Privacy Policy
INTRODUCTION – Not a certified translation, Portuguese version prevails before the law
With this privacy policy and personal data protection, Lusomena Investments, Unipessoal Lda., corporate entity number 517484170, headquartered at Estrada Consiglieri Pedroso, nº 80 Queluz Park, Lote 3 – Armazém 8, 2730-053 Barcarena, hereinafter referred to as “LUSOMENA” or “LUZNUR,” aims to inform Customers/Users about LUSOMENA’s policies and procedures regarding the collection, use, processing, and disclosure of any personal data transmitted directly by its Customers/Users or through third parties, through the use of the website operated by LUSOMENA – www.luznurcapital.com. LUSOMENA respects the privacy of its Customers/Users and is committed to protecting the information it collects from them, as well as complying with the current legal regulations defined by the General Data Protection Regulation (GDPR).
Accessing and using the website, as well as subscribing to the services and products it offers, imply the agreement, acceptance, and binding of users to this privacy policy and data protection.
1. WHO WE ARE?
LUSOMENA is a commercial company that operates in the real estate mediation and promotion sector, providing services to national and foreign clients.
LUSOMENA is committed to protecting the personal data of Customers/Users of the products and services it offers, as well as the personal data of the respective owners in all situations where personal data processing occurs.
2. NEED FOR THIS POLICY
Through this policy, the aim is to inform Customers/Users about the general rules for the processing of personal data, which are collected and processed in strict compliance with the legislation on personal data protection in force at all times, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), as well as other legislation on this subject that is applicable or comes into force, notably Law No. 58/2019 of 8 August.
LUSOMENA is dedicated to the protection and confidentiality of personal data, having adopted the measures it considers appropriate to ensure the accuracy, integrity, and confidentiality of personal data, as well as all other rights of the respective owners of such personal data.
LUSOMENA adheres to best practices in the field of security and protection of personal data and has implemented the necessary technical and organizational measures to comply with the GDPR and ensure that the processing of personal data is carried out lawfully, fairly, transparently, and limited to the purposes authorized under the GDPR and other applicable legislation.
Through this Privacy Policy and Data Protection, the aim is also to finalize the provisions on the protection and processing of personal data provided in the contracts that Customers/Users have established or will establish with LUSOMENA, as well as the rules set out in the terms and conditions that regulate the provision of various services, duly advertised on our website.
3. PERSONAL DATA SECURITY MEASURES
LUSOMENA has always been committed to ensuring the protection and security of the personal data provided to it. To this end, LUSOMENA has implemented an internal security policy, and compliance with these rules is an obligation for all those who legally access them, especially its employees. These rules and security measures are of a technical and organizational nature and aim to protect personal data against its dissemination, loss, misuse, alteration, unauthorized access or processing, as well as against any other form of unlawful processing.
Furthermore, third parties who, within the scope of service provision, process the Customer/User’s personal data on behalf and on behalf of LUSOMENA, are required, in writing, to implement appropriate technical and security measures that, at all times, meet the requirements set forth in the GDPR and any other applicable legislation, aiming to safeguard the rights of the data subject.
As part of LUSOMENA’s internal security policy, all forms of online collection of personal data are encrypted and securely stored, and physical and logistical security measures have also been implemented.
However, this action by LUSOMENA does not exempt Customers/Users from adopting security measures, particularly regarding the use of personal online defense systems (firewall, antivirus, anti-spyware, website credibility verification tools, etc.)
4.WHAT ARE PERSONAL DATA?
For the purposes of Article 4(1) of the GDPR, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.’
5. PROCESSING OF PERSONAL DATA
For the purposes of Article 4(2) of the GDPR, ‘processing’ means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
6. WHO IS THE DATA CONTROLLER?
LUSOMENA is the data controller responsible for the processing of personal data in accordance with the purposes and means of processing at any given time. If a data subject needs to contact LUSOMENA for the purposes stated in this policy or under the GDPR, they can do so by emailing info@luznurcapital.com or by sending a written communication to the company’s registered office at: Estrada Consiglieri Pedroso, No. 80 Queluz Park, Lot 3 – Warehouse 8, 2730-053 Barcarena.
7. IS THERE A DATA PROTECTION OFFICER?
Although LUSOMENA is not required to have a data protection officer under the GDPR and other applicable legislation, LUSOMENA has chosen to implement this solution.
The possibility of having and appointing a data protection officer is provided for in Articles 37 and subsequent articles of the GDPR.
