Cookie Policy

1. Identity of the Controller

1.1 Controller

The controller responsible for the processing of personal data described in this Policy is:

Rui Gabriel Raminhos Guerreiro, empresário em nome individual, trading as Cubic Houses
NIF: 218 823 061
Address: Avenida da República, 116 — 2.º Esquerdo, 8700-310 Olhão, Portugal
Email: rui@cubichousesolhao.com
Telephone (WhatsApp): +351 936 380 392

References in this Policy to “Cubic Houses”, “we”, “us”, or “our” mean the controller identified above.

1.2 Data Protection Officer

Cubic Houses has not appointed a Data Protection Officer. The reasoning is set out in Section 1.2 of the Privacy Policy.

All matters relating to cookies and the processing of personal data described in this Policy may be addressed to the contact details in Section 1.1.

1.3 Relationship with the Privacy Policy

This Cookie Policy supplements the Cubic Houses Privacy Policy and should be read alongside it. Where this Policy refers to processing of personal data carried out as a consequence of cookie use (for example, the legal bases for processing, recipients of the data, retention periods, international transfers, or your rights as a data subject), the Privacy Policy contains the full description and is the authoritative reference.

In the event of any inconsistency between this Policy and the Privacy Policy in respect of personal data processing, the Privacy Policy prevails.

2. Scope of this Policy

2.1 Surfaces Covered

This Policy describes the use of cookies and similar technologies on:

• the Cubic Houses public website at cubichousesolhao.com (the “Website”); and
• HostDeck, the proprietary booking and owner platform operated by Cubic Houses, accessible to authenticated users at the URLs notified to those users on account creation.

The Website and HostDeck have different cookie footprints and consent models. The general rules described in Sections 3 to 5 and 8 to 14 apply to both surfaces. The specific cookies used on each surface are listed separately:

• cookies on the Website are described in Section 6;
• cookies on HostDeck are described in Section 7.

2.2 Surfaces Not Covered

This Policy does not cover:

• Third-party booking platforms (Airbnb, Booking.com, and similar) through which Cubic Houses' properties may be booked. Cookies set by those platforms are governed by the platform's own cookie and privacy policies.
• Third-party websites linked from the Website or HostDeck. Where the Website or HostDeck contains links to external sites (for example, partner suppliers, mapping services, or social media profiles), the cookies set by those sites are governed by their own policies.

Cubic Houses is not responsible for the cookie practices of third-party platforms or websites that it does not operate.

2.3 Who this Policy Applies To

This Policy applies to anyone who accesses the Website or HostDeck, including:

• prospective and current guests of properties managed by Cubic Houses;
• prospective and current accommodation owners;
• visitors browsing the Website without making a booking or contacting Cubic Houses;
• any other person who interacts with the Website or HostDeck.

3. What Are Cookies and Similar Technologies

3.1 Cookies

A cookie is a small text file that a website places on your device (computer, tablet, or mobile phone) through your browser when you visit the site. Cookies allow the website to recognise your device on subsequent visits or as you move between pages, and to store small amounts of information about your interaction with the site.

Cookies do not contain executable code and cannot, by themselves, install software, read other files on your device, or transmit viruses. They can, however, be used to record information about your activity on the site that places them, and — depending on how they are configured — to track that activity across other sites.

3.2 Similar Technologies

This Policy uses the term “cookies” as a shorthand that also covers other technologies that perform comparable functions. The legal regime governing cookies under Lei 41/2004 (Article 5) and the GDPR applies equally to these technologies. They include:

• Local storage and session storage: mechanisms built into modern browsers that allow a website to store data on your device. Local storage persists until explicitly cleared; session storage is cleared when the browser tab is closed.
• Pixels (web beacons): small, typically invisible images or scripts embedded in a web page or email, used to detect that the page or email has been opened and to collect related information.
• Software development kits (SDKs): code libraries integrated into a website or application that may collect information about your device and use of the site or application.
• Device fingerprinting: techniques that identify a device through a combination of its characteristics (browser version, installed fonts, screen resolution, time zone, and similar), without storing data on the device itself.

Where this Policy refers to “cookies”, the same rules apply to these similar technologies unless otherwise stated.

