Privacy Policy

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., in compliance with the Personal Data Protection Regulation (GDPR), makes this Privacy Policy available to users of this website, with the aim of providing information on how we process users' personal data and protect their privacy and information.

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., asks users to take a few minutes to carefully read our Privacy Policy.

Introduction

This Privacy Policy applies to the website of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., which is available to the public at the URL https://www.aedashomes.com(hereinafter referred to as “website” or “platform”), as well as the interactions that users carry out with AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., through said website.

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., may change this Privacy Policy from time to time. In the event of any changes, we will inform you through the website or by other means, so that you are aware of the new privacy conditions. By continuing to use the features provided by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., after notification of the above-mentioned changes, users agree to the changes, except in cases where their express consent is required.

Who is responsible for processing your personal data?

The entity responsible for processing personal data is AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., , SA (hereinafter, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., ), with tax identification number A-87586483 and registered office located at Paseo de la Castellana, nº 130, Planta 5ª, 28046 Madrid.

To ensure the proper management of the processing of users’ personal data, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., has appointed a Data Protection Officer, to whom users may contact to resolve any queries they may have, and who can be contacted via the following email address: DPO@aedashomes.com

For what purposes do we process users' personal data?

Personal data provided by users through this website may be processed by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., for the following purposes, depending on the type of data provided by them, as well as the interactions that users establish with AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., through this website:

1. Contact

• Objective:  The personal data of users who contact AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., through any of the contact channels made available on the platform will be processed for the purpose of managing said contact, responding to requests received through said channels and providing the requested services.
   
• Data processed for this purpose: Identification and contact data (e.g. first and last name, email address, telephone number, postal address, IP address, etc.).
   
• Basis of legitimacy: The management, processing and development of the contractual and legal relationship established between users and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., .

2. Management of users registered on the platform

• Objective:  The personal data of registered users, who have a user account on the platform that allows access to its restricted area, will be processed for the purpose of managing the user profile that allows access to the platform, managing platform users and providing them with access to the content, features and services made available through the platform.
   
• Data processed for this purpose: Identification and contact data (e.g. first and last name, email address, telephone number, postal address, IP address, etc.).
   
• Basis of legitimacy: The management, processing and development of the contractual and legal relationship established between users and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.

The user is solely responsible for safeguarding their access codes to the platform, keeping them secret and using them responsibly. Users assume, in each case, the consequences or damages that may arise from the lack of diligence in safeguarding their access codes.

3. Management of the functionalities provided by the platform

• Objective:  The personal data of users who use the functionalities made available by the platform (request and management of after-sales services, communication and notification of after-sales incidents in properties brokered by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., etc.), will be processed by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., for the purposes of managing the platform’s functionalities, as well as user requests. In order to carry out some after-sales services, user data may be communicated to our partners.
   
• Data processed for this purpose: Identification and contact data (e.g. first and last name, email address, telephone number, postal address, IP address, etc.), Navigation data (e.g. use of the Web platform, sections visited, etc.).
   
• Basis of legitimacy: The management, processing and development of the contractual and legal relationship established between users and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., .

4. Management of services and provision of benefits associated with the AEDAS Club

• Objective:  Manage purchases made on the offer website, manage purchases made directly through the AEDAS Club website, as well as manage mobile coupons and promotions. cashback.
   
• Data processed for this purpose: Identification and contact data (e.g. first and last name, email address, telephone number, postal address, IP address, etc.), Browsing data (e.g. use of the Web platform, sections visited, etc.), Transaction data for goods and services (e.g. purchases made through Club partners, etc.). 
   
• Basis of legitimacy: The legal relationship between each user and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., as a participant in the AEDAS Club, being a prerequisite to have been a customer of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.,.

5. AEDAS Club Customer Support Service

• Objective:  To resolve issues related to a promotion, portal access, refunds or to suggest a discount.
   
• Data processed for this purpose: Identification and contact data (e.g. first and last name, email address, telephone number, postal address, IP address, etc.), Browsing data (e.g. use of the Web platform, sections visited, etc.), Transaction data for goods and services (e.g. purchases made through Club partners, etc.).
   
• Basis of legitimacy: The legal relationship between each user and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., as a participant in the AEDAS Club, being a prerequisite to have been a customer of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.,.

6. Trend analysis and preparation of market studies

• Objective:  Perform aggregated statistical operations based on users’ transactions and interactions with the benefits made available at the Club. This processing does not, under any circumstances, imply the creation of user profiles or the taking of automated decisions that may have legal effects for each user.
   
• Data processed for this purpose: Identification and contact data (e.g. first and last name, email address, telephone number, postal address, IP address, etc.), Browsing data (e.g. use of the Web platform, sections visited, etc.), Transaction data for goods and services (e.g. purchases made through Club partners, etc.), Personal characteristics data. And social circumstances (e.g. housing situation, time availability, etc.).
   
