Privacy Policy

Data Controller

Nuno Vitória Lourenço, Estate Agent at KW Alfa Madeira (Keller Williams Portugal), carrying on estate agency through Joint Achievement — Mediação Imobiliária, Lda, holder of licence AMI 13132. Email: nunovlourenco@kwportugal.pt · Tel: +351 969 326 491 · Funchal, Madeira Island, Portugal.

Data Collected

We collect the following personal data: full name, mobile number, email address, the subject of your enquiry and information about your property requirements, provided voluntarily through the contact form.

The date and time of submission and the address of the page from which the form was sent are also recorded automatically and linked to your enquiry. Should the primary submission fail and the alternative route described below be used, the IP address from which the message was sent is also recorded, for security and abuse-prevention purposes.

How the Form is Processed

When you submit the form, the data travels by two routes at once, so that your enquiry is not lost to a technical failure:

• It is sent by email to the data controller, through the service EmailJS (EmailJS.com), which handles delivery of the message;
• It is recorded in a private spreadsheet hosted on Google Sheets, accessible only to the data controller, so that your enquiry can be followed up.

Should both routes fail, the message is forwarded by a sending service hosted on the website's own server, at nunokw.pt.

The data is not used for any automated profiling, nor does it feed advertising tools. The form also includes a hidden field, invisible to visitors, whose sole purpose is to detect automated submissions by bots; it collects no personal data.

Purpose

The data collected is used solely to make contact and follow up in connection with estate agency and mortgage brokerage services.

Legal Basis (GDPR art. 6(1)(a))

The processing of your data is based on the express consent given by the data subject when completing the contact form, under article 6(1)(a) of the GDPR.

Retention

Data is retained for as long as is necessary to provide the service requested, or until the data subject withdraws consent, subject to the following maximum periods:

• Enquiries with no subsequent contractual relationship: up to 3 years from the last contact, after which the record is deleted from the spreadsheet and the mailbox.
• Enquiries that led to services being provided: for the period required by the legal obligations applicable to estate agency and credit brokerage, notably in tax matters and the prevention of money laundering.

Withdrawal of consent means the record is deleted, except where retention is required by a legal obligation. Deletion covers both the spreadsheet and the corresponding email messages.

Sharing with Third Parties and Processors

Your data is not sold or passed to third parties for their own purposes. It is shared only where necessary to provide the service (for example, with lenders in connection with mortgage brokerage), and always with the data subject's prior consent.

To operate the contact form we use the following processors, who process the data on our behalf and on our instructions:

Wherever data is transferred outside the European Economic Area, this takes place under the Standard Contractual Clauses approved by the European Commission or an applicable adequacy decision, notably the EU-US Data Privacy Framework.

Rights of the Data Subject

You have the right to access, rectify, erase, restrict the processing of and port your data, and to withdraw consent at any time. Contact: nunovlourenco@kwportugal.pt. You may also complain to the Portuguese data protection authority, the CNPD (www.cnpd.pt).

Cookies and Tracking Technologies

This website uses technical cookies that are strictly necessary to its operation and do not require consent. With your prior, express consent, it also uses third-party analytics and advertising cookies: Google Analytics (usage measurement), Google Ads and the Meta Pixel (measurement and optimisation of advertising campaigns). The notice shown on entering the site lets you allow the two purposes separately — analytics and advertising — and refuse one without refusing the other. None of these cookies is installed without the corresponding permission. You can review or withdraw your choice at any time under "Cookie settings" in the footer of any page. These services are provided by Google Ireland Limited and Meta Platforms Ireland Limited, which may process data outside the European Economic Area under the Standard Contractual Clauses approved by the European Commission.

Cookies Used

The table below identifies the non-essential cookies used on this website, their provider, purpose and retention period. All of them depend on your prior consent.

Tag Management

The measurement and advertising tools are loaded through Google Tag Manager, a service of Google Ireland Limited. Google Tag Manager does not itself collect personal data or install tracking cookies; it simply fires the tools listed below, and only after your consent.

Google Analytics

We use Google Analytics 4, an analytics service provided by Google Ireland Limited, to understand how the website is used and improve the service we provide. The data is collected in aggregate form and does not allow us to identify you individually.

Google Ads (Conversion Tracking and Remarketing)

We use Google Ads, the online advertising service of Google Ireland Limited. Through this tool we use cookies to show relevant adverts to users based on their previous visits to the website (remarketing) and to measure how effective the campaigns are (conversion tracking). The information generated is transmitted to and stored on Google's servers, which uses it to assess website usage and produce reports on campaign activity.

Meta Pixel

We use the Meta Pixel, an analytics tool provided by Meta Platforms Ireland Limited, which lets us follow the behaviour of users after they are directed to the website by clicking a Facebook or Instagram advert, measuring the effectiveness of the adverts for statistical and market-research purposes. The data is anonymous to us — we cannot see personal data on individual users. It is, however, stored and processed by Meta, which may link it to your Facebook account and use it for its own advertising purposes, under Meta's Data Policy. Dataset identifier: 1166162497068660.

Server-to-Server Transmission (Meta Conversions API)

Alongside the Meta Pixel, which runs in your browser, we use the Conversions API of Meta Platforms Ireland Limited, which transmits the same events from our server. This duplication exists because ad blockers and browser restrictions frequently prevent measurement in the browser; each event carries a unique identifier that allows Meta to recognise that the two transmissions are the same one and not count it twice.

What is transmitted: the type of event (an enquiry or a request for information), the page address, your IP address, your browser identifier and the cookies _fbp and _fbc, where they exist. Where the event results from the contact form being completed, your email, mobile number, first name and surname are also sent, solely in the form of an irreversible cryptographic hash (SHA-256), calculated in your browser before anything is sent. This data is never transmitted to Meta in readable form. The purpose is to measure the effectiveness of the adverts and it has no bearing on how your enquiry is handled.

This transmission depends on your consent to advertising cookies: if you have not given it, or if you withdraw it, no request is made to Meta. Legal basis: consent (article 6(1)(a) of the GDPR).

User-Provided Data (Google)

When you allow analytics cookies, the cryptographic hash (SHA-256) of your email, mobile number and name may be transmitted to Google Ireland Limited along with the enquiry event, a feature known as enhanced conversions. It serves to attribute the enquiry to the campaign that produced it with greater accuracy. As above, the hash is calculated in your browser and Google never receives this data in readable form. Legal basis: consent.

Advertising and Remarketing

Campaigns on Google Ads and Meta (Facebook and Instagram) may use browsing data to show relevant adverts, including remarketing to people who have already visited the site. You can turn off advert personalisation at adssettings.google.com and in the advert settings of your Meta account.