3.3 Categories by Origin

Cookies can be classified by who places them:

• First-party cookies are placed directly by the site you are visiting — in the case of this Policy, by Cubic Houses through the Website or HostDeck.
• Third-party cookies are placed by a domain other than the site you are visiting, typically as a result of content or services embedded in that site (for example, an analytics provider, a video player, or a social media widget). The third party that places the cookie is the controller for the data it collects through that cookie.

3.4 Categories by Duration

Cookies can also be classified by how long they last:

• Session cookies are stored only for the duration of your visit and are deleted when you close your browser.
• Persistent cookies remain on your device for a defined period (which may range from minutes to years) or until you delete them.

The duration of each cookie used by Cubic Houses is shown in the inventory tables in Sections 6 and 7.

4. Legal Framework and Legal Bases

4.1 Applicable Law

The use of cookies and similar technologies in Portugal is governed by two distinct but complementary legal regimes:

• Lei 41/2004, of 18 August (Portuguese ePrivacy law, transposing Directive 2002/58/EC as amended), which governs the placing and reading of information on a user's device. Article 5(3) of this law requires the prior, informed consent of the user before any cookie or similar technology is placed or read, except where the cookie is strictly necessary for a service explicitly requested by the user.
• The General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), which governs the processing of personal data that may follow from the use of cookies (for example, the analysis of user behaviour through analytics cookies, or the building of advertising profiles through marketing cookies).

The two regimes apply in sequence: Lei 41/2004 governs whether a cookie may be placed at all, and the GDPR governs what may then be done with any personal data collected through it.

4.2 Legal Bases

The legal basis on which Cubic Houses places each cookie depends on the function of the cookie.

Strictly necessary cookies (Section 5.1) are placed without consent, on the basis of Article 5(3) of Lei 41/2004, which exempts cookies that are strictly necessary for the provision of a service explicitly requested by the user. Where these cookies result in the processing of personal data, the legal basis under the GDPR is the legitimate interests of Cubic Houses in operating the Website and HostDeck securely (Article 6(1)(f) GDPR), or — where the user is engaging in a transaction or contractual interaction — the performance of a contract or pre-contractual measures (Article 6(1)(b) GDPR).

All other cookies — those in the preferences, analytics, and marketing categories described in Sections 5.2 to 5.4 — are placed only with your prior consent, given through the cookie banner described in Section 8. The legal basis under Lei 41/2004 is your consent under Article 5(3), and the legal basis under the GDPR is your consent under Article 6(1)(a).

You may withdraw your consent at any time, with effect for the future, through the mechanisms described in Sections 8 and 9. Withdrawal does not affect the lawfulness of any processing carried out before withdrawal.

4.3 No Cookie Walls

Access to the Website and to HostDeck is not conditional on your consent to non-essential cookies. You may reject all non-essential cookies and continue to use the Website and HostDeck without any restriction beyond the loss of the specific functionality that those cookies enable.

4.4 Relationship with the Privacy Policy

This Section describes the legal bases for the placing of cookies. Where the use of a cookie results in the processing of personal data, the full description of that processing — including the purposes, recipients, retention periods, international transfers, and your rights — is set out in the Privacy Policy.

5. Categories of Cookies We Use

Cubic Houses classifies the cookies and similar technologies it uses into four categories, based on the function they serve. The category determines whether your consent is required (Section 4.2) and how the cookie is presented in the consent banner (Section 8).

The specific cookies in each category, on each surface, are listed in:

• Section 6 for the Website (cubichousesolhao.com); and
• Section 7 for HostDeck.

5.1 Strictly Necessary

Strictly necessary cookies are required for the Website or HostDeck to function and to provide the services you request. Without these cookies, parts of the site or platform would not work, or would not be secure.

Examples of functions performed by strictly necessary cookies include:

• maintaining your session while you navigate between pages of the same site;
• keeping you authenticated after you log in to HostDeck;
• protecting forms and authenticated actions against cross-site request forgery (CSRF) attacks;
• balancing requests across servers to keep the site available;
• recording your cookie consent choices, so that the banner does not reappear on every page.

Strictly necessary cookies are placed without your consent, on the legal basis described in Section 4.2. They cannot be disabled through the cookie banner. You may block them at the level of your browser settings, but doing so will prevent the Website or HostDeck from functioning correctly.

