1. Content
The use of your personal data is governed by this Privacy Policy, drawn up in accordance with the legislation in force regarding the protection of personal data. Your personal data will only be shared with third parties in accordance with the provisions of this Privacy Policy.
This privacy policy explains:
- Who is the data controller
- What is personal data
- How we collect personal data
- The types of personal data we collect
- How we use your personal data
- The legal basis for the processing of your personal data
- How we share your personal data
- The retention time of personal data
- How we keep your personal data safe
- International transfers of personal data
- Your rights in relation to your personal data
- How to make complaints or contact us
- Information on changes to this Policy
2. Data controller
Mentions of "Savills Portugal", "we" or "our" in this document refer to Savills Portugal - Mediação Imobiliária, Lda., And Savills Portugal - Consultoria, Lda., with the legal entity identifier and registration numbers 505759810 and 507296605 respectively, who are responsible for the processing of personal data.
3. What is personal data?
Personal data is any information that can identify you or allow us to identify you, such as name, contact details, date of birth, bank account details or any information about your needs or circumstances that allow us to identify you.
Some personal data is classified as "special" information under the terms of data protection legislation. This includes information related to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive, so it needs special precautions regarding its collection, conservation, and use. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal record data.
Any mentions of personal information contained in this Privacy Policy refer to personal data and, where applicable, special categories of personal data.
4. What personal data do we collect?
We collect your full name and contact details (such as phone number, email, and address) whenever you hire our services.
As well as this, when you request our service provision, in order to comply with legal obligations, such as the current anti-money laundering and counter terrorist financing legislation, we collect information related to your identity, using at least one form of photographic identification (such as passport, driving license, citizen card or other identification document) and one other document proving address (such as a household bill).
We also check if you have kinship or affinity relationships with our employees so that we can assess possible conflicts of interest that may oblige us to take measures in accordance with our legal or regulatory obligations.
Depending on the service provided to you (or at your expense), we may also collect additional personal information, as detailed below.
Purchase, sale, lease, exchange, or constitution of other real rights over your property
In case of purchase, sale, lease, exchange, or constitution of other real rights over your property:
- We collect a telephone number to enable contacts, organize visits to the property, and provide updated information on any offers relating to the property;
- When you contact us for information on the purchase of a particular property, we use your contact details to respond to you, which may include sending information about other properties as an alternative so that we can assist you in your search.
- We collect personal data when you hire our services in compliance with the contractual obligations to which we are attached;
- In real estate mediation, we may share your personal data with lawyers and solicitors acting on behalf of the parties to the mediated business and/or in order to facilitate its completion;
- Also in the context of real estate mediation, we may share your personal data with other licensed real estate agents who intervene in the mediated business, in order to facilitate its completion;
- If you are not the owner of the property, we will ask for details about your legitimacy to act in representation of the business, such as a power of attorney or other instrument of representation;
- We collect your bank account details to ensure the payment of any due amounts to be paid in advance within the scope of the contracted services;
- If you want to buy a property that we have for sale, we may collect personal data that allows us to meet your specific preferences or needs.
If you want to rent a property:
- When you contact us for information about renting a particular property, we use your contact details to answer you, which may include sending information about other properties as an alternative so that we can assist you in your search.
- We may process: personal data that allows us to meet your preferences and needs; personal identification and banking details, and supporting documents to comply with the current anti-money laundering and counter terrorist financing legislation.
Real estate investment deals
In the provision of real estate investment services, we collect personal identification data to ensure compliance with the legal requirements provided for in the legislation to prevent money laundering and terrorist financing. If the investor is a legal person, personal data will be collected from those who legally represent it (administrators, managers, attorney)
Property Management
In the provision of property management services, we will additionally request emergency contacts, in case we need to contact you outside working hours or if there is a matter that requires your urgent attention.
When providing portfolio management services, we will share your personal information with third party investors as necessary so that we can fulfil our obligations to you and provide you with appropriate advice regarding your real estate investments.
If you are a tenant in a property managed by Savills Portugal, it may be necessary to share your personal information with the owner of the property; in this case, we will first consider your rights.
Whenever we operate CCTV within a property, we can capture your image within the restrictions imposed by law and with respect for your rights.
Others
If you sign up to receive our market studies, news or other market updates, we additionally collect information about the industry in which you work and the type of content you would like to receive.
