Privacy

Privacy Policy

Last updated: 15 September 2026

UGON — Home Buying Service is the trading designation used on this website. UGON is not a legal entity.

During the search, organisation of your requirements, market analysis, matching and digital support stage, the data controller is APOCI — Associação Portuguesa de Consultores Imobiliários, NIPC 518 824 667, registered office at Rua Diogo Couto n.º 26, 2.º Dto., 2750-563 Cascais, Portugal.

Privacy contact: privacidade@apoci.pt.

If a matter progresses to a stage requiring legally regulated real-estate mediation acts, strictly necessary data may be shared with the legally authorised entity acting at that stage, after the user has been duly informed and before that intervention.

Data we process

We may process name, telephone number, email, contact source, purchase intention, areas, location, property type, budget, timing, preferences, search criteria, answers given during the search, declared financing status, properties analysed, sent, viewed or rejected, feedback, interactions and relevant search history.

We may also process limited technical data associated with the use of the website and our systems, such as IP address, date/time, technical logs and source/referrer where available. Communications made by email or WhatsApp may form part of the operational history of the process.

Identification, credit, income or transaction-related documentation will only be requested when the relevant stage of the process justifies it. We do not seek to collect special categories of personal data unless strictly necessary and supported by an appropriate legal basis.

Why we use data and our legal basis

We use data to respond to contact and organise the requested search; create and maintain the search profile and criteria; produce Market Studies, analysis and matching; communicate by email or WhatsApp; preserve continuity and operational history; support the progression of the process; prevent fraud, protect systems and maintain auditability; and measure service quality and performance.

Depending on the case, these processing activities are based on steps requested by the user and provision of the service, APOCI’s legitimate interests in providing, protecting and improving the requested service, performance of a contract or pre-contractual steps, and compliance with legal obligations.

Consent will be used where required by law, including for direct marketing where no other legal basis applies and for non-essential tracking technologies. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Automation and artificial intelligence systems

We may use automated tools, including artificial intelligence systems, to organise information, support market analysis, matching, preparation of communications and operational tasks.

Under the current model, these tools do not make solely automated decisions that produce legal effects or similarly significant effects on the user. Sensitive decisions and material steps remain subject to human intervention. If this model changes, this policy will be updated.

Technology providers and recipients

To provide the service we may use, among others, Fillout for forms, Supabase for database and operational infrastructure, 360dialog and WhatsApp/Meta for communications, as well as website hosting, email, security, storage and technical-support providers.

These providers receive only the data necessary for the functions they perform and are subject to applicable contractual and data-protection conditions.

The Supabase project currently used is hosted in the eu-west-1 region, Ireland. Some providers may involve processing outside the European Economic Area. In such cases, transfers should only take place through a legally recognised mechanism.

Retention

We retain data only for as long as necessary for the relevant purpose and applicable legal obligations.

While a search is active, data necessary to support it may be retained. When a contact no longer progresses, retention is reassessed considering the last relevant interaction, reasonable possibility of reactivation, operational purpose and any need to establish, exercise or defend legal claims.

Home-buying processes closed without a transaction and without a specific legal retention duty are retained only while a legitimate purpose remains for keeping the relevant history; after that, data should be deleted or anonymised where applicable.

Technical security logs and audit records are retained for the period necessary for prevention, detection and investigation of incidents, audit and compliance, with data minimisation and technical rotation.

Backups follow technical retention and rotation cycles defined by the infrastructure and are not kept longer than necessary for security and recovery purposes.

Where a real-estate mediation contract exists or specific legal duties apply, certain documents and records may need to be retained for longer periods under applicable law.

Data processed exclusively for marketing will be retained until consent is withdrawn, an objection is made, or the relevant purpose ends.

Your rights

You may request access to your data, rectification, erasure where applicable, restriction of processing, objection and portability where the legal requirements are met. You may also withdraw any consent previously given.

Requests may be sent to privacidade@apoci.pt. We may request additional information only where necessary to verify the identity of the requester.

You may also lodge a complaint with the Portuguese data protection authority, Comissão Nacional de Proteção de Dados — CNPD.

Cookies and device storage

The website should not install tracking or storage technologies that are not strictly necessary without prior consent.

While Meta Pixel, Google Analytics or equivalent technologies are not in use, we do not install a consent mechanism merely as a precaution. If such technologies are activated, they should not load before the required consent exists.

Children

The service is intended for adults. We do not seek to intentionally collect data from people under 18. If such data is received without a legal need, it will be deleted.

Changes

This policy may be updated to reflect legal, operational or technological changes. The current version will be published on this page with the date of the latest update.