CASTILHO COLLECTIONS

PRIVACY POLICY

CASTILHO COLLECTIONS

KEY PRINCIPLES

At Castilho Collections, we value your privacy and are committed to protecting your personal data. The security of your information is a priority, and we follow the strictest standards to ensure its protection at every stage, from the moment you interact with us through to the provision of our services. 

This document provides a clear overview of the data we may collect, how it will be used, and how we ensure its security. In it, we explain our practices regarding the processing of personal data when you visit the website www.castilhocollections.com or use our services. 

Please read our Privacy Policy carefully to understand how we handle your information. By continuing to browse our website or use our services, you acknowledge that you accept and agree to the practices described therein. 

If you do not agree with this policy, we recommend that you do not use our services or our website. 

We invite you to read our Privacy Policy in detail. 

The website castilhocollections.com is the specialized platform and business unit of Castilho International Legal Corporation, dedicated to debt collection. All of its activities are carried out under the joint responsibility and management of CASTILHO INTERNATIONAL – LEGAL ASSET MANAGEMENT, LDA. and TAVARES CASTILHO, RODRIGUES & ASSOCIADOS – SOCIEDADE DE ADVOGADOS SP RL, which ensure compliance with applicable legal, regulatory, and ethical standards.

The personal data that Castilho International Legal Corporation processes to provide these services pertains to its clients and other individuals as necessary, including employees and the employees of suppliers.

This policy sets forth Castilho International Legal Corporation’s commitment to ensuring that any personal data—including special categories of personal data—processed by Castilho International Legal Corporation is handled in accordance with data protection laws. Castilho International Legal Corporation processes personal data of employees worldwide, including personal data of a large number of non-European Union citizens, but is committed to ensuring that all personal data it processes is handled in accordance with data protection laws. Castilho International Legal Corporation ensures that best practices in data protection are embedded in the culture of our employees and our organization.

Other data protection policies and procedures at Castilho International Legal Corporation include:

-Record of processing activities;

-Privacy notices (website, customers, employees);

-Process for reporting personal data breaches and recording breaches;

-Data Retention Policy;

-Procedure for data subjects' rights;

-Data protection impact assessment process;

– IT security policies.

The “Data Protection Act” includes the General Data Protection Regulation 2016/679 and all relevant EU and Portuguese data protection legislation.

SCOPE

This policy applies to all personal data processed by Castilho International Legal Corporation and is part of Castilho International Legal Corporation’s approach to ensuring compliance with data protection laws. All employees of Castilho International Legal Corporation must comply with this policy, and noncompliance may result in disciplinary action for misconduct, including termination.

DATA PROTECTION PRINCIPLES

Castilho International Legal Corporation adheres to the data protection principles described below. When processing personal data, it ensures that:

-They are processed in a lawful, fair, and transparent manner with respect to the data subject (“lawfulness, fairness, and transparency”);

– They are collected for specific, explicit, and legitimate purposes and are not further processed in a manner incompatible with those purposes (“purpose limitation”);

-They are appropriate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);

-They are accurate and, where necessary, kept up to date, and reasonable measures will be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay (“accuracy”);

-They are maintained in a manner that allows for the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (“storage limitation”);

– They are processed in a manner that ensures the appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (“integrity and confidentiality”);

Castilho International Legal Corporation will facilitate any request from a data subject who wishes to exercise their rights under data protection laws, always communicating in a concise, transparent, intelligible, and easily accessible manner and without undue delay.

PROCESSES/PROCEDURES/GUIDELINES

Castilho International Legal Corporation will:

  • Ensure that the legal basis for the processing of personal data is identified in advance and that all processing complies with the law;
  • Not to do anything with your data that you would not expect, given the content of this policy and the fair processing notice or privacy notice;
  • Ensure that there are appropriate privacy notices informing employees and others about how and why their data is being processed, and inform data subjects of their rights;
  • Collect and process only the personal data you need for the purposes you have previously identified;
  • Ensure that the personal data it holds is accurate, or that a system is in place to ensure that it is kept up to date to the extent possible;
  • Retain your personal data only for as long as necessary, after which Castilho International Legal Corporation will securely delete or destroy the personal data—Castilho International Legal Corporation’s data retention policy defines the appropriate period;
  • Ensure that appropriate security measures are in place to guarantee that personal data can only be accessed by those who need to access it and that it is stored and transferred securely.

