PRIVACY POLICY

Effective Date: 15 July 2019

Welcome, and thank you for your interest in Sherlock (“Sherlock”, “we,” or “us”), our web site at sherlockhomes.pt (the “Site”), and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals though from written or oral means, such as email or phone (collectively, together with the Site, our “Service”)..

This Site is operated by ONE CHOICE PROPERTIES – MEDIAÇÃO E CONSULTORIA IMOBILIÁRIA S.A, with registered office at Second Home, Mercado da Ribeira, Av. 24 de Julho Piso 1, 1200-479 Lisboa, registered with the Lisbon Chamber of Commerce under no. 515047317, with a share capital in the amount of €50.000,00 holder of the AMI license no. 15820 issued by Instituto dos Mercados Públicos, do Imobiliário e da Construção (“IMPIC”), with the brand “Sherlock” registered with INPI, I.P., under the number 612587.

This Privacy Policy (“Policy”) describes how we collect information on or through the Service and process your personal data acting as the data controller, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by purchasing or using the Service, you accept the privacy practices described in this Policy. We will not use or share your information with anyone except as described in this Policy.

This Policy is incorporated into, and is subject to, the Sherlock’s Terms & Conditions of Service. of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in Sherlock’s Terms & Conditions of Service.

1. Definitions

• “Client” means a customer of Sherlock.
• “Client Data” means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Servic.
• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
• “Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
• “User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
• “Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.

2. Information We Collect.

(a) Our Service: We may collect personally identifiable information about you, such as your full name, phone number, email address, or similar, when you register for an account. If you choose to use our Service, we or our third-party payment processors will collect your payment information. When you use the Service or if you visit our Site, we may receive certain information about you as described below:

By visiting the Site, we will automatically collect the following personal data about you:

• the date and time of your visit,
• your IP address,
• your web browser,
• the date and time of your visit,
• certain cookies (see below).

Should you create an account and have access to Restricted Area in our Site, we will collect certain additional personal data from Client in order to entitle us to provide the Service, as follows:

• Client name;
• Client address;
• Client telephone number;
• Client email address;
• information on the property of Client; and
• data concerning the transactions intended by Client.

In cases where we ask you to provide any personal data, there is no obligation to do so, but if you do not, you will not be able to use all functions of our Site or to make use of our real estate services in general.

We do not send any promotional emails; however, we may send you service related emails related to your account. If you no longer wish to receive these emails, you may opt out of them by canceling your account.

(b) Cookies and Tracking Technologies: Technologies such as: cookies, beacons, tags and scripts are used by Sherlock. These technologies may be used in analyzing trends, administering the Site, tracking your movements around the Site and to gather demographic information about our user base as a whole. We use cookies to remember Users’ settings as well as for authentication and analytics. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Sites may be limited.

This Site uses Google Analytics, Google Tag Manager, Google AdWords (Conversion Tracking), LinkedIn (Conversion Tracking), Bing analytics and conversion tracking, Intercom, SalesForce, Weglot, Facebook Pixel and Yahoo (Conversion Tracking). Some or all of these tools may be used to track information about your behaviour on our Site depending on your region. If you are located in Europe, your IP address, keystroke activity, and personal information are never stored or shared with any third-parties. We process and keep all data for our own Site within Europe. For more information or to opt-out, please visit the respective website(s) of these vendors or contact us at sherlock@sherlockhomes.pt.

3. How We Use Your Information

1. 1. We use the information that we collect to operate and maintain our Site and the Service and to respond to Client’s questions and concerns. The legal basis is Portuguese Data Protection Act (Law no. 67/98, of 26 October) and EU General Data Protection Regulation 2016/679, of 27 April 2016 (GDPR), notably consent of Client, execution of real estate mediation contract, legal obligation, legitimate and public interests
2. Where Client is asked for consent, Client may withdraw consent at any time. However, doing so would not affect the lawfulness of the processing of your data based on the consent before its withdrawal.
3. 1. If you have given your consent, we use the information that we collect to send you marketing communications. The legal basis is Article 12 of is Portuguese Data Protection Act (Law no. 67/98, of 26 October) and art. 6(1)(a) of GDPR.

