What is our purpose
CrediBairrada / Decisões e Soluções Anadia (Decisões de Vida – Mediação Imobiliária, Unip. Lda.), hereinafter “CrediBairrada®”, is aware of the implications of, and of its responsibility to comply with, the changes introduced in the field of personal data protection, in particular the General Data Protection Regulation, approved by Regulation (EU) 2016/679 of 26 April 2016, which took effect on 25 May 2018.
CrediBairrada® is therefore committed to protecting all the personal data made available to it and has adopted a number of technical and organisational security measures to protect personal data against any form of unlawful processing.
CrediBairrada® is equally committed to continuously improving the procedures and techniques it uses to protect personal data, and to meeting the duties of confidentiality arising from its activity as a credit intermediary, under article 3(1) of Decree-Law no. 81-C/2017.
We therefore recommend that clients and prospective clients who wish to use our services read this document.
Who we are
CrediBairrada is a registered trademark (INPI no. 682463) of the company Decisões de Vida – Mediação Imobiliária, Unip. Lda, which acts as:
- Real estate broker holding AMI/INCI licence no. 13413, which can be checked at www.impic.pt;
- Tied credit intermediary, non-exclusive, registered with Banco de Portugal under no. 0001465, which can be checked at www.bportugal.pt;
- Agent and PDEADS of Decisões e Soluções – Intermediários de Crédito, Lda, which is registered with the Portuguese Insurance and Pension Funds Supervisory Authority (ASF) as an insurance agent since 29/09/2009 under no. 409311648, authorised for Life and Non-Life insurance, which can be checked at www.asf.com.pt.
CrediBairrada® operates across the whole value chain of real estate brokerage, credit intermediation, insurance and health plans, to bring savings and a close relationship to its clients.
CrediBairrada® is the controller of the personal data of its clients and staff and, in that capacity, decides which data are collected, the means of processing and the purposes for which the data are processed.
We consider it essential to adopt every good practice in the processing of personal data. CrediBairrada® therefore undertakes to monitor the compliance of its processing with the applicable rules, to cooperate at all times with the Portuguese Data Protection Authority (CNPD) as the national supervisory authority, and to work together with its processors to ensure full compliance with its data protection policy.
Contact details for questions about data protection:
Business model
Our mission is to give clients fair solutions that add value to their lives, supporting the decisions that shape each client’s story.
As a tied, non-exclusive credit intermediary registered with Banco de Portugal under no. 0001465, and in our insurance activity as PDEADS of Decisões e Soluções – Intermediários de Crédito, Lda, which is registered with the ASF as an insurance agent since 29/09/2009 under no. 409311648, authorised for Life and Non-Life insurance, we do not charge the client any fee.
CrediBairrada® has agreements with various institutions, which bear the cost of the credit and insurance intermediation process.
Our process has three stages:
- 1Financial qualification
- 2Assessment
- 3Proposal and processing
- Financial qualification
The process begins when you submit your request. From then on, the client is supported by a dedicated, specialised case manager, who becomes their single point of contact for their case(s).
Working with the client and all the necessary information and documents, the dedicated manager carries out a financial qualification and then an assessment.
The documents requested are essential for the solvency analysis of the case and are always proportionate to the type of case being handled.
- Assessment
To complete the assessment, a dedicated manager will contact the client to assess the case, carry out the solvency analysis and explain the next steps.
Depending on the assessment, additional documents may be requested for the proposal. The timing and the way in which the client can gather and send each document are agreed with the client.
The case manager, together with a range of digital tools, will help the client obtain all the necessary documents so that processing can begin lawfully and as quickly as possible.
- Proposal and processing
To ensure that you receive a unique, personalised proposal and an exceptional level of service, the case is handled by a single person who knows all the associated credit and insurance conditions and who specialises in negotiating with the various institutions.
At this stage, the dedicated manager presents a solution to the client based on their profile, ensuring a tailored solution on the best market terms and with the best cover.
Once a pre-approved solution has been found, and because we value personal support, your dedicated manager follows the whole process through to completion, making sure that what was proposed matches what is signed.
What personal data we collect and process
Personal data is any information relating to an identified or identifiable natural person, as well as any set of separate pieces of information that can lead to the identification of that person. Personal data that has been de-identified, encoded or pseudonymised, but which can identify a natural person when used together, is also personal data.
The main categories of personal data we process are:
Identification and contact details
Name, address, mobile number, phone number, email address, civil identification number and tax identification number.
Biographical data
Nationality, sex, date of birth, place of birth, marital status, information about the household, information about the client’s profession (for example, the number of years with their current employer) and academic qualifications.
Financial data
Monthly and annual salary, financial commitments with credit institutions and financial assets.
Segments and profiles
Credit risk profile or level, profile for the purchase of investment products (through capitalisation insurance), and profile for the commercial segmentation of savings-oriented services such as loans and insurance.
Opinions and preferences
Management of answers to satisfaction surveys, of client comments on social networks (Facebook, LinkedIn, Instagram) and of comments on the websites and blogs owned by CrediBairrada®.
Content
Management of the information contained in communications between the client and Decisões de Vida – Mediação Imobiliária, Unip. Lda, its brands or the brands it represents, whether written or by phone (where the phone call is recorded).
Use of the website
IP address and technical access data (such as the browser used), processed by our hosting provider to deliver the website and protect it against abuse. The website does not use cookies or visitor analytics.
CrediBairrada® obtains data through the following channels:
- Data provided by clients
Information provided directly by clients in the website’s forms (name, email, phone and their answers to each form), in emails exchanged between the client and their case manager, in phone conversations with the client, during the client’s visits to our office in Anadia, and in answers to satisfaction surveys.
- Profiling
Analytical data produced by CrediBairrada® by applying statistical models to the data held in its databases.
- Technical website access data
The website itself does not use cookies or visitor analytics. When you visit it, our hosting provider records technical data such as your IP address, only to deliver the pages and protect the website and its forms against abuse.
The contact page includes a Google Maps map. When you open that page, Google (Google Ireland Limited) may collect data such as your IP address and set cookies, under its own privacy policy, available at policies.google.com/privacy.
- Data obtained from third parties
CrediBairrada® obtains data from third parties (partners) relating to the solvency analysis carried out by those partners, to the pre-approval of the case (FINE), to cross-selling, to insurance and to the property valuation. When a case proceeds to completion, we obtain data relating to the approval letter (final FINE), the draft deed, the date of the deed and the credit agreement.
Obligation to provide personal data
Under its legal obligations to prevent money laundering, CrediBairrada® must identify clients seeking financing, usually by means of an identity document. If this identification is not carried out, CrediBairrada® cannot proceed with the case without committing an offence. During the business relationship between the client and CrediBairrada®, the client will need to send other documents to meet the pre-contractual and contractual obligations required to complete the case.
How we process personal data
Processing of personal data covers a wide range of operations performed on personal data, whether by manual or automated means. It includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.
The General Data Protection Regulation (GDPR) applies to the processing of personal data wholly or partly by automated means, and to the processing other than by automated means of personal data held in filing systems.
At CrediBairrada®, we process personal data fairly and transparently, on a lawful basis and for specific purposes.
Performance of a contract (purposes of processing)
- Risk management
Analysis of risk criteria such as the debt-to-income ratio, net disposable income and DSTI, as well as possible defaults or late payment of instalments.
- Product management
Collection of data to offer new products or improve the products available to clients; to let clients find out about other ways of saving; to support clients actively looking for a property to buy; and to support clients actively selling their property through CrediBairrada®’s real estate brokerage.
- Contacts and complaints
Receiving, analysing and answering clients’ requests for information and complaints. Requests and complaints can arrive through various channels, such as online, by phone or by letter.
