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Privacy Policy

INTRODUCTION

      1. We, Migronis LDA and Migronis KFT, operating under the brand name Migronis, respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

IMPORTANT INFORMATION AND WHO WE ARE

  • Data Controller Migronis LDA in Portugal and Migronis KFT in Hungary are the controllers and responsible for your personal data (collectively referred to as “Migronis", "we", "us", or "our" in this privacy policy). Each entity acts as a joint controller when processing data shared between the two entities.
  • Contact Details Our full details are:
  • Migronis LDA, Address: Av. da República, N° 6, 1° Esq., 1050-191, Lisbon, Portugal
  • Migronis KFT, Address: H-2161 Csomád Verebeshegy u. 11, Hungary
  • Email: [email protected]
  • You have the right to make a complaint at any time to the national supervisory authority for data protection issues.

 

THE DATA WE COLLECT ABOUT YOU

      1. Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
        1. IdentityData includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, and government-issued identification numbers (such as passport numbers).
        2. Contact Data includes billing address, delivery address, email address, and telephone numbers.
        3. Financial Data includes bank account and payment card details.
        4. Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
        5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
        6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
        7. Usage Data includes information about how you use our website, products, and services.
        8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
        9. Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly.

 

HOW WE USE YOUR PERSONAL DATA

    1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      1. To perform the contract we are about to enter into or have entered into with you.
      2. To comply with a legal obligation.
      3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
      4. With your consent.
    2. Specifically, we may use your personal data for the following purposes:
      1. To register you as a new client.
      2. To process and deliver services including managing payments, fees, and charges; collecting and recovering money owed to us.
      3. To manage our relationship with you, including notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey.
      4. To enable you to partake in a prize draw, competition, or complete a survey.
      5. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
      6. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
      7. To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.
      8. To make suggestions and recommendations to you about goods or services that may be of interest to you.

 

 

DISCLOSURES OF YOUR PERSONAL DATA

    1. We may share your personal data with the parties set out below for the purposes set out in paragraph 4 above:
      1. External Third Parties Services: Such as service providers acting as processors who provide IT and system administration services.
      2. Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
      3. Regulatory and governmental bodies that require reporting of processing activities in certain circumstances.

 

 

INTERNATIONAL TRANSFERS

    1. We may transfer, store, and process your personal data outside of your country. In such cases, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      1. Transfers to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
      2. Use of specific contract clauses approved by the European Commission which give personal data the same protection it has in Europe.
      3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

 

DATA SECURITY

      1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

 

DATA RETENTION

    1. We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

YOUR LEGAL RIGHTS

      1. Under certain circumstances, you have rights under data protection laws in relation to your personal data including:
        1. The right to request access to your personal data.
        2. The right to request correction of the personal data that we hold about you.
        3. The right to request erasure of your personal data.
        4. The right to object to processing of your personal data.
        5. The right to request restriction of processing your personal data.
        6. The right to request the transfer of your personal data to another party.
        7. The right to withdraw consent at any time where we are relying on consent to process your personal data.
      2. If you wish to exercise any of the rights set out above, please contact us.

 

SPECIAL NOTICE – MINORS

      1. Migronis is committed to safeguarding the privacy of children. This section of our Privacy Policy addresses our practices for handling personal data from minors under the age of 16, or a lower age if permitted by the laws of your country, particularly in the context of services related to golden visas and citizenship through investment.
      2. Age Verification. Prior to collecting personal data from a minor, we employ age verification processes. If a user is determined to be a minor, we will either restrict the user's access to our services or require consent from a parent or guardian before proceeding with data collection.
      3. Parental Consent. Upon verifying that an individual is a minor, we require consent from a parent or guardian to collect, use, and disclose the minor's personal data. This is particularly relevant as our services often involve family applications for visas or citizenship, requiring the processing of minors' data. Consent can be given or withdrawn by contacting us directly at [email protected].
      4. Use of Personal Data. The personal data of minors collected will be used exclusively for fulfilling the services requested, including applications for golden visas or citizenship. This data may be shared with our partners outside the European Union as necessary to complete these services.
      5. International Transfer of Personal Data. Personal data collected from minors may be transferred to and processed by our partners located outside of the European Union. These transfers are conducted in compliance with GDPR safeguards to ensure the protection of minors' personal data across borders.
      6. Rights of Parents/Guardians. Parents or guardians can access, review, correct, or request the deletion of their child's personal data. Furthermore, they can object to the processing of the data. Such requests should be directed to our designated contact point.
      7. Data Retention. We retain personal data collected from minors no longer than is necessary to achieve the purposes for which it was collected or as required by law. We ensure secure deletion of the data when it is no longer needed.

 

COOKIE POLICY

      1. Use of Cookies and Tracking Technologies. Migronis uses cookies and similar tracking technologies to enhance user experience, analyze site usage, and facilitate our services related to golden visas and citizenship by investment. This includes session cookies, which are temporary and deleted when you close your browser, and persistent cookies, which remain on your device for a pre-specified period.
      2. Types of Cookies Used
        1. Essential Cookies: Necessary for the operation of our website, including log-in, navigation, and transaction completion.
        2. Performance Cookies: Collect information about how you use our website, such as pages visited and traffic sources, to improve our site's functionality.
        3. Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferences and settings.
        4. Advertising Cookies: Used to deliver advertisements more relevant to you and your interests, as well as to limit the number of times you see an ad and help measure the effectiveness of advertising campaigns.
      3. Consent for Cookies. Upon visiting our website, you will be prompted with a cookie consent banner where you can manage your preferences. We will not set non-essential cookies on your device without your explicit consent. You can change your preferences at any time by accessing the cookie settings available on our site.
      4. Managing Cookies. You have the ability to accept or decline cookies through our consent management platform and can also configure your web browser settings to refuse cookies. However, disabling cookies may affect the functionality and service provision on our website.
      5. Third-Party Cookies. Some cookies may be set by third parties on our website, such as analytics services or social media features. These cookies are managed by the third parties, and their use is governed by the privacy policies of those third parties.

 

CHANGES TO THIS PRIVACY POLICY

    1. We may update this privacy policy from time to time. We will notify you of any changes by posting the new policy on this website. You are advised to review this privacy policy periodically for any changes.
    2. This privacy policy was last updated on 1 May 2024.
    3. For any further information or queries regarding our privacy practices, please contact us at the details provided in Section 2.