Privacy Policy of Casa & Key Algarve

Effective Date: February 2, 2024

Casa & Key Algarve respects your privacy and security and is committed to protecting your personal data. This privacy policy aims to inform you on how we manage your personal data, about your data and privacy rights, and how you are protected.

1. WHO WE ARE & OUR POLICY PURPOSE

Casa & Key Algarve and its brands are wholly owned and licensed by Elizabeth Freitas Pimenta Unipessoal LDA. A real estate agency based in Portugal, in the Algarve.

This privacy policy aims to provide you with information on how Casa & Key Algarve and its brands collect and process your personal data through your use of this website and/or our services, including any data you may provide through this website when you sign up for our newsletter, purchase, or use of our services.

Data Controller

Elizabeth Freitas Pimenta Unipessoal LDA consists of the following trade names:.

Casa & Key Algarve: www.casaandkeyalgarve.com

Casa & Key Algarve Holiday Rentals: www.rentals.casaandkeyalgarve.com

This privacy policy is issued on behalf of each trade name belonging to Elizabeth Freitas Pimenta Unipessoal LDA., the data controller of the above-noted trade names.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this policy. If you have questions, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

• Casa & Key Algarve
• DPO: Elizabeth Freitas Pimenta 
• Email:info@casaandkeyalagrve.com
• Registered address: Rua Drummond De Andrade Lote 26 1F Portimão 8500-610
• Telephone number: (+351) 966 509 048

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us at: info@casaandkeyalgarve.com

Third-party links

Elizabeth Freitas Pimenta Unipessoal LDA’s websites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. HOW YOUR PERSONAL DATA IS COLLECTED

To ensure we can provide you with the best services, information, and value for your property investments, we use different methods to collect data from and about you, including:

1. Direct interactions. You may give us data through a personalised consultation, by filling out forms, or by corresponding with us by mail, phone, email, or otherwise. This includes personal data you provide when you:
• Request information about a property(s) or service(s) by completing a form online;
• Select us as your mediation or marketing partner and have an account with us;
• Request property and supporting service marketing to be sent to you;
• Subscribe to our services or publications;
• Enter a promotion or survey;
• Provide us feedback.
2. Automated technologies, interactions, and cookies. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites utilising our cookies.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as:

• Analytics providers such as Google, based outside the EU;
• Social media services;
• Advertising networks;
• Search information providers

3. DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information that can directly and personally identify an individual data subject. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

1. Identity Data: first name, maiden name, last name, username or similar identifier, marital status, title
2. Contact Data: billing address, delivery address, email address and telephone numbers
3. Marketing and Communications Data: Preferences for receiving marketing from us and our third parties
4. Transaction Data: details about payments to and from you and other details of products and services you have purchased from us
5. Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to interact with or access this website
6. Profile Data: your client identification number, purchases or orders, interests, preferences, feedback and survey responses
7. Usage Data: information about how you use our website, products, and services.

We may also collect, use, and share aggregated data, such as statistical or demographic data, to aid in improving the products and services we provide. Aggregated data may be derived from your personal data, but when sanitised for aggregation purposes, it will not include details that would directly or indirectly reveal your identity, so it is not considered personal data.

Failure to provide personal data: where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may need to cancel a service you have with us; we will, however, notify you should this be the case.

4. HOW WE USE YOUR PERSONAL DATA

We may use your personal data in the following circumstances:

• Where we need to perform a contract we enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests
• Where we need to comply with a legal or regulatory obligation

We rely on consent as a legal basis for processing your personal data in relation to contacting you by phone, sending direct marketing communications to you via email, or other means. Where you have placed a request with us by completing a form or purchasing our services, we consider that you have an interest in those products or services and similar products or services offered by or through us or our partners, and we are permitted under data protection legislation to send those communications to you.

We comply with data protection legislation in our electronic marketing and you have the right to withdraw consent to marketing at any time by emailing us at: info@casaandkeyalgarve.com

Marketing

Our goal is to provide you with the best options possible when purchasing your property abroad. Our tailored model for work purchasing service ensures that you are able to invest wisely. We strive to provide you with choices regarding certain personal data uses, particularly in marketing and advertising:

Promotional offers from us - we may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, placed a request with us, purchased goods or services from us, if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing - When you request information on products, services or properties provided by our commercial partners, we will pass your personal data on to them and they may contact you regarding those products, services or properties. We will get your express opt-in consent before we share personal data provided for that purpose with any other company or organisation (other than ourselves) for marketing purposes.

Opting out - At any time you can request that we, or third parties, stop contacting you, sending you marketing messages or material. When you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Change of purpose - We will only use your personal data for the purposes for which we collected it, unless we reasonably consider it useful or compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in section 4 above.

• Internal Third Parties
• External Third Parties
• Specific third parties such as commercial partners and legal entities
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. DATA SECURITY

We continually endeavour to ensure security measures are in place to prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we are required to keep information on our clients for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Request erasure below for further information.

8. YOUR LEGAL RIGHTS

You have the right to:

1. Access - to your personal data. This enables you to receive a copy of the personal data we hold about you and to check it is correct and we are lawfully processing it. For security purposes you may be asked to verify your identity before your data is released.
2. Correction - of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. Verification of your identity and accuracy of the new data you provide to us may be required.
3. Erasure - of your personal data. Enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object - to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Restrict processing - this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Transfer - your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent - at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To find out more about these rights, please refer to section 9. If you wish to exercise any of the rights set out above, please contact us at: info@casaandkeyalgarve.com.

Data access fees

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with requests under abusive circumstances.

Authentication requirements

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

Time to respond will be dependant on the request and urgency of the situation. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In the event of an urgent situation or breach we will endeavour to inform or respond to you within 72 hours or as soon as practicable.

9. LAWFUL BASIS

Legitimate Interest means the interest of the business(s) and in conducting and managing the business to provide you the best service/product and experience to facilitate your property search, purchase and investment(s). We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Brands/trade names controlled by Elizabeth Freitas Pimenta Unipessoal LDA., acting as joint controllers.

External Third Parties

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities, who may act as processors or joint controllers, based in Portugal (or abroad, in relation to properties, products or services located abroad) who require reporting of processing activities in certain circumstances.

• Commercial partners providing processing, technical and security services or products, services or information related to properties, including real estate agents, property developers, private sellers, lawyers and notaries, mortgage and financial services companies, event organisers, media and marketing companies.