PRIVACY POLICY

Effective date: 01/04/2026

Introduction

Welcome to Ando Living.

We value your privacy and are committed to responsibly protecting your personal data.

In this page, the website user (hereinafter referred to as the “User” or “Data Subject”) may find information regarding the processing of personal data carried out by Ando Living in the context of browsing their website, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data (General Data Protection Regulation) (“GDPR“) and other applicable data protection legislation.

Data Controller

Ando Living Unipessoal, Ltd., with its registered head office at Rua Serpa Pinto 14-A, 1st floor, 1200-445, Lisbon, and VAT number 507010094 (hereinafter referred to as “Ando Living” or “we“), is the data controller responsible for the processing of your personal data in the context of browsing the website https://andoliving.com/.

Purpose of Personal Data Processing, Legal Basis and Retention Period

We will collect and process the personal data you provide us by filling out the available forms.

Personal data will be retained only for the period necessary to fulfil the purposes for which they were collected. At the end of this period, the data will be deleted. However, this retention period may vary depending on the purpose for which the personal data is processed.

Purpose of Processing	Legal Basis	Retention Period
Sending direct marketing communications	Prior User consent. Alternatively, if the Data Subject has entered into a service agreement, Ando Living will process their contact details for direct marketing purposes of its own products and/or services, based on its legitimate interest in keeping their customers updated about its commercial offers.	Personal data will be retained until the Data Subject withdraws their consent. If the legal basis for processing is legitimate interest, the data will be retained until the User objects to the processing of their data for this purpose. Thus, after 2 years from giving consent or sending the first marketing communication, Ando Living will request confirmation that the Data Subject wishes to remain on its database.
Responding to information requests	Ando Living’s legitimate interest in clarifying Users’ queries regarding its offers, as well as its interest in promoting works of art and design by local artists in relation to the “Contact Us – Design Apartments” form.	Personal data will be retained for a period of 1 year after the information has been provided. In the event that this contact leads to the conclusion of a contract, this processing of personal data may be considered a pre-contractual step and, as such, the data may be retained until the end of the period for the judicial exercising of rights arising from the contract.
Sending the subscribed Newsletter	Prior consent of the User provided through the submission of their email address.	Personal data will be retained until the Data Subject withdraws their consent. Even so, two years after the Data Subject has given their consent, Ando Living will request confirmation that the Data Subject still wishes to remain registered in its database.
Rental bookings	Contract execution and carrying out pre-contractual due diligence. In this regard, we note that the processing of the personal data collected is essential in order for us to confirm your booking. If you do not provide personal data marked as “mandatory,” we will be unable to process your booking. Compliance with legal obligations under the legal framework governing the entry, stay, exit, and removal of foreigners from national territory, as well as tax obligations.	Personal data will be retained for the entire duration of the contractual relationship and an additional period of 6 months after the contract has ended.

If you contact Ando Living through its website to obtain further information about the Ando Europe Fund, please be advised that your personal data will be processed jointly by Ando Living and OptylonKrea under joint liability.

The following table summarises the essence of the Joint Liability Agreement:

Identity of the Joint Data Controllers	OptylonKrea, Ltd, with its registered head office at Rua Alexandre Herculano, Nº. 50, 10th Floor, Lisbon, 1250-011, Lisbon, and VAT number 515212008. Contact details: Telephone: +351 212 400 124 Email: [email protected]
	Ando Living Unipessoal, Ltd, with its registered head office at Rua Serpa Pinto 14-A, 1.º, 1200-445, Lisbon, and VAT number 516996290. Contact details: Email: [email protected]
Purpose of Processing To respond to requests for information from Users of the Websites and to provide specialised advice regarding the Ando Europe Investment Fund.	Legal Basis The legitimate interests of Ando Living and OptylonKrea in ensuring the quality of their customer support services through the provision of specialised advice and comprehensive information in response to Users’ requests.	Retention Period Personal Data processed under this Agreement for the exclusive purpose indicated in the table above shall be retained for a period of 1 year after the User has provided the information.
Exercise of the Data Subject’s Rights	To exercise your rights under the GDPR in relation to the Personal Data processing operation carried out under Joint Liability, you may submit your request to Ando Living via the contact email address [email protected] .Without prejudice to the foregoing, pursuant to Article 26(3) of the GDPR, you may exercise your rights against any of the parties responsible for the processing.

The Website installs cookies on your device. For further information regarding the cookies we use and the data processing carried out through them, please consult our Cookie Policy.

Sharing your data

In the context of implementing the features of our website, we may share your personal data with third-party service providers (such as HubSpot, Inc. and ActiveCampaign, LLC, operating as subcontractors) which help us operate our website and manage communications.

In particular, the subcontractor HubSpot provides Ando Living with a CRM platform designed to help us attract, engage and retain customers through integrated marketing, sales, customer service and content management tools. The subcontractor ActiveCampaign also provides a marketing platform which allows us to analyse Ando Living‘s interaction with Users.

Your personal data may also be shared with third parties in the context of corporate transactions, such as mergers or acquisitions.

Finally, for the purposes of complying with legal obligations, Ando Living informs Users that their personal data may be disclosed to any other public or judicial authority to whom Ando Living is required, under current legislation, to communicate such personal data.

International transfers of personal data

In the context of contracting the services of HubSpot and ActiveCampaign, we inform you that your personal data will be transferred to these companies based in the United States of America.

Also be aware that both Hubspot and ActiveCampaign participate in, and are certified under, the EU-U.S. Privacy Framework, as available here, in strict compliance with the GDPR.

Your Rights

Users of the Ando Living website have the following rights with regards to personal data processed by Ando Living:

i. Where the processing of personal data occurs with User consent, the User has the right to withdraw their consent at any time, without this affecting the personal data processing operations carried out in the meantime.

ii. The right of access to their personal data, that is, to obtain confirmation from Ando Living as to whether or not we process their personal data, and to request a copy thereof;

iii. The right to correction of their personal data when such are inaccurate or incomplete;

iv. In certain limited circumstances, the right to deletion of their personal data;

v. In certain limited circumstances, the right to restrict their personal data, in which case Ando Living will tag the User’s personal data and will only reuse them with the User’s consent or where such data are required for legal proceedings;

vi. In certain limited circumstances, the User may ask Ando Living to receive their personal data in a structured, commonly used and machine-readable format and, where possible, for us to transmit such data directly to a third party designated by the User (the “right to data portability”);

vii. In certain limited circumstances, the User has the right to object, at any time and for reasons pertaining to their particular situation, to the processing of their personal data, in which case Ando Living will cease processing their personal data unless there are compelling and legitimate reasons for such processing which override the interests, rights and freedoms of the User or for the purposes of declaring, exercising or defending a right in legal proceedings.

The User may exercise the aforementioned rights by submitting a written request to the Company’s registered head office address or by email to: [email protected].

The User is further informed that, should they consider that their personal data has been processed in breach of the applicable data protection legislation, they have the right to lodge a complaint with the National Data Protection Authority (Comissão Nacional de Proteção de Dados – CNPD) (www.cnpd.pt).

Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When this occurs, the alteration date will be indicated in the version history table shown below.

In addition, where the change to this Privacy Policy substantially affects its key provisions, we will, in accordance with the guidelines of the European Data Protection Committee, notify you of this change via the email address you have provided us.

Please note that in the case where we do not process your personal email data, we suggest that you review the Privacy Policy section no less than once a year.

Contacts at Ando Living

If you have any questions regarding this Privacy Policy or the processing of your personal data, you may contact us at:

Ando Living

Rua Serpa Pinto 14-A, 1.º,

1200-445 Lisbon

Email: [email protected]