5.2 Preferences

Preferences cookies (also called functional cookies) allow the Website or HostDeck to remember choices you make about how the site behaves, in order to provide a more personalised experience. They are not required for basic functioning.

Examples include:

• remembering your preferred language;
• remembering display preferences (for example, light or dark mode, currency, or unit of measurement);
• remembering that you have dismissed a non-critical notice or banner.

Preferences cookies are placed only with your consent, given through the cookie banner.

5.3 Analytics

Analytics cookies allow Cubic Houses to understand how the Website and HostDeck are used in aggregate — for example, which pages are visited most often, how users move through the site, where errors occur, and how the site performs technically. The purpose is to improve the design, content, and reliability of the site.

Analytics cookies may be first-party (placed by Cubic Houses directly) or third-party (placed by an analytics provider on Cubic Houses' behalf). Where third-party analytics providers are used, they appear in the inventory tables in Sections 6 and 7, and any associated international data transfers are covered in Section 10.

Analytics cookies are placed only with your consent. If you do not consent, the Website and HostDeck will function normally; Cubic Houses will simply have less aggregated information about how they are used.

5.4 Marketing

Marketing cookies are used to deliver advertising that is relevant to you, to measure the effectiveness of advertising campaigns, and — where third-party providers are involved — to build profiles of your interests across multiple sites.

Marketing cookies are typically third-party. They are placed only with your consent, given through the cookie banner.

Cubic Houses is not currently running advertising activity that requires marketing cookies, and accordingly no marketing cookies are placed regardless of your consent choice. If this changes, the inventory tables in Sections 6 and 7 will reflect that.

6. Cookies on the Website (cubichousesolhao.com)

This Section lists the cookies and similar technologies used on the Cubic Houses public Website at cubichousesolhao.com.

The Website is currently being rebuilt. The inventory below reflects the cookies in use at the effective date of this Policy. As the rebuild progresses and analytics or other tools are added, the inventory will be updated and — where the changes are material — the cookie banner will be re-displayed (see Section 8). The cookie banner remains the live source of truth for the cookies actually in use at any given time.

6.1 Strictly Necessary Cookies

These cookies are placed without your consent on the legal basis described in Section 4.2. They cannot be disabled through the cookie banner.

The exact cookie names and providers in this category will be populated upon deployment of the rebuilt Website.

6.2 Preferences Cookies

These cookies are placed only with your consent.

Currently no cookies in this category. The cookie banner is the live source of truth for any cookies added in the future.

6.3 Analytics Cookies

These cookies are placed only with your consent.

Currently no cookies in this category. Once an analytics tool is selected and deployed, the cookies it places will be listed here, together with the provider, the purpose served, the type, the duration, and any associated international data transfer (see Section 10).

6.4 Marketing Cookies

These cookies are placed only with your consent.

Currently no cookies in this category. Cubic Houses does not currently run advertising activity that requires marketing cookies. If this changes, the cookies in use will be listed here.

6.5 Similar Technologies

Beyond cookies in the strict sense (Section 3.1), the Website may use similar technologies as defined in Section 3.2.

Currently no use of local storage, session storage, pixels, SDKs, or device fingerprinting beyond what is required for strictly necessary functions. Any change will be reflected in the relevant category above and notified through the cookie banner.

7. Cookies on HostDeck

This Section lists the cookies and similar technologies used on HostDeck, the proprietary booking and owner platform operated by Cubic Houses.

HostDeck is accessible only to authenticated users (accommodation owners, Cubic Houses staff, and authorised partners). Guests do not access HostDeck directly. The cookie footprint on HostDeck is therefore narrower than on the Website: most cookies on HostDeck are strictly necessary for authentication, session management, and security.

HostDeck is in active development. The inventory below reflects the cookies in use at the effective date of this Policy. As the platform evolves and additional tooling (for example, analytics) is added, the inventory will be updated and — where the changes are material — the cookie banner will be re-displayed (see Section 8). The cookie banner remains the live source of truth for the cookies actually in use at any given time.

7.1 Strictly Necessary Cookies

These cookies are placed without your consent on the legal basis described in Section 4.2. They cannot be disabled through the cookie banner. Disabling them through your browser settings will prevent you from logging in to HostDeck or using its features.