You can contact the data protection officer of LUSOMENA, in this case João Carvalho, at the following email address: info@luznurcapital.com
8. TYPES OF PERSONAL DATA THAT MAY BE PROCESSED
Considering the activities carried out by LUSOMENA, this entity processes personal data necessary for the provision of services, supply of goods, or in its social responsibility activities, treating personal data such as name, address, telephone number, email address, or taxpayer identification number. The information collected may vary depending on the information provided by the Client/User.
With the exception of legal obligations, all data will be processed exclusively by LUSOMENA only to the extent necessary for the development of its activities, also allowing the Client/User to access specific service features, suggestions, and proximity information services.
Personal data, traffic data, geographic location, profile, and/or consumption data may be processed for advertising purposes or to disclose offers of goods or services by LUSOMENA, provided that the respective data subject has authorized/consented to it.
If there is prior consent from the Client/User, it can be withdrawn at any time, without prejudice to the lawfulness of the processing based on the previously given consent. To withdraw consent, you can use the email address: info@luznurcapital.com
9. CIRCUMSTANCES OF PROCESSING BY SUBCONTRACTORS
In the scope of the activities carried out, LUSOMENA may engage third parties to provide certain types of services that may involve access, by these entities, to personal data of Clients/Users. When this happens, LUSOMENA ensures that subcontractors comply with the provisions of the GDPR and any other applicable legislation, as well as compliance with certain rules that are similar to our internal security policy. In the case of personal data being communicated to other subcontracted entities, LUSOMENA remains responsible for that personal data.
10. PURPOSE OF PERSONAL DATA
Personal data is intended solely for LUSOMENA or companies within its group and may only be used by third parties for the purpose of fulfilling legal obligations
11. COLLECTION OF PERSONAL DATA
LUSOMENA only collects personal data through telephone, email, contractual means, through its website(s), and always ensures the prior consent of the data subjects.
Please note that some personal data is indispensable for the execution of the contracts entered into, and the lack or insufficiency of such data may jeopardize the provision of services or the supply of goods by LUSOMENA. The rules of this policy apply to data subjects who are not
Clients/Users of LUSOMENA.
The collected personal data may be processed both electronically and non-electronically. LUSOMENA ensures compliance with the GDPR and any other applicable legislation. Personal data is stored in specific databases created for this purpose. Personal data will never be used for a purpose other than that for which it was collected or for which consent was given by the data subject.
12. PURPOSES
In general, the personal data collected is based on and intended for the management of the contractual relationship, the provision of contracted services, the adaptation of services to the needs and interests of the Client/User, and information and advertising actions.
As previously stated, personal data may also be processed for the purpose of fulfilling legal obligations.
If consented by the Client/User, LUSOMENA may use the personal data provided by the data subject for other purposes, such as social responsibility actions, sending complaints and suggestions, informing about campaigns, promotions, advertising, and news about LUSOMENA’s products and/or services, as well as conducting market research or evaluation surveys.
13. RETENTION OF PERSONAL DATA
The retention and storage of personal data are necessarily related to the purpose for which the information was collected and processed.
Except in cases where there may be a legal obligation to retain personal data, such data will only be stored and retained for the minimum period necessary for the purpose for which they were collected.
14. TRANSFER OF PERSONAL DATA
LUSOMENA does not transfer personal data, and if such transfer were to occur, it would be done in accordance with the GDPR and any other applicable legislation. However, this does not affect the exercise of the right to data portability by the data subject.
15. YOUR RIGHTS AND HOW TO EXERCISE THEM
As a data subject, LUSOMENA guarantees you the right to access, rectify, update, limit, and delete your personal data at any time (except for data that is essential for the provision of services or the supply of goods in an ongoing contractual relationship), the right to object to the use of your data for commercial purposes by LUSOMENA, the right to withdraw consent, and the right to data portability. LUSOMENA provides all the rights conferred by the Law that the data subject may exercise.
To exercise these rights, you can contact us via email at info@luznurcapital.com or by written communication addressed to the company’s registered office at Estrada Consiglieri Pedroso, nº 80 Queluz Park, Lote 3 – Armazém 8, 2730-053 Barcarena.
16. COMPLAINTS
Although you can directly submit any complaints to LUSOMENA as mentioned above, you have the right to lodge a complaint directly with the supervisory authority, which in Portugal is the National Data Protection Commission (CNPD), located at Av. D. Carlos I, 134, 1º, 1200-651 Lisbon.
17. CHANGES TO THE PRIVACY AND PERSONAL DATA PROTECTION POLICY
LUSOMENA reserves the right to make changes to this policy whenever necessary. Any such changes will be publicized through the channels used by LUSOMENA.