5. How we use your personal data
What is the legal basis for data processing?
In accordance with data protection legislation, we can only use your personal data if there is a legal basis for that purpose. Under the law, our use of data serves the following purposes:
- Employment-related purposes;
- Hiring our services;
- For the fulfilment of legal obligations;
- When processing is necessary in order to carry out activities for which it is in the legitimate interest of Savills Portugal (or third parties) to do so, provided that their interests and fundamental rights do not override those interests, including:
- Necessary processing in order to promote our business, brands and services, and to measure the reach and effectiveness of our campaigns - including sending you email marketing if you have expressly requested it. You are always entitled to choose not to receive this information.
- Necessary processing in order to improve our knowledge of the real estate sector, including carrying out market analysis and research so that we can better understand the trends in the real estate sector and be able to provide more personalized and relevant services to our customers in the future.
- Necessary processing so that we can resolve administrative and technical aspects of our business efficiently and effectively, including verifying the accuracy of your personal data; processing for administrative purposes; processing for network and information security purposes; to protect your personal data from loss, damage, misappropriation or unauthorized access, or to respond to your request related to the exercise of any of the rights described below.
In more restricted circumstances, our use of data also serves the following purposes:
- The protection of your vital interests or that of another person;
and/or
- When necessary to public interest
- We may process special categories of personal data and information about your criminal record in the following restricted circumstances:
- With your explicit and informed consent, through clear information on the purposes of the intended use provided prior to said consent.
Purchase, sale, lease, exchange, or constitution of other real rights over your property
- If you intend to sell or lease, we use your personal information to fulfil our obligations to sell or lease your property; if you plan to buy or lease, we use your information to organize visits, obtain feedback and prepare the sale or lease agreement;
- We will use your personal information to comply with legal and regulatory obligations to which we are bound;
- We may share your personal information with lawyers and agents of the parties as needed to facilitate business. We may also share your personal information with joint agents or promoters, as appropriate;
- We will share your personal data with reference agencies or service providers for the purpose of preventing and detecting crime, fraud and/or money laundering and checking your suitability for renting that property. In such circumstances, the service provider may act as the controller for that data.
Property Management
- When we manage properties on your behalf, we may need to share your personal information with subcontractors to maintain your properties.
- We operate CCTV on properties based on our legitimate interest in protecting the property and ensuring the safety of visitors, tenants, and customers, as well as assisting in crime prevention and detection.
Investment
- When you hire portfolio management services, we will share your personal information with lenders, where necessary, to enable us to fulfil our obligations to you, to assist you in obtaining financing and to advise you properly on your real estate investments.
Other uses we make of your data
- If we sell any part of our company and / or integrate it into another organization, your data may be disclosed to our consultants and potential buyers or joint venture partners and their consultants. If this occurs, new owners of the company may only use your information in the same or similar manner as defined in this Privacy Policy;
- We will share personal data to comply with legal obligations, to exercise rights, or to prevent crime, fraud or money laundering with industry regulators, government organizations, the Tax and Customs Authority and with courts. In such circumstances, these entities may act as the data controllers for your personal information;
- We share data with subcontracting entities that provide services and act in the name and on behalf of Savills Portugal and through their documented instructions (e.g. legal, accounting, archival and IT support services);
- We may share your personal data with employees of the Savills Group, where further knowledge is necessary, to ensure that we can fulfil our obligations to you;
- We will keep your personal information in our customer management systems and use it to send direct marketing regarding similar services offered by Savills Portugal to those who have hired us which we think may be of interest to you. You will always have the opportunity, at no additional cost, to opt out of receiving this information.
- If you sign up to receive our studies, news or other market updates, in addition to the above, we collect data about the industry in which you work and the type of content you would like to receive.
What happens if you do not provide the personal data we request?
We need to collect certain personal data to carry out the contracted service provision. For example:
- If we are selling a property that you own, we need to collect data so that we can update it with information about views, offers and the development of the sale process;
- In cases where you have requested a property with certain characteristics, we may need to request some additional details about your preferences or specific circumstances so that we can find a suitable property;
We may also need to collect some personal information in order to comply with legal or regulatory obligations, such as those in relation to the prevention of money laundering and financing of terrorism.
If you do not provide us with the information requested for these purposes, we will not be able to perform the contract, as well as provide or continue to provide certain services. Whenever we collect your information we will let you know.
