OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
Table of Contents
Definitions
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – Ellis Real Estate Portugal
Relevant Legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section Datacontroller) for clarification.
Data Protection Principles
We promise to follow the following data protection principles:
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- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Contact forms and email links
Should you choose to contact us using the contact form on our website or an email link, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section Third Party Data Processors. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
Real Estate services – Information you have provided us with
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- Your first name, last name, email address, phone number & message;
- Your property with description, location and images;
- Guest stay data, including date of arrival and departure, special requests made, observations about your object preferences;
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your IP address. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. If so, we use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website might use the analytics.js implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this or other websites.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it. The information is only used for safety in an effort to block illegal access to this website and / or to avoid spam. It does not use your IP address to identify you, the individual, in any way.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.
How we use your Personal Data
We use your Personal Data in order to:
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- provide our real estate service to you. This includes for example registering your preferences; providing you with other services that you have requested; providing you with promotional items at your request and communicating with you in relation to those services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience;
- fulfil an obligation under law or contract;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
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- to identify you;
- to provide you a service or to send/offer you a offer;
- to communicate either for help, assistance, sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
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- to communicate with you;
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of services offered/provided;
- to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
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- to send you emails about your reservation, our services and occasional exclusive offers;
- for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than is necessary.
Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
We will inform you of any further Processing and purposes.
Third Party Data Processors
We do not share your Personal Data with strangers. We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section. All these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
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- Google (Privacy policy)
Google Web Fonts
For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
Further information about handling user data, can be found at
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- Google (Privacy policy)
- Google (Google Fonts)
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems 24/7/365 for possible vulnerabilities and attacks. The website and webserver are always up to date with latest software and are secured with a reputable firewall.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
Children
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
This website uses various types of cookies.
What are cookies?
Cookies are small text files that store certain data. The website you are visiting sends the file automatically to your internet browser. The text file is then installed on your PC, laptop, tablet or mobile phone (depending on which of these devices you are using to visit the website).
Why does we use cookies?
A cookie makes your next visit to the website easier if you are using the same PC, laptop, tablet or mobile phone and the same internet browser. Your website preferences are stored in the cookie and then loaded automatically.
What cookies does this website use?
We use various types of cookies:
Functional cookies
Functional cookies are anonymous cookies used to ensure that the website operates smoothly. Without them the website would not work properly. Functional cookies remember your settings, for example the language in which the website is shown. But they cannot identify you personally. We do not need to obtain consent to use functional cookies.
Analytical cookies
Analytical cookies enable us to analyse the use of the website. This allows us to improve the website, making it pleasanter for you to use and easier for you to find what you are looking for. We do not need to obtain consent to use analytical cookies.
This website does not use third party cookies. If you share a page through the social media buttons (Facebook, Twitter, LinkedIn, YouTube etc.), you must then log in on the relevant social media channel and approve the terms and conditions of that channel. The website has only included links to the relevant social media channels.
Why does the announcement keep returning?
A cookie is linked to an internet browser, not to a person. For example, if you first use Google Chrome to visit the website and later use another internet browser such as Internet Explorer, we must once again inform you that cookies are used on the website. This also applies if you use a different device when returning to the website.
Do you regularly delete all your cookies? If so, you will also delete your previous choice permitting the use of cookies on this website. In such a case, we will once again have to inform you that cookies are used on this website.
How can I block cookies?
You can do this by adjusting the preferred settings of your internet browser to reject all cookies. Please note that this may mean that the website no longer functions properly. In the internet browser you can also choose to permit only certain types of cookies or be sent notification when a website wishes to store a cookie.
How you can adjust the settings for blocking and controlling certain types of cookies depends on the internet browser you are using. To find out, you can consult the help function of your internet browser or visit www.aboutcookies.org where the procedure for controlling cookies in most browsers is set out step by step.
How can I delete cookies?
You can delete all cookies that have been stored on your PC, laptop, tablet or mobile phone by an internet browser. How you do this depends on which internet browser you use. To find out, you can consult the help function of your internet browser or visit www.aboutcookies.org where the procedure for deleting cookies in most browsers is set out step by step.
We might use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
About this webiste’s server
This website is hosted by Alentejo Hosting within a Dutch data centre located just outside Amsterdam (Wormer).
There services are provided from the DataOne datacenter in Wormer, near Amsterdam in The Netherlands. DataOne is a hypermodern datacenter which surpasses all requirements for datacenter facilities.
Some of the data centre’s more notable security features are as follows:
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- All facilities (electricity, network, cooling, fire detection system and gas extinguishing installation) are redundant
- Blast proof anti-intruder shielded external windows and doors
- Hot and Cold corridor
- Server cabinets have locked doors (no open racks)
- Perimeter and internal IP CCTV system monitored 24×7
- 24×7 on-site security guards
- Only authorised persons are allowed into the facility
Full details of Alentejo Hosting’s data centre can be found here.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
Data Controller
Supervisory Authority
The data controller of this website is: Ellis Real Estate Portugal, a Portuguese Company with company number: 513997555
Whose registered office is:
Rua José de Oliveira,
Lote 4.1, 1 andar O,
8800-532, Santa Luzia,
Tavira, Portugal
Data Protection Officer
Mrs. Ellis Reichgelt
Director, Ellis Real Estate Portugal
Email: info@ellisrealestateportugal.com
This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.
Change log
25/05/2018
- Privacy policy instigated