• Basis of legitimacy: The legitimate interest of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., is based on the legitimate interest of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., in continually improving the entity's business model and in correcting any deficiencies that may arise in the provision of the service offered.

7. Commercial communications specific to AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., to customers

• Objective:  The personal data of website users who are also customers of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., may be processed for the purposes of sending advertising, promotional information or information of interest to them, relating to products, promotions and commercial offers of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., through any means, such as postal mail, electronic means (e-mail, courier, SMS or other equivalent electronic means of communication) or social networks, including based on the analysis and preparation of the respective profile, which will be prepared exclusively with internal data. Regarding the analysis and preparation of each user's profile, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs you that, with the aim of optimizing and introducing improvements, as well as offering you appropriate information according to your preferences, it may carry out treatments that consist of the preparation and analysis of profiles and apply segmentation techniques for commercial and advertising purposes, which will be carried out exclusively with the data that each user provides us (internal data of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.,).
   
• Data processed for this purpose: Identification and contact data, data relating to transactions of goods and services, data on personal characteristics or social circumstances (derived from the application of segmentation and profiling techniques).
   
• Basis of legitimacy: This purpose is based on the regulations governing the information society (in the case of communications by e-mail or similar means) and on the legitimate interest of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., which consists of arousing interest and promoting the contracting of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.’s products, as well as improving the image of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.,. In this sense, users may object, at any time, to the processing of their data for this purpose, using the channels made available for this purpose by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., and in each of the commercial communications issued, the latter in the case of communications by e-mail or similar means. If users wish to obtain more information about the legitimate interest invoked by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., in relation to this purpose, they can request additional information at DPO@aedashomes.com.

8. Commercial communications specific to AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., aimed at non-customer consumers

• Objective:  The personal data of users of the website who are consumers of the brand's products and who have also given their express consent in the forms made available for this purpose, may be processed by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., for the purposes of sending advertising and promotional information or information that may be of interest to them, relating to products, promotions and commercial offers of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., by any means, such as postal mail, electronic means (e-mail, messages, SMS or other equivalent electronic means of communication) or social networks, including based on the analysis and preparation of their profile, which will be prepared exclusively with internal data. Regarding the analysis and creation of each user's profile, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs you that, with the aim of optimizing and introducing improvements in the sending, as well as offering you appropriate information according to your preferences, it may carry out treatments that consist of the creation and analysis of profiles and apply segmentation techniques for commercial and advertising purposes, which will be carried out exclusively with the data you provide us (internal data of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.,).
   
• Data processed for this purpose: Identification and contact data and data on personal characteristics or social circumstances (derived from the application of segmentation and profiling techniques).
   
• Basis of legitimacy: The consent of users, requested through the forms provided for this purpose. In this sense, users may revoke their consent for the processing of their data for this purpose, using the channels made available for this purpose by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., .

9. Carrying out satisfaction surveys related to the service provided.

• Objective:  Users’ contact details may be processed by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., to carry out satisfaction surveys or market studies related to transactions carried out on the website.
   
• Data processed for this purpose: Identification and contact details.
   
• Basis of legitimacy: The processing is based on the legitimate interest of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., which consists of the need to know the degree of consumer satisfaction with the products sold through the website. In this sense, users may object, at any time, to the processing of their data, using the channels made available for this purpose by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., . If users wish to obtain more information about the legitimate interest invoked by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., in relation to this purpose, they may request additional information at DPO@aedashomes.com.

10. Fraud prevention

• Objective:  Users' personal data will be processed in order to comply with legal and business regulations, as well as to cooperate with competent authorities in preventing crimes or fraud.
   
• Data processed for this purpose: Identification and contact data, and data relating to transactions of goods and services.
   
• Basis of legitimacy: This purpose is based on the legitimate interest of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., in ensuring the reasonable use of the resources made available on this website and in reducing the risk of being a victim of fraud or fraudulent transactions. If users wish to obtain more information about the legitimate interest invoked by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., in relation to this purpose, they can request additional information at DPO@aedashomes.com.

What are the sources of the data?

The data processed by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., comes from the following sources:

• Data provided by users, by filling in the forms made available by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., or by any other means through which users establish a relationship with AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., (for example, name, surname, email, telephone number, postal address, IP address, etc.).
   
• Data generated as a result of users’ browsing and use of the web platform (e.g. use of the web platform, sections visited, etc.).
   
• Data generated as a result of the development, processing and management of the relationship established between users and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., (for example, number of contacts established with the customer).
   
• Data generated as a result of the development, processing and management of the AEDAS Club functionalities and any other service provided by or through AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., (for example, purchases made through Club partners, etc.).

To whom are user data communicated?

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs users that the processing of personal data described and communicated in this Privacy Policy may imply the communication of their data by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., to third parties.

The aforementioned data communications will be carried out by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., exclusively in cases where this is necessary within the scope of the management and processing of the request issued by each user, with the legitimate basis for such data communication being management, processing and development of the contractual and legal relationship  between users and AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., .

