This Privacy Policy of Ideias Dinâmicas - Investimentos Imobiliários, Lda., operating under the trade name, registered trademark of the company, Manoeuvre, establishes how Manoeuvre collects and processes personal data from its clients.

We recommend that you read this document carefully and thoroughly. By providing your personal data, you acknowledge and accept the terms and conditions set out in this Privacy Policy.

1. Data controller

The data controller responsible for processing your personal data is Manoeuvre.

However, Manoeuvre may, as part of its activity, use partners to pursue the data collection purposes indicated below. In these cases, Manoeuvre ensures that such partners provide sufficient guarantees for the implementation of technical and organisational measures to protect the rights of data subjects.

2. Personal data we collect and process

Under the terms of the applicable regulations, personal data refers to any information, of any nature and regardless of its format, including sound and image, relating to an identified or identifiable natural person. An identifiable person is someone who can be identified directly or indirectly, in particular by reference to an identification number or to one or more specific details of their physical, physiological, mental, economic, cultural, or social identity.

The personal information collected by Manoeuvre may include your name, email address, phone number, fax number, address, date of birth, national identity card or other identification document, taxpayer number, and banking and/or other details.

The personal information collected by Manoeuvre may include the image, voice, name, email address, phone number, fax number, address, date of birth, national identity card or other identification document, taxpayer number, curriculum vitae, banking details and/or other details of Users and Artists.

Artists expressly authorised the aforementioned data for this purpose and assumed that they were true and up-to-date, unless otherwise indicated by them.

Providing certain personal data is mandatory and, if these data are missing or insufficient, Manoeuvre may not be able to provide you with the services or information you have requested. In each specific case, Manoeuvre will inform you about the mandatory or optional nature of the provision of the personal data in question.

Manoeuvre assumes that the data have been provided by the data subject or that they have given authorisation to do so and assumes that the data are true and up-to-date, unless indicated otherwise by the data subject.

3. General rules applicable to data collection and processing

Manoeuvre undertakes to lawfully process personal data, respecting the principle of good faith and ensuring absolute confidentiality.

Personal data are only collected for specific, explicit, and legitimate purposes, and will never be processed in a manner incompatible with those purposes.

Manoeuvre ensures that the personal data collected are adequate, relevant, and not excessive in relation to the purposes for which they are collected and processed.

4. How personal data are collected and processed

Personal data are collected electronically or in hard-copy format and processed in the following situations:

- in the context of the conclusion, or potential conclusion (agreement proposals), requests by the data subject to conclude agreements with Manoeuvre, purchase and sale of Artworks, among others;

- in the context of auctions organised by Manoeuvre, upon registration of the data subject for the purpose of participating in them or through the submission of purchase orders or bidding requests, or when purchasing withdrawn assets;

- through the completion and submission of a Consent Form by the data subject.

The collected data are processed electronically and stored in specific databases created and managed for this purpose by Manoeuvre in strict compliance with personal data protection legislation.

5. Legitimacy and purpose of collecting personal data

Personal data are collected and processed when processing is legitimately necessary for the following purposes:

- compliance by Manoeuvre with contractual and pre-contractual obligations, including asset assessments, placing assets in auctions, and the holder's participation in auctions, whether in person or through telephone orders or bids;

- compliance by Manoeuvre with any legal obligations to which it is subject.

If the necessary consent is given when personal data are collected or later, they are also collected and used for marketing purposes, including sending information, invitations, and other commercial initiatives by post and/or email and/or SMS, regarding sales through auctions or organised direct online sales and other services provided by Manoeuvre. In this context, segmentations and/or profiles may also be created for the same promotional/advertising purpose.

Residually, and within the terms and limits of personal data protection legislation, personal data may also be collected and processed when such processing is legitimately necessary for:

- protecting the vital interests of the data subject, if they are physically or legally incapable of giving consent;

- pursuing the legitimate interests of the data controller or a third party to whom the data are disclosed, provided that the interests or rights, freedoms, and guarantees of the data subject are not overridden.

6. Sharing personal data

Manoeuvre may share personal data with official entities on the basis of legal requirements.

Manoeuvre may also share personal data with partners and service providers for the purpose of providing such services, always respecting the duty of confidentiality and the principle of the purpose for which they were collected.

If data transfers to third-party countries outside the European Union or the European Economic Area occur, Manoeuvre will comply with the law, particularly regarding the adequacy of the country of destination concerning the protection of personal data and the requirements applicable to such transfers. Personal data will not be transferred to jurisdictions that do not provide adequate guarantees of security and protection.

7. Personal data retention period

The period of time during which data are stored and retained varies according to the purpose for which they were collected. When there is no specific legal requirement, the data will be stored and retained only for the minimum period necessary for the purposes for which they were collected and subsequently processed.

For marketing purposes, the personal data collected will be retained for a maximum period of 5 (five) years from the date on which consent was given or the last contact made (whichever occurs last), without prejudice to the possibility of withdrawing consent at any time.

Once the maximum retention period is reached, personal data will be securely destroyed.

8. Security Measures

Manoeuvre is committed to ensuring the protection and security of the personal data collected and processed. To this end, it adopts various technical and organisational security measures to protect personal data against dissemination, loss, misuse, alteration, unauthorised access, as well as any other form of unlawful processing.

These measures include the following:

- limited personal access to personal data on a "need-to-know" basis and only as part of the communicated purposes;

- transfer of collected data in encrypted form;

- storage of highly confidential data (e.g., credit card information) in encrypted form;

- protection of information technology systems through a firewall, in order to minimise the risk of unauthorised access;

- monitoring access to information technology systems, with a view to preventing and detecting the misuse of personal data.

Manoeuvre requires its partners to adopt technical and organisational safety measures equivalent to those it implements.

9. Rights of the data subject

Manoeuvre guarantees the data subject, at all times, all the rights arising from personal data protection legislation, including the rights to access, update, rectify, omit, limit the processing or deletion of personal data and, where applicable, the right to data portability.

In particular, Manoeuvre grants the data subject the right to revoke, withdraw, reduce the scope, or limit the scope of any consent previously given at any time, namely with regard to the use of data for marketing purposes.

To exercise these rights, please use the following contacts: E-mail address: dpd@ideiasdinamicas.com or - of the contacts listed below (from 9am to 12pm and from 2pm to 6pm); Postal Address: Grupo Ideias Dinâmicas, Comissão de Proteção de Dados Pessoais, Rua Álvaro Castelões, 821 – 2º, sala 2.2 4450-043 Matosinhos PORTUGAL; Telephone: +351 229 398 320.

10. Amendments to the Privacy Policy

Manoeuvre reserves the right to amend this Privacy Policy at any time. In the event that such changes are materially relevant, to the extent that it can reasonably be assumed that the conditions on which you gave your consent are compromised, Manoeuvre undertakes to request your consent again.

May 2022