Privacy Policy

MoveToSetú and its owners and affiliates (“MoveToSetúbal”, “MoveToSetú”, “we” or “us”) are committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy (the “Privacy Policy”) is to inform you about our privacy practices, including how we collect, use and disclose your personal information.

This Privacy Policy applies to our website, mobile applications and related services (collectively, the “MoveToSetúbal Services”). By visiting, accessing, or using the MoveToSetúbal Services, you consent to the policies and practices of this Privacy Policy so please read them carefully. If any policies or practices of this Privacy Policy are unacceptable to you, please do not visit, access, or use the MoveToSetúbal Services.

We are responsible for processing the personal data you provide to us. We will process them to be able to render the services you request. At the time you request a service, this request becomes a contractual relationship that is the legal basis to be able to process them. We may also send you commercial messages when you have accepted them. If you have authorized the assignment of your data or you have requested us to provide a service rendered by other companies, the latter will need to have access to your data in order to be able to render the service. You can, at any time, access, rectify or cancel your data, as well as exercise other rights, as explained below.

When you click the “Accepted and Agreed” button or equivalent, you state you know and understand our privacy policy.

What’s in this Privacy Policy?

  1. Data Controller
  2. Privacy Policy Amendments
  3. Personal Information We Collect
  4. Cookies Policy
  5. How We Use Personal Information
  6. How We Share Personal Information
  7. Information Security
  8. Retention of Personal Information
  9. Rights Regarding your Personal Information
  10. Direct Marketing
  11. Data Transfer
  12. Embedded content from other websites
  13. Third Party Websites and Services
  14. Children’s Privacy
  15. Contact Us

Data Controller

Kenneth J. Mitteldorf, doing business as MoveToSetú, with a registered office in Setúbal, at Av. Bento Gonçalves 30, 9-dto, Setúbal 2910-431, with Tax Identification Number 292038054, is the data controller of the personal data that are sent through our website, its sub-domains or our apps. We provide information in the following sections about the rights you hold as well as how we use your personal data, whether you use our Website and Apps to search for information (hereinafter referred to as the “User”) or if you post a listing as an individual (either as a User or as an “Advertiser”) by virtue of the General Data Protection Regulations (hereinafter referred to as the “GDPR”)

If you have any queries related to the processing of your personal data, you can contact our Data Protection Officer using the following email address: [email protected]. 

Privacy Policy Amendments

Your privacy matters to us so please take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time. We will always have the latest version of this Privacy Policy on this page. Visiting, accessing, or using the MoveToSetúbal Services following any change to this Privacy Policy is considered to be your acceptance of any such changes. You should, therefore, read this Privacy Policy from time to time. If you do not agree to be bound by this Privacy Policy, you should not visit, access or use the MoveToSetúbal Services.

Personal Information We Collect

The personal information we collect about you may include the following. In each case, we identify the grounds that we rely on to process your personal information under the GDPR:

  1. Account Profile – when you open an account, we may collect your first name, last name, email address, username and password. You may also provide additional details on your account profile, such as your profile picture, photos, location data, personal website, Instagram username, and Facebook profile. Applicable legal grounds: contract performance, consent, legitimate interests (to enable us to perform our obligations and provide our services);
  2. Device Information – information that is automatically collected about your device, such as IP address, hardware, operating system, browser, etc. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance;
  3. Location Information – information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance;
  4. Server Log Information – information that is generated by your use of the MoveToSetúbal Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to MoveToSetúbal pages that you visit. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance;
  5. Correspondence – information that you provide to us in correspondence, such as when you submit questions or inquiries and with respect to ongoing customer support. Applicable legal grounds: legitimate interests (to enable us to perform our obligations and provide our services), consent, contract performance.
  6. When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
  7. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: After approval of your comment, your profile picture is visible to the public in the context of your comment.
  8. If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies Policy

MoveToSetúbal may also make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (“Cookies”) on your computer or other devices used to access the MoveToSetúbal Services. Cookies are small bits of information that are automatically stored on the web browser of your device that can be retrieved by us. The type of information we collect includes, but is not limited to, uniquely identifying visitor information and information related to your usage preferences. We use these technologies to help us recognize you as a user, collect information about your use of the MoveToSetúbal Services to better customize our services and content for you. By using the MoveToSetúbal Services, you acknowledge and agree that we may collect and/or transmit any data collected to our third-party service providers, such as analytics providers, mapping services, payment processors, and website security services, which may also make use of such technologies described above. Please note that if you block or delete cookies you will not be able to use some or all of the MoveToSetúbal Services.

Our website uses the following types of cookies:

  • Cookies to facilitate user navigation and remember where you are located when browsing the website. These cookies typically disappear after one month.
  • Session cookies to track the session on pages that require registration. These cookies are necessary to access the services or content restricted to users browsing as registered users. If you do not select ‘remember password’, these cookies are deleted when the browser is shut down or the computer is turned off
  • Measuring and web analytics cookies. These cookies are used to analyze visits and times of web site navigation. Information collected from these cookies is directly transmitted to and stored on the servers of service providers.
  • Advertising cookies. These cookies are used to know if you have seen an advertisement and how long the advertisement has not been seen for. This allows us to show you the most appropriate advertising at all times.
  • Third party advertising cookies. Advertisements displayed on this Site are often generated by third parties. Some of these third parties may store cookies on your browser while you are browsing our Site. Companies that generate these cookies have their own privacy policies.
  • Other third-party cookies. Other third party cookies can be stored on your browser when you are browsing our Site. For example, when you click on the ‘share’ button on MoveToSetú in order to share content on a Instagram, Instagram will store a cookie on your computer. The companies that generate these cookies have their own privacy policies.
  • If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
  • If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
  • When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
  • If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

How can these cookies be disabled? Browsers can be configured so that these cookies are automatically deleted once the browser is closed, or the computer or device is turned off

You can click here to see and adjust Your Cookies Settings.

