This Privacy Policy establishes the commitment Torre Norte, S.A. with their website visitors, regarding the protection of their personal data when using this website (Polaris website, hereinafter referred to “Website”). Through this Privacy Policy, Torre Norte, S.A. inform the website visitors regarding the processing carried out with their data, as well as their rights as data subjects. Torre Norte, S.A. act in strict compliance with the principles described in this policy, Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and the applicable data protection legislation, in all personal data processing activities.

Personal data refers to the set of information related to yourself that enables you to be identified, either directly or indirectly.

The Website is intended solely for, and may only be used by, natural persons over 16 years of age. We do not process willingly and knowingly process the personal data of children. If we become aware that we have collected children’s personal data, we will immediately proceed to its erasure. We ask that you contact us if you know that we processed children’s personal data.

When you submit a message on the Website, we will collect as necessary personal data your name, the enterprise you work for, message content, and email address or telephone number.

Should you in doing your request inform other personal data, you shall do so voluntarily; such other personal data are not necessary.

The provision of your personal data is neither a legal nor a contractual obligation, and if you do not provide the necessary personal data, it may make it impracticable for us to answer.

2. Controller of Personal Data Processing

We use the Website’s visitor’s personal data with the purpose of providing them with information in response to the requests they address us through the Website.

We process the personal data that the Website’s visitor provide on the basis of the visitor’s consent, granted to us at the time of addressing a request.

In light of the above, we clarify that we do not request personal data relating to philosophical or political beliefs, party or trade union affiliation, religious faith, private life and racial or ethnic origin, as well as the processing of data relating to health and sex life, including genetic data.

We store Website’s visitor’s personal data only for the period of time necessary to answer to their requests and to fulfil legal obligations.

After the storage period ends, your personal data will be anonymized or will be securely destroyed/eliminated.

The Website’s visitor has the right to withdraw consent at any time, although this right does not affect the lawfulness of the processing carried out based on the previously given consent nor the subsequent processing of the same data, based on another legal ground. The Website’s visitors is also ensured, at any time, the right of access to their personal data, as well as their rectification, erasure, portability, restriction and/or opposition to processing. As data subject, the Website’s visitors has the right to request from Torre Norte, S.A. the erasure of their data, without undue delay, and the latter is obliged to erase the personal data, without undue delay, when applicable, namely, one of the following reasons applies:

a) The personal data are no longer necessary for the purpose for which they were collected or processed;

b) The user has withdrawn their consent to the data processing (in cases where the processing is based on consent) and there is no other ground for such processing;

c) The user objects to the processing and there are no overriding legitimate interests justifying the processing.

To exercise any of the aforementioned rights, the Website’s visitor must address, in writing, Torre Norte, S.A. through the registered office address or through the following email address: dadospessoais@polaris-offices-lx.com. The Website’s visitor’s requests will be handled with special care so that the effectiveness of the user’s rights may be ensured. The user may be asked to provide evidence of identity in order to ensure that the sharing of personal data is only made with the respective data subjects, or their representatives.

The personal data provided on the Website, namely via the contact form (including name, email address, telephone number, and the content of the message), may be disclosed to third parties solely for the purpose of managing and responding to requests submitted by data subjects. In this context, data may be transmitted to:

• partner real estate agencies, which may follow up on the interests expressed by the Website’s visitors regarding properties or units within the promoted building.
• Sierra Portugal, S.A., as the Polaris building operating manager, in order to handle the requests sent through the website.
• the digital service provider responsible for hosting and maintaining the website on behalf of Torre Norte, S.A., acting as a data processor under Article 28 of the GDPR, bound by contract to ensure confidentiality, security, and integrity of the data.

When visiting the website, data may also be collected through cookies, including those used for analytical purposes such as Google Analytics 4.0. In this context, the data recipient is Google LLC, which processes personal data (such as IP addresses and user identifiers) on behalf of Torre Norte, S.A., under the terms of its Data Processing Agreement. Despite data being processed in a pseudonymized form, under certain circumstances, Google may be able to identify individual users and may therefore qualify as a data recipient within the meaning of Article 4(9) of the GDPR. For further details, users are encouraged to consult the Cookie Settings Panel.

Data will not be shared with other entities unless required by law or based on the data subject’s prior and informed consent.

7. Updates to this Privacy Policy

These terms and conditions govern the use of the website belonging to Sonae Sierra and AXA Investment Managers.

The information present on this website serves exclusively for the direct information of the user, and its use is of their exclusive responsibility. Torre Norte, S.A. reserve the right to make changes and corrections, suspend, interrupt or close the website whenever they deem appropriate, without prior notice and for the period they consider necessary, for any technical, administrative, force majeure or other reasons, and may not therefore be held liable. Torre Norte, S.A. is not responsible and cannot be held responsible for hyperlinks to third-party websites, as well as reject any responsibility for the content of those third-party websites, with their access and visit being the sole responsibility of the website visitor. Torre Norte, S.A. are also not responsible for the privacy policies of third-party websites. The hyperlinks that may exist to those websites do not imply the acceptance of the content made available therein, nor represent the existence of any link with their owners on the part of Torre Norte, S.A.

The website visitor also undertakes not to carry out any operations that may harm the functioning of the website and its areas, or to access an area/account and respective contents without authorization. Testing, evaluating or breaching the vulnerability of the website’s security, installing or attempting to install viruses/programs that damage and/or contaminate it, triggering or attempting to trigger “DoS” (Denial of Service) attacks, or advising third parties to do so. Failure to respect the ethical rules of use and good manners implies the termination of the website visitor, with misappropriation, counterfeiting, the use of misappropriated or counterfeit content, illegitimate identification and unfair competition being punished under the applicable legislation. Torre Norte, S.A. will cooperate with the competent authorities for the enforcement of the law or court decision that requests or orders the disclosure of the identity or assistance in the identification and/or location of any person transmitting the above-described content.

The Terms of Use and the Privacy Policy are governed by and shall be interpreted in accordance with Portuguese law. The website visitor irrevocably accepts the jurisdiction of the Portuguese courts to settle any conflict arising from and/or related to the Privacy Policy and/or the use of this website.