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PRIVACY NOTES

This Privacy Policy intends to provide all the relevant information about the collection and processing of your personal data for use on this website, including any data you may provide through this website by subscribing to our newsletter, asking for information about our projects or services, or taking part in a survey and/or application process.

This privacy policy must be read together with and in addition to any other privacy information or notice that we may provide in specific cases.

This website is not for children and we do not intentionally collect data relative to children.

1. ABOUT US

TRANSFOR GROUP,

with head office at Rua Serpa Pinto, 14A – 2º 1200-445, is a private Portuguese company working in the civil construction sector.

TRANSFOR GROUP consists of the following companies: Transfor Engenharia e Construção S.A. (Licence no. 50673 and Tax no. 505185628), Transfor Indústria S.A. (Licence no. 60176 and Tax no. 506829952) and Nova Transfor – Interiores S.A. (Licence no. 87944 and Tax no. 514671122).

2. CONTROLLER OF THE DATA PROCESSING

TRANSFOR is the controller of the processing of your personal data, and you may contact us to clarify any doubts you have, or to exercise your rights using the following contact details:

TRANSFOR GROUP

Head Office: Rua Serpa Pinto, 14ª – 2º

1200-445 Lisbon

Telefone: +351 211 165 847

E-mail: info@transforgroup.com

3. WHAT KIND OF PERSONAL DATA WE COLLECT

Personal data is information about a living, identified or identifiable person. It is a identifiable a person that can be identified, direct or indirectly, mainly by a identifier, such as a name, number of identification, location data, electronic identifiers or by a specific physical aspect, fisiologic, genetic, mental, economic, cultural or social.

We can collect, use, store and transfer different kinds of personal data about you, which we group into the following categories:

a. Identification data, namely and when applicable, name and date of birth;

b. Contact data, namely address, e-mail address and telephone numbers;

c. Professional data, namely and when applicable, business field and curriculum vitae;

d. Technical data, namely and when applicable, your IP address, session start data, browser type and version, settings and time zone location, types and versions of browser plug-ins, operating system and platform and other technologies of the devices you use to visit this website;

e. Website usage data, namely information about how you use our website, products and services;

f. Communication and marketing data, namely and when applicable, the user preferences in relation to communication and marketing.

We do not collect any special categories of personal data about you, namely data relating to health, biometric data, genetic data and data regarding racial or ethnic origin, data about your sex life, religious and political convictions or union membership.

4. HOW YOUR PERSONAL DATA ARE COLLECTED

Personal data may be collected using a variety of methods such as through direct interactions with you, whereby the data subject shall provide us with his/her data by filling in a form or contacting us by post, e-mail or other means, namely when requesting information about our real estate products, when subscribing for news or newsletters or when a request is made to send marketing communications or other interactions linked to our business. We can also collect personal data from public sources or third parties authorized to share such data.

Data can also be automatically collected by interacting with this website, namely collecting technical data and website usage data. See more information in our Cookies Policy.

5. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSE

We only process personal data when it is necessary to comply with legal requirements or when it is necessary to fulfil a contract or pre-contractual procedures therein related.

We may also process information if we have a legitimate interest to do so, provided that, case by case, our interest is in accordance with the applicable legislation and the data subject’s rights; this may occur for the purpose of communication with our clients, recruitment of employees, prevention and detection of fraud, information about investment projects, clarification of additional information, questions or information requests about investment opportunities.

When none of the other conditions apply to justify the data processing, we shall only process the information if we have obtained consent from the data subject to process his/her personal data for specific, explicit and legitimate purposes.

6. INTERNATIONAL TRANSFERS AND TRANSMISSION OF PERSONAL DATA

Unless expressly declared in this document or in any additional privacy notice, we shall not transfer your personal data outside the European Economic Area (EEA).

We may have to share your personal data with external entities who provide services to us, namely suppliers of administration services of IT systems, professional consultants such as lawyers, auditors and insurers based in the EEA, as well as public entities, regulatory bodies, Tax and Customs Authorities and other entities to comply with legal requirements.

7. DATA SECURITY

Your personal data are important to us and, as such, we have implemented suitable security measures to prevent your personal data from being accidentally lost, used or accessed, changed or disclosed without authorization, as well as internal procedures to mitigate any risks associated with processing these data.

We also make every effort necessary to ensure that the third parties that collaborate with us as partners or service providers are under contract to guarantee suitable protection of the personal data they may have access to. We restrict access of the personal data to specific employees, and only when the access to these data is justified to carry out their jobs.

