Privacy Policy

Last updated: May 19, 2026

1. Data controller

The controller of personal data collected through this site is Privilege Garden, Unipessoal, Lda., NIPC 514854235, with registered office at Avenida 31 de Janeiro, n.º 80, Braga, Portugal.

For any matter relating to the processing of your personal data, please contact us at [email protected] or by post at the address above.

No Data Protection Officer has been designated, as the conditions of Article 37 GDPR are not met. Any data-protection queries may be sent to [email protected].

2. Personal data we collect

We collect the data you voluntarily provide through the contact form on this site, namely:

  • Name
  • Email address
  • Phone number (optional)
  • Apartment type of interest (T2, T3, all, pre-registration for future phases)
  • Free-text message you choose to send
  • Site language at the time of contact
  • Date and time of submission

In addition, for security and abuse-prevention purposes, we keep an ephemeral record of the source IP address of the request. This record is held in server memory only, for a short period of time, and is used exclusively for rate limiting.

3. Purposes and legal bases

We process your personal data for the following purposes and on the following legal bases:

  • Responding to your information request and commercial contact. Legal basis: consent given when submitting the form, under Article 6(1)(a) GDPR.
  • Providing pre-contractual information on apartments, prices and reservation conditions. Legal basis: pre-contractual steps at the data subject's request, under Article 6(1)(b) GDPR.
  • Fraud prevention, abuse mitigation and information security (ephemeral IP logging). Legal basis: legitimate interests, under Article 6(1)(f) GDPR.
  • Compliance with legal obligations arising from real-estate development and brokerage. Legal basis: Article 6(1)(c) GDPR.

4. Recipients and processors

Your data may be shared with the following categories of recipients:

  • Internal team of the developer Privilege Garden, Unipessoal, Lda., to respond to your enquiry.
  • Email delivery processor: Resend, Inc. (resend.com), with servers in the United States of America, used to deliver the messages generated by the form.

We do not sell, rent or otherwise transfer your personal data to third parties for their own marketing purposes.

5. International transfers

Our email processor Resend, Inc. is based in the United States of America. This transfer takes place under the Standard Contractual Clauses adopted by the European Commission (Implementing Decision (EU) 2021/914), together with appropriate technical and organisational measures, taking into account the Court of Justice of the European Union ruling in case C-311/18 (Schrems II).

Message content is delivered to the recipient (the Privilege Gardens team) and is transient within the processor's systems. Where available, we also rely on certification under the EU-US Data Privacy Framework as an additional safeguard. You may request further information about these safeguards via the email address above.

6. Retention

We keep your data only for as long as necessary for the purposes for which it was collected:

  • Contact messages and associated data: up to 12 months after the last contact, unless a commercial relationship is opened in the meantime or a longer period is required by law.
  • If a reservation or purchase contract is signed, data is retained for the legal periods applicable in commercial, tax and anti-money-laundering matters (as a rule, up to ten years).
  • Ephemeral IP record for rate limiting: minutes, in server memory.

Once these periods expire, data is securely deleted or anonymised.

7. Your rights

As a data subject, and under Articles 15 to 22 GDPR, you have the right to:

  • Obtain access to the personal data concerning you.
  • Request rectification of inaccurate or outdated data.
  • Request erasure where applicable.
  • Request restriction of processing.
  • Object to processing based on legitimate interests.
  • Request portability of the data you have provided.
  • Withdraw consent at any time, without affecting the lawfulness of prior processing.

You can exercise these rights by contacting us at [email protected]. You may also lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, cnpd.pt.

8. Security

We adopt appropriate technical and organisational measures to protect your data against unauthorised access, disclosure, alteration or destruction. These include HTTPS transmission, rate limiting, restricted access to incoming messages and careful selection of processors that offer sufficient data-protection guarantees.

9. Cookies

This site only uses strictly functional cookies, exempt from prior consent, as described in our Cookie Policy. If analytics or marketing cookies that are not exempt are added in the future, a consent banner will be shown before any such cookie is placed.

10. Changes to this policy

This policy may be updated to reflect legal or operational changes. The version in force is the one published on this page, together with the update date shown at the bottom of the document. We recommend that you review it from time to time.

11. Contact

Privilege Garden, Unipessoal, Lda., NIPC 514854235
Avenida 31 de Janeiro, n.º 80, Braga, Portugal
Email: [email protected]

Last updated: 19 May 2026.