Data Protection Policy

Personal Data Protection Policy

Doutor Finanças – Unipessoal, Lda., hereinafter “Doutor Finanças” respects your privacy and values the relationship it maintains with its customers. This legal notice serves the purpose of making known how Doutor Finanças treats the personal data of its clients and guarantees their privacy in the development and performance of its activities. Doutor Finanças as Responsible for the Processing of your personal data, under the terms and within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons acts with regard to to the processing of personal data and the free circulation of such data (“General Regulation on Data Protection”), in so far as it collects and analyzes your personal data from your customers through the channels available on your public website: //

1. What is our commitment

Our commitment, as a linked credit intermediation company, without exclusivity, registered with Banco de Portugal with the number 000420, and as an Insurance Mediation company, registered with the Insurance and Pension Funds Supervisory Authority with the number 418460081/3, is to (i) be transparent in the relationship with our customers and partners,  (ii)  be close to our customers, offering special treatment to each client, (iii) always seek to simplify the treatment of processes, (iv) generate confidence through professionalism and suitability, promoting savings, (v) be committed to providing the best follow-up service, seeking to help our customers find a solution to their case.

In order to fulfil our commitment, it is important (i) to maintain the security and protection of each customer's personal data, (ii) to have adequate tools enabling the exercise of the rights of data subjects, (iii) to comply with Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 - General Data Protection Regulation (GDPR),  (iv) to comply with the confidentiality obligations departing from the activity of credit intermediary and insurance mediation, in accordance with the provisions of the applicable national legislation.

2. Who we are

Poupamos Juntos, Lda. is a group of companies, which include Doutor Finanças, Unipessoal Lda, credit intermediary, Doutor Finanças Protege - Insurance Mediation, Unipessoal Lda, Doutor Finanças Energia- Consulting in Energy Efficiency Unipessoal Lda and Doutor Finanças Empresas. In this document, the expressions "Doutor Finanças", "we", "our" are used to represent all companies of the Group. Doutor Finanças operates throughout the value chain in the (i) financial, (ii) insurance, (iii) telecommunications, (iv) health plans (v) energy area, to generate Savings to its customers.

Doutor Finanças is the Responsible for the personal data of the respective Customers and Employees and who, in this context, decides what data are collected, the means of processing and the purposes for which the data are processed.

We consider it essential to take all good practices for the processing of personal data, and therefore Doutor Finanças proposes (i) to monitor the conformity of the processing of data with the applicable standards, (ii) to have a specific contact for clarification of data processing issues, (iii) to cooperate with the National Data Protection Commission (CNPD),  as a national supervisory authority (iv) to work together with its subcontractors to ensure full compliance with data protection policy.

Contact details for clarification on data protection:

Doutor Finanças

Building Atlas II, floor 1, S11, Av. José Gomes Ferreira 11, 1495-139 Algés

Email address:

Business model

Our mission is to help clients to look for the best credit solutions for their case, simplifying process management as much as possible and providing a personalized service. As a linked credit intermediation company, without exclusivity, registered with Banco de Portugal with the number 000420, we do not charge any amount to the client. Doutor Finanças has agreements with different institutions, which support the cost of the credit intermediation process.

Our process is divided into 4 phases:

  1. Financial check-up
  2. Diagnosis
  3. Prescription
  4. Treatment

Financial Check-up

The process begins with the registration of the client’s application. After registering, the client enters our online clinic and now has a personal area to be able to communicate with the specialist "Doutor" allocated to his process.

The online clinic, which was developed by Doutor Finanças, manages the flow of processes that each Doutor will have associated with him, to ensure that the client is contacted in less than 24 hours.

In the personal area that was created in the online clinic, the client has all the information of the necessary documentation for the financial check-up to be done and subsequent diagnosis. The requested documentation is essential for the solvency analysis of the case to be carried out.


To complete the diagnosis, the client will be contacted by the specialist Doutor, who will frame the process and do the solvency analysis, as well as explain the next steps to the client.

Upon diagnosis, additional documents may be requested, which will be necessary for the prescription. In the personal area of the client in the online clinic, the client will have the information of the type of documents that are needed and will also have instructions on how to collect the documents and why each document is needed.


To ensure that the client receives a unique and personalized treatment with an exceptional level of service, the process goes to another Doutor, whose specialty is to negotiate credit and insurance conditions.

At this stage, the specialist Doutor will present a solution to the client through his profile and thus ensure that he has a solution tailored to him/her.


At this stage of the process, in which the solution has already been found, its process can be allocated to a Doutor specialized in formalization. The purpose is to advise the client in the most important phase of the process, to ensure that the conditions obtained from the partners are effectively applied to the client so that he begins to enjoy the savings obtained.