4. How We Share Your Information

1. Personally Identifiable Information: Sherlock will not rent or sell Client’s personally identifiable information to others. We may store personal information in locations outside the direct control of Sherlock (for instance, on servers or databases co-located with hosting providers). Any personally identifiable information you elect to make publicly available on our Site or under the Service, such as postings on the comments sections of the Site, will be available to others. If you remove information that you have made public on our Site or the Service, copies may remain viewable in cached and archived pages of our Site or the Service, or if other users have copied or saved that information. We do not have control on the content of the information posted on the comments sections.
2. Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third party services providers to help them understand the usage patterns for our Service. Such results consist solely of non-personally identifiable information. By publishing any comments on our Site, you agree that you have obtained all necessary consents to make such information public and that doing so will not violate any laws. If you remove information that you have made public on the Service or Site, copies may remain viewable in cached and archived pages of the Service or Site, or if other users have copied or saved that information. Non-personally identifiable information may be stored indefinitely.
3. Situations Where We Are Required To Share Your Information: Sherlock will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms & Conditions of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Sherlock, our Clients, Users or others.
4. Testimonials: We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at sherlock@sherlockhomes.pt

5. Storage and Processing.

our information collected through the Site or Service may be stored and processed in Portugal or any other country in the European Union where Sherlock or its subsidiaries, affiliates or service providers maintain facilities. Sherlock may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions. If you are located in the European Union or European Economic Area, please note that we will not transfer information, including personal data, to a country outside of the European Union or European Economic Area.

6. How We Protect Your Information.

Sherlock is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to Sherlock or guarantee that your information on the Service may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive information (such as log in credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at sherlock@sherlockhomes.pt. We use an outside help platform, and a credit card processing company to bill you for the Service. These companies do not retain, share, store or use personally identifiable information for any other purposes.

7.Privacy Shield.

Sherlock complies with the EU GDPR framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. Sherlock has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

8.Compromise of Personal Information.n

In the event that personal information is compromised as a breach of security, Sherlock will promptly notify our Clients in compliance with applicable law.

9. Your Choices About Your Information.

For current Sherlock Clients, you can review, correct, update or delete inaccuracies to the information about you that Sherlock keeps on file by logging into your account to update your password and billing information. Alternatively, you can contact us directly at sherlock@sherlockhomes.pt. We will acknowledge your request within seventy-two (72) hours and handle it promptly. Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the rights (i) to check whether and what kind of personal data we hold about you and to access or to request copies of such data, (ii) to request correction, supplementation or deletion of personal data about you that is inaccurate or processed in non-compliance with applicable requirements, (iii) to request that we restrict the collection, processing or use of personal data about you, (iv) in certain circumstances, to object for legitimate reasons to the processing of your personal data, (v) to the extent that your data is processed on the basis of your consent, to request data portability, (vi) to know the identities of third parties to which your personal data are transferred and (vii) to provide instructions on how your data must be handled after your death when relevant. In case of any complaints, you also have the right to lodge a complaint with the competent data protection authority. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority. The contact information of the Portuguese Data Protection Agency (Comissão Nacional de Proteção de Dados) is: Av. D. Carlos I, 134 – 1.º 1200-651 Lisboa – Tel: +351 213928400 – Fax: +351 213976832 – e-mail: geral@cnpd.pt. If you have any questions about this Privacy Policy or your rights under data protection law, you can contact us at: sherlock@sherlockhomes.pt.

9. Our Retention Of Your Information.

1. 1. If you have an account with Sherlock, we will retain your information for as long as your account is active or as needed to provide you the Service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
2. 2. If you are a visitor to the Site we will retain your information for as long as necessary but no longer than one (1) year after your last visit to ou

10. Children’s Privacy.

Protecting the privacy of young children is especially important. For that reason, Sherlock does not knowingly collect or solicit personal information from anyone under the age of 16. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at sherlock@sherlockhomes.pt.

11. Notification Procedures.

t is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you via email, written or hard copy notice, or through visible posting of such notice on the Site, as determined by Sherlock in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

12. Links to Other Web Sites.s

We are not responsible for the practices employed by websites or services linked to or from the Service or Site, including the information or content contained therein. Please remember that when you use a link to go from the Sherlock Service or Site to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

Social Media Widgets: Our Site includes social media features, such as the Facebook Like button and other widgets, that run on our Site. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the organization providing it.

13. Changes to Our Privacy Policy.

All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the ‘effective date’ at the top of this page..

If you have any questions about this Privacy Policy, the practices of this Site, or about the data provided under the Service, please contact us at hello@sherlockhomes.pt.