Privacy Policy

1. Data Controller

The data controller for personal data collected through this website and our services is PortoPrime, with registered office at Rua Fernando Farinha 25C, 1950-273 Marvila, Lisboa, Portugal.

For any privacy-related questions or to exercise your rights, contact us at: • Email: privacy@portoprime.pt • Phone / WhatsApp: +351 915 481 058

2. Information We Collect

We collect the following categories of personal data:

• Identification data — full name, email address, phone number • Property information — location, type, condition, ownership status • Communication content — messages you send through forms or WhatsApp • Technical data — IP address, browser type, device, operating system • Behavioural data — pages viewed, links clicked, time on site, referral source • Marketing identifiers — Meta browser cookies (_fbp), click identifiers (fbc)

We do not knowingly collect data from children under 16.

3. How We Use Your Data

We process your data for the following purposes, on the legal bases indicated:

• To respond to your enquiries and provide our services — performance of a contract (Art. 6(1)(b) GDPR) • To send you the Investment Guide PDF or other resources you requested — consent (Art. 6(1)(a) GDPR) • To improve our website and services through analytics — legitimate interest (Art. 6(1)(f) GDPR) • To run targeted advertising on Meta platforms (Facebook, Instagram) — consent (Art. 6(1)(a) GDPR) • To comply with our legal and tax obligations — legal obligation (Art. 6(1)(c) GDPR)

4. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our website, remember your preferences (such as language), analyse traffic, and measure the performance of our advertising.

The types of cookies we use:

• Essential cookies — required for the site to function (e.g., locale preference). Always active. • Analytics cookies — help us understand how visitors use the site. • Marketing cookies — Meta Pixel cookies (_fbp, _fbc) used to measure and personalise advertising on Facebook and Instagram.

You can refuse non-essential cookies via the cookie banner shown on first visit, or change your browser settings at any time.

5. Sharing With Third Parties

We share data with the following categories of recipients, only when strictly necessary:

• Meta Platforms Ireland Ltd. — for advertising measurement and audience building. We send hashed contact details and pseudonymous identifiers via the Meta Pixel and the Conversions API. See Meta's privacy policy at https://www.facebook.com/privacy/policy/ • Vercel Inc. — our hosting provider, which processes server logs and IP addresses on our behalf. • Email service providers — for sending transactional emails (lead notifications, the Investment Guide). • Portuguese tax and regulatory authorities — only when legally required (e.g., AL/AIMA reporting where applicable).

We do not sell your personal data to anyone.

6. International Data Transfers

Some of our processors (Meta, Vercel) are based outside the European Economic Area, including in the United States. Where data is transferred outside the EEA, we rely on the European Commission's Standard Contractual Clauses or other adequacy mechanisms recognised under Articles 45–46 GDPR to ensure your data receives an essentially equivalent level of protection.

7. Data Retention

We retain personal data only as long as necessary for the purpose for which it was collected:

• Lead-form submissions — up to 24 months from last contact, unless you become a client. • Active client data — for the duration of the contract plus 10 years (Portuguese accounting / tax law). • Marketing analytics — up to 13 months at Meta level (default Pixel data window).

After the retention period, data is deleted or anonymised.

8. Your Rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you (Art. 15) • Rectify inaccurate data (Art. 16) • Erase your data ("right to be forgotten", Art. 17) • Restrict processing (Art. 18) • Object to processing based on legitimate interest, including direct marketing (Art. 21) • Data portability (Art. 20) • Withdraw consent at any time, without affecting prior processing (Art. 7(3))

To exercise any of these rights, email privacy@portoprime.pt. We will respond within 30 days.

You also have the right to lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD) — https://www.cnpd.pt

9. Security

We use industry-standard technical and organisational measures to protect your data: HTTPS encryption in transit, encrypted databases at rest, restricted access on a need-to-know basis, and regular security reviews. No system is 100% secure, but we work continuously to minimise risk.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The "last updated" date at the top of the page indicates the current version. Material changes will be communicated via a notice on our website or by email to active clients.

11. Contact

If you have questions about this Privacy Policy or our data practices, contact us:

PortoPrime Rua Fernando Farinha 25C 1950-273 Marvila, Lisboa, Portugal Email: privacy@portoprime.pt Phone / WhatsApp: +351 915 481 058