The owner of this website may be contacted regarding cookies at this address: [email protected]

Links of interest: guide to behaviour-based advertising:

How We Use Personal Information

We take steps designed to ensure that only those persons who need access to your personal information to fulfil their employment duties will have access to it. We may use the personal information we collect to:

  1. Register you as a User and create your User profile;
  2. Save and manage your searches, interests and preferences;
  3. Enable you to contact advertisers and owners of places or services listed on our site;
  4. Enable you to add listings to our site;
  5. Enable you to post comments, reviews, ratings and engage in discussions with other users;
  6. Enable you to post advertisements on our site;
  7. provide you with the MoveToSetúbal Services, including customer support;
  8. optimize and enhance the MoveToSetúbal Services, including to develop new products, services, features, and functionality;
  9. respond to inquiries, claims, and other requests;
  10. provide you with information that we think may interest you, including in regards to our products and services;
  11. conduct satisfaction surveys;
  12. Manage any claims for payment of due amounts you (or the company you represent) may owe us in relation to our services for subscriptions, advertisements, or other obligations;
  13. monitor the usage of the MoveToSetúbal Services, including by conducting automated and manual security checks;
  14. understand and analyze the usage trends and preferences of our users;
  15. create aggregated and anonymized reporting data about the MoveToSetúbal Services;
  16. investigate legal claims;
  17. carry out such purposes for which we may obtain consent from time to time; and
  18. carry out such other purposes as may be permitted or required by applicable law.

How We Share Personal Information

We may disclose your personal information to law enforcement and governmental entities when required by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We may also disclose your personal information to a third party in the event of any potential or completed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business.

We rely on third party services providers to perform a variety of services on our behalf, such as identity verification, detection of fraud or security threats, telephone or technical support, payment card processing, hosting services, and data storage or processing, and we may transfer your personal information to our service providers for such purposes. Third party service providers have access to and may collect personal information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and that such third parties provide sufficient guarantees to implement appropriate technical and organizational measures to protect your personal information.

You may find tools on the Service that let you send information, including User Content, to other companies’ services, or to advertisers or other users of our site. For example, you may find features that allow you to link your account on the Service with an account on another service (e.g., Facebook or Instagram or the implementation of other companies’ like or share buttons), or that allow you to contact a business or another user to request additional information. If you use these tools, we will share certain of your personal information with those third parties. We may also utilize your requests for additional information for our own marketing purposes, send you additional related marketing materials, and share your request with our advertising partners.

Information Security

We take your privacy very seriously and have implemented physical, organizational and technological security measures with a view to protecting your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. In particular, we encrypt the MoveToSetúbal website with SSL; we periodically review information collection, storage, and processing practices; and we restrict access to your information on a need-to-know basis for our employees, contractors, and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. Depending on each processing purpose, the period for storing your data will be:

  • During the contractual relationship, in other words while you are using our services or while we or the supplier is handling your requests;
  • Until your query or claim has been settled;
  • Until you revoke your consent;
  • If you are a representative or contact person of an Advertiser or listing owner, during the contractual relationship with the company you represent or until you notify us that you are no longer its contact person; or
  • Until you request its cancellation.

Rights Regarding Your Personal Information

Under certain circumstances and in accordance with the GDPR or other applicable data protection laws, you have the following rights:

  1. Access – ask if we are processing information and, if we are, request access to your personal information. This enables you to receive a copy of the personal information we hold and certain other information about you;
  2. Correction – request that any incomplete or inaccurate personal information about you that we hold be corrected;
  3. Erasure – ask us to delete or remove your personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with legal claims;
  4. Restriction – ask us to suspend the processing of your personal information, for example, to establish its accuracy or the reason for processing it;
  5. Transfer – request the transfer of certain personal information to another party;
  6. Objection – challenge our processing of personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information in certain circumstances;
  7. Automated decisions – contest any automated decision made where it has a legal or similar significant effect and ask for it to be reconsidered; and
  8. Consent – where we are processing personal information with consent, withdraw your consent.

You also have a right to make a complaint with a data protection supervisory authority, in particular in the Country (as defined below) where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us as set forth in the “Contact Us” section.

Direct Marketing

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from you. If you no longer want to receive marketing-related communications from us, you may opt-out of such communications by clicking the “unsubscribe” link at the bottom of emails you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below. We will endeavor to respond to your opt-out request promptly, but we ask that you please allow us reasonable time to process your request. We will not provide your information to third parties for direct marketing or other unrelated purposes without your written consent.

Please note that if you opt-out from receiving marketing-related communications, we may still need to send you communications about your use of our products or services, or other matters, subject to applicable laws and regulations.

Data Transfer

Your personal information may be stored and processed in any country, province or state (each a “Country”) where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to Countries outside your Country of residence, which may have different data protection rules than in your Country. While such information is outside of your Country, it is subject to the laws of the Country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other Country, pursuant to the laws of such Country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with the GDPR requirements of providing adequate protection for the transfer of personal information from the EU/EEA to other countries.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Third Party Websites and Services

This Privacy Policy applies only to the MoveToSetúbal Services and does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children’s Privacy

The MoveToSetúbal Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the MoveToSetúbal Services at any time or in any manner. If we learn that personal information has been collected on the MoveToSetúbal Services from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has provided personal information, then you may alert us as set forth in the “Contact Us” section and request that we delete that child’s personal information from our systems.

Contact Us

For any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Portugal, our Privacy Officer can be reached at [email protected].

This Privacy Policy was last updated on March 19th, 2019. v1.0