Privacy policy

Last updated: 22 May 2026.

This Privacy Policy explains how OneMark Properties collects, uses, stores and protects the personal data of Website Users, and what rights the User can exercise in relation to that data, in accordance with the General Data Protection Regulation and applicable national legislation.

Applicable legal framework

The processing of personal data by OneMark Properties is governed, in particular, by the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (General Data Protection Regulation — GDPR);
• Law No. 58/2019, of 8 August, which ensures the implementation of the GDPR in the national legal order;
• Law no. 41/2004, of 18 August, in its current wording, relating to the processing of personal data and the protection of privacy in the electronic communications sector;

Other applicable national and European legislation regarding the protection of personal data.

What data do we collect

Simply accessing the Website does not imply the collection of the User's personal data, without prejudice to the processing of cookies under the terms of Part IV.

However, personal data is collected whenever the User, on their own initiative, decides to interact with certain features of the Website, namely:

• Identification data, such as first name and surname;
• Contact data, such as email address, telephone number or postal address;
• Data relating to the expressed interest, such as information about the project, segment or type of property that motivated the contact;

Technical navigation data, collected automatically through cookies, as detailed in the Cookies Policy (Part IV).

OneMark Properties does not collect, within the scope of the Site, sensitive personal data, in accordance with article 9 of the GDPR (namely data relating to health, racial or ethnic origin, political, philosophical or religious beliefs, trade union membership, sexual life or orientation, or genetic and biometric data).

Purposes of treatment

The personal data collected is processed by OneMark Properties for the following purposes:

• Response to requests for information, namely clarifications on real estate projects, commercial conditions and other matters submitted through the Website's forms;
• Pre-contractual due diligence, including the preparation and follow-up of potential contractual relationships with OneMark Properties;
• Marketing communications, namely sending newsletters, communications about new projects, institutional events or commercial conditions, exclusively with the User's prior consent;

Lead management and commercial analysis, including general segmentation of contacts for institutional and commercial communication purposes.

Compliance with legal obligations, particularly in matters of data protection, prevention of money laundering and terrorist financing, taxation and other applicable legislation.

Legal basis for processing

The processing of personal data by OneMark Properties is based on one of the following legal bases, set out in article 6 of the GDPR:

• Consent of the data subject, for processing for marketing and commercial communications purposes [article 6, paragraph 1, subparagraph a)];
• Carrying out pre-contractual measures, at the request of the data subject, to respond to commercial contacts and requests for information regarding the Company's projects [article 6, paragraph 1, subparagraph b)];
• Legitimate interest of OneMark Properties, for lead management, general segmentation of commercial contacts and protection of the Website's security, through prior consideration of the holder's rights [article 6, paragraph 1, paragraph f)];

Compliance with legal obligations, namely to respond to requests from competent authorities or court orders [article 6, paragraph 1, subparagraph c)].

Conservation period

Personal data are kept only for the period strictly necessary to fulfill the purposes for which they were collected, without prejudice to the minimum retention periods imposed by law. In indicative terms:

• Requests for information not converted into a contractual relationship: up to twenty-four (24) months after the last contact;
• Consent-based marketing communications: until the User withdraws consent;
• Data associated with pre-contractual or contractual relationships: for the period legally required in tax, commercial and civil matters, counting from the end of the relationship;

Data collected through cookies: as indicated in the cookie table, in Part IV.

After the applicable retention periods have elapsed, personal data is irreversibly deleted or anonymized.

Data sharing and communication

OneMark Properties may transmit personal data to:

• Subcontractors, namely providers of hosting, technological infrastructure, marketing, communication and auditing services, always under a written contract that ensures compliance with the obligations set out in the GDPR;
• Competent authorities, in compliance with a legal obligation, CNPD deliberation, court order or request from another public entity endowed with the legally required powers;

Third parties, when this is essential to protect the vital interests of the User or another natural person, or for another legitimate purpose provided for by law.

OneMark Properties does not sell, rent or give personal data to third parties for external commercial purposes.