6. How we keep your personal data safe
The security of your personal data is very important to us and we have measures in place to prevent unauthorized access to your personal data, such as:
- Client files are stored in secure client management systems. Access to our customer systems is reserved for those who, within the company, need access to their personal data for legitimate and proven business purposes;
- Printed documentation is stored in locked compartments;
- All data is kept in data centres that have systems and protocols to protect against unauthorized access and other external factors that may cause damage to your personal data. There are strict and limited access requirements.
We guarantee that access to personal data is restricted to employees of Savills Portugal and according to the need for knowledge of the information. We provide training to our employees in the field of personal data protection.
7. How long do we keep your personal data?
The period during which we keep your personal data varies depending on the type of service contracted. The retention period may be longer than the term of the service provision due to legal or regulatory obligations.
8. International data transfers
We may transfer, store, or process your personal data outside Portugal and the European Economic Area (EEA). In cases where third countries to which data is to be transferred do not offer an equivalent level of protection similar to the legal regime in force in Portugal, we will guarantee the implementation of safeguarding measures.
We will use one of the following safeguarding measures:
- Transfers to non-EEA countries for which an adequacy decision must be made by the European Commission
- Implementation of standard clauses adopted by the European Commission with the recipient country. This means that the recipient country is obliged to adopt levels of protection similar to those in force for organizations within the EEA;
- Transfers to organizations that have implemented binding rules applicable to companies approved by an EU sectoral authority.
9. Rights relating to personal data
As the holder of personal data, you have several rights, namely:
- The right to be informed of the uses we make of your personal data
- Access your personal data
- The right to request that your personal data be corrected whenever you consider them to be incorrect, incomplete or inaccurate;
- The right to request that your personal data be deleted in the following circumstances:
- If we continue to process personal data beyond the required period for which it was collected;
- When withdrawing consent wherever processing has occurred on this basis;
- When processing is carried out on the basis of legitimate interest and you object to such processing for reasons that must be considered to be prevalent;
- If personal data is processed illegally (that is, in breach of current personal data protection legislation);
- If it is necessary to delete personal data to comply with a legal obligation.
- The right to request data portability: personal data holders have the right to receive the personal data that they have provided to Savills Portugal or to transmit it to another company whenever processing is based on consent or performance of the contract and pre-contractual obligations, and processing is carried out using automated means. The data will be provided or transmitted in a normal, structured, and machine-readable format.
You have the right to restrict the processing of your personal data, if:
- The data is inaccurate, during the period necessary to verify its accuracy;
- Its processing is illegal;
- We no longer need personal data for processing purposes, but require that data for the defence, exercise or declaration of a right in a judicial process;
- You have a complaint about the processing of your personal data processed based on the legitimate interest of Savills Portugal. In the event of a complaint, we will carry out an assessment to determine if there are reasons that prevent the further processing of personal data
To exercise these rights, contact: rgpd@savills.pt
10. Complaints and Contact Details
Complaints
In case of complaints about the use of personal data, you should contact Savills Portugal through at rgpd@savills.pt, where we will try to solve the problem. If we are unable to resolve the problem, you have the right to complain to the National Data Protection Commission. If you need more contact information for the National Data Protection Commission, contact us via e-mail at rgpd@savills.pt.
Contact address
In case of doubts, comments or requests about any aspect of this Privacy Policy, you should contact us, sending an email to rgpd@savills.pt, or write to the following address: Savills, Praça Marquês de Pombal, nº 16, 7º andar, 1250-163 Lisbon – Portugal
11. Changes to the Privacy Policy
Savills Portugal reserves the right at any time to change this Privacy Policy in order to adapt it to new practices or to make it compatible with possible legislative changes.
If the changes made are significant, Savills Portugal will endeavour to inform customers of the changes through the normal contact channels.
12. Savills' use of cookies
What is a cookie?
A cookie is a small text file that is downloaded to your computer when you visit certain websites and allows a website to recognize a user's computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to website owners.
What cookies are used by Savills?
When browsing our website, cookies strictly necessary for the performance and functioning of the website are used automatically. We will only use non-essential cookies if you give us your consent by selecting "Accept all cookies" in the cookie banner.
The table below lists the cookies used by Savills and provides a description of how each cookie works. Clicking on the '+' symbol will expand the box so you can get more information about each cookie. When there is more information about a cookie on an external website, a link is available under 'More information'.