(Last updated: 11.10.2022)
3 Lagoas Unipessoal, Lda. (hereinafter referred to as “3 Lagoas”), collective entity number 516 332 422, with headquarters at Av. Almirante Gago Coutinho nº30, 1000-017 Lisboa, Portugal, is the entity responsible for the website lisbonheights.pt and lisbonheights.com (hereinafter, the “Website”), also acting as the controller in accordance with the General Data Protection Regulation; i.e. it is the entity that “determines the purposes and means of the processing of personal data”.
This document (hereinafter the “Policy”) contains information on how personal data is collected and processed through the website.
If you have any further questions, please contact us at email@example.com
Processing of personal data
Fundamentals for data processing
According to the General Data Protection Regulation, processing of personal data means any operation or set of operations which is performed upon personal data or upon sets of personal data, by automated or non-automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
The processing of personal data for a specific purpose must meet one of the legal grounds provided for in the RGPD. 3 Lagoas may process your personal data on the following grounds:
- The processing of personal data for a specific purpose must meet one of the legal grounds provided for in the RGPD. 3 Lagoas may process your personal data on the following grounds:
- Where processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract (Article 6th, nr.1, point b));
- If the processing is necessary for compliance with a legal obligation to which 3 Lagoas is subject (Article 6th, nr. 1, point c));
- If the processing is necessary for the purposes of the legitimate interests pursued by 3 Lagoas or by a third party, except where the interests or fundamental rights and freedoms of the data subject require protection of personal data, in particular where the data subject is a child (Article 6th, nr. 1, point f)).
Purposes of processing
3 Lagoas processes your personal data in terms of the General Regulation on Data Protection and related legislation for the purposes and on the grounds described below. The criteria we use to establish the retention periods of your data are also identified below.
|Provides you with the information you have requested (e.g. a newsletter).||Consent – We only use your personal data for this purpose if you ask us to do so. You can withdraw your consent at any time.|
|Respond to your contact request (e.g. when you fill in a contact form).||Consent – We only use your personal data for this purpose if you ask us to do so. You can withdraw your consent at any time.|
|To optimise your browsing experience on the Website (cookies).||Consent – We only use your personal data if you give us consent to do so. You can withdraw your consent at any time.|
Personal data retention
There are legal requirements that require data to be kept for a minimum period of time. Therefore, where there is no specific legal obligation, the data will be stored and kept for only the minimum period necessary for the purposes for which it was collected, after which it will be deleted.
Personal data disclosure
Within the scope of the treatment of personal data, 3 Lagoas uses third parties, on its behalf and in accordance with the instructions given by it, to treat the User’s data.
3 Lagoas ensures that such subcontracting entities provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing meets the requirements of the applicable law and ensures the security and protection of the rights of the data subjects, under the terms of the subcontracting agreement concluded with these entities.
The table below shows the recipients of the transmissions of personal data:
|Categories of recipients||Purposes of personal data processing|
|Real estate partners||Provision of real estate development services|
|IT infrastructure and service providers||Provision of services (e.g. website hosting and maintenance)|
|Marketing Companies / e-mail Marketing||Marketing Services / e-mail Marketing|
3 Lagoas may also transmit personal data of the Users of this Website to third parties, not qualified as subcontracting entities, when it considers such communication of data as necessary or appropriate (i) under applicable law, (ii) in compliance with legal obligations/judicial orders, or (iii) to respond to requests from public or government authorities.
Exercise of rights by data subjects
Rights of the data subject
With regard to the processing of their personal data, the data subject enjoys the following rights under Articles 15 to 22 of the General Data Protection Regulation, as described below.
Right of access::
The data subject has the right to obtain confirmation as to whether his or her personal data is processed by 3 Lagoas. You also have the right to access your personal data and to obtain the following additional information or clarifications:
- reasons why your personal data is processed;
- the types of personal data that are processed;
- the entities to whom your personal data may be transmitted, including entities located in countries outside the European Economic Area, in which case you will be in this case you will be informed of the guarantees applied to the transfer of your data;
- the period for which your data will be stored, or, where that is not possible, the criteria for fixing that period;
- the rights you have with regard to the processing of your personal data;
- where the personal data have not been supplied by you, information on their origin;
- the existence of automated individual decisions, including profiling, in which case information on the logic involved in the processing and the significance and expected consequences of the processing.
Right of rectification:
Whenever you consider that your personal data is incorrect or incomplete, you may request that it be rectified or completed.