The exact cookie names, providers, and authentication cookie duration in this category will be populated as HostDeck stabilises.

7.2 Preferences Cookies

These cookies are placed only with your consent.

Currently no cookies in this category. As HostDeck adds user-configurable display preferences (for example, language or interface preferences) that need to persist across sessions, those will be listed here.

7.3 Analytics Cookies

These cookies are placed only with your consent.

Currently no cookies in this category. Once an analytics tool is selected and deployed on HostDeck, the cookies it places will be listed here, together with the provider, the purpose served, the type, the duration, and any associated international data transfer (see Section 10).

7.4 Marketing Cookies

HostDeck does not use marketing cookies and is not expected to use them in the foreseeable future. HostDeck is an authenticated operational platform; it does not host advertising content and is not used for marketing purposes.

7.5 Similar Technologies

Beyond cookies in the strict sense (Section 3.1), HostDeck may use similar technologies as defined in Section 3.2 — in particular, local storage and session storage, which are routinely used by modern web applications to store interface state on the user's device.

To be populated — the specific use of local storage and session storage on HostDeck will be listed here as the platform stabilises. Where these technologies are used solely for strictly necessary purposes (for example, holding the current state of a multi-step form between page loads), they fall under the same legal basis as strictly necessary cookies and do not require consent. Where they are used for non-essential purposes, consent applies.

8. Consent — How the Cookie Banner Works

This Section describes how Cubic Houses obtains, records, and respects your consent for cookies that are not strictly necessary.

8.1 When the Banner is Displayed

A cookie banner is displayed:

• on your first visit to the Website or HostDeck;
• on subsequent visits, where you have not yet made a consent choice (for example, because you previously dismissed the banner without choosing, or because the consent record cookie has been deleted);
• when material changes are made to the cookies in use (for example, the addition of a new analytics provider or a new category of cookies). In this case, the banner is re-displayed even to users who have previously made a consent choice, so that consent can be obtained again on the basis of the updated information.

The banner is not displayed on every visit. Once you have made a consent choice, that choice is recorded (Section 8.5) and the banner does not reappear until one of the conditions above applies, or until you actively re-open it (Section 8.6).

8.2 Granular Consent

The banner allows you to consent to or reject each non-essential category separately:

• Strictly necessary cookies (Section 5.1) are always active and cannot be toggled off in the banner. They are placed without consent on the legal basis described in Section 4.2.
• Preferences cookies (Section 5.2) are placed only if you actively consent to this category.
• Analytics cookies (Section 5.3) are placed only if you actively consent to this category.
• Marketing cookies (Section 5.4) are placed only if you actively consent to this category.

All non-essential categories are off by default and require an affirmative action by you to be activated. No category is pre-ticked.

8.3 Equal Prominence

The banner presents three primary options on its first layer, each requiring a single click:

• Accept all — consent to all categories;
• Reject all — reject all non-essential categories (strictly necessary cookies remain active);
• Manage preferences — open a more detailed view in which you can consent or reject each category individually.

The “Accept all” and “Reject all” options are presented with equal visual prominence: the same size, the same colour treatment, and the same position on the banner. Neither option is hidden behind additional clicks, and neither is styled to be more visually attractive than the other.

8.4 No Cookie Walls

As stated in Section 4.3, access to the Website and to HostDeck is not conditional on your consent to non-essential cookies. You may dismiss the banner, reject all non-essential cookies, or close the banner without making a choice, and continue to use the Website and HostDeck without restriction.

8.5 Recording Consent

When you make a consent choice through the banner, Cubic Houses records:

• the date and time of your choice;
• the version of the banner displayed (which corresponds to the cookies in use at that time);
• the categories you accepted or rejected;
• a technical identifier that allows the consent record to be associated with the consent record cookie on your device.

This consent record is retained for 12 months from the date of the choice, for the purpose of demonstrating that valid consent was obtained, in accordance with Article 7(1) GDPR. The consent record is not used for any other purpose.

The consent record cookie itself appears in the strictly necessary inventory tables in Sections 6 and 7.

