Privacy Policy

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Privacy Policy

Last updated: September 2026


TOTE SER Capital recognizes the importance of protecting personal data and is committed to ensuring privacy, security, and transparency in the handling of the information entrusted to it.

This Privacy Policy explains how the personal data of users of the website www.toteser.com, as well as that of clients, investors, owners, partners, suppliers, and other individuals who contact or establish a professional relationship with TOTE SER Capital, is collected, used, stored, and protected.

The processing of personal data is carried out in accordance with Regulation (EU) 2016/679 of April 27, 2016 – the General Data Protection Regulation (GDPR) – Law No. 58/2019 of August 8, and other applicable national and European legislation.

Data Controller

The entity responsible for processing the personal data collected through this website is:

  • Architecture TOTE SER, Lda.
  • Term used on the website: TOTE SER Capital
  • Avenida Miguel Bombarda, 36 - 12º
  • 1050-165 Lisboa
  • Portugal

  • Phone: +351 213 240 920
  • Mobile: +351 916 116 632
  • Email: geral@toteser.com
  • Website: www.toteser.com

For any questions regarding privacy, the protection of personal data, or the exercise of your rights, please contact us at geral@toteser.com

What Personal Data Do We Collect?

TOTE SER Capital may collect different categories of personal data depending on the interaction with each user.

The following, among others, may be processed:

  • name;
  • email address;
  • phone number;
  • company, job title, or professional activity, when applicable;
  • identification data necessary for entering or performing a contractual relationship;
  • information regarding real estate, assets, or real estate opportunities provided by the data subject;
  • information regarding investment criteria and preferences;
  • information necessary for the analysis of investment, co-investment, or real estate development opportunities;
  • information voluntarily included in messages sent via the website, email, or other means of contact;
  • data regarding subscription to the newsletter and other communications;
  • technical data related to the use of the website, such as IP address, device type, browser, pages visited, and other information obtained through cookies or similar technologies.

TOTE SER Capital seeks to limit the collection of personal data to what is appropriate, relevant, and necessary for each purpose.

How We Collect Data

Personal data may be collected:

  • through the forms available at www.toteser.com;
  • by subscribing to the newsletter;
  • by email or phone;
  • during in-person or videoconference meetings;
  • during business and professional interactions;
  • in the context of relationships with clients, investors, property owners, partners, or suppliers;
  • in the context of presenting or analyzing real estate properties and investment opportunities;
  • through partners or other entities, when there is a legal basis for such communication;
  • through cookies and similar technologies used on the website.

Whenever data is not obtained directly from the data subject, it will be processed in accordance with applicable legal requirements.

Purposes and Legal Bases for Processing

Contact and Information Requests

Data submitted via contact forms, email, telephone, or other channels may be used to:

  • respond to requests for information;
  • provide clarification regarding TOTE SER Capital's services;
  • respond to inquiries regarding real estate or investment opportunities;
  • schedule meetings or contacts;
  • follow up on proposals or opportunities presented.

The processing may be based on the performance of pre-contractual measures at the data subject's request or on TOTE SER Capital's legitimate interest in responding to communications addressed to it.

Property Owners and Real Estate Assets

When a property owner submits a property or asset to TOTE SER Capital, the information provided may be used to:

  • analyze the property and the associated opportunity;
  • conduct preliminary studies;
  • evaluate solutions for enhancing value and profitability;
  • structure potential transactions;
  • present the asset, when applicable, to potential investors or partners;
  • develop a potential contractual relationship.

Information will only be disclosed to third parties when there is an appropriate basis for doing so and to the extent necessary to analyze or carry out the transaction.

Investors and Potential Investors

Data regarding investors and potential investors may be processed for the following purposes:

  • understand the relevant investment criteria and objectives;
  • present opportunities that may be suitable for your profile;
  • prepare meetings, presentations, and documentation;
  • analyze potential investment or co-investment transactions;
  • manage professional and institutional relationships;
  • follow up on previously discussed opportunities.

The processing may be based on the performance of pre-contractual measures, a contractual relationship, consent when required, or TOTE SER Capital's legitimate interest in managing professional and institutional relationships.

Provision of Services and Contractual Relationships

When a contractual relationship is established, the data necessary for:

  • provision of the agreed-upon services;
  • administrative and contractual management;
  • billing;
  • financial and accounting management;
  • communication between the parties;
  • fulfillment of the obligations arising from the contracts entered.

In these cases, the processing is based on the performance of the contract and compliance with applicable legal obligations.

Compliance with Legal Obligations

Certain data may be processed and retained when necessary to comply with legal, tax, accounting, regulatory, or other obligations applicable to the business activity.

Where applicable to the nature of a specific real estate transaction, there may also be specific obligations regarding identification, due diligence, record-keeping, and retention of information related to the prevention of money laundering and terrorist financing.

Newsletter and Marketing Communications

If you subscribe to the newsletter or authorize the sending of commercial communications, TOTE SER Capital may use your name and email address to send:

  • articles and content;
  • podcast episodes and updates;
  • institutional information;
  • market studies and analyses;
  • real estate or investment opportunities;
  • invitations to events;
  • other communications related to TOTE SER Capital's activities.

When processing is based on consent, consent may be withdrawn at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

Each marketing communication will provide, where applicable, a mechanism to unsubscribe.

Website Management and Security

Technical data related to the use of www.toteser.com may be processed for the following purposes:

  • to ensure the website functions properly;
  • to ensure its security;
  • to prevent misuse or fraud;
  • to identify and resolve technical issues;
  • to improve the user experience.

