Privacy policy

This policy explains how TurnKey (Grégory Vincent / APFL Unipessoal Lda) collects, uses and protects your personal data, in accordance with the General Data Protection Regulation (GDPR) and Portuguese Law 58/2019.

Data controller

Grégory Vincent, acting through APFL Unipessoal Lda.
Contact email: gregory.vincent@iadportugal.pt

Data collected

Through the site's forms, we collect only the data required to process your request:

• First and last name
• Email and phone number
• Information related to your project (business type, area, budget, revenue, etc.)
• Any additional message you share with us

No sensitive data (health, orientation, beliefs) is collected.

Purposes

• Respond to your valuation or information request
• Propose mandates matching your search (buyers list)
• Ensure commercial follow-up in the context of a potential mandate

Legal basis

Processing of your data is based on your consent (voluntary form submission) and on the performance of pre-contractual measures taken at your request.

Recipients

Your data is processed exclusively by Grégory Vincent / TurnKey. It is never sold, rented or transferred to third parties.

We use the following technical sub-processors:

• Formspree (United States) for form reception
• Cloudflare (United States) for site hosting
• Google Workspace for email management

These sub-processors adhere to the standard contractual clauses approved by the European Commission for transfers outside the EU.

Retention period

• Requests without follow-up: 12 months
• Active files (mandates, buyers list): duration of the relationship + 3 years
• Legal obligations (accounting, invoices): 10 years

Your rights

Under the GDPR, you have the following rights:

• Right of access to your data
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to portability
• Right to object
• Right to withdraw consent at any time

To exercise these rights: gregory.vincent@iadportugal.pt

In case of dispute, you may contact the CNPD (Comissão Nacional de Proteção de Dados): cnpd.pt