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Privacy Policy

GDPR Privacy Policy

  1. Introduction

SABA HOUSE Unipessoal Lda is committed to protecting and respecting your privacy. This policy outlines how we collect, use, and protect your personal data in compliance with the General Data Protection Regulation (GDPR).

  1. Data Controller

SABA HOUSE Unipessoal Lda is the data controller responsible for your personal data. Our contact details are:

  • Address: Rua Braamcamp, 52 – 1º, 1250-051 Lisboa
  • Email: dataprotection@sabahouse-advisors.com
  • Phone: +351 912 967 599
  1. Data Collection

We may collect and process the following personal data:

  • Name
  • Contact details (email, phone number, address)
  • Identification documents (passport, ID card)
  • Birth and Civil Status certificates
  • Financial information (bank statements, investment details)
  • Tax Records
  • Criminal Record
  • Employment and education history
  • Health Insurance policy
  • Any other information legally required for the provision of our services

3.1 Children’s privacy protection

  • Our services are not designed for, or intentionally targeted at children. When we process data from children, we will require parental or guardian consent.
  1. Purpose of Data Processing

We process your personal data for the following purposes:

  • To provide golden visa services
  • To provide D1, D2, D6, D7 and D8 visa services.
  • To open a bank account
  • To comply with legal and regulatory requirements
  • To communicate with you regarding your application
  • to book an appointment with one of our advisors
  • to provide you with additional services
  • to send you information per your request and or that may be of your interest
  • To improve our services and customer experience
  1. Legal Basis for Processing

Our legal basis for processing your personal data includes:

  • The data subject has given explicit and unambiguous consent to the processing of his or her personal data
  • Processing is necessary for the performance of a contract to which the data subject is party

If the data protection law in your country of residence does not have the lawful basis of “performance of a contract,” then SABA HOUSE will ask for your consent for the processing of your personal data for one or more specific purposes, pursuing the performance of the contract.

  • Legal obligation: Processing is necessary for compliance with a legal obligation.
  • Legitimate interests: Processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests.

 

  1. Data Sharing

We may share your personal data with:

  • Government authorities and regulatory bodies
  • Legal and financial consultants and advisors.
  • Bank entities who collaborate with SABA HOUSE in assisting the data subjects in the process of opening a bank account in Portugal
  • Service providers and business partners
  • Any other third parties as required by law
  • The sharing of your personal data with certain recipients may imply transfers of your data out of the European Economic Area (EEA). We pay particular attention to the protection of your personal data. Thus, where such transfers out of the EEA shall take place, we first implement appropriate safeguards by signing the standard contractual clauses of the European Commission with the entity out of the EEA, which processes your personal data.
  • We may share or disclose your contact information with our suppliers and partners where it is necessary for the processing of your requests or to deliver an additional service that you have requested. For example, if you have asked us to deliver your travel document to your home or office, we will need to provide the courier company with your name, delivery address, and a contact phone number.
  • We only use suppliers and partners that have sufficient privacy and data protection measures in place.
  • We do not sell your personal data to third parties
  1. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

Unfortunately, the transfer for information via the Internet is never entirely secure, which is why we cannot guarantee the security of the data transferred to our website via the Internet. We protect our website and other IT systems against loss of availability, integrity and confidentiality through suitable technical and organizational measures. Your personal data is transferred as encrypted data in our website. You can identify the secure connection by the address, when it begins with ‘https://…’ instead of ‘http://…’ and a closed padlock is shown in your browser. For more information on our SSL certificate, click on the padlock

  1. Data Retention

Data subjects’ personal data is stored throughout the duration of the relationship established with SABA HOUSE and until ten (10) years from its term, considering that in some situations the storage period may be longer, in which cases this extension will be legally justified and sustained. This period was defined in accordance with data protection applicable laws and civil and commercial contracting applicable laws, and in order to deal with the eventuality of SABA HOUSE having the need to provide evidence in any legal claim or potential legal claim among itself and data subjects.

Regarding personal data processing for marketing purposes and commercial communication, this processing shall be exclusively done with the data subject’s prior explicit consent, given at the time of the personal data collection.

The consent for processing of personal data for marketing purposes and commercial communication may be withdrawn at any time, although the withdrawal of consent shall not affect the lawfulness of processing based on previous consent nor the subsequent processing of the same data, based on another legal basis, such as, for example, performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract and compliance with legal obligations to which SABA HOUSE is subject to. If you contact us with follow-up questions or a complaint, we may retain your contact information, and any other information provided for the time it takes to resolve your matter.

We may be legally required to hold some types of information for a longer period to fulfill our statutory or contractual obligations (for example, invoices for taxes purposes).

