Privacy and Personal Data Protection Policy

1. Types of collection of personal data and purposes

IRG INTERNATIONAL REALTY – MEDIAÇÃO IMOBILIÁRIA, LDA. (“IRG”) collects and processes personal data upon the voluntary subscription by the respective holders of its newsletter.

Thus, by subscribing the IRG´s newsletter, the data subject gives his / her express consent to have his or her personal data used by IRG to send the newsletter, which is intended to promote properties, launching of new products, the invitation to business-related events and overall contents of the company.

The newsletter subscription is absolutely optional, being an exclusive and free option of the subscriber, based on his/her express consent, which may be withdrawn at any time.

IRG also automatically collects data such as IP addresses, browser type, domain and visitor´s access time to IRG´s internet site.

The data thus obtained does not, however, allow the possibility of identifying the respective holder, but only the mechanism used in accessing the site.

The collection of such data is exclusively meant for the improvement of the service that is provided to the users of the site.

2. Types of personal data collected

IRG collects the following types of personal data:

• Full name and e-mail address.

3. Security and confidentiality of personal data

IRG guarantees the implementation of appropriate actions, designed to keep your personal data protected against any accidental loss and safe from any access, change or unauthorized disclosure.

The personal data are collected and kept in a database implanted in a password protected system, with limited access, and located in physical facilities that are subjected to strict access control measures.

IRG also ensures that its site has adequate security measures to prevent, as far as possible, unauthorized access, theft, unlawful modifications and the loss of personal data introduced there, through constantly searching and implementing measures and complementary security techniques, that are in its reach, with the purpose to fulfill the above-mentioned.

4. How we share personal data and handle subcontracted companies and service providers

IRG uses third-party subcontracting to manage its newsletter using companies with an adequate security level and that are required to comply with IRG’s instructions on data protection issues.

Thereby, IRG guarantees that any subcontracted entity treats the personal data of the newsletter subscribers, for and on behalf of IRG, with the obligation to undertake the necessary technical and organizational measures necessary to protect personal data against the destruction, accidental or unlawful, accidental loss, change, dissemination or unauthorized access and against any other form of illicit or unauthorized treatment.

The subscriber of the newsletter hereby authorizes IRG to provide his/her personal data to its partners responsible for the promotion of properties outside Portugal, in which case IRG has no responsibility to the subscriber of the newsletter about how its partners use the personal data.

Whenever requested, IRG obliges itself to give the subscribers of the newsletter the identification of its partners to whom their personal data is being transferred.

5. Personal data storage

IRG will keep the personal data of the subscribers as long as they maintain their consent for the reception of the newsletter.

Under the option to end the subscription of the newsletter, IRG guarantees that the personal data of the respective holder will be immediately eliminated, not being used for any other purpose, unless expressly agreed by the same.

6. Ways to access, change, correct and delete your personal data

IRG guarantees to the data subject a timeless and unconditional access to his/her data, with the purpose of its confirmation, modification, amendment, and update.

The data subject may also, at any time, oppose to the use of his/her personal data for the purpose of sending the newsletter.

The exercise of the rights, described in the previous paragraphs by the data subject or any other information to be provided regarding their personal data, should be carried out by a request, addressed to the Data Protection Officer designated by the IRG.

7. Contacts of the person in charge and in charge of the treatment:

IRG INTERNATIONAL REALTY – MEDIAÇÃO IMOBILIÁRIA, LDA. is responsible for the processing of personal data collected under the subscription of the newsletter. Contacts are as follows:

Avenida Aida, Edifício Arcadas do Parque, loja 19
2765-187 Estoril, Portugal
+351 214 643 630
info@irglux.com

IRG as responsible for the data has a Data Protection Officer who´s accountable for guaranteeing the integrity of personal data, as well as for the application and execution of technical and security measures to fulfill legal obligations regarding data protection.

This Data Protection Officer will also be responsible for receiving and replying to any request addressed by the holder of the personal data.

The Data Protection Officer can be reached at any time by the owners of personal data through the following contacts:

Avenida Aida, Edifício Arcadas do Parque, loja 19
2765-187 Estoril, Portugal
+351 910 215 235
sandra@irglux.com

8. Changes to the current Privacy and Personal Data Protection Policy

IRG reserves its right to at any time update or alter the current Privacy and Personal Data Protection Policy.

Any change to the Privacy and Personal Data Protection Policy should be immediately communicated to the data subject, who should also be informed about where he/she can consult such alterations.

9. Law and Jurisdiction

The visit and usage of the site as well as the subscription of the newsletter will be subject to the acceptance by the respective users and / or subscribers of this Privacy Policy and Protection of Personal Data.

Any question regarding the interpretation and the compliance to the Privacy and Personal Data Protection Policy should be made using the legislation in force in the territory of Portugal, and, in case of litigation, the Portuguese courts.




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