Document	Privacy Policy
Company	VSM CAPITAL SGPS, S.A.
NIF	513958339
Address	Avenida Sidónio Pais, n.º 16, 5.º Dt, 1050-215 Lisboa, Portugal
Website	oneplanetfund.eu
Contact	info@oneplanet.com
Last updated	11-06-2026

1. Who We Are and What We Do

VSM CAPITAL SGPS, S.A. (“we”, “us”, “our”) is a private limited company incorporated under Portuguese law, with tax identification number (NIF) 513958339, registered office at Avenida Sidónio Pais, n.º 16, 5.º Dt, 1050-215 Lisboa, Portugal.

We operate the website oneplanetfund.eu and provide consultancy services on residency by investment in Portugal — specifically in relation to the Autorização de Residência para Investimento (ARI), commonly known as the Portugal Golden Visa. Our service consists of informing, advising, and guiding individuals who wish to explore the ARI pathway, and connecting them with the relevant regulated professionals (fund managers, immigration lawyers, and tax advisors) as appropriate.

We are the data controller for personal data collected through this website. For any data-related query, contact us at info@oneplanet.com.

DPO	Under Art. 37 GDPR, Data Protection Officer is Raquel Carvalho

2. What Personal Data We Collect

2.1 Data you give us directly

When you submit an enquiry, complete the eligibility quiz, or book a consultation through our website, we collect:

• Name and contact details (email, phone number)
• Country of residence and nationality
• Your interest in Portuguese residency — reasons, timeline, family situation
• Indicative investment capacity — used only to direct you to relevant information, not to assess a financial product
• Content of any messages or notes from calls

2.2 Data collected automatically

When you visit the website, we collect:

• Technical data: IP address, browser type, device type, operating system
• Usage data: pages visited, time on page, quiz responses, referral source
• Cookie data: as described in our Cookie Policy [CONFIRM: link]

2.3 Data from third parties

• Third-party scheduling tools (e.g. Calendly) when you book a consultation
• Analytics platforms (e.g. Google Analytics) — anonymised or pseudonymised data
• Advertising platforms (e.g. Google Ads) — aggregated audience signals only

3. Why We Use Your Data

Purpose	Legal basis (GDPR Art. 6)	Retention
Respond to enquiries about the ARI consultancy service	Art. 6(1)(b) — pre-contractual steps at your request	2 years from last contact
Provide ARI consultancy and eligibility assessment	Art. 6(1)(b) — performance of the consultancy service	Duration of engagement + 3 years
Refer you to fund managers, immigration lawyers, or tax advisors, with your consent	Art. 6(1)(a) — consent	Until referral is complete or consent withdrawn
Send information about Portugal, the ARI programme, or our services	Art. 6(1)(a) — consent	Until consent is withdrawn
Improve our website via analytics	Art. 6(1)(f) — legitimate interests	13 months
Comply with applicable Portuguese and EU law	Art. 6(1)(c) — legal obligation	As required by law

4. Sharing Your Data

We do not sell your data. We share it only as follows:

• With fund managers, licensed immigration lawyers, or tax advisors — only where you have given explicit consent to be introduced to them
• With scheduling services (Calendly) and analytics platforms (Google) — under Data Processing Agreements
• With our hosting and IT providers — under Data Processing Agreements, EU/EEA-based where possible
• With Portuguese courts or public authorities — where required by law

Where data is shared with a party based outside the EEA (including the United States), we rely on Standard Contractual Clauses (SCCs) or another lawful transfer mechanism approved by the European Commission.

5. Your Rights

Under GDPR you have the right to access, rectify, erase, restrict, or port your personal data, to object to processing, and to withdraw consent at any time. To exercise any right, contact info@oneplanet.com. We respond within 30 days. You may also complain to the Comissão Nacional de Proteção de Dados (CNPD) at www.cnpd.pt.

6. Cookies

We use cookies for functionality, analytics, and (where consent is given) ad measurement. Full details are in our Cookie Policy at oneplanetfund.eu/cookies You can manage your preferences via the consent banner at any time.

7. Security and Retention

We use appropriate technical and organisational measures to protect your data, including TLS/SSL encryption and access controls. We retain personal data only for as long as necessary for the purpose collected, or as required by law. In the event of a breach affecting your rights, we will notify you and the CNPD as required by Arts. 33–34 GDPR.

8. Children

Our services are directed at adults only. We do not knowingly collect data from persons under 18. Contact info@oneplanet.com immediately if you believe this has occurred.

9. Updates

We may update this policy at any time. The current version is always at oneplanetfund.eu/privacy-policy/. Material changes will be communicated by email or website notice.