Privacy Policy

1. Data Controller

FOZ VILLA is the data controller for the personal data collected through the website fozvilla.pt, its subdomains and associated communication channels.

For the purposes of the General Data Protection Regulation (GDPR — Regulation EU 2016/679) and Law No. 58/2019, of 8 August, FOZ VILLA acts as the data controller for the personal data described in this Policy.

2. Personal Data We Collect

FOZ VILLA collects personal data that you provide directly, as well as data collected automatically when using our website. The collected data includes:

Data provided directly:

• Full name
• Email address
• Phone number / WhatsApp
• Property location (for valuation requests)
• Property information (type, region, features)
• Messages and communications sent through our forms
• Curriculum Vitae and professional information (in the context of applications)
• Content of conversations with the Villas AI assistant, including any contact details you provide in that conversation

Data collected automatically:

• IP address and device information
• Browsing data and pages visited
• Session cookies and preferences
• Website performance data (Google Analytics)

3. Purposes and Legal Basis of Processing

We process your personal data for the following purposes and based on the following legal bases:

• Response to contact and valuation requests — Legal basis: pre-contract or contract execution (Art. 6(1)(b) GDPR)
• Job application management — Legal basis: explicit consent of the applicant (Art. 6(1)(a) GDPR)
• Newsletter sending — Legal basis: consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time.
• Website analysis and improvement — Legal basis: legitimate interests of FOZ VILLA (Art. 6(1)(f) GDPR)
• Compliance with legal obligations — Legal basis: legal obligation (Art. 6(1)(c) GDPR)
• Handling conversations with the Villas AI assistant — Legal basis: performance of pre-contractual steps taken at your request and legitimate interest in following up on your enquiry (Art. 6(1)(b) and (f) GDPR)

4. Retention Period

We retain your personal data for the time strictly necessary to fulfill the purposes for which it was collected:

• Valuation and contact requests: up to 2 years after the last contact, unless there is an ongoing contractual relationship
• Applications: up to 1 year after the final recruitment decision, unless consent is given for a longer retention period
• Newsletter: until subscription is cancelled
• Fiscal and contractual data: 10 years, in accordance with applicable tax and commercial legislation
• Browsing data (cookies): in accordance with the applicable cookies policy, generally up to 13 months
• Conversations with the Villas AI assistant: conversations are kept for 3 days so that a consultant can review your enquiry. After that they are deleted and only counts remain, with no data that identifies you

5. Data Sharing with Third Parties

FOZ VILLA does not sell, rent or transfer your personal data to third parties for commercial purposes. We may share personal data with:

• Technology service providers that support us in managing the website, CRM and communications (Google, Meta/Facebook), always under a confidentiality agreement and in compliance with the GDPR
• Real estate partners, exclusively when necessary to complete a transaction and with your prior knowledge
• Public authorities, when legally required to do so

All FOZ VILLA subcontractors provide sufficient guarantees of implementation of appropriate technical and organizational measures to protect personal data.

6. International Transfers

Some of our service providers (such as Google and Meta) may process personal data outside the European Economic Area. In these cases, we ensure that such transfers are carried out under adequate legal mechanisms, namely the Standard Contractual Clauses approved by the European Commission.

7. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access — obtain confirmation as to whether your data is being processed and access it
• Right of rectification — correct incomplete or inaccurate data
• Right to erasure — request deletion of your data (“right to be forgotten”), under the conditions provided for in the GDPR
• Right to restriction of processing — request suspension of processing in certain circumstances
• Right to portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — at any time, without affecting the lawfulness of processing previously carried out

To exercise any of these rights, contact us at FozVilla@fozvilla.pt. We will respond within a maximum of 30 days.

You also have the right to lodge a complaint with the National Data Protection Commission (CNPD) at www.cnpd.pt.

8. Cookies and Similar Technologies

Our website uses cookies and similar technologies to improve your browsing experience and for analytical purposes. The cookies used include:

• Strictly necessary cookies — essential for the operation of the website, do not require consent
• Analytical cookies — Google Analytics, to understand how visitors use the website (require consent)
• Marketing cookies — Meta Pixel (Facebook), for conversion measurement and targeted advertising (require consent)

You can manage your cookie preferences through your browser settings or through our cookie consent banner. Refusing non-essential cookies does not affect the main functionality of the website.

9. Data Security

FOZ VILLA implements appropriate technical and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, disclosure or any other unauthorized processing, including:

• Encrypted data transmission via SSL/TLS (HTTPS)
• Restricted access to personal data on a need-to-know basis
• Intrusion monitoring and detection systems
• Regular backups and data recovery procedures

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify you within the time limits and terms provided for in the GDPR.

10. Minors

The fozvilla.pt website is not directed at children under 16 and we do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will proceed to delete it immediately. If you are a parent or legal guardian and become aware that a minor has provided us with personal data, please contact us at FozVilla@fozvilla.pt.

11. Changes to This Policy

FOZ VILLA reserves the right to update this Privacy Policy periodically, in particular to reflect legislative, technological or operational changes. The updated version will always be published on this page with the date of the last revision.

We recommend that you consult this page regularly. Materially significant changes will be communicated by email or through a notice on the website.

12. How to Contact Us

For any questions related to this Privacy Policy or the processing of your personal data, contact us through the following means: