PRIVACY POLICY
 
Last updated January 01, 2024
 
This privacy notice for Gentle Theory LDA (doing business as Ace Property Management) (‘we‘, ‘us‘, or ‘our), describes how and why we might collect, store, use, and/or share (‘process‘) your information when you use our services (‘Services‘), such as when you:
 
  • Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@acepropman.com.
 
 
SUMMARY OF KEY POINTS
 
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
 
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
 
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
 
Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
 
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
 
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.
 
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
 
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
 
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
 
 
TABLE OF CONTENTS
 
 
 
 
1. WHAT INFORMATION DO WE COLLECT?
 
Personal information you disclose to us
 
In Short: We collect personal information that you provide to us.
 
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
 
 
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • names
 
  • phone numbers
 
  • email addresses
 
  • debit/credit card numbers
 
  • contact or authentication data
 
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • social security numbers or other government identifiers
 
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
 
 
Information automatically collected
 
In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when you visit our Services.
 
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
 
 
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.
 
 
Information collected from other sources
 
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
 
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.
 
 
2. HOW DO WE PROCESS YOUR INFORMATION?
 
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

 
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
 
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
 
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
 
  • To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
 
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
 
  • to send information to border control. to send information to border control
 
 
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
 
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
 
If you are located in the EU or UK, this section applies to you.
 
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
 
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
 
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
 
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
 
 
If you are located in Canada, this section applies to you.
 
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
 
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
 
  • For investigations and fraud detection and prevention
 
  • For business transactions provided certain conditions are met
 
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
 
  • For identifying injured, ill, or deceased persons and communicating with next of kin
 
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
 
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
 
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
 
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
 
  • If the collection is solely for journalistic, artistic, or literary purposes
 
  • If the information is publicly available and is specified by the regulations
 
 
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
 
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
 
 
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
  • Finance & Accounting Tools
 
  • Government Entities
 
  • Cloud Computing Services
 
  • tour operators
 
  • Activity service providers
 
 
We also may need to share your personal information in the following situations:
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
 
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
 
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
 
 
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
 
In Short: We may use cookies and other tracking technologies to collect and store your information.
 
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: __________.
 
6. HOW LONG DO WE KEEP YOUR INFORMATION?
 
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
 
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
 
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
 
7. DO WE COLLECT INFORMATION FROM MINORS?
 
In Short: We do not knowingly collect data from or market to children under 18 years of age.
 
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@acepropman.com.
 
8. WHAT ARE YOUR PRIVACY RIGHTS?
 
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
 
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
 
We will consider and act upon any request in accordance with applicable data protection laws.
 
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
 
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
 
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
 
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
 
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
 
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: __________.
 
If you have questions or comments about your privacy rights, you may email us at info@acepropman.com.
 
9. CONTROLS FOR DO-NOT-TRACK FEATURES
 
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
 
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
 
In Short: If you are a resident of , you are granted specific rights regarding access to your personal information.
 
What categories of personal information do we collect?
 
We have collected the following categories of personal information in the past twelve (12) months:
 
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
 
YES
 
 
B. Protected classification characteristics under state or federal law
Gender and date of birth
 
YES
 
C. Commercial information
Transaction information, purchase history, financial details, and payment information
 
YES
 
D. Biometric information
Fingerprints and voiceprints
 
NO
 
E. Internet or other similar network activity
Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements
 
NO
 
F. Geolocation data
Device location
 
NO
 
G. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
 
NO
 
H. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
 
NO
 
I. Education Information
Student records and directory information
 
NO
 
J. Inferences drawn from collected personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
 
YES
 
K. Sensitive personal Information  
 
NO
 
 
We will use and retain the collected personal information as needed to provide the Services or for:
  • Category A – As long as the user has an account with us
 
  • Category B – As long as the user has an account with us
 
  • Category C – As long as the user has an account with us
 
  • Category J – As long as the user has an account with us
 
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
  • Receiving help through our customer support channels;
 
  • Participation in customer surveys or contests; and
 
  • Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
 
Learn about how we use your personal information in the section, ‘HOW DO WE PROCESS YOUR INFORMATION?
 
 
Will your information be shared with anyone else?
 
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
 
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal information.
 
We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
  • Category A. Identifiers
 
  • Category J. Sensitive personal information
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
 

We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:

The categories of third parties to whom we sold personal information are:
 
The categories of third parties to whom we shared personal information with are:
  • Data Analytics Services
 
 
 
 
11. DO WE MAKE UPDATES TO THIS NOTICE?
 
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
 
We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
 
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
 
If you have questions or comments about this notice, you may email us at info@acepropman.com or contact us by post at:
 
Gentle Theory LDA
Rua Antonio Aleixo
Lt1 3dto
Almancil, Faro 8135-114
Portugal
 
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
 
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.