- Digital document archive
Collection, classification and storage of documents in digital format.
- Insurance brokerage
CrediBairrada® acts as an entity directly involved in insurance brokerage (PDEADS). Data is collected and analysed so that we can present the client with Life and Non-Life insurance quotes.
Compliance with legal and regulatory obligations (purposes of processing)
- Risk management
Analysis of ratios and risk-weighting criteria, such as the debt-to-income ratio, verification of the borrowers’ identity, professional experience, etc.
- Fraud prevention
Detection of fraud, for example tampered identity documents, payslips, bank statements or other documents.
- Prevention of money laundering and terrorist financing (AML/CFT)
Collection and analysis of copies of the identity documents of the parties to the credit, to prevent money laundering and terrorist financing.
- Accounting and financial reporting
Bookkeeping and preparation of financial reports, such as the balance sheet and financial statements.
- Information to and requests from public authorities
Provision of mandatory information to public bodies and answers to requests from the sector’s regulators (for example: courts, criminal police, CMVM, Banco de Portugal, CNPD, ASF, IMPIC/INCI).
- Real estate
CrediBairrada® operates as a real estate brokerage holding AMI/INCI licence 13413, actively supporting clients in buying and selling property.
Legitimate interest (purposes of processing)
CrediBairrada® processes personal data to carry out tasks related to its activities. This processing takes place within the client relationship, when personal data is processed for the direct marketing of other products or to present relevant information. CrediBairrada® only asks for the data needed to present savings and real estate proposals for products of legitimate interest, such as insurance and loans, and to actively support clients in buying and selling property.
- Information to clients
Sending relevant information about the products marketed by CrediBairrada®. This information may be sent in various formats, such as email, letter, SMS, Messenger or WhatsApp.
- Marketing
Providing information or running campaigns by phone, text message, email or post, to encourage the use of, or promote the purchase or subscription of, products or services. Campaigns may be based on client profiling.
- Client segmentation
Clients are characterised and segmented so that the products and services offered by CrediBairrada® meet each client’s specific needs.
- Profiling
CrediBairrada® may process clients’ data to create products and services better suited to their interests and preferences, to define their usage profile and level of interest, and to assess their likelihood of taking up those products and services. In this way we aim to personalise the service provided at every contact with the client.
You have the right to refuse the profiling of your data, which will mean you no longer receive a personalised service.
- Satisfaction and service quality
Satisfaction surveys are carried out to measure satisfaction with the service provided and with the products taken out, and complementary services may be suggested, for example a review of your mortgage spread or of your insurance portfolio.
- Management control
Production of information for the control and management of CrediBairrada®.
Consent of the data subject (purposes of processing)
CrediBairrada® may carry out other processing of data provided it obtains prior, express consent, given electronically, in writing, orally or through a clear, informed and freely given action.
- Proof of consent
Emails sent by clients, call recordings and documents signed by clients are some of the forms of proof of consent used by CrediBairrada®.
- Service quality monitoring
Call recordings and emails will be used to monitor the quality of service.
- Market research
Collection and analysis of personal data for market studies or market analysis.
CrediBairrada® only processes personal data that has been duly authorised and about which the data subjects have been informed in advance. Any additional secondary processing is only carried out if it is compatible with the purposes authorised and communicated to the data subjects, or if the data subjects have given specific and explicit consent to it.
How long we keep and process personal data
CrediBairrada® keeps and processes personal data only for as long as necessary: while the legitimate purposes for which the client signed up remain, to meet contractual, legal and regulatory obligations, or to protect CrediBairrada®’s legitimate interests.
Grounds for keeping personal data
- Legitimate interest
CrediBairrada® may keep personal data for longer than the client relationship on the basis of legitimate interests that justify it, in particular CrediBairrada®’s defence in legal proceedings, or where legal, regulatory, tax or accounting obligations require it.
