Data Protection and Privacy | HOW (Houses of the World)
Data Protection and Privacy Commitment
HOW (Houses of the World) complies with all applicable EU and national laws regarding data protection, privacy, and information security.
For any questions or additional information, or to exercise your rights in this regard, please contact the HOW (Houses of the World) Data Protection Office by email at contact@how.pt.
Definitions
“Personal data”
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier. Personal identifiers include, for example, a name, an identification number, location data, online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
“Processing of Personal Data”
“Processing” means any operation or set of operations performed on personal data or on sets of personal data, whether by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of making available, comparison or interconnection, restriction, erasure, or destruction.
"Cookies"
“Cookies” are small text files containing information deemed relevant that the devices used to access a website (computers, cell phones, or portable mobile devices) download via the web browser when a website is visited by a Customer or User.
Data Controller
“HOW (Houses of the World – Real Estate)”, headquartered at Rua do Pinheiro Manso 662 | 1.22, registered with the Porto Commercial Registry under the single registration and corporate entity number 519012844, with a share capital of €500.00, hereinafter referred to as HOW (Houses of the World), is the entity responsible for the website www.how.pt and for the computer applications, hereinafter referred to as channels or applications, through which Users, Service Recipients, or Customers have remote access to the services and products of HOW (Houses of the World) that are presented, marketed, or provided at any time through said channels or applications.
The use of these channels or applications by any User, Service Recipient, or Customer may involve the processing of personal data. HOW (Houses of the World), as the entity responsible for such processing, ensures the protection, privacy, and security of this data in accordance with the terms of this Data Protection and Privacy Policy.
Contact Information for the Data Controller
To contact the HOW (Houses of the World) Data Protection Office, please send an email to contact@how.pt, describing the subject of your request and providing an email address, a phone number, or a mailing address.
For any other purpose, you may use the following general contact information for HOW (Houses of the World):
– Mailing Address: Rua do Pinheiro Manso 662 – 1.22 | 4100-411 Porto
– Email: contact@how.pt
– General Phone: 223 171 129
Collection and Processing of Personal Data
HOW (Houses of the World) processes only the personal data strictly necessary to provide information and operate its channels, in accordance with the uses made by Users, Service Recipients, or Customers, whether such data is provided by Users, Service Recipients, or Customers for the purpose of registering requests or obtaining information, or those provided by them for the purpose of subscribing to those channels, or those resulting from the use of the services provided by HOW (Houses of the World), such as accesses, inquiries, instructions, transactions, and other records related to their use.
In particular, the use or activation of certain features of the channels may involve the processing of various direct or indirect personal identifiers, such as name, home address, contact information, device addresses, or geographic location, provided that the User, Service Recipient, or Customer has given their express consent.
In all cases, Users, Service Recipients, or Customers will always be informed of the need to access such data in order to use the features of the relevant channels.
The personal data collected by HOW (Houses of the World) is processed electronically, in certain cases automatically, including through the processing of files or profiling, and in the context of managing pre-contractual, contractual, or post-contractual relationships with Users, Service Recipients, or Customers, in accordance with applicable national and EU regulations.
Categories of Personal Data Processed
The categories or types of personal data of Users, Service Recipients, and Clients that are subject to processing are as follows:
i. Name;
ii. Home and/or work phone number;
iii. Mobile phone number;
iv. Home and/or work address;
v. Email address
Legal Principles
All data processing operations comply with the fundamental legal principles governing data protection and privacy, specifically regarding data circulation, lawfulness, fairness, transparency, purpose limitation, data minimization, retention, accuracy, integrity, and confidentiality. HOW (Houses of the World) is available to demonstrate its accountability to the data subject or any other third party with a legitimate interest in this matter.
Foundations of Legitimacy
All data processing operations carried out by HOW (Houses of the World) have a legal basis, namely either because the data subject has given consent to the processing of their personal data for one or more specific purposes, or because the processing is considered necessary for the performance of a contract to which the data subject is a party, or for pre-contractual measuresat the request of the data subject, or because the processing is necessary for compliance with a legal obligation to which the controller is subject, or because the processing is necessary for the purposes of the legitimate interests pursued by HOW (Houses of the World) or by third parties.
Purpose of the Processing
All personal data processed through HOW (Houses of the World) channels is intended exclusively for providing information to Users, managing the personal information of Service Recipients deemed necessary for relationship management or communication purposes, as well as for providing the services contracted by Clients and, in general, for managing pre-contractual, contractual, or post-contractual relationships, contractual, or post-contractual relationship with Users, Service Recipients, or Clients.
