Privacy Policy

Why this privacy policy?

This Privacy Policy exists because we want to inform our Clients and Users of the general rules on privacy and on the processing of their personal data, which we collect and process in strict compliance with the Personal Data Protection Law.

COMFYLAND follows best practices in personal data security and protection and has, to that end, approved a demanding program capable of safeguarding the data provided to us by everyone who deals with the Company in any way.

In this context, COMFYLAND has a Data Protection Officer responsible for implementing and monitoring this Privacy Policy and for defining clear rules for processing personal data, ensuring that everyone who entrusts us with their personal data knows how the Company processes it and what rights they have in this regard.

Please read this Privacy Policy carefully: if you are accessing our website, providing your personal data implies that you know and accept the conditions set out here. By providing your personal data, you therefore authorize its collection, use and disclosure in accordance with the rules defined here.

Intellectual property rights

The content of the website, including without limitation images, text, software, photographs, sound, music, videos, interactive features and the like ("Content"), the trademarks and logos ("Marks"), and any other industrial or intellectual property rights contained in it, are the property of COMFYLAND, and their use by unauthorized third parties is expressly prohibited.

The content of the website is provided for information and personal use only and may not be used, copied, reproduced, distributed, transmitted, broadcast, sold, licensed or otherwise exploited for any other purpose without the prior written consent of the respective owners. The user agrees not to use, disable or interfere with security-related features of the Website and the Application.

The user may, however, print material contained on this website, provided it is not altered, is for personal and non-commercial use, keeps the source and copyright notice, and no other proprietary notice is removed.

Nothing on this website should be construed as granting its users any kind of license or other authorization for use.

The website may contain images or other materials whose copyright belongs to third parties, such as suppliers or other entities that contribute to its creation or maintenance (for example, stock photos).

Content and warranties

The user agrees that use of the website is at their own risk. To the fullest extent permitted by law, COMFYLAND disclaims all warranties, express or implied, in connection with the use of the website. COMFYLAND does not guarantee the correctness or accuracy of the content provided on its websites and assumes no responsibility or liability for any (i) errors or inaccurate content, (ii) personal injury or property damage of any kind resulting from access to and use of the website and application, (iii) unauthorized access to or use of our secure servers and/or any personal and/or financial information stored on them, (iv) interruption or cessation of transmission to or from our website, (v) bugs, viruses, Trojan horses or the like that may be transmitted to or through the website, and/or (vi) errors or omissions in any content or any loss or damage incurred as a result of the use of any content posted, sent, transmitted or made available through the website, (vii) unavailability, or any difficulty or inability to download or access content, or any other failure of the communication system that may result in the website being unavailable.

COMFYLAND assumes no responsibility or liability for content transmitted between users, or between users and any third parties, outside this website.

What does this privacy policy cover?

On the website you may find links to other websites unrelated to COMFYLAND. Such links are provided in good faith, and COMFYLAND cannot be held responsible for the collection and processing of personal data carried out on those websites, nor for the accuracy, credibility and features of websites belonging to third parties.

Providing links to other websites unrelated to COMFYLAND therefore does not imply any acceptance of responsibility for those websites, to which this Privacy Policy does not apply. COMFYLAND strongly recommends reading the Privacy Policies of every website you visit.

1. Data controller

For the purposes of Regulation (EU) 2016/679 (GDPR), the data controllers are SPIRIT ENTERPRISE, SGPS UNIPESSOAL LDA and COMFYLAND LDA, company tax numbers (NIPC) 519417372 and 519317084, with registered office at Rua Almirante Gago Coutinho N.º 19 A, 1885-036 Moscavide, Portugal, hereinafter "COMFYLAND".

2. Data processed and its source

COMFYLAND processes only the data that is adequate, relevant and necessary for the service, namely: identification and contact details; tax and bank/payment data; vehicle data (including license plate and VIN/chassis number); ownership/transfer data; documents, declarations, powers of attorney, contracts and invoices; communications and case history. As a rule, the data is provided by the client or comes from the documentation and from the entities lawfully involved in the process.

3. Purposes and legal bases

The data is processed to enter into and perform the contract; to prepare, follow up and complete car legalization/regularization, import, registration and ownership transfer processes; to communicate with the client and the entities involved; to obtain and deliver documentation; to invoice, manage payments and comply with administrative, tax, accounting and legal obligations; and to keep documentation and exercise or defend rights.

Depending on the purpose, processing is based on the performance of the contract or pre-contractual steps (Art. 6(1)(b) GDPR), compliance with a legal obligation (point (c)), legitimate interest, where applicable and after the necessary balancing test (point (f)), or consent (point (a)) only where that is the appropriate basis. Consent, where required, will be freely given, specific, informed, unambiguous and separate from the processing necessary for the service.

4. Recipients and the Group

The data may be disclosed, to the extent necessary, to the Institute for Mobility and Transport (IMT), the Tax and Customs Authority (AT), the Institute of Registries and Notary (IRN)/Registry Offices, insurers, carriers, customs brokers, garages, the certified accountant, technology providers (including CRM, hosting, storage, email and IT support) and the competent authorities, where required by law.

The fact that COMFYLAND is part of the SPIRIT ENTERPRISE group does not in itself mean that data is disclosed to the other companies of the Group. Any future intra-group disclosure will depend on a specific purpose, an appropriate legal basis and compliance with the duty to inform and other legal requirements.

5. Processors, security, retention and transfers

Providers that process data on behalf of and on the instructions of COMFYLAND are subject to Art. 28 GDPR and to appropriate confidentiality and security obligations. COMFYLAND will adopt appropriate technical and organizational measures, including access control, individual credentials, protection of equipment and files, backups and incident response procedures.

The data will be kept only for as long as necessary for the purposes and for the applicable legal periods, and may also be kept where necessary to establish, exercise or defend legal claims; once those periods have ended, it will be securely deleted or anonymized.

6. Rights and provision of data

Data subjects may, under the law, exercise their rights of access, rectification, erasure, restriction, objection and portability, where applicable, and withdraw any consent previously given, without affecting the lawfulness of prior processing. Requests: geral@comfyland.pt. You may also lodge a complaint with the Portuguese Data Protection Authority (CNPD).

Providing the data essential to the contract, to the legalization process or to compliance with legal obligations is necessary; failure to provide it may prevent the service from starting, continuing or being completed. Data for optional purposes that depend on consent does not affect the provision of the service.

7. Updates and acknowledgment

This information may be updated whenever relevant changes occur, and the version in force is made available through the website, the CRM or other means.