Your rights as a data subject
CrediBairrada® guarantees that data subjects can exercise their rights in relation to the processing of their data.
Data subject rights
Access
Clients have the right to access the personal data they provide to CrediBairrada® and the conditions under which it is processed. Access is provided by email.
Rectification
Clients have the right to ask for inaccurate personal data to be corrected (for example: address, email address, phone number). Corrections can be requested by email or by letter.
Objection
Clients have the right to object to processing based on CrediBairrada®’s legitimate interest.
Withdrawal of consent
Clients have the right to withdraw their consent to the processing of their personal data.
Erasure
Clients have the right to ask for the personal data held by CrediBairrada® to be erased, provided there are no valid grounds for CrediBairrada® to keep it (for example: compliance with legal and tax obligations, or the defence of CrediBairrada® or of third parties in legal proceedings).
Restriction
Clients have the right to ask for the processing of their personal data to be restricted when they contest the accuracy of the data, when the processing is unlawful and they oppose erasure of the data.
Complaint to the CNPD
Clients have the right to lodge a complaint with the CNPD on matters relating to the exercise of their rights and the protection of their personal data.
Clients can exercise their rights under the GDPR by writing to the postal address or email addresses given above. CrediBairrada® will reply within a maximum of 30 days; this period may be extended for particularly complex requests. In such cases, CrediBairrada® will inform the client that it needs to extend the response period by a further 30 days and explain why.
Whenever CrediBairrada® considers that it cannot meet a request, the client will be informed of the reasons within the periods stated above.
Exercising these rights is free of charge. However, CrediBairrada® may charge an administrative fee to cover the costs of requests considered excessive or repetitive, abnormal and/or made in bad faith.
What personal data we share
CrediBairrada®’s staff have access to personal data to the extent necessary to perform their duties and to ensure that CrediBairrada® meets all its legal obligations as a tied credit intermediary, PDEADS and real estate agent. In addition, personal data may be made available to third parties in the client’s legitimate interest:
Third parties
- Public and supervisory bodies
Banco de Portugal, ASF, CNPD, IMPIC/INCI and the tax authorities, whenever there is a legal or regulatory obligation to do so.
- Partners
As a credit intermediary and PDEADS, CrediBairrada® will submit the credit application to the partners with which it has a tied agreement, as published in the Banco de Portugal register at www.bportugal.pt, and to the insurance companies that have agreements with Decisões e Soluções, Intermediários de Crédito, Lda, registered with the ASF under no. 409311648, which can be checked at www.asf.com.pt.
- Processors
Processors and service providers acting on behalf of, or under the instructions of, CrediBairrada®. For the website, these are Cloudflare, Inc., which hosts the website and protects it against abuse, and Resend, which sends the emails generated by the forms (the email to our team and the confirmation you receive).
These providers may process data outside the European Economic Area, in particular in the United States. In such cases, the transfer relies on the safeguards provided for in the GDPR, such as the EU-U.S. Data Privacy Framework or the standard contractual clauses approved by the European Commission.
As a tied, non-exclusive credit intermediary, CrediBairrada® is bound by banking secrecy. Personal data is therefore only transferred to third parties where there is sufficient authorisation within the client relationship and/or where the processors engaged by CrediBairrada® likewise guarantee the confidentiality of clients’ personal data and compliance with all other data protection rules and legislation.
How we protect personal data
CrediBairrada® considers the protection of the confidentiality and integrity of its clients’ data to be one of the cornerstones of the relationship of trust with the people who use our services.
CrediBairrada® has put in place appropriate organisational measures, processes and security systems to protect your personal data against destruction, alteration and unauthorised access.
CrediBairrada® is committed to continuing to develop security processes and systems that protect its clients’ personal data.
Changes to this privacy policy
CrediBairrada® reserves the right to change this privacy policy at any time, to bring it into line with best market practice or with future legislative or regulatory changes, above all to strengthen consumers’ rights.