In this sense, and whenever necessary, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., may communicate data to the following third parties:

• Construction companies of the property owned by a user and in whose intermediation AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., participated.
   
• Service providers for on-site verification of incidents at the property reported by the user through the platform.
   
• Service providers for repairing incidents in the property that the user reports through the platform and that need to be resolved. These repair service providers can be arranged through the property's construction companies or through AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., .

Furthermore, when the user in question the expressly authorize, we may disclose your data to certain partners so that they can provide you with a service of interest to you. These transfers are subject to a agreement between AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., and the partner, in which both undertake to provide the necessary guarantees to ensure the security of each user’s data. In this sense, we may communicate user data, for example, to after-sales service providers, such as RUNUP BUSINESS, SL (QLIP).

No international transfer of users’ personal data is envisaged. However, in the event of an international transfer, this will be carried out in accordance with the criteria and requirements of the regulations in force, through the adoption of appropriate legal guarantees, which may consist of the formalisation with the recipient of the data of (i) standard contractual clauses approved by the European Commission to legitimise the international transfer of data to third countries or (ii) another valid legal instrument that guarantees an adequate level of protection equivalent to that of the European Economic Area.

How long will we keep user data?

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., will keep users’ personal data for the time necessary to manage the reported incidents and/or to achieve the intended purpose of the respective processing.

Subsequently, provided that users have not exercised their right to deletion, their data will be kept for the legal periods applicable in each case, taking into account the type of data, as well as the purpose of the processing.

In any case, users can request detailed information about the data retention periods applied at AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., by contacting our Data Protection Officer, who can be contacted at the following address DPO@aedashomes.com.

What personal data must users provide in each case?

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs users that, when personal data is collected through a form made available through our website, it will be necessary for users to provide at least the data indicated as mandatory. If at least this data, considered necessary, is not provided, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., will not be able to manage the provision of the service or respond to the users' request.

What guarantees do users have to give us when they provide us with their personal data?

Users guarantee that the data provided is true, accurate, complete and up-to-date, and are responsible for any direct or indirect damage or loss that may be caused as a result of failure to comply with this obligation.

In the event that users provide data belonging to a third party, they guarantee that they have informed that third party of all the aspects contained in this Privacy Policy and have obtained their consent to provide us with their data for the purposes of the processing in question. All this, before the provision of data by a third party through our website.

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs users that, in order to provide their personal data, in any way, through our website, they must be over 18 years of age. Users who provide data to AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., through this website declare and guarantee that they are over 18 years of age, assuming full responsibility for this declaration.

What measures do we take to protect users' personal data?

In response to AHLC – PROMOÇÃO IMOBILIÁRIA, LDA.’s concern in ensuring the security and confidentiality of user data, the required security levels have been adopted to protect personal data and the technical means available have been installed to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided through this Web platform. In any case, it should be noted that Internet security measures are not impregnable..

What are users' rights regarding their personal data?

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs all users that they have the right to obtain confirmation as to whether or not we are processing personal data concerning them.

Likewise, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs users that they have the following rights over their personal data:

• Access your data: Know what personal data we are processing.
   
• Request the rectification or deletion of your data: Rectify personal data that they consider to be inaccurate and that concerns them, and that is processed by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., as well as the right to request the deletion of their data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
   
• Request limitation of the processing of your data: The limitation of the processing of each user's data, in which case we inform you that we will only keep the data for which you have requested the limitation of processing for the exercise or defense of claims.
   
• Portability of your data: Receive the personal data concerning them and which they have provided, in a structured, commonly used and machine-readable format, as well as its transmission by AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., to another data controller.
   
• Object to the processing of your data: Object to the processing of your data, in which case we will stop processing it, unless we have to continue doing so for legitimate reasons or for the exercise or defense of possible claims.

We also remind you that users have the right to object, at any time, to the sending of advertising for the products and services of AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., as well as to withdraw any consent they have given for the processing of their data, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal.

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs users that they can exercise their rights over their personal data by writing to AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., with the reference “Exercise of customer rights”.

Orders can be shipped to any of the following addresses:

• AHLC – REAL ESTATE PROMOTION, LDA., , SA Paseo de la Castellana, No. 130, 5th floor. 28046 Madrid.
• DPO@aedashomes.com

In both cases, the identity of the person exercising their rights must be proven. If this is not sufficient, additional information may be requested.

AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., will provide the requested information within a maximum period of one month from receipt of the request, although we inform you that this period may be extended for a further two months, taking into account the complexity and number of requests.

Finally, AHLC – PROMOÇÃO IMOBILIÁRIA, LDA., informs users that they may file a complaint with the competent Data Protection Supervisory Authority, which in Portugal is the National Data Protection Commission (CNPD), (www.cnpd.pt). However, in the first instance, users may lodge a complaint with our Data Protection Officer (DPO@aedashomes.com), which will resolve the respective complaint within a maximum period of two months.