Consultation in Banco de Portugal's Credit Liability Centralization (CRC)

The partner entities, lenders, with whom Doutor Finanças concludes binding contracts may, within the scope of the credit granting process, consult whenever they deem it necessary, the Banco de Portugal´s Credit Liability Centralization (CRC) with the purpose of obtaining the necessary data to identify the entities with whom the client maintains, directly or indirectly, credit responsibilities.

The specialist Doutor, together with the online clinic, will help the client to obtain all the necessary documents, so that the treatment can be started lawfully and as soon as possible.

Insurance mediation

Regarding the contracting of insurance, the mission of Doutor Finanças Protege is to always be at the client's side, to present solution(s) of life and non-life branches. meeting their expectations and better protect them in order to increase the reduction of household expenses, in a transparent manner with a simple and clear message.

In this way our Specialist Doutor will carry out simulations for the insurance desired by the client, carry out the completion through the collection of data necessary for the issuance of policy, make necessary monitoring of this negotiation, with the Insurers, the hiring and monitoring in case of claims.

As Insurance Mediators Doutor Finanças Protege will mediate your insurance proposal with the various partners with whom it has mediation protocols, without exclusivity.

3. What personal data do we collect and process

Personal data is information relating to a person, identified or identifiable, as well as the set of distinct information that may lead to the identification of the holder. Personal data that have been mischaracterized, encoded or even pseudonymized, but that used together can identify a person, are also considered personal data.

Data collected in the newsletter subscription

The personal data indicated (e-mail) are processed, stored by Doutor Finanças and used solely for sending the Newsletter. Doutor Finanças does not share or transfer this data to third parties and will keep it solely for the period in which the subscription is in force. You can subscribe to this newsletter at any time by clicking "unsubscribe" in the footer of the newsletter' email. You may also, at any time, withdraw your consent or owe the processing of your personal data, as well as request its rectification, limitation or deletion ("right to erasure of the data"), in accordance with and within the limits set forth in the GDPR, through the addresses:

The main categories of personal data we process are:

Identification and contacts
Name, address, mobile phone contact, telephone contact, email address, civil identification number and tax identification number.

Biographical data
Nationality, gender, date of birth, place of birth, marital status, information about the household, data on the profession (such as the number of years you work in the current company) and academic qualifications.

Financial data
Maturity (i) monthly, (ii) annual, financial liabilities with credit institutions and financial assets.

Segments and profiles
Profile or degree of credit risk, profile for acquisition of investment products (through capitalization insurance), profile for commercial segmentation of services aimed at saving such as (i) credits (ii) insurance, (iii) electricity, (iv) gas.

Opinions and preferences

Data management regarding responses to satisfaction questions, management of customer comments made on social networks (i) Facebook, (ii) linkedin, (iii) Instagram, management of comments on the sites (i), (ii)

Access accounts

User account access to the personal area in the online clinic.


Management of the information contained in the communications between the client and Doutor Finanças (i) written, (ii) telephone (if the telephone call is recorded).

Use of websites and applications

Pages visited, IP address, geographic location and browser used.

Doutor Finanças obtains the data through the following channels:

Data provided by customers

Elements provided directly by customers (i) in the process of subscribing the order on the website, (ii) in the emails exchanged between the client and the analyst/negotiator/formalization, (iii) in the interactions on the phone between the client and the analyst/negotiator/formalization or in the trips that the client can make to our Clinic in Lisbon or Porto, (iv) by responding to satisfaction questionnaires

Definition of Profiles

Analytical data produced by Doutor Finanças, through the application of static models to the data contained in the online Clinic.

Persistent cookies

Doutor Finanças website has cookies that generate data relating to the use of the website by customers (e.g.: articles most viewed by the client, time spent in each article, time spent on the site). For more information you should consult the Doutor Finanças’s Cookie Policy.

Data obtained from third parties

Doutor Finanças obtains data from third parties (partners), referring to (i) solvency analysis that is carried out to the client by the partners, (ii) data regarding the pre-approval of the process (FINE), (iii) data relating to cross-selling, (iv) data relating to insurance, (v) data relating to the valuation of the property. When the process proceeds to formalization, we obtain data (i) referring to the letter of approval (final FINE), (ii) data referring to the draft, (iii) data referring to the date of deed, (iv) data relating to the credit agreement.

Obligation to provide personal data

Within the framework of legal obligations relating to the regime of prevention of money laundering, Doutor Finanças has to identify customers to obtain financing, usually through the identification document. If this identification is not made, Doutor Finanças cannot follow up the proceedings, under penalty of incurring an infringement.  In the course of the commercial relationship between the client and Doutor Finanças, it will be necessary to send other documents by the client for the fulfillment of pre-contractual and contractual obligations, necessary for the formalization of the process.