8.6 Withdrawing or Changing Your Consent

You may withdraw your consent or change your consent choices at any time, with effect for the future. The banner can be re-opened through:

• a persistent link (for example, “Cookie preferences”) in the footer of every page of the Website and of HostDeck;
• the same banner that is displayed on first visit, by clearing the consent record cookie through your browser settings.

Withdrawal of consent does not affect the lawfulness of any processing carried out on the basis of consent before the withdrawal.

When you withdraw consent for a category, cookies in that category that have already been placed are no longer used to collect new information. Cubic Houses also takes reasonable steps to delete those cookies from your device, although deletion may depend on your browser's behaviour. You can delete cookies manually through your browser settings (Section 9).

8.7 Re-prompt After Rejection

If you reject all or some non-essential categories, the banner does not reappear during the same browser session, and does not reappear on subsequent visits for at least six months from the date of your choice — except where Section 8.1 applies (material changes to the cookies in use).

After this period, the banner may be displayed again so that consent can be confirmed in light of any developments since your previous choice. You may, of course, reject again.

Where the banner is re-displayed during this period for confirmation, your previous consent choice continues to apply until you make a new choice or until the consent record expires (Section 11.2).

9. Managing Your Preferences

You can manage your cookie preferences in two ways: through the Cubic Houses cookie banner (Section 9.1), and through your browser's cookie settings (Section 9.2). The two mechanisms work in parallel — the banner controls what Cubic Houses places, and the browser controls what your device accepts and retains.

9.1 Through the Cookie Banner

The cookie banner is the primary way to manage your preferences for cookies set by Cubic Houses on the Website and on HostDeck.

To make or change a choice:

• Re-open the banner through the “Cookie preferences” link in the footer of any page of the Website or HostDeck;
• Use the granular controls described in Section 8.2 to consent to or reject each non-essential category;
• Save your choices.

To withdraw consent entirely:

• Re-open the banner;
• Select “Reject all”.

Your updated choice takes effect immediately for cookies that have not yet been placed. Cookies in categories you have rejected are no longer used to collect new information, and Cubic Houses takes reasonable steps to delete them from your device (Section 8.6).

9.2 Through Your Browser

Your browser also lets you control how cookies are accepted, retained, and deleted on your device. Browser-level controls operate independently of the Cubic Houses cookie banner — they apply to all websites you visit, not only to the Website or HostDeck.

You can typically use your browser to:

• block all cookies, or block third-party cookies only;
• delete cookies that have already been stored;
• be notified before a cookie is placed;
• configure exceptions for specific websites.

Information on how to do this is provided by each browser:

• Google Chrome: support.google.com/chrome/answer/95647
• Mozilla Firefox: support.mozilla.org/kb/cookies-information-websites-store-on-your-computer
• Apple Safari: support.apple.com/guide/safari/manage-cookies-sfri11471
• Microsoft Edge: support.microsoft.com/microsoft-edge/delete-cookies-in-microsoft-edge
• Opera: help.opera.com/latest/web-preferences/#cookies

The above links are provided for convenience. Cubic Houses is not responsible for the accuracy or availability of third-party documentation.

If you use a different browser, the relevant information is typically available in that browser's help section under “cookies” or “privacy”.

9.3 Limits of Browser-Level Blocking

Blocking strictly necessary cookies (Section 5.1) at the browser level will prevent the Website or HostDeck from functioning correctly. In particular:

• you may be unable to log in to HostDeck;
• forms may fail to submit;
• the cookie banner itself may reappear on every page, because the consent record cookie cannot be stored.

Cubic Houses therefore recommends that, if you wish to block non-essential cookies only, you do so through the Cubic Houses cookie banner (Section 9.1) rather than through your browser.

9.4 Do Not Track and Global Privacy Control

Some browsers send signals such as Do Not Track (DNT) or Global Privacy Control (GPC) that indicate a user's general preference not to be tracked.

There is currently no harmonised standard at EU level for the interpretation of these signals in the context of Lei 41/2004. Cubic Houses does not currently adjust its cookie behaviour automatically on the basis of DNT or GPC signals. The cookie banner remains the primary mechanism through which your consent choices are obtained and respected.

Cubic Houses will reconsider this position if EU or Portuguese law, or guidance from the CNPD or the EDPB, establishes a binding interpretation of these signals.

