Privacy Policy

Effective Date: 1 January 2024

This Privacy Policy describes how APLAUSO DOURADO UNIPESSOAL LDA (“Advisors Greece”, “we”, “us”, “our”) collects, uses, discloses, and protects your information when you use our website https://stg-httpsadvisorsgreececom-stagegr.kinsta.cloud (the “Website”) and related services (collectively, the “Services”).

By using the Services, you consent to the collection and use of your information as described in this Policy. This Policy complies with the EU General Data Protection Regulation (GDPR) and Portuguese data protection laws.

1. Key Definitions

Personal Data: Any information relating to an identified or identifiable natural person.
Data Subject: An identifiable natural person (you).
Processing: Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
Data Controller: The entity that determines the purposes and means of processing Personal Data.
Data Processor: Third-party entities that process data on our behalf.
Cookies: Small text files placed on your device to store data about your browsing activity.
GDPR: EU General Data Protection Regulation (EU) 2016/679.

2. Data Controller

APLAUSO DOURADO UNIPESSOAL LDA acts as the Data Controller for all Personal Data processing activities carried out through the Website and Services.

Registered Company: APLAUSO DOURADO UNIPESSOAL LDA Rua Padre Américo, Número 7B, 1.º Dto, 1600-548 LISBOA, Portugal onboarding@advisorsgreece.com

3. Information We Collect

3.1 Personal Data You Provide

Contact Information: name, email address, phone number, mailing address
Account Details: username, password, profile information
Inquiry Information: investment preferences, property preferences, intended use, financial situation details (for advisory purposes)
Engagement Data: details of services agreed, engagement letters signed, fees paid
Communications: messages, consultation notes, support tickets
Source of Funds Documentation: information required for Greek Golden Visa compliance and anti-money-laundering verification
Identification Documents: passport, national ID, address verification, where required for engagement or for Greek property purchase

3.2 Information Collected Automatically

Usage Data: IP address, browser type and version, pages visited, session duration, device identifiers, operating system
Cookies and Tracking Technologies: see Section 9 below
Referral Information: how you found our Website

4. Legal Basis and Purposes for Processing

We process Personal Data based on the following legal grounds under GDPR:

Purpose	Legal Basis	Data Processed
Provide and maintain Services	Performance of contract	Contact info, account details
Process consultations and advisory services	Performance of contract	Inquiry info, financial details
Send updates, newsletters, and offers	Consent; legitimate interests	Contact info, preferences
Personalise and improve Services	Legitimate interests	Usage data, preferences
Comply with Greek Golden Visa regulations and anti-money-laundering requirements	Legal compliance	All relevant data
Prevent fraud and abuse	Legitimate interests	Usage data, account activity

5. How We Use Your Information

We use your Personal Data to:

Provide independent Greek Golden Visa and Greek property advisory services
Analyse Greek property developers, individual properties, and broader market data
Coordinate with independent Greek legal counsel, notaries, banks, tax representatives, and other service providers on your behalf
Facilitate your Greek Golden Visa application and Greek property purchase process
Communicate updates about Greek Golden Visa programme changes and property market conditions
Send property opportunity updates and shortlists where relevant to your engagement
Respond to inquiries and provide customer support
Improve our Services and user experience
Comply with Greek immigration, anti-money-laundering, and applicable financial regulations

6. Disclosure and Transmission of Personal Data

We may share Personal Data with:

6.1 Service Providers (Data Processors)

Third-party companies that provide services on our behalf, including:

Web hosting providers
Email service providers
Analytics providers (Google Analytics)
CRM and customer support tools
Payment processors

All Data Processors are bound by written contracts requiring them to process data in accordance with this Policy and GDPR.

6.2 Professional Partners

When coordinating your Greek Golden Visa application or Greek property purchase, we may share necessary information with:

Independent Greek immigration lawyers
Greek notaries and tax representatives
Greek property developers and sellers
Greek banks and credit institutions
International wire transfer providers
Independent surveyors, where applicable

Such sharing is only performed with your explicit consent and for purposes of providing the Services you have requested.