Castilho International Legal Corporation will ensure that all employees who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are properly trained and supervised.

Failure to comply with this policy may result in disciplinary action for misconduct, including termination. The collection (including access) or disclosure of personal data in violation of Castilho International Legal Corporation’s data protection policies may also constitute a criminal offense. 

RIGHTS OF DATA SUBJECTS

Castilho International Legal Corporation has procedures in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection laws. All employees have received training and are aware of data subjects’ rights. Employees can identify such a request and know whom to forward it to.

All requests will be considered without undue delay and, to the extent possible, within one month of receipt. 

Access to data: the right to request information about how personal data is being processed, including whether personal data is being processed, and the right to access that data and receive a copy of it, as well as the right to obtain the following information:

– The purpose of the processing;

– The categories of personal data;

– The recipients to whom the data has been or will be disclosed;

– The retention period;

– The right to file a complaint with the National Data Protection Commission;

– The source of the information, if it is not obtained directly from the data subject;

– The existence of any automated decision-making.

Rectification: the right to allow a data subject to correct inaccurate personal data concerning him or her.

Erasure: the right to have data erased and to obtain confirmation of the erasure, but only when:

– The data is no longer necessary for the purpose for which it was collected, or;

– When consent is withdrawn, or;

– When there is no legal basis for the processing, or;

– There is a legal obligation to delete the data.

Restriction of processing: the right to request the restriction of certain processing activities in the following circumstances:  

– If the accuracy of the personal data is disputed, or;

– If our processing is unlawful but the data subject does not want the data to be erased, or;

– If the data is no longer necessary for the purpose of processing, but is necessary for the data subject to establish, exercise, or defend legal claims, or;

– If the data subject has objected to the processing, pending verification of that objection.

Data portability: The right to receive a copy of the personal data provided by the data subject and processed by automated means in a format that allows the individual to transfer the data to another data controller. This applies only if Castilho International Legal Corporation is processing the data based on consent or a contract.

Right to object to processing: the right to object to the processing of personal data based on legitimate interests, unless Castilho International Legal Corporation can demonstrate compelling legitimate grounds for the processing that override the interests of the data subject or for the establishment, exercise, or defense of legal claims.

SPECIAL CATEGORY PERSONAL DATA

Includes the following personal data that reveals:

– Racial or ethnic origin;

– Political views;

– Religious or philosophical beliefs;

– Union membership;

– The processing of genetic data and biometric data for the sole purpose of identifying an individual;

– An individual's health;

– An individual’s sex life or sexual orientation;

– Criminal convictions or offenses.

Castilho International Legal Corporation processes special-category data from clients and third parties as necessary to provide legal services for the establishment, exercise, or defense of legal claims.

Castilho International Legal Corporation processes special category data of employees as necessary to comply with labor and social security laws. This policy sets forth the safeguards we consider appropriate to ensure that we comply with the data protection principles described above. Castilho International Legal Corporation also has a data retention policy that specifies the length of time for which special category data will be retained.

RESPONSIBILITY FOR THE PROCESSING OF PERSONAL DATA

The partners of Castilho International Legal Corporation bear ultimate responsibility for data protection.

If you have any concerns or wish to exercise any of your rights under the GDPR, you can contact the data protection officer as follows:

By email:

info@castilholegalcorp.com

Sending a letter to:

129-B Avenida da Liberdade, 1250-140 Lisbon

Or

Calle de Velásquez, No. 10, 1st Floor, ZIP Code 28001, Madrid

By phone:

(+351) 234 482 214

MONITORING AND REVIEW

This policy was last updated on June 3, 2026, and will be regularly monitored and reviewed at least every two years.