Right to erasure:
In legal terms, you have the right to request the erasure of your personal data when one of the following situations occurs:
- the personal data are no longer necessary for the purpose for which they were collected or processed;
- opposes the processing of the data and there are no overriding legitimate interests justifying the processing or the data are processed for direct marketing purposes (sending of unsolicited communications);
- personal data are unlawfully processed;
- the personal data must be erased under a legal obligation to which 3 Lagoas is subject; or
- personal data are collected in connection with the provision of information society services.
The right to erasure does not apply where processing is necessary for the following purposes:
- exercise of freedom of expression and information;
- compliance with a legal obligation that requires processing and applies to 3 Lagoas;
- reasons of public interest in the field of public health;
- farchiving purposes in the public interest, scientific or historical research purposes or statistical purposes to the extent that exercising the right to erasure would seriously undermine the achievement of the purposes of such processing; or
- the establishment, exercise or defence of legal claims.
Although you may exercise your right to erasure at any time, the exercise of this right with regard to profiling for the purpose of sending personalised offers and promotions (direct marketing) is compromised.
Right to limitation of treatment:
You may request the limitation of the processing of your personal data in the following cases:
- if you contest the accuracy of your personal data, for a period of time that allows 3 Lagoas to verify their accuracy;
- if the processing is unlawful and you oppose the erasure of your personal data and request in return the limitation of the processing;
- if 3 Lagoas no longer needs the personal data for the purpose of the processing, but they are necessary for the establishment, exercise or defence of legal claims; or
- if you have lodged an objection to the processing until it is ascertained that the legitimate interests of 3 Lagoas prevail over your own.
Right to data portability:
You have the right to receive the personal data you have provided in a structured, commonly used and machine-readable format. You also have the right to request that 3 Lagoas transmits this data to another controller, as long as this is technically possible.
Right of opposition:
In legal terms, you have the right to object to the processing of your personal data at any time, for reasons relating to your particular situation, in the following situations:
- when the processing is based on the legitimate interest of 3 Lagoas, without prejudice to 3 Lagoas being able to provide compelling and legitimate reasons for such processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims; or
- when the processing is carried out for purposes other than those for which the data were collected, but which are compatible with them.
You may therefore object at any time and without the need for justification, to the processing of your data for direct marketing purposes, including profiling which is related to such marketing, without this affecting the lawfulness of the processing carried out on the basis of the consent previously given.
Right not to be subject to automated individual decisions:
Segmentation and profiling for the purposes of personalised marketing is taken exclusively on the basis of automated processing, however, they have no effect on your legal sphere or do not significantly affect you in a similar way.
Right to lodge complaints with the supervisory authority:
You have the right to lodge complaints with the competent supervisory authority regarding matters relating to the processing of your personal data.
In Portugal, the competent supervisory authority is the Comissão Nacional de Proteção de Dados.
For more information, please go to www.cnpd.pt.
How to exercise your rights
You can exercise these rights directly by contacting firstname.lastname@example.org or at:
3 Lagoas Unipessoal, Lda
Av. Almirante Gago Coutinho nº 30, Piso 0, 1000-117, Lisboa | Portugal
The exercise of your rights is free of charge, without prejudice to the fact that, whenever there are repeated, manifestly unfounded and repetitive requests, 3 Lagoas may require the payment of a reasonable fee, due to the administrative costs of providing the information or taking the requested measures, or even refuse to comply with the request.
Where 3 Lagoas has reasonable doubts as to the identity of the individual making the request, it may request that additional information necessary to confirm his or her identity be provided.
3 Lagoas Unipessoal, Lda develops its best efforts to protect the personal data of the Users against unauthorised access through the Internet. As such, it uses security systems, rules and procedures to ensure the protection of personal data, as well as to prevent unauthorised access to the data, its improper use, its disclosure, loss or destruction.
3 Lagoas Unipessoal, Lda guarantees the privacy and security in the transmission of User data using Secure Sockets Layer (SSL) encryption of all information exchanged over the Internet.
In any case, it should be noted that when circulating data on an open Internet network, the risk of unauthorised access and use cannot be eliminated, which means that the User must implement adequate security measures when navigating the Website in order to avoid the risk of access to personal data by unauthorised third parties.
Questions and suggestions
If the User has any questions related to the treatment of his/her personal data and the exercise of the rights conferred to him/her by the applicable law and, in particular, referred to in the present Notice, please contact us through the following means:
3 Lagoas Unipessoal, Lda.
Address: Av. Almirante Gago Coutinho nº 30, Piso 0, 1000-117 Lisboa | Portugal
Changes to this Policy
The information contained in this document may be subject to change over time.
Therefore, we advise you to consult the Website, where this information will be constantly updated, so that you can always be aware of the treatment of your data.
Whenever there are changes regarding the treatment of your personal data, 3 Lagoas will inform you through the Website.