4. How we process personal data

The processing of personal data covers a wide range of operations carried out on personal data, by manual or automated means. It includes the collection, registration, organization, structuring, conservation, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of making available, comparison or interconnection, limitation, payment, or destruction of personal data.

The General Data Protection Regulation (GDPR) applies to the processing of personal data by fully or partially automated means, as well as to the processing by non-automated means of personal data contained in files.

At Doutor Finanças, we treat personal data fairly and transparently, in accordance with its grounds of lawfulness and for specific purposes.

Compliance and contractual execution

Treatment purposes

Client Area in the Online Clinic

Collection and registration of personal data and documents proving the data collected, storage of communications between the client and Doutor Finanças.

Risk Management

Analysis of risk criteria such as stress rate, net disposable income and DSTI, as well as possible defaults or late payment of the benefit.

Product management Data
Collection to make new products available or improve the products available to customers. Enable the customer to know other forms of savings, in telecommunications, energy and electricity through their partner companies. Support clients in the active demand for property for acquisition, as well as support customers in the active sale of their property, through group companies and partner companies in the real estate mediation industry.

Management of contacts and complaints

Reception, analysis, and response to requests for information and complaint by customers. The request for information or complaint can be reached through various channels, such as digital, telephone or letter.

Contact management

Reception, analysis, and response to requests for information from customers.

The request for information can be reached through various channels, such as digital, telephone or by letter.


At Doutor Finanças we receive and treat the information from the receipt of complaints with Suitability, Rigor and Transparency.

Any complaints, in the context of the provision of credit intermediation or insurance mediation services, may be submitted through various channels, such as digital, telephone or via email at the address, expressly and circumstantially indicating the grounds of the claim and all the identifying elements that motivated it.

The client also has the possibility to use alternative dispute resolution means, with CACCL, based in Lisbon, or with CICAP, based in Porto, where he can file his complaints to prevent conflicts with this credit intermediary.

Responses may be given by the same means within 30 days of receipt of the complaint

Management of the document archive in digital format

Collection, classification, and storage of documents in digital format in the client's personal area, in the online clinic.

Purpose of Treatment

Risk management

Analysis of ratios and risk weighting criteria, such as stress rate, verification of the identity of credit holders, professional experience, etc.

Fraud prevention

Fraud detection, such as: tampering with ID cards, salary receipts, bank statements.

Prevention of capital laundering and terrorist financing (BCFT)

Crime prevention and analysis of the copying of credit stakeholder identification documents to avoid BCFT situations.

Accounting and financial reporting

Accounting record, and preparation of financial reports, such as balance sheet and financial statement.

Provision of information and response to requests from public authorities

Mandatory information to public entities and to requests from regulators in the sector. (example: courts, politics, CMVM, Banco de Portugal, CNPD, ASF).

Energy and Electricity

Doutor Finanças acts as a Partner of companies supplying energy and electricity, in order to enable him other forms of savings.

Real estate

Doutor Finanças acts as a Partner of companies in the real estate mediation sector, supporting clients in the purchase and sale of real estate actively.

Legitimate interest

Doutor Finanças processes personal data to carry out tasks related to its activities. The processing is carried out in the context of the relationship with the customer when it processes personal data for the purposes of direct marketing of other products or presentation of relevant information. Doutor Finanças only requests the necessary data to submit the proposals for savings and real estate mediation, for products that are of legitimate interest, such as Insurance, Credits, Telecommunications, Energy and Electricity and supporting customers in the purchase and sale of real estate actively.

Treatment purposes:

Providing information to the customer

Sending relevant information regarding the products marketed by Doutor Finanças, the information can be sent in various formats, such as e-mail, letter, SMS.


Provision of information or campaigns through telephone, message, email, or mail, to stimulate the use or promote the acquisition or subscription of products or services. Campaigns can be generated by defining customer profiles.

Customer segmentation

So that the products and services provided by Doutor Finanças, meet the specific needs of each client, the characterization and segmentation of customers is carried out.

Definition of Profiles

Doutor Finanças can process the data of customers to create products and services more appropriate to the interests and preferences of customers, to define their profile of use, degree of interest and assess their propensity related to them. With this, we seek to customize the service that is made in each contact with the client.

The client has the right to refuse to profile your data, which means that he/she will no longer have a personalized service.

Evaluation of satisfaction and quality of the service

Satisfaction questionnaires are carried out to assess the degree of satisfaction of the service provided, as well as to assess the degree of satisfaction of the contracted products, and the analysis of complementary services can be proposed, such as: analysis of the spread of Housing Credit, analysis of the insurance portfolio.

Management control
Production of information for control and management of Doutor Finanças.

Data will be collected for audits. The audits will be carried out by the quality department of Doutor Finanças, when it comes to evaluating the quality of the service provided to clients, the quality of process management with the client and the bank by Doutor Finanças’s team. The financial audit will be carried out by The Finanças Department of The Financial Department.

