1. Introduction

ROV Group, operated by George Vinter, is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect information when you visit https://rov-group.com (the "Site").
This Policy is written in compliance with the EU General Data Protection Regulation (GDPR) (Regulation 2016/679), the Portuguese Data Protection Law (Law No. 58/2019), and applicable international privacy standards.

2. Data Controller

The data controller responsible for your personal data is:
George Vinter
Email: [email protected]
Website: https://rov-group.com
As an unincorporated sole operator, George Vinter is personally responsible for the lawful processing of your data under GDPR Article 4(7).

3. What Personal Data We Collect

We collect the following categories of personal data when you submit an enquiry form on the Site:
– Full name
– Email address
– Phone number
– Property enquiry details (e.g. location, budget, property type)
We do not collect sensitive personal data (e.g. health data, financial account details, or identity documents).
We do not currently use cookies for analytics or tracking beyond what is technically necessary to operate the Site. If this changes, this Policy will be updated and cookie consent will be obtained.

4. Legal Basis for Processing

We process your personal data on the following legal bases under GDPR Article 6:
– Consent (Art. 6(1)(a)): When you submit an enquiry form, you consent to being contacted by us and/or our real estate partners regarding your enquiry.
– Legitimate Interests (Art. 6(1)(f)): To operate our marketing platform, manage leads, and maintain our business relationships with partners, where these interests are not overridden by your rights.
– Legal Obligation (Art. 6(1)(c)): Where we are required to process data to comply with applicable law.

5. How We Use Your Data

We use your personal data to:
– Respond to your property enquiries.
– Share your contact details and enquiry information with relevant third-party real estate agents, developers, or brokers who may be able to assist you.
– Maintain records of leads generated for our business partners (from whom we receive marketing referral fees).
– Improve our Site and marketing activities using aggregated, anonymised data.
– Comply with legal obligations.
We do not use your data for automated decision-making or profiling.

6. Sharing Your Data

We may share your personal data with:
– Third-party real estate partners (agents, developers, brokers) who are relevant to your enquiry. These partners act as independent data controllers once they receive your data.
– Google LLC (Google Analytics): For website performance analytics. We use Google Analytics with IP anonymisation enabled. Google may process data in the USA under Standard Contractual Clauses.
– Telegram Messenger Inc.: If you contact us via Telegram. Please refer to Telegram's own Privacy Policy.
– Future partners such as Meta (Facebook/Instagram Ads) and Mailchimp (email marketing) – this Policy will be updated before such tools are activated.
We do not sell your personal data to any third party.

7. International Transfers

Some of our third-party service providers (e.g. Google) are based outside the European Economic Area (EEA). Where data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, in accordance with GDPR Chapter V.

8. Data Retention

We retain your personal data only for as long as necessary:
– Enquiry data: Retained for up to 24 months from the date of submission, or until the purpose is fulfilled, whichever comes first.
– Business records: Retained for up to 7 years to comply with tax and accounting obligations under Portuguese law.
After the applicable retention period, data is securely deleted or anonymised.

9. Your Rights Under GDPR

If you are located in the EU/EEA, you have the following rights regarding your personal data:
– Right of Access (Art. 15): Request a copy of the data we hold about you.
– Right to Rectification (Art. 16): Request correction of inaccurate data.
– Right to Erasure (Art. 17): Request deletion of your data ('right to be forgotten').
– Right to Restriction (Art. 18): Request that we limit how we process your data.
– Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
– Right to Object (Art. 21): Object to processing based on legitimate interests.
– Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at: [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD) at www.cnpd.pt, or with the supervisory authority in your country of residence.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or disclosure. However, no internet transmission is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Site is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted data to us, please contact us and we will promptly delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated date. We encourage you to review this Policy periodically. Material changes will be communicated via a notice on the Site.

13. Contact

For any privacy-related questions, requests, or complaints:
George Vinter | [email protected] | https://rov-group.com
Portuguese Data Protection Authority (CNPD): www.cnpd.pt