9.5 Mobile Devices

Where you access the Website or HostDeck through a mobile browser, the controls described above apply in the same way. Where you access HostDeck through a mobile application (if and when such an application is offered), the application uses operating-system-level controls for tracking and identifiers, which are described in the application's own documentation.

10. International Transfers

10.1 General Principle

Where a cookie or similar technology results in the transfer of personal data to a country outside the European Economic Area (the “EEA”), the safeguards described in Section 7 of the Privacy Policy apply. Those safeguards include adequacy decisions adopted by the European Commission under Article 45 GDPR, Standard Contractual Clauses adopted under Article 46 GDPR, and the EU–US Data Privacy Framework where applicable.

10.2 Transfers Triggered by Current Cookie Use

The cookies currently in use on the Website (Section 6) and on HostDeck (Section 7) do not, by themselves, trigger transfers of personal data outside the EEA. The hosting infrastructure underlying the Website and HostDeck may involve processors with group infrastructure in the United States; those transfers are described in Privacy Policy Section 7 and are governed by the safeguards listed there.

10.3 Transfers Triggered by Future Cookie Use

If Cubic Houses adopts third-party tools that place cookies and result in transfers outside the EEA — for example, an analytics provider hosted in the United States, or a marketing pixel operated by a non-EEA company — this Section will be updated to identify:

• the cookie or technology concerned;
• the recipient and the destination country;
• the safeguard applied.

A material change of this nature also triggers re-display of the cookie banner (Section 8.1), so that consent for the new processing can be obtained on the basis of the updated information.

10.4 Where to Find More Information

For the full description of how Cubic Houses handles international transfers — including the list of current third-country recipients, the safeguards applied, and your right to receive further information about a specific transfer — see Section 7 of the Privacy Policy.

11. Retention

11.1 Per-Cookie Retention

The retention period of each individual cookie is shown in the “Duration” column of the inventory tables in Sections 6 and 7. Where a cookie is described as a “session cookie”, it is deleted when you close your browser. Where a cookie is described as “persistent”, it remains on your device for the period stated in the table or until you delete it (whether through the cookie banner, your browser settings, or otherwise).

11.2 Consent Record Retention

The consent record described in Section 8.5 — comprising the date and time of your choice, the version of the banner displayed, the categories you accepted or rejected, and the technical identifier — is retained for 12 months from the date of the choice.

The legal basis for this retention is the demonstration of valid consent under Article 7(1) GDPR. The consent record is not used for any other purpose.

After 12 months, the consent record is deleted. The next time you visit the Website or HostDeck, the cookie banner is re-displayed and a new consent record is created on the basis of your fresh choice.

11.3 Personal Data Retention Beyond the Cookie

Where a cookie results in the processing of personal data, the personal data itself may be retained beyond the lifetime of the cookie that originally collected it. The retention periods for personal data are set out in Section 8 of the Privacy Policy.

For example: a session cookie used to maintain your authentication on HostDeck is deleted when you close your browser, but the records of your activity on HostDeck during that session may be retained for the periods described in Privacy Policy Section 8.2 (for owner data) or Section 8.1 (for guest data, where applicable).

11.4 Anonymised and Aggregated Data

Cubic Houses may retain data derived from cookies in anonymised or aggregated form indefinitely for statistical, analytical, and service improvement purposes, where the anonymisation is irreversible and the data can no longer be linked to an identifiable individual. This is consistent with Section 8.4 of the Privacy Policy.

12. Your Rights

12.1 Cookie-Specific Rights

In relation to cookies and similar technologies, you have the following rights:

• The right to give or refuse consent. No non-essential cookie is placed without your prior consent, given through the cookie banner (Section 8). Refusing consent has no consequence for your access to the Website or HostDeck (Section 4.3).
• The right to withdraw your consent at any time, with effect for the future, through the mechanisms described in Sections 8.6 and 9.1. Withdrawal does not affect the lawfulness of any processing carried out before withdrawal.
• The right to change your consent choices at any time — for example, to consent to analytics cookies after previously rejecting them, or vice versa. The mechanism is the same as for withdrawal.

