I – Who is responsible for your Personal Data?
Personal data is any information, of whatever nature and whatever its medium, including sound and image, relating to an identified or identifiable natural person.
It is to be considered identifiable person the natural person that can be identified, directly or indirectly, in particular by reference to a name, identification number, location data, electronic identifiers or one or more specific elements of their physical, physiological, genetic identity, mental, economic, cultural or social.
Widerproperty Counterparties are overwhelmingly legal persons rather than natural persons.
The counterparty should contact Widerproperty at firstname.lastname@example.org in case of any doubt or need regarding data protection.
II – Information obtained by Widerproperty
Information from our Clients or Users may be obtained through our Site, personally, by completing the Customer Form, when the Customer delivers a business card to any of our Employees, at work meetings or events and also to through the information necessary to draw up a contract with Widerproperty.
Information obtained by any of the means described above will contain the name, company name, telephone number, email address, profession, position held or the capacity of representative.
When you visit the site or in person, you may be asked to provide other Personal Information about which you will be informed of how it will be used and what it is intended for.
III – For what purpose we treat your personal data?
Widerproperty will process the personal data that the counterparty provides to us through the interactions it has established with us in the course of our business for the purposes set forth below:
1. in the context of real estate mediation activity – to comply with the legislation in force, namely the one related to the real estate mediation and money laundering activity applicable to it;
2. in the context of its activity in providing real estate consultancy, management and exploration services – for drafting the respective service contracts to its clients – owners of real estate assets – and for the purpose of invoicing the same services;
3. in the context of shopping centre management – on the respective sites, certain information about the visit may be collected, such as the name of the internet service provider and the internet protocol (IP) address through which you accessed the internet; the date and time of access to the site; the pages that were accessed on the site and the internet address of the website from which you linked to the site. Information may also be disclosed to tenants, including email address and telephone number, at your express request, and it is your responsibility to process the data obtained by this means, and should follow the respective Privacy Policies.
4. in the context of disclosing your business activity – including sending newsletters or other informational information about your business activity;
5. in the context of the use and access to the Shopkeeper Portal in the activity of managing shopping centres;
6. in the context of the use and access to the My Wider Portal, in the condominium management activity;
7. within the Pipedrive internal platform, as part of its commercial prospecting activity with a view to attracting new customers;
IV – What is the legitimacy for the processing of your personal data?
The legal basis for the processing of data for the purposes above under a) and b) is the execution of the respective service contract;
The legal basis for the processing of data for the purposes described in c), d) and e) is the consent requested from the User, without the withdrawal of this being any condition for the execution of any service agreement in force under a) and b).
Widerproperty, at the time of registration, will collect and process personal data essential for registration and access to the User. You acknowledge and agree that failure to complete certain personal data may prevent Widerproperty from providing all services linked to such data.
In no event shall Widerproperty assign, exploit or otherwise use such data for any purpose other than as expressly stated or for which the requested data were transmitted.
V – How long do we keep your personal data?
Widerproperty will retain customer data for the duration of its contractual relationship and thereafter, data will be retained for the period to which it is legally bound, inter alia, but without limitation under tax and money laundering legislation; as such, the data will not be retained for longer than necessary for the purposes described by law, without prejudice to the retention that may be required for the formulation, exercise or defence of potential claims, but provided that applicable law permits.
After the above deadlines, the data will be deleted.
VI – Who has access to your personal data?
Widerproperty may make transfers or communications of personal data to fulfill its obligations to the Public Administrations where required in accordance with the law in force at any given time and, where appropriate, also to other bodies, such as State Security Forces and Bodies, and Judicial Bodies.
In addition to the foregoing paragraph, Widerproperty may, in the course of its business, use third parties to provide certain services. Sometimes, the provision of these services implies the access, by these entities, to personal data of their Clients / Users. In such cases, Widerproperty will take appropriate measures to ensure that entities having access to the data are reputable and provide the necessary guarantees at this level, which is duly enshrined and contractually agreed between Widerproperty and these third parties.
