Privacy & Cookie Policy

2. Definitions

"Personal Data"

means any information that enables us to identify you directly or indirectly.

"Processing"

means any operation performed on personal data, including collection, storage, use, and deletion.

"Data Subject"

means the individual to whom the personal data relates (i.e. you, the Client).

"CNPD"

means the Comissão Nacional de Proteção de Dados, the Portuguese data protection supervisory authority.

3. What Personal Data We Collect

3.1 Identity and Contact Data

• Full name, date of birth, nationality
• Email address, telephone number, postal address
• Passport, national identity document, or other government-issued identification

3.2 Financial and Administrative Data

• Bank statements and proof of financial means
• Tax identification information (NIF / TIN)
• Proof of address (utility bills, rental contracts)

3.3 Immigration and Residency Data

• Visa and residence permit applications and supporting documents
• Social Security registration data (NISS)
• Immigration status and entry documentation

3.4 Family and Education Data

• Information relating to dependent children, including age and educational background
• Academic transcripts and school-related records

3.5 Insurance Data

• Health and personal insurance information required for policy arrangement

3.6 Technical and Usage Data

• IP address, browser type and version, device type
• Pages visited, time on page, referral source
• Cookie and tracking data (see Section 9)

4. How We Collect Your Data

We collect your personal data:

5. Legal Bases for Processing

We process your personal data on the following legal bases under the GDPR:

Performance of a contract (Article 6(1)(b))

to deliver the relocation services you have engaged us for.

Legal obligation (Article 6(1)(c))

to comply with Portuguese, EU, and applicable legal requirements.

Legitimate interests (Article 6(1)(f))

to improve our services, prevent fraud, maintain security, and conduct marketing to existing clients.

Consent (Article 6(1)(a))

for marketing communications to prospective clients and non-essential cookies. You may withdraw consent at any time.

6. How We Use Your Data

We use your personal data to:

7. Data Sharing and Third-Party Transfers

7.1 Third Parties We Share Data With

We may share your personal data with: Portuguese government agencies and public bodies (e.g. AT, AIMA/SEF, Segurança Social, local councils, banks); banks and financial institutions as part of account opening processes; insurance providers for policy arrangement; educational institutions for school enrolment; landlords and housing agencies for accommodation services; and IT, cloud storage, and payment processing providers acting as data processors under written agreements.

7.2 Marketing

We may use your contact details to inform you about our services and promotions. You may unsubscribe at any time by emailing us or using the unsubscribe link in any marketing email.

7.3 International Transfers

Where your data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including Standard Contractual Clauses adopted by the European Commission, in accordance with Chapter V of the GDPR.

8. Data Retention

After the applicable retention period, data is securely deleted or irreversibly anonymised. Note that some data held in server backups or archived records may not be immediately erasable due to technical constraints; we will inform you where this is relevant.

Client service records

10 years from completion of engagement

Tax and financial records

As required by Portuguese law (generally 10 years)

Marketing contact data

Until consent is withdrawn or erasure is requested

Identity verification documents

Deleted within 30 days of verification, unless required for the ongoing service

9. Cookie Policy

9.1 What Are Cookies?

Cookies are small text files placed on your device when you visit our website. They help us provide a functional and personalised experience.

9.2 Types of Cookies We Use

• Essential cookies — Necessary for the website to function — no consent required
• Analytics cookies — Help us understand how visitors use our website (e.g. Google Analytics) — consent required
• Marketing cookies — Deliver relevant content and track campaign performance — consent required
• Session cookies — Temporary cookies deleted when you close your browser — no consent required
• Persistent cookies — Remain on your device to recognise returning visitors — depends on type

9.3 Managing Cookies

You can control cookies through our cookie consent banner when you first visit the website, or through your browser settings. Note that disabling certain cookies may affect the functionality of the website. You can also delete cookies already stored on your device through your browser settings.

10. Your Rights

Under the GDPR, you have the following rights:

Right of access

to obtain a copy of your personal data we hold

Right to rectification

to correct inaccurate or incomplete data

Right to erasure (“right to be forgotten”)

to request deletion of your data in certain circumstances

Right to restriction of processing

Right to data portability

Right to object to processing

based on legitimate interests

Right to withdraw consent

at any time where processing is based on consent

Exercising your rights

To exercise any of these rights, please send a written request to legal@e-expat.com. We may require a copy of a valid identity document to verify your identity before processing your request. We will respond within 30 days. You also have the right to lodge a complaint with the CNPD at www.cnpd.pt.

11. Children's Data

Where we process data relating to children (individuals under 16 years of age) as part of our school placement services, we do so only as strictly necessary to deliver the requested service, and solely with the prior consent of the child's parent or legal guardian.

12. Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. All documents submitted to us are stored securely and shared only with authorised parties as required to deliver your service. No method of transmission over the internet is completely secure. While we do our best to protect your data, we cannot guarantee absolute security.

13. Changes to This Policy

We may update this Policy periodically. The latest version will always be available on our website with the date of the most recent revision. Continued use of our website or services after any update constitutes your acceptance of the revised Policy.

14. Contact

JASMINELOFT - UNIPESSOAL LDA (trading as e-expat). Email: legal@e-expat.com. Website: https://e-expat.com