12.2 Rights Under the GDPR

Where the use of cookies results in the processing of personal data about you, you also have the rights set out in Section 9 of the Privacy Policy. These include:

• the right of access to your personal data;
• the right to rectification of inaccurate or incomplete data;
• the right to erasure (“right to be forgotten”);
• the right to restriction of processing;
• the right to data portability;
• the right to object to processing based on legitimate interests;
• rights relating to automated decision-making.

The conditions for exercising these rights, the response time, and the limits and refusals that may apply are described in Privacy Policy Section 9.

12.3 How to Exercise Your Rights

To exercise any of the rights described in this Section that go beyond the cookie banner, contact Cubic Houses through:

• email at rui@cubichousesolhao.com, with the subject line “Privacy request”; or
• post to the address in Section 1.1.

Your request should describe the right you wish to exercise and provide enough information for Cubic Houses to identify you and the personal data concerned.

12.4 Right to Lodge a Complaint

If you believe that Cubic Houses' use of cookies, or its handling of consent or your personal data, is unlawful, you have the right to lodge a complaint with the Portuguese supervisory authority for data protection:

CNPD — Comissão Nacional de Proteção de Dados
Address: Av. D. Carlos I, 134 — 1.º, 1200-651 Lisboa
Telephone: +351 213 928 400
Email: geral@cnpd.pt
Website: www.cnpd.pt

You may also lodge a complaint with the data protection authority of the EU Member State of your habitual residence, your place of work, or the place of an alleged infringement, in accordance with Article 77 GDPR.

13. Changes to this Policy

13.1 Updates

Cubic Houses may update this Policy from time to time, for example to reflect:

• changes to the cookies in use on the Website or HostDeck (for example, the addition of a new analytics provider, the removal of a tool no longer in use, or a change to the duration of an existing cookie);
• changes to the cookie banner or to the mechanisms through which consent is obtained, recorded, or withdrawn;
• changes in applicable law, including amendments to Lei 41/2004, the GDPR, or other relevant legislation;
• guidance issued by the CNPD, the European Data Protection Board (“EDPB”), or other competent authorities;
• structural or editorial changes to improve the clarity of the Policy.

The current version of this Policy is identified by the version number and effective date at the head of this document. Cubic Houses maintains an archive of previous versions and will provide a copy of any previous version on request.

13.2 Material Changes

Where Cubic Houses makes a change to this Policy that materially affects how cookies are used or how consent is obtained — for example, the addition of a new category of cookies, a new third-party provider, a new international transfer, or a change to the cookie banner mechanics — Cubic Houses will:

• re-display the cookie banner so that consent for the new processing can be obtained on the basis of the updated information (Section 8.1); and
• where Cubic Houses holds a current email address for you and the change affects you in respect of that contact, notify you by email in advance of the change taking effect.

Material changes do not apply retroactively. Processing carried out under a previous version of this Policy remains governed by that version.

13.3 Non-Material Changes

Non-material changes — for example, corrections of typographical errors, formatting adjustments, updates to external links, or clarifications that do not change the substance of this Policy — take effect on publication of the new version, without separate notification and without re-display of the cookie banner.

13.4 Continued Use

If you continue to use the Website or HostDeck after a change to this Policy takes effect, that continued use does not, by itself, constitute consent to any new processing introduced by the change. Where consent is required for a change, it is obtained through the cookie banner in accordance with Section 8.

13.5 Language

This Policy is issued in English and Portuguese. In the event of any inconsistency between the two language versions, the Portuguese version prevails.

14. Contact

If you have any question about this Policy, about the cookies used by Cubic Houses, or about how to exercise your rights, you can contact Cubic Houses at:

Rui Gabriel Raminhos Guerreiro, empresário em nome individual, trading as Cubic Houses
NIF: 218 823 061
Address: Avenida da República, 116 — 2.º Esquerdo, 8700-310 Olhão, Portugal
Email: rui@cubichousesolhao.com
Telephone (WhatsApp): +351 936 380 392

For questions specifically about the processing of your personal data — including the rights described in Section 12.2 and the recipients listed in the Privacy Policy — please use the subject line “Privacy request” in your email, in accordance with Section 12.3.

For information about cookies and similar technologies on third-party platforms (such as Airbnb or Booking.com) or on websites linked from the Website or HostDeck, see Section 2.2.