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Privacy Policy

Privacy Policy – Divine Home


On this page, you will find the official privacy policy of Divine Home.


1. Who We Are


Divine Home operates as a licensed real estate agency. Our operations are registered and governed as follows:



  • Portugal: Sublimematriz Mediação Imobiliária Unipessoal Lda, registered with the Portuguese Chamber of Commerce in Faro with tax identification number (NIF) 513635408 and AMI Real Estate Broker License No. 11606. Our Portuguese branch offices are located in Albufeira, Loulé, São Brás de Alportel, Moncarapacho, and Mértola.

  • The Netherlands: Estate Unlimited B.V., registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under registration number 24479968.


In this privacy statement, "Divine Home," "we," "us," or "our" refers to the entities identified above, acting as joint data controllers for your personal data.


Divine Home strictly complies with all applicable European and national data protection laws, including Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), Portuguese Law 58/2019, and the Dutch GDPR Implementation Act (UAVG).


2. Scope: Whom Does This Policy Apply To?


This privacy policy explains how we collect, process, and protect the personal data of:



  • Property sellers and prospective sellers;

  • Buyers, prospective buyers, and registered home seekers;

  • Website visitors and users of our digital platforms;

  • Individuals interacting with our communication channels (email, phone, WhatsApp, online contact forms, and interactive chat tools);

  • External suppliers, commercial partners, and contractors.


3. Our Core Privacy Commitments



  • Transparency: We explain clearly and openly why and how your personal data is collected, stored, and utilized.

  • Data Minimization: We only request and retain data that is strictly necessary for our real estate brokerage services, operational management, or compliance obligations.

  • Purpose Limitation: Your data is only used for the purposes explicitly stated to you.

  • Storage Limitation: We do not keep your information longer than necessary to serve you or to fulfill our statutory obligations.

  • Security & Confidentiality: We use appropriate technical and organizational measures to safeguard your personal data against unauthorized access, loss, or misuse.

  • Individual Control: We facilitate the full exercise of your rights under the GDPR.


4. Personal Data We Collect


Depending on your relationship with Divine Home, we may process the following categories of personal information:



  • Identification & Contact Data: Name, gender, nationality, preferred language, residential address, telephone number, and email address.

  • Property Search & Profile Preferences: Criteria for property acquisitions (budget, preferred regions, property typologies), saved listings, favorites, notes, and search history.

  • Property / Object Data: For sellers, we process property characteristics, registered addresses, land registry (cadastral) records, photographic assets, and floor plans, insofar as these details can be linked directly or indirectly to an individual.

  • Communication & Interaction Records: Correspondence exchanged with our team via email, WhatsApp, telephone call logs, meeting notes, contact request forms, and conversational transcripts from our website's virtual assistant.

  • Financial & Compliance Data: Tax identification numbers (NIF), details of official identification documents (where legally mandated for AML/CFT verification), payment and banking details for deposits, transactions, and invoicing.

  • Technical & Browsing Data: IP addresses, operating system, browser type, pages visited, device identifiers, and clickstream behavior collected via technical, analytical, or marketing cookies (detailed in our Cookie Policy).


5. Purposes and Legal Bases for Processing


Under Article 6 of the GDPR, we process your personal data only when an established legal basis applies:



  • Performance of a Contract (Art. 6(1)(b) GDPR): Executing real estate mediation contracts (Contrato de Mediação Imobiliária), arranging property viewings, facilitating negotiations between buyers and sellers, coordinating with legal representatives, and preparing promissory purchase and sale contracts (CPCV) and deeds.

  • Legal Obligation (Art. 6(1)(c) GDPR): Complying with statutory duties, including Portuguese Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) legislation (Law 83/2017), real estate mediation regulations supervised by IMPIC, and fiscal/accounting record retention laws.

  • Legitimate Interests (Art. 6(1)(f) GDPR): Managing routine client relationships, optimizing our website's performance and security, analyzing market valuations, maintaining internal organizational records, and utilizing business productivity software to summarize communications and streamline day-to-day operations.

  • Consent (Art. 6(1)(a) GDPR): Sending marketing newsletters, tailored property alert emails, and placing non-essential cookies on your browser. Consent may be withdrawn at any time.


6. Use of Artificial Intelligence (AI) and Digital Technologies


To maintain responsive client service, streamline administrative workflows, and assist with property marketing across diverse language markets, Divine Home incorporates selected Artificial Intelligence (AI) tools into its operational workflows.


Applied AI Solutions and Purposes



  • Website AI Assistant: We operate an interactive AI virtual assistant on our website (www.divine-home.eu) to provide immediate assistance, help visitors navigate property listings, and receive initial contact inquiries. Conversations are recorded to allow our qualified agents to review and follow up on your requests.

  • Internal Productivity & Content Software: Our staff uses commercial AI productivity solutions to assist with administrative and marketing tasks, such as drafting multi-language property descriptions, designing marketing brochures, formatting social media content, and summarizing internal meeting notes, correspondence, and operational communications.


Data Protection Standards in AI Usage



  • Data Protection & Model Training Safeguards: We operate commercial, professional-tier software solutions governed by commercial data privacy terms. These arrangements prevent our internal prompts, correspondence summaries, or customer details from being used by external technology providers to train public artificial intelligence models.

