Notice on the Protection of Personal Data for Clients
and Subcontractors or Professional Suppliers
In the context of its activities, the company, in its capacity as real estate developer, is brought into contact with the personal data of natural persons, hereinafter called Personal Data, collected by the Professional Client, who acts in his/her capacity as controller of the same Personal Data.
When the contract with the Professional Client entails the processing of Personal Data by the company, it undertakes to do so within the limits of the purposes agreed with the Professional Client and in compliance with current regulations, including the General Data Protection Regulation (EU) 2016/679, applicable in the countries of the European Union, and relating to the protection of individuals with regard to personal data.
When modifying these regulations, the company will adapt this document as necessary and notify the Professional Client of any applicable changes by making an adapted version of this notice available online.
Circumstances in which the company may get in touch with or have to process the request of the Professional Client of Personal Data are the following (non-exhaustive list):
• to conserve and manage the commercial relationship that binds the Client to the company;
• to fulfil its regulatory and legal obligations in terms of financial management;
• to ensure the legitimate interests of the company in the event of litigation;
• for marketing purposes;
• for analysis and statistical evaluation purposes.
• Any related transaction and direct and indirect connection with its business and without limitation
When performing any service on behalf of the Professional Client, the company undertakes, when handling or processing Personal Data, to:
• Treat such Personal Data only as instructed by the Professional Client;
• Ensure the security of this Personal Data and limit access to the necessary minimum to be able to execute a contractual service requested by the Professional Client;
• Implement security measures to protect such Personal Data against intentional or accidental disclosure;
• Respect the strict confidentiality of this Personal Data and thereby neither give access to it nor transfer it to a third party without the instruction of the Professional Client;
• Inform the Professional Client and ensure their agreement, in the event that a subcontractor of the company should be involved in the processing of their data;
• Make no use whatsoever of such Personal Data for their own behalf;
• Impose an obligation of confidentiality on employees to have respect vis-à-vis Personal Data;
• Notice on the Protection of Personal Data for Professional Clients;
• Provide the Professional Client, insofar as he/she depends on the technical skills of the company, the necessary assistance, if the Professional Client must respond to deletion request for deletion or provision of such Personal Data (request formulated by a an authorised body, in accordance with current laws, or a natural person wishing to exercise the rights which he/she receives under the General Data Protection Regulation (UE2016 / 679);
• Notify, within the time limits imposed by law, the Professional Client and the competent authorities, in this case the National Commission for the Protection of Data (CNPD), after becoming aware of a security incident that may result in the violation of this Data.
Any obligation imposed by law on the company, and any commitment that the company undertakes regarding the processing of Personal Data or mere access to Personal Data, shall in no case absolve the Professional Client of their own obligations in this regard.
Notably, and even if the company acts as a subcontractor, the Professional Client will remain subject to the legal obligations imposed on them as the person in charge of the processing of Personal Data and will have to ensure, for their part, that this Data is protected.
Natural Persons/Private Clients