website, cookies are used which, however, do not collect information that identifies the user. General information is collected, such as how users arrive at and use the sites. The information collected is used for the purposes of monitoring the number of visits and statistical studies, as well as to ensure that the site functions correctly and to facilitate navigation and improve the user experience.
The use of cookies allows the navigation of the website to be constantly optimized in order to provide a high quality experience that surpasses the quality obtained on the user’s previous visit.
16. CHANGES TO DS PRIVATE’S PRIVACY POLICY
DS Private reserves the right to make adjustments or changes to this Personal Privacy Policy at any time, and such changes will be duly publicized in the various DS Private communication channels.
17. COOKIE POLICY
a. What are cookies?
“Cookies” are small software tags that are stored on the access equipment via the browser, retaining only information related to preferences and not, as a rule, data classified as personal. Whenever the data collected identifies or makes identifiable users of the website, they will be asked for their consent.
b. What are cookies for?
Cookies are used to help determine the usefulness, interest and number of uses of websites, enabling faster and more efficient browsing by eliminating the need to repeatedly enter the same information.
c. What kind of cookies are there?
There are two groups of cookies that can be used:
Permanent cookies – these are cookies that are stored in the browser on access devices (PC, mobile and tablet) and are used every time you visit the DS Private website again. They are generally used to direct browsing to the user’s interests, allowing us to provide a more personalized service.
Session cookies – these are temporary cookies that remain in the browser’s cookie file until you leave the website. The information obtained by these cookies is used to analyze web traffic patterns, making it possible to identify problems and provide a better browsing experience.
d. For what purposes can we use cookies?
Strictly necessary cookies – These allow you to browse the website and use the applications, as well as access secure areas of the website. Without these cookies, the required services cannot be provided.
Analytical cookies – These are used anonymously to create and analyze statistics in order to improve the functioning of the website.
e. How can you manage cookies?
All browsers allow the user to accept, refuse or delete cookies, and also inform the user whenever a cookie is received, namely by selecting the appropriate settings in their browser. The user can configure cookies in the “options” or “preferences” menu of their browser.
Please note, however, that disabling cookies may prevent some web services from working properly, affecting, partially or totally, navigation on the website.