  • Data Minimization: Our team follows internal protocols to avoid including unnecessary or sensitive personal identifiers within AI prompts.

  • Human Oversight (No Automated Decision-Making): Divine Home does not make decisions producing legal or similarly significant effects based solely on automated processing or profiling (under Article 22 of the GDPR). All real estate assessments, property valuations, legal contract reviews, and client negotiations are conducted and finalized directly by our human professionals.


7. Categories of Recipients and Third-Party Processors


Divine Home never sells, rents, or commercializes personal data to third parties. We share data only with established service providers, public bodies, and business partners acting as data processors or independent controllers:



  • Real Estate CRM & Database Software: Specialized real estate portfolio and customer relationship management systems used to organize client inquiries, property listings, and matching criteria.

  • Cloud Infrastructure & Productivity Suites: Enterprise cloud storage, electronic document management, and professional business productivity software.

  • Email Marketing & Communication Platforms: Dedicated digital communication and dispatch services used to distribute newsletters, market insights, and property alerts to opted-in subscribers.

  • IT, Hosting & Technical Support Providers: Technical infrastructure, web hosting, cybersecurity, and software providers operating under formal confidentiality and data processing agreements.

  • Transaction Partners: Partnering licensed real estate brokers (for agreed joint viewings), registered solicitors (solicitadores), legal advisors, mortgage brokers, and notary offices involved in formalizing your real estate transaction.

  • Public & Supervisory Authorities: Portuguese Tax Authority (Autoridade Tributária), IMPIC (Instituto dos Mercados Públicos, do Imobiliário e da Construção), Dutch tax authorities, and judicial or regulatory authorities upon lawful request.


International Data Transfers


Where certain digital software or hosting providers store data or maintain servers outside the European Economic Area (EEA), such as in the United States, Divine Home ensures transfers are covered by recognized legal safeguards, including the EU-U.S. Data Privacy Framework or standard Standard Contractual Clauses (SCCs) approved by the European Commission.


8. Data Retention Periods


We retain your personal data only for the period necessary to fulfill the purposes for which it was obtained:



  • Registered Home Seekers & Portal Accounts: Maintained for the duration of your active search profile until you deregister, request deletion, or remain inactive for a consecutive period of 3 years.

  • Marketing Communications & Newsletters: Retained until you withdraw your consent or click the unsubscribe link in our correspondence. Records evidencing consent or withdrawal are kept for compliance audit purposes.

  • Mediation Contracts & Real Estate Transaction Records: Transactional documents, promissory agreements, and client identification files are retained for 10 years in accordance with Portuguese statutory limitation periods and real estate regulations.

  • Fiscal & Accounting Records: Billing details, invoices, and relevant bookkeeping proofs are retained for a minimum of 10 years as required by Portuguese tax legislation.

  • AML/CFT Documentation: Identification and customer due diligence records collected under Anti-Money Laundering regulations are retained for 7 years following the completion of the transaction or termination of the business relationship.

  • Property Marketing Data: Public-facing listings on our portals are removed within a maximum of 1 year following the sale or withdrawal of a property, with core transactional details retained in our internal archive for legal defense and statistical appraisal purposes.


9. Your Rights Under the GDPR


As a data subject, you hold comprehensive rights regarding your personal information under the GDPR:



  • Right of Access: You may request confirmation of whether we process your data, along with a readable copy of that information and details regarding how it is handled.

  • Right to Rectification: You have the right to request the prompt correction of inaccurate or incomplete personal records.

  • Right to Erasure ("Right to Be Forgotten"): You may request that we erase your personal data when it is no longer required for the original purpose, provided retention is not mandated by tax, legal, or AML obligations.

  • Right to Restriction of Processing: You may request the suspension of data processing while the accuracy of data is verified or during a dispute.

  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format to transmit to another service provider.

  • Right to Object: You have the right to object at any time to the processing of your data based on legitimate interests or for direct marketing purposes.

  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.


Exercising Your Rights


To exercise any of the rights listed above, please submit a written request to:



  • Email: info@divine-home.eu


To safeguard client privacy, we may require proof of your identity before executing requests. When submitting identification copies, please redact non-essential sensitive attributes (such as photographs or national security identifiers, e.g., citizen card serial numbers or Dutch BSN).


Supervisory Authorities


If you believe Divine Home has handled your data in violation of applicable data protection legislation, you have the right to lodge a complaint with the competent supervisory body:



10. Contact Details and Policy Amendments


For questions, comments, or concerns regarding this privacy policy or our data handling practices, please contact us:



  • Email: info@divine-home.eu

  • Website: www.divine-home.eu

  • Registered Office (Portugal): Sublimematriz Mediação Imobiliária Unipessoal Lda, Albufeira, Algarve, Portugal.

  • Registered Office (The Netherlands): Estate Unlimited B.V., The Netherlands.


Divine Home reserves the right to revise or update this privacy statement to reflect operational, technological, or legal developments. The latest version will always be published on this page with the corresponding revision date.


Last updated: October 2026