1.Data controller
[to be completed], a sole trader operating under the trade name IMPORWELL, Portuguese tax number [to be completed], place of business at [to be completed]. Contact: geral@imporwell.com · +351 912 345 678.
We have not appointed a data protection officer, as we do not fall within Article 37 GDPR. For any question about your data, use the contacts above.
2.What we collect and why
We collect only what is needed to reply and to deliver the service. We never buy lists or gather data from any source other than the person themselves.
- Contact and proposal forms: name, email, phone, preferred channel and the message. Legal basis: consent and pre-contractual steps.
- Car sourcing request: search criteria, budget, timing and, for companies, name and tax number. Legal basis: pre-contractual steps.
- Client account: name, email and photo from the Google account used to sign in, saved cars and messages exchanged with us. Legal basis: performance of the contract and legitimate interest in keeping a support history.
- Testimonials: display name, town, car and the text you send for publication. Legal basis: consent, withdrawable at any time.
- Import process: data required to register the vehicle, including identification, address and documents required by the tax authority and IMT. Legal basis: contract performance and legal obligation.
- Technical usage data: pages visited and device type, only if you accept measurement cookies.
3.How long we keep it
- Enquiries that do not lead to an engagement: 24 months from last contact.
- Client accounts and messages: while the account exists, and 12 months after a deletion request unless a legal obligation requires otherwise.
- Published testimonials: until you ask for removal.
- Tax and import documentation: 10 years, as required by Portuguese tax and customs law.
4.Who we share it with
We do not sell or rent personal data, and we do not pass it to third parties for marketing.
- Google Ireland Limited — hosting, database and authentication (Firebase), with data stored in the European Union.
- Transporters and customs agents, where needed to move and register the vehicle.
- The Portuguese tax authority and IMT, for the vehicle customs declaration, vehicle tax and registration.
- Credit institutions and authorised intermediaries, only if you ask for financing support and with your consent.
- Accountants and auditors, in meeting tax obligations.
5.International transfers
Our hosting is configured in a European region. If any support operation involves access from outside the European Economic Area, that access is covered by the standard contractual clauses approved by the European Commission.
6.Automated decisions
We do not take decisions based solely on automated processing that produce legal effects concerning you. The system scores enquiries internally only to order the team's work; analysis and reply are always human.
7.Your rights
You may request access, rectification, erasure, restriction or portability of your data, object to processing, and withdraw consent at any time by writing to geral@imporwell.com. We reply within one month.
If you believe your data is not being handled properly, you may complain to the Portuguese data protection authority: CNPD, Av. D. Carlos I, 134 — 1.º, 1200-651 Lisbon, www.cnpd.pt.
8.Security
Data is hosted on Google Cloud infrastructure with authenticated, restricted access. The management area requires an authorised account and permissions are re-checked on every request. Traffic to the site is encrypted.
9.Changes to this policy
If we change this policy we publish the revised version here with a new date. Material changes are notified by email to anyone with an active account.