Privacy Policy

Last updated: January 1, 2026

1. introduction

Welcome to GROW, operated by GRÃO D’ESTRATÉGIA LDA (“we”, “our” or “us”).

Your privacy is important to us. This Privacy Policy explains how we collect, use and protect your personal data when you visit our website www.gro-w.com or contact us regarding our properties and investment opportunities.

By using our website, you agree to the terms of this Privacy Policy.

2. Company information

GRÃO D’ESTRATÉGIA LDA.
Rua de São Bernardo 34D, 1200-825 Lisboa, Portugal
NIPC: 516 984 056
We act as Data Controller for all personal data collected through this website.

3. Information we collect

We only collect personal data that you voluntarily provide when:

• Fill in a contact form to express interest in a property or investment opportunity; or
• Request additional information about our services.
  
  

The personal data we may collect includes:

• Name
• E-mail address
• Phone number
• Message or order details
  
  

We only collect the data necessary for the purposes described above and do not collect or process
sensitive personal data.

4. How We Use Your Information

We use the personal data you provide to:

• Respond to your requests;
• Provide information on properties or investment opportunities that match your interests
• Maintain communication regarding potential business relationships or collaborations with GROW.
  
  
  

Your personal data is processed exclusively for these purposes and in accordance with the applicable legal bases.
We do not sell, rent or share your personal data with third parties for marketing purposes.

5. Legal Basis for Treatment

We process your personal data based on the following legal grounds:

• Your consent, when you voluntarily provide your personal data through our website;
  you can withdraw your consent at any time.
• Legitimate interest, namely to communicate with you and manage business relationships in the context of property and investment services, provided that such interests do not override your rights and freedoms.

6. Data Retention

We retain your personal data only for the period necessary to fulfill the purposes described in this Policy or to comply with legal obligations.

You can request the deletion of your data at any time (see Section 9).

7. Data Security

We use our best efforts to protect personal data, in particular by adopting appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction.

Only authorized personnel have access to your information, and all processing complies with the principles of confidentiality and integrity.

The technical and organizational security measures created and implemented by us are also required of our service providers who may process personal data on our behalf.

With regard to the use of our website, it is the responsibility of users, as holders of personal data, to ensure that the devices and equipment used to access the website are adequately protected against malicious software, computer viruses and worms that could compromise the security of the personal data
provided through the website.

8. Data Sharing

Your personal data may be shared with trusted third party service providers (such as website hosting, email or CRM tools) who help us operate our business.

All these partners are bound by data processing agreements and comply with the requirements of the GDPR and the CNPD.

We do not transfer personal data outside the European Economic Area (EEA) unless appropriate protection measures are in place.

9. Your Rights

Under the terms of the General Data Protection Regulation (GDPR) and Portuguese Law no. 58/2019, you have the right to:

• Access your personal data and obtain information on how it is processed;
• Request the correction of inaccurate or incomplete data;
• Request the deletion of your personal data, when legally applicable;
• Withdraw consent at any time when processing is based on consent, without affecting the lawfulness of
  processing carried out prior to withdrawal;
• Request the restriction of processing or the portability of your data in certain circumstances;
• Oppose the processing of your personal data when this is based on legitimate interests;
• File a complaint with the National Data Protection Commission (CNPD)
  
  
  

CNPD contacts:

Website: www.cnpd.pt
Address: Av. D. Carlos I, 134, 1.º 1200-651 Lisboa, Portugal
Telephone: +351 213 928 400

To exercise your rights or make a request regarding your data, please contact us at:

info@gro-w.com

10. Cookies

Our website may use essential cookies to ensure proper functioning.

We do not use advertising or tracking cookies without your explicit consent.

For more information, please consult our Cookie Policy (if applicable).

11. Updates to this Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements or our business practices. The updated version will always be available on our website, with the revision date indicated above.

12. Contact us

If you have any questions about this Privacy Policy or how we handle your data, please contact us at:

GRÃO D’ESTRATÉGIA LDA
Rua de São Bernardo 34D, 1200-825 Lisboa, Portugal
info@gro-w.com
NIPC: 516 984 056