International transfers

Personal data collected by OneMark Properties is, as a rule, processed in the European Union. When, as part of the provision of services by subcontractors, data may be transferred to third countries, OneMark Properties ensures compliance with the conditions set out in articles 44 et seq. of the GDPR — namely through adequacy decisions from the European Commission, standard contractual clauses, or other legally permitted instruments.

User Rights

Under the terms of the GDPR and applicable legislation, the User may, at any time, exercise the following rights over their personal data:

• Right of access, obtaining confirmation of which data is being processed, as well as a copy thereof [article 15 of the GDPR];
• Right to rectification, requesting the correction of inaccurate data or the completion of incomplete data [article 16];
• Right to erasure, also known as the right to be forgotten, whenever there are no legal or contractual grounds for conservation [article 17];
• Right to limit processing, namely its suspension or restriction to certain categories of data or purposes [article 18];
• Right to portability, receiving, in a structured and machine-readable format, the data you have provided to OneMark Properties, or requesting its direct transmission to another controller [article 20];
• Right to object, particularly to processing for direct marketing purposes, at any time and without the need to provide reasons [article 21];
• Right not to be subject to automated decisions, including profiling that produces legal effects or significantly affects the User [article 22];

Right to withdraw consent, at any time, without prejudice to the lawfulness of the processing carried out based on the consent previously given.

The exercise of any of these rights is carried out upon written request addressed to OneMark Properties, through the contact details indicated in Part V of this document. OneMark Properties will respond to the request within a maximum period of one (1) month from receipt, this period may be extended by two (2) months, depending on the complexity or number of requests.

Security measures

OneMark Properties adopts appropriate technical and organizational measures to guarantee a level of security appropriate to the risk, in accordance with article 32 of the GDPR, namely:

• Logical and physical access controls to systems that process personal data;
• Encryption systems for communications between the User and the Website, namely through the HTTPS protocol;
• Backup and information recovery procedures;
• Continuous monitoring of incident response systems and procedures;
• Training and raising awareness of employees on data protection;

Periodic assessment of the effectiveness of the measures adopted.

It is also up to the User to adopt appropriate security measures on their equipment — namely the use of updated antivirus software and appropriate browser configuration — to reduce the risk of unauthorized access by third parties to their personal data and credentials.

Automated decisions and profiling

OneMark Properties does not make, within the scope of the Site, decisions based exclusively on automated data processing, including the definition of profiles, that produce relevant legal effects on the User or that significantly affect them in a similar way, in accordance with article 22 of the GDPR.

The general segmentation of contacts for the purposes of institutional communication does not, in itself, constitute profiling with relevant legal effects, and is subject to the User's right to object.

Complaints

Without prejudice to any other means of administrative or judicial recourse, the User has the right to lodge a complaint with the national supervisory authority — the National Data Protection Commission (CNPD) — if they consider that the processing of their personal data by OneMark Properties violates the legal regime in force.

Authority

National Data Protection Commission (CNPD)

Household

Av. D. Carlos I, 134, 1.º, 1200-651 Lisbon

Telephone

+351 213 928 400

Contacts and exercise of rights

To exercise any of the rights provided for in the Privacy Policy (Part III), as well as for clarifications regarding the processing of your personal data or any matters covered by these Legal Terms, the User must contact OneMark Properties using the following contact details:

Entity

Mark One Properties – Asset Management, Lda.

Household

Avenida da Liberdade, no. 129 – 7.º C, 1250-140 Lisbon

Requests must be submitted in writing and may be accompanied, if OneMark Properties reasonably requires it to confirm the applicant's identity, with a copy of a valid identification document.

Validity and final provisions

If any provision of these Legal Terms is considered invalid or unenforceable, in whole or in part, this will not affect the validity or applicability of the remaining provisions, which will remain in force.

OneMark Properties' tolerance of non-compliance with any provision of these Legal Terms does not constitute a waiver of the right to demand full compliance at a later date.

Date of last update

Version dated May 22, 2026. OneMark Properties reserves the right to update these Legal Terms at any time. Changes come into force from the date of their publication on the Website, with express indication of the date of update. It is recommended that you periodically consult this page.