4. Who We Share Your Data With

We do not sell your personal data. We share your data only when necessary to deliver the services you have requested, and only with the following categories of recipients:

Third-party professionals: Independent law firms, tax professionals, and fund managers that we coordinate with on your behalf. We share only the information necessary for them to provide their services to you. These professionals are independent data controllers and process your data under their own privacy policies.

Vida Living Spaces: Our real estate brand (operated by Fugaz Alegoria — Unipessoal Lda.) for property-related services. As Vida Living Spaces is operated by the same legal entity, your data remains within Fugaz Alegoria for these purposes.

Service providers: Companies that help us operate our website and business, including hosting providers, email service providers, analytics platforms, and advertising platforms. These providers act as data processors on our behalf and are bound by data processing agreements.

Legal and regulatory authorities: When required by law, regulation, or legal process.

5. International Data Transfers

Your personal data is primarily processed and stored within the European Economic Area (EEA). However, some of our service providers (such as website hosting, email, and analytics platforms) may be located in the United States or other countries outside the EEA.

Where we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, including:

Transfers to countries with an adequacy decision from the European Commission

The EU-US Data Privacy Framework, where applicable

Standard Contractual Clauses (SCCs) approved by the European Commission

You may request further details about the safeguards we use by contacting us.

6. How Long We Keep Your Data

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. General retention principles:

Client data related to active service agreements: for the duration of the service relationship, plus 5 years after its conclusion (to comply with Portuguese commercial record-keeping requirements).

Marketing contacts: until you withdraw your consent or unsubscribe.

Website analytics data: up to 26 months, in accordance with standard analytics retention settings.

Data required for legal compliance: as long as the relevant legal obligation applies.

When data is no longer needed, it is securely deleted or anonymized.

7. Your Rights

Rights under the GDPR (all users):

If you are located in the EU/EEA or if we process your data under GDPR, you have the following rights:

Right of access: You can request a copy of the personal data we hold about you.

Right to rectification: You can ask us to correct inaccurate or incomplete data.

Right to erasure: You can ask us to delete your personal data, subject to legal retention requirements.

Right to restrict processing: You can ask us to limit how we use your data in certain circumstances.

Right to data portability: You can request your data in a structured, machine-readable format.

Right to object: You can object to processing based on legitimate interests, including direct marketing.

Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with the Portuguese data protection authority (Comissão Nacional de Proteção de Dados — CNPD) or with the supervisory authority in your EU member state of residence.

Additional rights for California residents (CCPA/CPRA):

If you are a California resident, you have the following additional rights under the CCPA/CPRA:

Right to know: You can request details about the categories and specific pieces of personal information we have collected, the sources, the business purposes, and the categories of third parties with whom we share it.

Right to delete: You can request deletion of your personal information, subject to certain exceptions.

Right to opt out of sale or sharing: We do not sell your personal information. If we share data for cross-context behavioral advertising (e.g., through advertising pixels), you may opt out via our cookie consent mechanism.

Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise any of these rights, contact us at [email]. We will respond within 30 days (GDPR) or 45 days (CCPA) of receiving your request.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies. A cookie is a small text file stored on your device when you visit a website.

Types of cookies we use:

Strictly necessary cookies: Required for the website to function. These cannot be disabled.

Analytics cookies: Help us understand how visitors use our website (e.g., pages visited, time on site). We use these to improve our content and user experience.

Marketing and advertising cookies: Used to deliver targeted advertising and measure the effectiveness of our ad campaigns (e.g., Meta Pixel, Google Ads).

When you first visit our website, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies before they are set. You can change your cookie preferences at any time through the cookie settings link on our website.

You can also control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our website.

9. Third-Party Links

Our website may contain links to third-party websites, including those of the independent professionals we work with. We are not responsible for the privacy practices or content of those websites. We encourage you to read the privacy policy of every website you visit.

10. Children’s Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us and we will promptly delete it.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the “Last Updated” date at the top of this page. If we make material changes that affect how we process your personal data, we will notify you by email or through a prominent notice on our website before the changes take effect.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, contact us at:

Vida Portugal

Fugaz Alegoria — Unipessoal Lda.

Rua da Constituição, n.º 234, 4200-192 Porto, Portugal

Email: [email protected]

Website: vidaportugal.co

Supervisory authority: If you are not satisfied with our response, you have the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD), the Portuguese data protection authority, at cnpd.pt. EU residents may also contact the supervisory authority in their country of residence.