Privacy Policy

The controller of your personal data is Alfredo Real Estate Analytics — Serviços de Informação, Lda., a private limited company, with registered office at Alameda das Linhas de Torres, 150-152A, 1750-155 Lisboa, Portugal, NIPC 515 376 884, as the entity that determines the purposes and means of processing account, billing, support and platform-usage data.

Depending on use of the Services, we may process the following categories:

Data are obtained directly from you (registration, forms, platform use), through authentication or payment providers you choose to use, through integrations you voluntarily enable (section 10) and, to a lesser extent, through technical logs generated by use of the service.

When the Customer uploads personal data of third parties to the CRM (for example leads, owners or buyers), the Customer typically determines the purposes of that processing and acts as controller. Alfredo processes those data as processor, solely to provide the CRM and associated features, according to the Customer's documented instructions and the applicable Terms.

The Customer is responsible for informing data subjects, obtaining adequate legal bases and managing rights requests relating to those data; Alfredo may provide reasonable assistance.

In relation to the Customer's account data (login email, billing, platform use), Alfredo acts as controller.

We retain data only for as long as necessary for the purposes for which they were collected, including:

• Active account — for as long as the account exists and is necessary to provide the Services;
• After cancellation — a limited period for closure, credit claims, security and data-subject requests;
• Billing — up to 10 years, where Portuguese tax or accounting law so requires;
• Security logs — shorter periods, typically up to 12–24 months, unless an investigation is ongoing;
• Cookies — according to the periods indicated in the consent banner.

Data may be accessed by Alfredo staff subject to confidentiality, and by providers acting as subprocessors, strictly to the extent necessary, including categories such as:

• Infrastructure and hosting — Cloudflare (network, CDN and protection) and hosting and file storage services;
• Payments — Stripe, for payment processing and subscription management. Alfredo does not store full card data;
• Authentication — Google Firebase, for sign-in and credential management;
• Automated valuation (AVM) — statistical modelling service that receives property characteristics and market parameters in order to produce value estimates;
• Text generation with AI — OpenAI, exclusively for the optional generation of titles and descriptions of property listings, at the user's request. Property characteristics are sent; no CRM contacts and no data obtained through Google APIs are sent;
• Maps and geocoding — Google Maps Platform, for converting addresses into coordinates, address suggestions and street imagery;
• Product analytics — OpenPanel, for usage measurement, when enabled and, where applicable, subject to consent;
• Communications — providers of transactional email delivery and notifications.

We may also disclose data where required by law, court order or competent authority, or to protect the rights, security and property of Alfredo, users or third parties.

An up-to-date list of principal subprocessors may be requested via geral@alfredo.pt.

The Services are provided from the European Union / EEA wherever possible. Some subprocessors may process data outside the EEA.

In such cases, we ensure appropriate safeguards, namely Standard Contractual Clauses (SCCs) approved by the European Commission, and supplementary measures where necessary, under the GDPR.

We use automated processing in two distinct situations, with different purposes and input data:

These outputs are intended to support the user's professional decision-making. They do not constitute solely automated decisions producing significant legal effects concerning the data subject, within the meaning of Article 22 GDPR: the estimates concern properties and market parameters, and not the evaluation of persons.

You may contact us for additional information about the logic involved, to the extent technically and legally possible, without prejudice to trade secrets.

The platform allows optional integrations with Google services, which are enabled only by express action of the user and may be switched off at any time.

The refresh token for the Google Calendar integration is retained in association with the account, solely to maintain synchronisation, and is deleted when the user switches off the integration on the platform. The user may also revoke access directly in their Google Account, at myaccount.google.com/permissions.

Specifically, and in relation to data obtained from Google APIs, such data:

1. (a) Are used exclusively to provide and improve the calendar and contacts features that the user has enabled and for which access was authorised;
2. (b) Are not transferred to third parties, except where necessary to provide those features, for security reasons, to comply with a legal obligation or in connection with a merger or acquisition with the user's consent;
3. (c) *Are not used, transferred or sold to develop, train or improve artificial intelligence or machine learning models, whether generalised or foundation models*, our own or those of third parties, whether in raw, aggregated, anonymised or derived form;
4. (d) Are not used for advertising, including personalised advertising, remarketing or behavioural advertising;
5. (e) Are not read by humans, save with the user's express consent, for security purposes, to comply with applicable law, or where the data are aggregated and anonymised for internal operations purposes.

Alfredo does not integrate any third-party artificial intelligence service that receives data originating from Google APIs. The only generative AI provider used on the platform receives property characteristics only, for the drafting of listings, as described in section 09.

For questions relating to the Google integrations or to request the deletion of imported data, please contact geral@alfredo.pt.

You may exercise your rights by sending a request to geral@alfredo.pt. We will respond within one month, extendable under the GDPR. We may request additional information to verify your identity.

We use cookies strictly necessary for the operation of the Website and, subject to your consent, analytics cookies and similar technologies.

You may manage or change your preferences at any time through the cookie consent banner (including the option to reopen preferences from the Website footer, when available) and through your browser settings.

Disabling essential cookies may prevent normal operation of sign-in and security features.

The Services are not intended for persons under 16 years of age. We do not knowingly collect data from minors. If you become aware of such a situation, contact us so that we may proceed with erasure.

In the event of a personal data breach likely to result in a risk to the rights and freedoms of natural persons, we will notify the supervisory authority and, where required, the affected data subjects, within the time limits and under the terms of the GDPR.

For any question relating to this Policy or to the processing of your personal data, you may contact us through the following means:

This Policy may be unilaterally amended by Alfredo. Depending on the nature of the changes, the User may: (a) not be notified; (b) be notified; or (c) be notified and duly informed of the substance of the changes. Material changes will be communicated appropriately.