VILLA ROSA Presented by Vida Portugal

Privacy Policy

villarosadouro.com

Effective Date: August 24, 2026 Last Updated: September 2, 2026

This Privacy Policy explains how Villa Rosa (villarosadouro.com), presented by Vida Portugal ("we," "us," "our"), collects, uses, shares, and protects your personal data when you visit this website or submit an inquiry about the Villa Rosa opportunity. It also describes your rights regarding your personal data.

We are committed to protecting your privacy in compliance with the EU General Data Protection Regulation (GDPR), applicable Portuguese data protection law, and US state privacy laws including the California Consumer Privacy Act (CCPA/CPRA).

1. Data Controller

The data controller responsible for your personal data is:

Fugaz Alegoria — Unipessoal Lda. NIF/NIPC: 518687368 Rua da Constituição, n.º 234, 4200-192 Porto, Portugal Email: [email protected]

Fugaz Alegoria — Unipessoal Lda. operates both Vida Portugal and VIDA Living Spaces (Mediação Imobiliária, AMI license 25648), which acts as the licensed real estate intermediary marketing Villa Rosa on behalf of its owner. If you have any questions about how we handle your personal data, you can contact us at the address above.

2. What Personal Data We Collect

• Information you provide directly, when you submit an inquiry:

• Name, email address, phone number, and country of residence

• Preferred language

• How you heard about Villa Rosa

• If inquiring as a prospective private buyer: intended use of the property, timeline, whether you are represented by a real estate agent or attorney, and prior property-purchase experience in Portugal or the EU

• If inquiring as an institutional or business buyer: firm or entity name, your role, buyer type, financing status, typical deal size range, whether you are represented by a broker or advisor on this opportunity (and, where relevant, the name of that broker or advisor firm), and whether you wish to proceed under a Non-Disclosure Agreement before receiving further financial materials

• Any information you share with us in follow-up correspondence, calls, or during due diligence

Information collected automatically:

• IP address, browser type, device information, and operating system

• Pages visited, time spent on pages, referring URLs, and click behavior

• Cookies and similar tracking technologies (see Section 8 below)

Information from third parties:

• If you are referred to us by a broker, M&A advisor, or industry network partner, they may share your name and contact information with your consent

3. Why We Collect Your Data and Legal Bases

Under the GDPR, we must have a lawful basis for processing your personal data. Our purposes and the corresponding legal bases are:

• Responding to your inquiry and providing information about Villa Rosa — Legitimate interest (pre-contractual communications); consent where applicable.

• Qualifying you as a private/lifestyle or institutional inquirer, so we can send relevant materials and connect you with the right person on our team — Legitimate interest; consent.

• Administering a Non-Disclosure Agreement and controlling access to confidential financial or operating materials for institutional inquirers — Contract (the NDA itself); legal obligation to the seller of confidentiality.

• Sharing relevant information with the seller of Villa Rosa and their advisors, and with any broker or advisor representing you, to evaluate and progress your inquiry — Performance of pre-contractual steps; your explicit consent.

• Tracking referral relationships with brokers and industry networks who direct inquiries to us — Legitimate interest (administering commission-sharing arrangements).

• Sending you marketing communications or updates about Villa Rosa or related opportunities — Consent (you can withdraw at any time).

• Analyzing website usage to improve our content — Legitimate interest.

• Running targeted advertising campaigns — Consent (via cookie consent mechanism).

• Complying with legal or regulatory obligations, including Portuguese real estate mediation law — Legal obligation.

4. Who We Share Your Data With

We do not sell your personal data. We share your data only when necessary to evaluate and progress your inquiry, and only with the following categories of recipients:

• The seller of Villa Rosa and their advisors, to the extent necessary to evaluate your inquiry and, where applicable, progress a transaction.

• VIDA Living Spaces (AMI 25648), operated by the same legal entity, as the licensed mediator for this property.

• Brokers, M&A advisors, or firms representing you, where you have identified one, and industry referral partners who directed you to us, for referral-commission administration.

• Independent third-party professionals (such as legal or tax advisors), only where you engage them or ask us to make an introduction. These professionals are independent data controllers under their own privacy policies.

• Service providers who help us operate this website and manage inquiries, including our CRM/hosting platform, email service providers, and analytics or advertising platforms. These act as data processors on our behalf.

• Legal and regulatory authorities, when required by law, regulation, or legal process.

5. International Data Transfers

Your personal data is primarily processed and stored within the European Economic Area (EEA). Some of our service providers (such as CRM/hosting, email, and analytics platforms) may be located in the United States or other countries outside the EEA. Where we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, including transfers to countries with an adequacy decision from the European Commission, the EU-US Data Privacy Framework where applicable, and Standard Contractual Clauses (SCCs) approved by the European Commission. You may request further details about the safeguards we use by contacting us.

6. How Long We Keep Your Data

• Inquiry and qualification data for prospective buyers who do not proceed: retained for a reasonable period to allow follow-up, then deleted or anonymized unless you ask us to retain it longer or applicable law requires otherwise.

• Data related to an active transaction, including NDA records and materials shared under confidentiality: for the duration of the transaction process, plus 5 years after its conclusion, to comply with Portuguese commercial record-keeping requirements.

• Marketing contacts: until you withdraw your consent or unsubscribe.

• Website analytics data: up to 26 months.

• Data required for legal compliance: as long as the relevant legal obligation applies.

• When data is no longer needed, it is securely deleted or anonymized.

7. Your Rights

Rights under the GDPR (all users):

If you are located in the EU/EEA or if we process your data under GDPR, you have the right of access, rectification, erasure (subject to legal retention requirements), restriction of processing, data portability, objection (including to direct marketing), and the right to withdraw consent at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with the Portuguese data protection authority (Comissão Nacional de Proteção de Dados — CNPD) or with the supervisory authority in your EU member state of residence.

Additional rights for California residents (CCPA/CPRA):

If you are a California resident, you have the right to know what personal information we have collected about you and why, the right to delete it (subject to certain exceptions), the right to opt out of sale or sharing (we do not sell your personal information; see Section 8 for advertising cookies), and the right to non-discrimination for exercising these rights.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days (GDPR) or 45 days (CCPA) of receiving your request.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies. Types of cookies we use: strictly necessary cookies (required for the site to function, cannot be disabled), analytics cookies (help us understand how visitors use the site), and marketing/advertising cookies (used to deliver and measure targeted advertising).

When you first visit our website, you will be presented with a cookie consent banner allowing you to accept or reject non-essential cookies before they are set. You can change your preferences at any time through the cookie settings link on our website, and you can also control cookies through your browser settings.

9. Confidential Information and Non-Disclosure Agreements

This Privacy Policy governs how we handle your personal data. It is separate from, and does not replace, any Non-Disclosure Agreement you may sign to access confidential financial, operating, or transaction-specific materials about Villa Rosa. That NDA is a distinct contractual document governing the business information disclosed to you, and its terms apply in addition to this Privacy Policy.

10. Third-Party Links

Our website may contain links to third-party websites, including those of professionals we work with. We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us and we will promptly delete it.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of this page. If we make material changes affecting how we process your personal data, we will notify you by email or through a prominent notice on our website before the changes take effect.

14. Contact Us

Villa Rosa (presented by Vida Portugal) Fugaz Alegoria — Unipessoal Lda. Rua da Constituição, n.º 234, 4200-192 Porto, Portugal Email: [email protected] Website: villarosadouro.com

Supervisory authority: If you are not satisfied with our response, you have the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD), the Portuguese data protection authority, at cnpd.pt. EU residents may also contact the supervisory authority in their country of residence.