The processing may be based on TOTE SER Capital's legitimate interest in protecting and ensuring the operation of its digital systems

Website Statistics and Analysis

Subject to consent, when legally required, analytics tools may be used to understand website usage and obtain statistical information regarding:

  • number of visitors;
  • pages viewed;
  • source of visits;
  • time spent on the site;
  • devices used;
  • user interaction with the website.

This information is used to evaluate and improve the performance, content, and user experience of www.toteser.com.

Cookies

The website www.toteser.com may use cookies and similar technologies.

Some cookies are strictly necessary to ensure the website's functionality and security. Others may be used for analytical, statistical, functional, or marketing purposes.

Where required by law, non-essential cookies will only be used after obtaining the user's consent.

You may accept, reject, or manage your cookie preferences using the tool provided on the website.

For more detailed information about the cookies used, their duration, providers, and purposes, please refer to TOTE SER Capital's Cookie Policy.

Who can we share the data with?

Personal data may be disclosed to third parties whenever necessary and there is an appropriate legal basis for doing so.

Depending on the nature of the relationship or transaction, these third parties may include:

  • IT and technology service providers;
  • website and email hosting providers;
  • CRM software and system providers;
  • marketing, communications, and newsletter management services;
  • legal, tax, financial, and accounting consultants;
  • architects, engineers, consultants, and other professionals involved in projects;
  • banking and financial institutions;
  • investors, co-investors, or potential partners involved in the analysis of a specific transaction, when applicable;
  • owners, developers, or buyers involved in a transaction;
  • companies within the TOTE SER Capital group or partner entities involved in the provision of services;
  • real estate brokerage firms or professionals involved in a transaction, when applicable;
  • notaries, attorneys, solicitors, or other entities necessary for the completion of real estate transactions;
  • judicial, tax, administrative, regulatory, or law enforcement authorities, whenever required by law.

When third parties act as subcontractors for TOTE SER Capital, measures are taken to ensure that data is processed only in accordance with the instructions received and the obligations set forth in data protection laws.

TOTE SER Capital does not market or sell personal data to third parties.

International Data Transfers

Some technology providers used by TOTE SER Capital may be located outside the European Economic Area or process information there.

Whenever data is transferred to third countries, TOTE SER Capital will seek to ensure that a legally valid mechanism is in place for such transfers, namely:

  • the European Commission's adequacy decision;
  • standard contractual clauses approved by the European Commission;
  • or other safeguards permitted under the GDPR.

When necessary, additional measures may be implemented to ensure an adequate level of data protection.

Data Retention

Personal data will be retained for as long as necessary to fulfill the purpose for which it was collected.

Retention periods may vary depending on the nature of the relationship and applicable legal obligations.

Specifically:

  • Contact requests may be retained for as long as necessary to follow up on them;
  • Data related to contractual relationships will be retained for the duration of the relationship and thereafter for the periods necessary to comply with applicable legal obligations;
  • Data used for marketing communications may be processed until consent is withdrawn or the right to object is exercised;
  • Certain accounting, tax, contractual, real estate, or regulatory documents may be retained for the periods specified in applicable law.

When the data is no longer needed, it will be deleted or anonymized, unless its retention is still required by law or is necessary for the assertion, exercise, or defense of rights in legal proceedings.

Security and Confidentiality

TOTE SER Capital implements appropriate technical and organizational measures to protect personal data against:

  • unauthorized access;
  • improper disclosure;
  • alteration;
  • loss;
  • destruction;
  • unlawful or unauthorized processing.

Access to data is limited to individuals and entities that need it to perform their respective duties.

Despite the measures taken, no electronic transmission or storage system can guarantee absolute security.

Rights of Data Subjects

Under applicable law, the data subject may exercise the following rights, depending on the circumstances:

  • the right to access your personal data;
  • the right to have inaccurate or incomplete data corrected;
  • the right to have your data erased, where applicable;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability, where applicable;
  • the right to withdraw consent at any time, with respect to processing based on consent;
  • the right not to be subject to decisions based solely on automated processing, in the situations provided for in the GDPR.

The exercise of certain rights may be subject to limitations established by law, particularly when the retention of data is necessary to comply with a legal obligation.

To exercise any of these rights, please contact:

TOTE SER Capital may request additional information to verify the applicant's identity when necessary to prevent the disclosure of personal data to unauthorized persons.

Right to File a Complaint

If you believe that your personal data has been processed in violation of applicable law, you may file a complaint with the competent supervisory authority. In Portugal:

  • Comissão Nacional de Proteção de Dados — CNPD
  • Av. D. Carlos I, 134 - 1.º
  • 1200-651 Lisboa
  • Portugal

The exercise of this right does not preclude the possibility of resorting to other administrative or judicial remedies provided for by law.

Third-Party Links and Services

The TOTE SER Capital website may contain links, embedded content, or features provided by third-party websites and services.

These services may process personal data in accordance with their respective privacy policies.

TOTE SER Capital does not control the privacy practices of external entities; therefore, we recommend that you review their respective policies before using these services.

Changes to the Privacy Policy

This Privacy Policy may be amended or updated as necessary, particularly because of:

  • changes in laws or regulations;
  • changes to the services provided;
  • the introduction of new features on the website;
  • changes to the systems or technology providers used.

The most recent version will always be available at www.toteser.com, along with the respective update date.

Contact Information

For any questions regarding this Privacy Policy or the processing of your personal data:

  • TOTE SER Capital
  • Architecture TOTE SER, Lda.
  • Avenida Miguel Bombarda, 36 - 12.º
  • 1050-165 Lisboa
  • Portugal

  • Email: geral@toteser.com
  • Phone: +351 213 240 920
  • Mobile: +351 916 116 632