The personal data collected may also, from time to time, be processed for statistical purposes, for informational or promotional activities, and for commercial or marketing purposes, specifically to promote new features or new products and services, through direct communication, whether by mail, email, text messages, phone calls, or any other electronic communication service, and this data may be shared with other companies within the Quintela e Penalva Group for the same purposes.
Provided that prior notification and the collection of express consent for these latter purposes are always ensured, Users, Service Recipients, or Customers may, at any time, exercise their right to object to the use of their personal data for purposes other than the management of the contractual relationship, specifically for marketing purposes, to send informational communications, or for inclusion in mailing lists or informational services. To do so, they must submit a written request to the Data Protection Office of HOW (Houses of the World), in accordance with the procedures outlined below.
Data Retention Periods
Personal data will be retained only for as long as is necessary for the purposes for which it was collected or subsequently processed, and compliance with all applicable legal requirements regarding data retention is guaranteed.
Use of Cookies
HOW (Houses of the World) may use two main categories of “cookies”: “cookies” on its websites and “cookies” in its direct electronic communication channels; in either category, Users, Service Recipients, or Customers are always guaranteed the ability to disable them.
HOW (Houses of the World) uses cookies on its websites to improve performance and the browsing experience for Users, Service Recipients, and Customers, thereby increasing response speed and efficiency while eliminating the need to repeatedly enter the same information.
The use of cookies helps websites recognize users’ and customers’ devices the next time they visit, and in some cases is essential for the websites to function properly.
The cookies used by HOW (Houses of the World) across all its channels do not collect personal information that could identify Users, Service Recipients, or Customers; they store only general information, such as the method or geographic location of access and how users interact with the channels, among other details. Cookies retain only information related to the preferences of Users and Customers; no personal identifiers are recorded.
Users, Service Recipients, and Customers may, at any time, through the software application they use to browse the internet (a “browser”), choose to be notified when “cookies” are received, as well as block them from being stored on their system.
Depending on the intended purposes, HOW (Houses of the World) may, where appropriate, use three different types of “cookies,” in accordance with the following specifications:
(i) Essential cookies – some cookies are essential for accessing specific areas of our online channels, enabling navigation and the use of their applications, such as accessing secure areas of the websites through user registration – without these cookies, the services that require them cannot be provided;
(ii) Functionality cookies – functionality cookies allow us to remember your preferences when browsing our websites, so you do not need to reconfigure and customize them each time you visit;
(iii) Analytical cookies – these cookies are used to analyze how users interact with websites, allowing us to highlight articles or services that may be of interest to users, monitor website performance, identify the most popular pages, determine the most effective navigation methods between pages, or identify why certain pages are receiving error messages – these cookies are used solely for statistical analysis purposes and do not collect any personal information.
To this end, HOW (Houses of the World) can provide a high-quality experience to Users, Service Recipients, or Customers by personalizing information and offers and identifying or resolving any issues that may arise during their use of the service.
In terms of their duration, there are two types of "cookies":
(i) Permanent cookies – these are cookies that are stored on the devices used to access the channels (computers, mobile phones, etc.), at the level of the software application used to browse the internet (the “browser”), and are used whenever Users or Customers revisit any channel—generally, they are used to tailor browsing to the User’s or Customer’s interests, allowing HOW (Houses of the World) to provide a more personalized service;
(ii) session cookies – these are temporary cookies that are generated and remain available only until the session ends; the next time the Customer/User accesses their web browser, the cookies will no longer be stored – the information obtained allows us to manage sessions, identify problems, and provide a better browsing experience.
Users, Service Recipients, and Customers may disable some or all cookies at any time—to do so, they should follow the instructions provided in each web browser they use; however, disabling cookies may result in the loss of access to certain website features.
HOW (Houses of the World) may also use cookies when opening various electronic communications it sends, such as newsletters and emails, for statistical purposes—to determine whether these communications are opened and to track clicks on links or ads within them.
In this category of “cookies” as well, Users, Service Recipients, and Customers always have the option to opt out of receiving electronic communications by using the specific option provided in the footer of such communications.