6.3 Legal Authorities

We may disclose Personal Data when required by law, regulation, or legal process, including:

Greek Migration Ministry
Greek tax authorities
Greek Land Registry and Cadastral office
Portuguese tax authorities (in respect of our entity’s domestic obligations)
EU regulatory bodies
Court orders or legal proceedings

6.4 Business Transfers

In connection with a merger, acquisition, or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to the same privacy protections.

7. International Data Transfers

Your Personal Data may be transferred to and processed in countries outside the European Economic Area (EEA), particularly when:

Using non-EEA-based service providers (for example, cloud hosting, CRM systems, communications platforms)
Coordinating with professional service providers in your home country at your request

We ensure such transfers comply with GDPR by:

Relying on European Commission adequacy decisions
Implementing Standard Contractual Clauses (SCCs) approved by the EU
Ensuring service providers implement appropriate safeguards

You may request details about transfer mechanisms by contacting us.

8. Your Rights Under GDPR

You have the following rights regarding your Personal Data:

Right	Description
Right to Information	Obtain clear information on how we use your data (this Policy)
Right of Access	Request a copy of your Personal Data we hold
Right to Rectification	Request correction of inaccurate or incomplete data
Right to Erasure	Request deletion of your data (“right to be forgotten”) under certain conditions
Right to Restriction	Request we block future use of your data while assessing a request
Right to Data Portability	Obtain and reuse your data for your own purposes
Right to Object	Object to processing based on legitimate interests
Right to Withdraw Consent	Withdraw consent at any time (where processing is based on consent)
Right to Lodge Complaint	File a complaint with the Portuguese Data Protection Authority (CNPD) or your local EEA data protection authority

To exercise your rights, contact our Data Protection Officer: onboarding@advisorsgreece.com

9. Cookies and Tracking Technologies

We use cookies and similar technologies (web beacons, local storage) for:

Essential Cookies: Necessary for website function and security
Preferences Cookies: Remember your settings and language preferences
Statistics Cookies: Aggregate usage data to improve performance (Google Analytics)
Marketing Cookies: Deliver relevant content (if applicable)

You can manage cookie preferences via your browser settings. Note that disabling essential cookies may affect website functionality.

For detailed cookie information, see our separate Cookie Policy.

10. Data Retention

We retain Personal Data only as long as necessary to fulfil the purposes described in this Policy and comply with legal obligations:

Account Data: Until account deletion or 3 years after last activity
Advisory Records: 7 years (Portuguese legal requirement for the entity’s financial records)
Communications: 3 years after last contact
Usage Data: 24 months, unless anonymised
Marketing Data: Until consent is withdrawn

After retention periods expire, we securely delete or anonymise Personal Data.

11. Security and Confidentiality

We implement technical and organisational measures to protect Personal Data, including:

Encryption of data in transit and at rest (SSL/TLS)
Secure databases with appropriate firewalls
Access controls and authentication
Regular security audits and vulnerability testing
Employee training on data protection
Confidentiality agreements with all personnel

However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

12. Children’s Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect Personal Data from minors. If you believe we have collected data from a child, please contact us immediately and we will delete it.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

Right to Know: Request categories and specific Personal Data collected in the past 12 months
Right to Delete: Request deletion of Personal Data (subject to exceptions)
Right to Opt-Out: We do not sell Personal Data
Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise California privacy rights, contact us using the information in Section 16.

14. Changes to This Policy

We may update this Policy periodically. We will post the revised version with a new “Last updated” date and notify you by email or website notice if required by law.

15. Data Protection Officer

For all data protection matters, contact our Data Protection Officer: onboarding@advisorsgreece.com

16. Supervisory Authority

You have the right to lodge a complaint with the Portuguese Data Protection Authority, which has jurisdiction over our entity:

Comissão Nacional de Proteção de Dados (CNPD) Av. D. Carlos I, 134, 1º 1200-651 Lisboa, Portugal Tel: (+351) 213 928 400 Email: geral@cnpd.pt Website: www.cnpd.pt

If you are resident in another EEA country, you may alternatively lodge a complaint with your local data protection authority. Greek residents may contact the Hellenic Data Protection Authority (Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα).