Policy Purpose
This Policy explains the terms under which ALYX PROPERTIES processes personal data of the Users of the website, as well as the rights they may exercise, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April (‘GDPR’) and other applicable national legislation, namely Law No. 58/2019 of 8 August, which ensures the execution in the national legal order of the GDPR. This Policy’s purpose is to communicate to Users in a transparent way, for which given, explicit and legitimate purposes, that their personal data is collected and processed, at every moment, as well as the basis for the legality of the processing.
Data Controller
ALYX PROPERTIES is the entity responsible for the personal data processing and may, in the context of its activity, use entities subcontracted by itself to pursue the purposes herein provided.
Data Protection Officer
All questions regarding the privacy and processing of personal data can be addressed to the following contacts:
Email: dataprotection@algebracapital.pt
Post: Avenida da Liberdade n.º 110, 5.º Andar, 1250-146 Lisboa.
Processing Security
ALYX PROPERTIES is committed to ensuring the safe protection of personal data, having adopted technical and organizational security measures to protect the personal data made available against forms of unlawful processing, its dissemination, loss, misuse, amendment, treatment or unauthorised access. In this regard, it requires its data processors and its partners to adopt security measures equivalent to those it practices.
Data Processors
In the pursuit of its business, ALYX PROPERTIES may use third-party entities – Data Processors – for the provision of certain services, which may involve access by these third parties to the data subject’s personal data. ALYX PROPERTIES ensures that, in these circumstances, appropriate technical and organizational measures are adopted to ensure that these entities meet the applicable legal requirements and offer adequate guarantees in terms of data protection. Thus, any Data Processor shall process personal data in the name and on behalf of ALYX PROPERTIES and in accordance with the purposes determined by the latter.
Personal Data Processing
In compliance with the principles of lawfulness, loyalty and transparency, collection for specific, explicit and legitimate purposes, minimization, accuracy and security and integrity of information, ALYX PROPERTIES processes the personal data made available by the data subject or those to which the data subject has granted access, assuming that it is true and up-to-date. Processing means any operation carried out on personal data, by automated or non-automated means, such as collection, registration, organization, retention, amendment, consultation, use, disclosure, restriction, erasure or destruction.
Personal Data Collection
Personal Data means the information, of any nature, regardless of its support, relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, specially by reference to an identifier such as a name, an identification number, contact details, location data, online identifiers or to one or more factors specific to their physical, economic, cultural or social identity. In carrying out its duties, ALYX PROPERTIES may collect and process, among others, data from its employees, customers and service providers, which may be collected through the following means:
a. Data provided directly by the data subjects in the course of their activity, as well as through the website forms or other means of communication (e.g., email, letter);
b. Cookies: For more information see the Cookies Policy.
Purpose of the Data collected and Fundamentals of Lawfulness of the Processing
Personal data are processed for the specific, explicit and legitimate purposes for which they were collected, and cannot be further processed in a manner incompatible with these purposes. ALYX PROPERTIES processes the personal data necessary for the pursuit of its business, compliance with contractual or pre-contractual obligations, as well as applicable legal or regulatory obligations, and may perform other processing of personal data when it has obtained the data subject’s prior, free, express and informed consent.
Data Transmission to Third Parties
Personal data may be transmitted to group companies to which ALYX PROPERTIES belongs, ensuring confidentiality, compliance with the privacy policy implemented in accordance with applicable legal requirements, in a manner compatible with the purposes determining the processing. Personal data may also be transmitted to comply with applicable legal or regulatory obligations from judicial or administrative authorities, in cases where such transfer is mandatory, and to data processors who shall process the data on behalf of ALYX PROPERTIES and in accordance with the purposes determined by the latter.
Data Subjects Rights
Pursuant to the law in force, the data subject is entitled to the following rights which may be exercised through the contacts provided for in Section 3. ‘Data Protection Officer’ – Rights of access, rectification, erasure, restriction of processing, portability, opposition or refusing automated decisions. Where the processing is carried out on the basis of consent, the data subject has the right to withdraw it at any time, without said withdrawal of consent prejudicing the lawfulness of the processing carried out on the basis of the previously granted consent. The data subject also has the right to complain to the Portuguese Data Protection Authority.
Data Retention
The period of time during which the data is stored and retained varies according to the purpose for which the information is processed. Whenever there is no specific legal requirement, the data shall be stored and retained only for the minimum time necessary for the purposes that motivated its collection or its subsequent processing after which they shall be eliminated.
Data Communications
The User acknowledges that ALYX PROPERTIES may communicate Users’ data in the context of ongoing mergers, acquisitions and/or incorporations, not considering such communication as a transfer of data to third parties, nor there being any subcontracted processing.
Data Transfer
ALYX PROPERTIES shall only transfer data to third countries outside the European Union or the European Economic Area, where permitted by law, by legal requirement and/or with the data subject’s express authorisation. Should it use service providers from third countries, ALYX PROPERTIES shall contractually ensure that these entities comply with all legal obligations regarding data protection by providing them with ALYX PROPERTIES`s prior and documented instructions.
Amendments to the Privacy Policy
ALYX PROPERTIES reserves the right to, at any time, make adjustments or amendments to this Privacy Policy, said changes being duly publicised.
