Privacy Policy

Last updated: October 31, 2025

 

1. Introduction

This Privacy and Personal Data Protection Policy aims to inform users of the website realty.luznurcapital.com (hereinafter the “Website”) about how Lusomena Investments, Unipessoal Lda., corporate number 517484170, with registered office at Estrada Consiglieri Pedroso, No. 80, Queluz Park, Lote 3 – Warehouse 8, 2730-053 Barcarena (hereinafter “LUSOMENA” or “LUZNUR”), collects, uses, processes, and protects their personal data.
LUSOMENA respects the privacy of all users and ensures that personal data processing complies with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Law No. 58/2019 of 8 August, which implements the GDPR in Portugal. Access and use of this Website, as well as the completion of forms or account creation, imply knowledge and express acceptance of this Privacy Policy.

 

2. Who we are

LUSOMENA is a Portuguese company operating in real estate mediation, promotion, and marketing, providing services to national and international clients, including through digital platforms under the LUZNUR brand.
The Website functions as an informational and contact portal, allowing property viewing, user registration for saving favorites, and submission of information requests.
No payments or commercial transactions are processed through the Website.

 

3. Scope and purpose

This Policy establishes the general rules applicable to the collection and processing of personal data obtained through the Website, ensuring lawfulness, fairness, transparency, and limitation to the specific purposes for which data were collected.
LUSOMENA undertakes to adopt all appropriate technical and organizational measures to protect personal data against destruction, loss, alteration, disclosure, or unauthorized access.

 

4. Definition of personal data

Under Article 4(1) of the GDPR, “personal data” means any information relating to an identified or identifiable natural person, namely through a name, identification number, location data, online identifier, or other specific elements of their identity.

 

5. Collection and types of personal data

LUSOMENA may collect and process the following personal data:

  • Identification data: first and last name;
  • Contact data: email address and phone number;
  • Usage data: saved properties, preferences, browsing history, and submitted forms;
  • Technical data: IP address, device type, browser, and approximate location;
  • Other optional data: information voluntarily provided in messages, forms, or communications.

Data are collected directly through the Website or voluntary user contact and will only be used for the purposes expressly identified in this Policy.

 
6. Purposes of processing

Personal data collected are used exclusively to:

  1. Manage contact requests and respond to information inquiries;
  2. Enable user account creation and management;
  3. Send informational communications and newsletters, only with prior consent;
  4. Improve the operation and user experience of the Website;
  5. Comply with legal obligations or respond to requests from competent authorities.
    Data will never be used for purposes other than those indicated without the data subject’s prior consent.
 
7. Legal basis for processing

The processing of personal data by LUSOMENA is based on one or more of the following grounds:

  • Consent of the data subject;
  • Performance of pre-contractual measures at the data subject’s request;
  • Compliance with legal obligations to which LUSOMENA is subject;
  • Legitimate interest, where applicable, such as ensuring network and Website security.
 
8. Security measures

LUSOMENA implements appropriate technical and organizational measures to protect personal data, including:

  •  Use of encryption protocols (HTTPS);
  • Secure storage on servers located within the European Union;
  • Access control and internal permission management;
  • Internal confidentiality policies and staff training.

Users are also responsible for adopting appropriate security measures, such as using updated devices and antivirus software.

 
9. Data sharing and subcontracting

LUSOMENA does not sell or share personal data with third parties for commercial purposes.
However, it may use service providers (e.g., web hosting, maintenance, email delivery) that process data on behalf of LUSOMENA.
In such cases, written contracts ensure compliance with the GDPR and confidentiality and security obligations.

 
10. Data retention

Personal data are retained only for the period strictly necessary for the purposes for which they were collected or as required by law.
After the retention period, data are securely and irreversibly deleted.

 
11. Rights of data subjects

Under applicable law, data subjects have the following rights:

  • Access their personal data;
  • Rectify incorrect or outdated data;
  • Request erasure of their data (“right to be forgotten”);
  • Restrict processing;
  • Object to processing, where legally applicable;
  • Data portability to another entity;
  • Withdraw consent at any time, without affecting the lawfulness of prior processing.

These rights can be exercised via email at info@luznurcapital.com or by post to the company’s registered office.

 
12. Data protection officer

LUSOMENA has appointed João Carvalho as Data Protection Officer (DPO), who can be contacted at info@luznurcapital.com

 
13. International data transfers

Currently, LUSOMENA does not transfer personal data outside the European Economic Area (EEA).
Should such transfers occur in the future, appropriate safeguards will be implemented in accordance with the GDPR, such as EU Standard Contractual Clauses.

 
14. Social media

LUSOMENA maintains an institutional presence on social networks, including Instagram, LinkedIn, and YouTube.
Data processed on these platforms are governed by each network’s own policies.
Users interacting with LUSOMENA’s official pages acknowledge that their published content (e.g., comments, messages, images) may be publicly visible.

 
15. Complaints

Without prejudice to submitting a complaint directly to LUSOMENA, data subjects have the right to lodge a complaint with the competent supervisory authority:
Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134 – 1.º, 1200-651 Lisbon, Portugal

 
16. Changes to the privacy policy

LUSOMENA reserves the right to amend this Policy at any time to reflect legislative, technological, or organizational changes.
Any updates will be published on this Website, indicating the date of the latest revision.