8. PERSONAL DATA STORAGE PERIOD

We shall only store your personal data for the time needed to comply with the purposes for which they were collected, including for the purposes of complying with legal, taxation and accounting requirements.

To establish the suitable storage period for the personal data, we consider the quantity, nature and sensitivity of the data, the potential risk of damage caused by the non- authorized use or disclosure of the personal data, the purposes for which the data is processed and whether we can achieve these purposes using other means, and the applicable legal requirements.

More specifically, and without limitation, we have to keep basic information about our clients by law (including contact, identification, financial and transaction data) for a minimum period of 10 years after they have stopped being our clients, for the purposes of taxation, financial auditing and record-keeping.

In some circumstances, you can ask us to delete your data.

9. RIGHTS OF THE DATA SUBJECTS AND EXERCISING THESE RIGHTS

In certain circumstances, you have rights in relation to your personal data in accordance with data protection legislation.

For your information, you may at any time but always taking into account the specific situation and the respective legal restrictions exercise the following rights in relation to one of the Data Processing Controllers:

a) Request access to information, whereby the data subject is entitled to obtain confirmation that the data pertaining to him/her are being processed or not, and if so, accessing his/her personal data and the information outlined by law;

b) Request rectification of the data held about him/her, if these data are inaccurate or incomplete;

c) Request deletion of his/her personal data, without unjustified delay, when applicable, namely for one of the following reasons:

i. The personal data are no longer necessary for the purposes for which they were collected or processed;
ii. The data subject objects to the processing of the data and there are no overriding legitimate grounds for the processing them; or
iii. The data subject withdraws consent for the data processing (when the processing is based on consent) and there is no other reason for the processing in question;

d) The data subject request limited processing or his/her personal data, namely in one of the following situations:
i. To contest the accuracy of the personal data, for a period enabling a check on the accuracy of the personal data;
ii. The processing is lawful and the data subject opposes the deletion of the personal data and requests the restriction of their use instead;
iii. The personal data is no longer needed for the purposes of the processing, but they are required by the data subject for a declaration, to exercise or defend a legal right in a judicial proceeding;
iv. When the processing is opposed, until it is confirmed that the legitimate reasons of the controller for the processing prevail over the reasons of the data subject;

e) The data subject opposes the treatment of his/her personal data, in cases in which the data processing takes place for the purpose of our legitimate interests or when the data is processed for direct marketing purposes.

If you want to exercise one of the above-mentioned rights, contact us using the contact data shown above. We point out that it may be necessary to request specific information to confirm your identity and guarantee you are entitled to exercise these rights, and to guarantee that we do not supply data to third parties that do not have the right to receive such data.

All requests will be answered within one month, unless your request is particularly complex or if you have made several requests. Notwithstanding, we will always inform you if the response time is extended.

No fee shall be payable to exercise your rights. However, if your request proves unsubstantiated, repetitive or excessive, we are entitled to charge a reasonable fee, or alternatively to refuse the request.

We remind you that you are always entitled to present a complaint to the Portuguese Data Protection Authority (CNPD), whose contact details can be found at www.cnpd.pt. However, we would appreciate you giving us the opportunity to respond to your questions.

10. UPDATES AND LINKS TO THIRD-PARTY WEBSITES

This privacy policy can be updated at any time, and the latest version is provided directly on this page.

This website may include links to third-party websites, plug-ins and applications. Clicking on these links or activating these connections may enable third parties to collect or share data about you, which is not controlled by us and which cannot be imputed to us. Therefore, we recommend that you read the privacy policy of all the websites you visit outside this website.

11. COOKIES

This website uses cookies. When you visit the website, we may install small information files on your computer known as “cookies”. Cookies are stored by the browser on the hard disk.

Within the scope of this website, we distinguish between two kinds of cookies:

a) Technical cookies, i.e. cookies that are necessary for the good functioning of this website;
b) Performance and tracking cookies, i.e. cookies that gather information about the user and improve performance, but which are not necessary for proper functioning.

In general, cookies help us in several ways: we use cookies to organise the website or the information about our products, and to make this information more tailored to the interests or preferences of the user. Cookies allow us to know which pages and what content has been visited, the frequency of visits to certain pages, which are the favourite areas of the website and generally guide us about the website usage.

Users have the option to manage cookies by selecting the respective option in their browser. However, we point out that if you choose to deactivate or refuse cookies, some parts of this website may be inaccessible or not function correctly.