Norfin – Sociedade Gestora de Organismos de Investimento Coletivo, S.A., in its capacity as management entity, administrator, and representative of ARRÁBIDA – FUNDO ESPECIAL DE INVESTIMENTO IMOBILIÁRIO FECHADO, (hereinafter “Norfin”), is committed to protecting and respecting the privacy of users (hereinafter referred to as “User” or “Users”). This privacy policy governs the processing of Users’ personal data collected during the use of the website www.aroeiracollections.com (hereinafter referred to as the “Website”) by Norfin, as the data controller.
By providing personal data, the User acknowledges the terms of this Privacy Policy.
Who is the data controller?
In the course of its activities, Norfin, with registered office at Avenida Almirante Gago Coutinho, no. 30, Ground Floor, Lisbon, with the single registration and corporate identification number 500 963 312, collects personal data from Users, acting as the entity responsible for the processing of such data.
What personal data do we collect?
Personal data is any information, regardless of its nature or medium (physical, sound, or image), relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or indirectly, for example through a name, identification number, location data, electronic identifier, or other elements that allow the identification of that individual.
Access to and use of the Website do not, in themselves, require the provision of personal data by the User, without prejudice to the use of cookies, as described in the Cookie Policy.
However, if the User chooses to contact Norfin via the contact form available on the Website, the provision of personal data will be required, namely identification data (such as name), contact details (such as email address and phone number), and any other personal data the User voluntarily provides in the context of these interactions.
What are the purposes for processing your personal data and the legal basis?
Norfin will process the data collected through the contact form on the Website for the purpose of managing information requests submitted by Users, based on Norfin’s legitimate interest in responding to such requests.
How long do we keep personal data?
Personal data is processed in strict compliance with applicable legislation. Data will be retained in accordance with the purposes for which it was collected and within the legally permitted periods. Where no specific legal requirement applies, data will be stored only for the appropriate period and to the extent necessary for the purposes for which it was collected.
What are the data subjects’ rights?
Under applicable data protection law, the User has the following rights:
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Right of Access: The right to confirm whether or not your personal data is being processed by Norfin, and to access such data and certain information, including obtaining a copy.
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Right to Rectification: The right to have inaccurate personal data corrected and to complete incomplete data.
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Right to Erasure (“Right to be Forgotten”): The right to request the deletion of your data in certain situations, for example when the data is no longer necessary for the purpose it was collected. This does not override Norfin’s legal obligations to retain data.
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Right to Restriction of Processing: The right to request limitation of processing in certain cases, such as when processing is unlawful and you oppose deletion and request restriction instead.
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Right to Data Portability: The right to receive personal data you provided to Norfin in a structured, commonly used, machine-readable format and to transmit it to another controller.
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Right to Object: The right to object, at any time and for reasons related to your particular situation, to the processing of your personal data, especially when it is processed for direct marketing purposes.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD) or another competent supervisory authority if you believe your data is not being lawfully processed by Norfin in accordance with applicable legislation and this Policy.
To exercise any of the rights mentioned above, under the legally applicable conditions, the User must submit a written request to the following email address: info@aroeiracollections.com.
What security measures are in place?
Norfin has implemented a set of procedural and technological measures to ensure the security of personal data processing, whether performed directly or through subcontracted entities.
Norfin makes its best efforts to protect Users’ personal data from unauthorized access. This includes using appropriate technical and organizational measures to prevent unauthorized access, misuse, disclosure, loss, or destruction of personal data.
With whom do we share personal data?
Norfin uses third-party service providers to offer the best possible service to Users. These services may involve access to Users’ personal data by such providers.
These entities act as processors on behalf of Norfin and only process data according to Norfin’s documented instructions. Norfin ensures these subcontractors offer sufficient guarantees of implementing appropriate technical and organizational measures in compliance with applicable laws and to protect data subjects’ rights.
Norfin may also disclose Users’ personal data to third parties where such disclosure is deemed necessary or appropriate (i) under applicable law, (ii) to comply with legal obligations or court orders, or (iii) to respond to requests from public or governmental authorities.
Do we transfer personal data to third countries?
In the course of its activities, Norfin does not transfer personal data to third countries (outside the European Economic Area).
Should such transfers occur, Norfin will ensure the implementation of appropriate legal mechanisms and safeguards to ensure that the data enjoys a level of protection essentially equivalent to that in the European Union.
Changes to this Privacy Policy
Norfin reserves the right to amend or update this Privacy Policy at any time. Users are advised to consult this Policy regularly to be aware of any changes.