Disclosure of Data to Other Entities
The provision of information or services by HOW (Houses of the World) to its Users, Service Recipients, or Customers through its channels may involve the use of third-party subcontractors, including entities based outside the European Union, to provide certain services; this may result in such entities accessing Users’ personal data, Service Recipients, or Customers.
Under these circumstances and whenever necessary, HOW (Houses of the World) will only engage subcontractors that provide sufficient assurances that they will implement appropriate technical and organizational measures to ensure that the processing complies with the requirements of applicable regulations; such assurances will be formalized in a contract signed between HOW (Houses of the World) and each of these third parties.
Recipients of Data
Except as required to comply with legal obligations, under no circumstances will personal data of Users, Service Recipients, or Customers be disclosed to third parties other than subcontractors, companies within the Quintela e Penalva Group, or legitimate recipients; nor will any other disclosure be made for purposes other than those mentioned above.
International Data Transfers
Any transfer of personal data to a third country or an international organization will only be carried out in order to comply with legal obligations or where compliance with the applicable EU and national legal standards in this area is ensured.
Safety Measures
Taking into account the most advanced techniques, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the risks—of varying likelihood and severity—to Users, Service Recipients, or Customers, HOW (Houses of the World) and all entities that are its subcontractors implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
To this end, various security measures are implemented to protect personal data against disclosure, loss, misuse, alteration, unauthorized processing or access, as well as against any other form of unlawful processing.
It is the sole responsibility of Users, Service Recipients, or Customers to keep access codes confidential and not to share them with third parties; furthermore, in the specific case of computer applications used to access the channels, maintain and keep access devices secure and follow the security practices recommended by manufacturers and/or operators, particularly regarding the installation and updating of necessary security applications, including, among others, antivirus software.
If it becomes necessary to subcontract services to third parties that may have access to the personal data of Users or Customers, HOW’s (Houses of the World) subcontractors will be required to adopt the necessary organizational security measures and protocols, as well as technical measures, to protect the confidentiality and security of personal data, and to prevent unauthorized access, loss, or destruction of personal data.
Exercising the Rights of Data Subjects
Users, Service Recipients, and HOW (Houses of the World) Customers may, as data subjects, exercise their data protection and privacy rights at any time, including the rights of access, rectification, erasure, portability, restriction of processing, and objection to processing, in accordance with the terms and limitations set forth in applicable regulations.
Any request to exercise data protection and privacy rights must be submitted in writing by the data subject to the HOW (Houses of the World) Data Protection Office, in accordance with the procedure and contact information described below.
Complaints, Suggestions, and Incident Reports
Users, Service Recipients, and HOW (Houses of the World) Customers have the right to file a complaint, either by recording it in the Complaints Book or by submitting it to the regulatory authorities.
Users, Service Recipients, and HOW (Houses of the World) Customers may also submit suggestions via email to the HOW (Houses of the World) Data Protection Office.
Incident Reporting
HOW (Houses of the World) has implemented an incident management system to address data protection, privacy, and information security.
If any User, Service Recipient, or Customer wishes to report a personal data breach that results, whether accidentally or unlawfully, in the destruction, loss, alteration, disclosure, or unauthorized access to personal data transmitted, stored, or otherwise processed, they may contact the HOW (Houses of the World) Data Protection Office or use the general HOW (Houses of the World) contact information described above.
Changes to the Privacy Policy
In order to ensure that this Data Protection and Privacy Policy is kept up to date, further developed, and continuously improved, HOW (Houses of the World) may, at any time, make any changes deemed appropriate or necessary to this Policy. Such changes will be published through various channels to ensure transparency and to keep Users, Service Recipients, and Customers informed.
Express Consent and Acceptance
The terms of the Data Protection and Privacy Policy are in addition to the terms and provisions regarding personal data set forth in specific communication and/or promotional campaigns for HOW (Houses of the World) products or services that may be conducted in the future.
The voluntary, specific, and informed provision of personal data by the data subject implies knowledge and acceptance of the terms set forth in this Policy; it is understood that, by using the channels or by providing their personal data, Users, Service Recipients, and Customers are expressly authorizing the processing of such data in accordance with the rules defined in each of the applicable channels or data collection tools.
Office of Data Protection
To exercise any data protection or privacy rights, or for any matter related to data protection, privacy, and information security, Users, Service Recipients, and Customers of HOW (Houses of the World) may contact the Data Protection Office via email at contact@how.pt, describing the subject of the request and providing an email address, a phone number, or a mailing address for a response.