  1. Your Rights
  • As an expression of our commitment for ensuring the privacy of data subjects, SABA HOUSE assures, in compliance with the applicable national and EU legislation, a wide range of rights which may be exercised under the following terms:

 

  • Right of Access
  • The data subjects may, at all times, contact SABA HOUSE and require confirmation that the personal data concerning him or her that are being processed and, in such case, of being informed regarding: (i) the categories of personal data concerned; (ii) the  purposes of the processing of their data; (iii) the period for which the data will be stored or the criteria used to determine that period; (iv) the rights they are entitled to and how to exercise them; (v) the data source relating to them; (vi) the existence of automated decision-making, including profiling.

 

  • SABA HOUSE may only provide information from data subjects and not personal data from other people. Furthermore, in the event the access to information may adversely affect the rights of another person, SABA HOUSE reserves the right to not disclose such information. 

 

  • If requested by the data subject, SABA HOUSE will send a copy of his or her personal data in the processing phase, in electronic format. If further copies are requested, SABA HOUSE reserves the right to charge a fee equivalent to the administrative costs incurred to satisfy the request.

 

  • Right to Erasure
  • Also known as “right to be forgotten”, enables the data subject to request the elimination or removal of his or her personal data where there is no mandatory reason for SABA HOUSE to continue to use them.

 

  • The right to erasure is not absolute because SABA HOUSE may have the right or the legal obligation to retain the information under the applicable legislation.   

 

  • Right to Rectification
  • Wherever verified that the processed personal data is out-of-date, incomplete or inaccurate, the data subject is entitled to request SABA HOUSE its rectification within the shortest possible time.

 

  • Right to Data Portability
  • The data subject also have the right to: (i) receive from SABA HOUSE personal data concerning him or her, in a commonly used and machine-readable format; (ii) to transmit those data to third parties unrelated to SABA HOUSE, under him or her exclusive responsibility; and/or (iii) to request SABA HOUSE to transmit those data to third parties. The right to data portability only covers the data to which the data subject has consented to processing, data related to a contract to which the data subject is party or if the processing is performed by automatic means.

 

  • SABA HOUSE reserves the right to refuse data portability requests where these affect the rights and freedoms of others, or conflict with any legal requirement.

 

  • Right to Restriction of Processing
  • In certain situations, the data subject has the right to “block” or to remove the continued using of data subject’s information. When processing is restricted, SABA HOUSE continues to be able to store data subject’s information, although it may not continue to use them.

 

  • The data subject may request restriction of processing for an indefinite period, when intending to suspend the processing, but storage his/her data. This situation may occur when:

 

  • data subjects contest the accuracy of the personal data, being the processing limited for a period enabling SABA HOUSE to verify the accuracy of the personal data; or
  • data subject waits for a response to a restriction of a processing request.
  • Where processing has been restricted, personal data shall only be processed with the data subject’s consent, except for specific processing established by law. SABA HOUSE assures that the data subject who has requested the restriction of his or her data is informed before the restriction of processing is lifted. SABA HOUSE reserves the right to restrict processing data from data subjects when it no longer needs it, committing to storage the data for the storage period pre-established. SABA HOUSE assures that the data subject who has requested his/her data restriction is informed prior to the respective annulment.

 

  • Right to Object
  • SABA HOUSE ensures the necessary means so that the data subject might be able to object to certain processing of personal data for certain purposes, notwithstanding the directives or laws in force.

 

  • The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on legitimate interests.

 

  • However, SABA HOUSE shall continue to process data from the data subject if it is able to demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or in case of need the personal data to establish, exercise or defense of legal claims.

 

  • Object at any time to processing of their personal data for direct marketing purposes (including profiling related to such direct marketing) through the e-mail address dataprotection@sabahouse-advisors.com

 

  • Right to Lodge a Complaint
  • Notwithstanding SABA HOUSE adoption of best practices in relation to the protection of personal data, data subjects are granted the right to lodge a complaint before the Portuguese National Data Protection Authority (“Comissão Nacional de Proteção de Dados”) (https://www.cnpd.pt) in relation to the processing of personal data performed by SABA HOUSE, through any of the channels permitted by the aforementioned authority.

Accessing your information: Authentication.

In order to protect your privacy and to authenticate that the request is genuinely from you and not from anyone else impersonating you, we might request some additional details of your last interaction with us, some details that nobody else would know about.

This is to ensure that it is really you who is making the request and not someone else. We will only request enough information to enable us to identify you properly.

  1. Changes to This Policy

We retain the right to make changes to this data protection policy statement with future effect at any time. The respective current version is available on our website. Please visit our website regularly and inform yourself of the respective valid data protection regulations.

  1. Contact Us

If you have any questions or concerns about this policy or our data practices, please contact us at:

  • Email: dataprotection@sabahouse-advisors.com
  • Phone: +351 912 967 599