This policy explains what we do with personal data on madeiraatlanticproperty.com. It is written to be read, not to be survived. If anything here is unclear, email us and we will answer in plain words.

1. Who is responsible for your data

The controller of your personal data is Blissful Basics Destinations, [TO CONFIRM: registered address], [TO CONFIRM: company registration number / NIPC], trading as Madeira Atlantic Property.

Contact for anything in this policy, including all rights requests: privacy@madeiraatlanticproperty.com.

We have not appointed a Data Protection Officer, and are not required to. The address above reaches a person, not a queue.

2. What we collect, and why

What	Why	Lawful basis
Name and email address	To send you the guide, calculator result or checklist you asked for	Contract — Art. 6(1)(b). You asked for a thing; we send the thing.
Email address, for ongoing emails	To send you further articles and updates	Consent — Art. 6(1)(a). Separate, unticked, never bundled with the download.
Budget, timeline, area of interest, whether you have visited	So an introduction is useful rather than generic	Consent, given when you fill the field. Every one of these is optional.
Your name and contact details, passed to a named brokerage	To make an introduction you have asked for	Separate explicit consent — Art. 6(1)(a), captured at the moment of introduction and naming that specific brokerage.
Pages you visited, referrer, approximate location, device	To understand what is worth writing next	Consent, via the cookie banner. Denied by default until you choose.
Records of an introduction: date, reference number, brokerage	To show which introduction was made and when, if it is ever questioned	Legitimate interests — Art. 6(1)(f). Our interest is being able to show what we did if a reader or a brokerage later disputes it. It is limited to the fact of the introduction.

We do not collect special category data. Please do not send us health, religious or political information — we have no use for it and no place to put it.

3. Consent for an introduction is separate, and it names names

This is the part worth being explicit about. Giving us your email to download something does not give us permission to hand your details to an estate agent.

When you want an introduction, we ask you again, and we tell you the specific brokerage by name before you agree. You can decline. You can also withdraw afterwards — reply to the introduction email and we will tell the brokerage to delete what we sent.

4. Who else sees your data

GoHighLevel (HighLevel Inc., United States) — our CRM and email system. It processes your data on our instructions under a data processing agreement.
Licensed Portuguese brokerages — only the specific one you agreed to, only after you agreed, and only the details needed to contact you. Each is an independent controller from that point and has its own privacy policy. At the date of this policy the panel is one brokerage: IAD Portugal, SA, sociedade anónima, Avenida da Boavista n.º 934, 4100-112 Porto, NIPC 513 467 408, holder of licence AMI 11220 issued by IMPIC, I.P. The consultant handling Madeira is David Leça. If that ever becomes more than one brokerage, this list is where it will say so.
Google — analytics and tag management, but only if you accept analytics cookies.
Vercel — hosts this website and processes server logs.
Anthropic (Anthropic PBC, United States) — provides the AI assistant on this site. If you use it, the question you type and the recent messages of that conversation are sent to Anthropic so it can write the answer. Nothing is sent to Anthropic unless you use the assistant, and you never have to. Please do not type anything into it you would not want to leave the EEA. [TO CONFIRM: Anthropic data processing agreement and its retention position, before any sentence about training is written here]

We do not sell your data. We do not share it for anyone else’s advertising. Nobody gets your details as part of a list.

5. Sending data outside the EEA and the UK

GoHighLevel, Google, Vercel and Anthropic are United States companies, so your data is transferred to the US. Those transfers rely on the European Commission’s Standard Contractual Clauses, together with the EU–US Data Privacy Framework where the recipient is certified under it. [TO CONFIRM: confirm each processor’s current DPF certification and keep dated evidence]

You can ask us for a copy of the transfer safeguards we rely on.

6. How long we keep it

You subscribed but never open anything: deleted after 24 months of no engagement.
You unsubscribe: removed from mailings immediately. We keep your email on a suppression list so we do not accidentally mail you again.
We introduced you to a brokerage: the introduction record is kept so we can show what we did if it is ever questioned. That record is the reference, the date and the brokerage — not your browsing history. [TO CONFIRM: the retention period. It said 7 years, and the only reason given for 7 was evidencing a fee. No fee is payable to us, so that justification is gone and the period has to be set on a different basis — a legal call, not a copy one.]
Analytics: retained per the Google Analytics setting, currently 14 months.

7. Your rights

Under the GDPR and the UK GDPR you can ask us to: give you a copy of your data, correct it, delete it, restrict what we do with it, hand it over in a portable format, or stop processing it. Where we rely on consent you can withdraw it at any time, and withdrawing does not undo what was lawful before.

Email privacy@madeiraatlanticproperty.com. We answer within 30 days. There is no fee.

If we get it wrong, you can complain to a regulator:

Portugal: Comissão Nacional de Proteção de Dados (CNPD) — cnpd.pt
United Kingdom: Information Commissioner’s Office (ICO) — ico.org.uk

If you are in California, you may also ask what personal information we disclosed and direct us not to share it. Passing your details to a brokerage may count as “sharing”, so we treat it that way and ask permission first regardless.

8. Automated decisions

None. No profiling that produces a legal or similarly significant effect. A person decides which brokerage suits your enquiry.

9. Cookies

Covered separately in the cookie policy. Short version: nothing non-essential loads until you say yes, and refusing is exactly as easy as accepting.

10. Changes

If we change this materially we will say so on the page and date it. The effective date is at the top.

Privacy policy