Any entity subcontracted by Widerproperty will treat the personal data of its Clients and Users on behalf and on behalf of Widerproperty and will take the necessary technical measures and internal procedures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, diffusion or unauthorized access and against any other form of unlawful treatment.
In any event, Widerproperty remains responsible for the personal data made available to you.
VII – What are the rights of users?
Widerproperty informs the User of its ability to exercise rights of access, rectification, opposition, deletion, portability and limitation of processing, as well as to refuse the automated processing of personal data collected by Widerproperty.
These rights may be exercised free of charge by the User or, as the case may be, by his representative, through a written request, signed and addressed to Widerproperty – Gestão e Mediação Imobiliária SA at the following address:
Rua Diogo Macedo, 16 – 4.º G/H
4400-107 Vila Nova de Gaia
This request should contain the reference “Data Protection / Widerproperty” and include the following data:
1. User / customer / counterparty name and surnames
2. address for notification purposes
3. ID Card or Passport card number and validity
4. text in which the request is made. In the case of a representative, this must be proved by a reliable document.
5. In addition, the User may exercise these rights through the email email@example.com
In addition to the previous rights, the User will be entitled to withdraw the consent granted at any time through the procedure described above, without the withdrawal of consent affecting the legality of the treatment prior to the withdrawal of consent.
Widerproperty may continue to process your data to the extent permitted by applicable law.
Widerproperty reminds the User that it is entitled to lodge a complaint with the relevant supervisory authority.
VIII – How to revoke the consent to send commercial communications or to disclose Widerproperty’s activity?
As mentioned in the previous section, the User is entitled at any time to revoke your consent to send commercially available communications by simply notifying Widerproperty that you do not wish to continue to receive commercial communications.
To do so, you may revoke your consent as described in the previous section or click on the link included in each commercial communication, as applicable, thereby cancelling the sending of electronic commercial communications.
IX – What security measures have we implemented?
Widerproperty is committed to ensuring the protection of personal data made available to it and has approved and implemented internal rules in this regard.
In particular, Widerproperty has established access profiles for certain types of data, with information from its various customers, suppliers and counterparties properly segmented.
Compliance with these rules will be an obligation on all who access existing personal data made available to Widerproperty.
Widerproperty, concerned with privacy and for enhancing the confidentiality and integrity of information within its organization, continuously monitors, controls and evaluates its processes to ensure respect for privacy and information security in accordance with international standards.
In addition, third parties who, in the context of the provision of services contracted by Widerproperty, process the personal data of Customers / Users on behalf and on behalf of Widerproperty, are required in writing to perform appropriate technical and security measures and that , at all times, meet the applicable legal requirements ensuring the rights of the data subject are defended.
Access to business data is compartmentalized and given only to the relevant elements of each department of each operation.
Data accessibility is ensured by standardized protocols implemented on high-reliability servers accessible through low-latency, high-throughput data connections.
Access control is centrally managed by implementing industry-recognized standards and procedures for their robustness.
The assignment and revocation of data access is defined by the administration of the organization and the direction of the different departments and projects, in order to maintain the necessary compartmentalization and limitation of the data, but to guarantee its access to all employees whose professional duties require it.
Data is physically archived on central servers, with continuous power, controlled physical access and hardware redundancies.
Widerproperty has therefore implemented the technical and organizational security measures necessary to ensure the security of your personal data and to prevent its alteration, loss and processing and / or unauthorized access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed, whether caused by human acts or by the physical or natural environment, in accordance with applicable law.
Widerproperty has its own website or web page and is responsible for managing the Shopping Centre websites under its management.
If there are cookies, a Policy will be prepared and made available on the site.
The Widerproperty website may include hyperlinks to other websites that are not operated or controlled by Widerproperty. Should this possibility occur, Widerproperty will not guarantee or be responsible for the lawfulness, reliability, usefulness, truthfulness and timeliness of the content of these sites or their privacy practices.
However, before you make your personal information available to those sites outside of Widerproperty, your compliance with data protection may differ from ours.
Lisbon, May 23, 2018