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1. IDENTIFICATION OF THE DATA CONTROLLER


  • Company: Refundos - Sociedade Gestora de Fundos de Investimento Imobiliário, S.A. ("REFUNDOS")
  • Head Office: Av. Fontes Pereira de Melo, 14 - 6.º, 1050-121 Lisboa
  • Legal Person Identification Number: 502913290
  • Telephone: (+351) 213 021 763
  • E-mail: refundos@refundos.pt


2. INFORMATION AND CONSENT


The Data Protection Act (hereinafter "DPA") and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, hereinafter "GDPR") shall ensure the protection of natural persons with regard to the processing of personal data and the free circulation of such data. According to the law, personal data is any "information relating to an identified or identifiable natural person ("the data holder"); an identifiable person is considered to be identifiable, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, identifiers by electronic means or to one or more specific elements - physical, physiological, genetic, mental, economic, cultural or social - of that natural person. "

The protection of the personal data of those who in any way relate to REFUNDOS constitutes a fundamental commitment of our company, therefore we work daily to ensure the best levels of protection of the personal data that we process, respecting the legislation and all national and European guidelines applicable to data processing.

While managing the relationship with our suppliers, service providers, customers and users, we can access their personal data, as well as access the data of REFUNDOS directors and collaborators. By accepting this Privacy Policy, we intend to inform you how REFUNDOS processes this personal data and the purposes for which it is processed, along with informing the rights of data holders and how those rights may be exercised.

In no case will REFUNDOS carry out any of the following activities with the personal data provided through this site, without the express prior consent of the data owner:

    I. Deliver it to other persons or other entities, and/or
    II. Transfer it outside the European Economic Area (EEA).


3. PURPOSE OF THE PROCESSING OF PERSONAL DATA


The personal data processed by REFUNDOS will only be used for the following purposes:

    I. Compliance with legal obligations;
    II. Management of contractual relationships with clients and suppliers;
    III. Business prospecting;
    IV. Processing of information requests;
    V. Claim processing.


4. SAFETY PRECAUTIONS


REFUNDOS states that it has implemented and will continue to implement the security measures of a technical and organizational nature necessary to ensure the security of the personal data provided, in order to prevent its alteration, loss, unauthorized processing and/or access, taking into account the current state of the technology, the nature of the data stored and the risks to which they are exposed.

REFUNDOS guarantees the confidentiality of the data provided through this website.

The personal data is processed with the level of protection legally required to guarantee its security and prevent unauthorized alteration, loss, treatment or access, taking into account the state of the technology, being the user aware and accepting that the measures of Internet security are not impregnable.

Whenever REFUNDOS accesses personal data, it undertakes to:

  • Store it by means of legally enforceable security measures of a technical and organizational nature that guarantee their safety, thus avoiding unauthorized alteration, loss, processing or access, according to the current state of technology, the nature of the data and the possible risks to which they are exposed;

  • Use the data exclusively for the purposes previously defined;

  • Make sure that the data is handled only by the employees whose intervention is necessary to satisfy the request of the data holder, being the same obliged to duties of secrecy and confidentiality. Should the information be disclosed to third parties for said purposes, they should be required to keep the confidentiality in accordance with the provisions of this document.
It is, however, your responsibility to guarantee and ensure that the computer you are using is properly protected from harmful software, computer viruses and worms. In addition, you should be aware that without the adoption of appropriate security measures (for example, safe configuration of the browsing program, up-to-date antivirus software, security barrier software and non-use of software of questionable origin) the risk of personal data and passwords to be accessed by third parties, without authorization to do so, is aggravated.


5. EXERCISE OF RIGHTS


In accordance with the provisions of the DPA and the GDPR, the user may exercise at any time his right to information, access, rectification, erasure, limitation, portability and opposition by means of a written request addressed to REFUNDOS by the following means:

  • Postal address to: Av. Fontes Pereira de Melo, 14 – 6.º, 1050-121 Lisboa
  • Email to the e-mail address: refundos@refundos.pt


6. CONTROL AUTHORITY


Under legal terms, the data holder has the right to submit a complaint regarding the protection of personal data to the competent control authority, the National Data Protection Commission (CNPD) www.cnpd.pt



7. COOKIES POLICY


Cookies policy is an integral part of the privacy policy of REFUNDOS website. Accessing and browsing the website or the use of its services implies acceptance of the terms and conditions contained in the privacy policy.

To facilitate and provide a better browsing experience through the website, REFUNDOS informs you that it uses cookies or other files with similar functionality ("cookies").

Due to how Internet communication standards work, access to websites may involve the use of cookies. REFUNDOS is responsible for the cookies and for the treatment of the data obtained through the cookies, either of its own or of third parties, through its website, deciding on the purpose, content and use of the treatment of the collected data.

What is a cookie?

Cookies are files that contain small amounts of information that is downloaded to the user's device when you visit a web page.

The main objective is to recognize the user whenever he / she accesses the website, also allowing to improve the quality and to offer a better use of the website, in order to simplify navigation.

Cookies are essential to the functioning of the internet; they do not damage the user's equipment or device and, if enabled in the configuration of your browser, they help identify and resolve possible errors in the operation of the website.

Use of cookies by REFUNDOS

By accessing the website, you expressly accept the use of this type of cookies on your devices. If you disable cookies, your website navigation may not be optimized, and some of the features on the website may not work correctly.

REFUNDOS uses cookies specifically for the purposes identified above and in case REFUNDOS uses other cookies for the purpose of granting more and better services, the user will be informed accordingly.

User setup to prevent cookies

In accordance with current legislation, information is provided on how the user can configure the browser to manage and maintain their privacy and security in relation to cookies, through links to access the official support website of the main browsers so that they can decide whether or not to accept the use of cookies.

It is understood that the user accepts the use of cookies if he continues browsing this page without first proceeding to deactivate the cookies. Cookie settings can be changed in your browser preferences by following the instructions below:

    Chrome:
    I. Click "Settings" in the toolbar;
    II. Click "Show advanced settings";
    III. In the "Privacy" section, click "Content Settings";
    IV. Select "Block data settings from websites";
    V. You can change the following settings in the "Cookies" section: Delete cookies; Block cookies by default; Allow cookies by default; Keep cookies and website data by default until you quit your Internet browser; Create exceptions for cookies from specific websites or domains.

    Firefox:
    I. Click the "Tools" menu;
    II. Select "Options";
    III. Click the "Privacy" icon;
    IV. In the "Cookies" section, deactivate the "Accept cookies from sites" option;
    V. Click "OK" to save your changes and close.

    Internet Explorer:
    I. Click the "Tools" menu and choose "Internet Options";
    II. Select the "Privacy" tab;
    III. Move the bar until the phrase "Block all cookies" appears.

    Safari:
    I. Select "Preferences";
    II. In the top panel, select the "Privacy" icon;
    III. In the "Accept cookies" section, select "Never".

    Other browsers:
    Please look in the "help" menu of the internet browser or contact your provider.