Management and security of the information system (Online Clinic)
The online clinic records access and use by customers. This information is used to improve the experience and relationship between the client and Doutor Finanças’s team, but also for security purposes. Periodic analysis of potential information security incidents is carried out.

Doutor Finanças may perform other processing of the data, provided that it obtains the prior consent, expressed, by computer, written, orally or through an explicit, informed and free action.

Treatment purpose:

Proof of consent information

E-mail sent by customers, call recording, document signed by client, are some of the examples of consent proofs used by the Doutor Finanças.

Monitoring the service quality

Call recording and email service will be used to monitor the quality of the service.

Market studies

Collection and analysis of personal data in the context of market study or analysis.

Personalize the user experience

Using Cookies to record activity and customer preferences on Doutor Finanças's websites.

Use of Cookies to record activity and customer preferences on Doutor Finanças's websites.

Doutor Finanças only processes personal data duly authorized and subject to prior information to the respective holders. Any further secondary data processing is carried out only if (i) they are compatible with the purposes authorized and communicated to the data subjects or (ii) if they are subject to specific and explicit consent of the data subjects.

5. What are the time limits for the retention and processing of personal data

Doutor Finanças retains and processes personal data only for as long as necessary and if the legitimate purposes for which the client has signed up and for the fulfillment of contractual, legal and regulatory obligations or for the protection of the legitimate interests of Doutor Finanças.

Grounds for the retention of personal data:

Legitimate interest

Doutor Finanças may retain personal data for a period longer than the relationship with the client, based on legitimate interests that fundament it, namely the defense of Doutor Finanças in legal proceedings.

Legal or regulatory obligation

Legal limitation periods associated with legal, tax/accounting or regulatory obligations.

6. What are your rights as a personal data subject

Doutor Finanças guarantees the exercise of the rights of data subjects in relation to their processing.

Rights of the holder


Customers have the right to have access to the personal data they provide to Doutor Finanças and its conditions of processing. This access is made through your personal area, which contains all the information relating to the process.


Customers have the right to request rectification of their personal data that are inaccurate (Example: address, email address, telephone contact).  This rectification is done through your personal area.


Customers have the right to oppose the processing of data based on the legitimate interest of Doutor Finanças.

Withdrawal of consent

Customers have the right to withdraw consent to the processing of their personal data.


The client has the right to request the erasure of his personal data held by Doutor Finanças, if there are no valid grounds for its retention by Doutor Finanças (e.g.: compliance with legal and tax obligations, Doutor Finanças’s defense or third parties in a court case).


Customers have the right to request the limitation of processing of their personal data when (i) they dispute the accuracy of personal data, (ii) the processing is unlawful and oppose the payment of personal data.

Complaint in CNPD

Customers have the right to lodge complaints with the CNPD regarding matters relating to the exercise of their rights and the protection of their personal data.

Customers can exercise their rights, according to the GDPR, by written request to the postal address indicated or email to the indicated contacts of Doutor Finanças.

Doutor Finanças will respond to requests within a maximum of 30 days and may lengthen within the response period for especially complex requests. In these cases, Doutor Finanças will inform clients of the need to increase the response time for an additional period of 30 days, justifying why.

Whenever Doutor Finanças considers that it is not possible to match the requests, the customers will be informed of the reasons, within the deadlines identified above.

The exercise of rights is free of charge. However, Doutor Finanças may apply an administrative fee for costs associated with situations considered excessive/recurrent, anomalous and/or in bad faith.


Anyone can report, in good faith, to Doutor Finanças a real suspicion, of topics related to the privacy of their personal data, corruption, ethical and confidentiality issues, or deviations from good practices, whenever they have a reasonable conviction that the suspicion is real, at the time of reporting.

In Doutor Finanças we are directly responsible for investigating any complaint, of this nature, that is forwarded to us.

Also, Doutor Finanças is responsible for responding to the whistleblower, within the legal deadlines, with a view to resolving the complaint under the principles that govern us of Ethics, Responsibility, Commitment, Confidentiality and Confidentiality, as well as the principle of non-Retaliation, as a measure of protection of the whistleblower.

The Whistleblower has legal protection, in accordance with the provisions of the Law, considering that the whistleblowing is made in good faith.

In the face of a real suspicion of infringement, you must lodge a whistleblowing using the following form:

7. What personal data do we share

Doutor Finanças employees have access to personal data, to the extent necessary, for the performance of their duties, as well as to ensure compliance with all legal obligations of Doutor Finanças as a linked credit intermediary. In addition, personal data may be made available to third parties in the legitimate interest of the Client:

Third parties

Companies of the Group

Companies denominated or participated by Poupamos Juntos Lda.

Public and Regulators

Banco de Portugal, ASF, CNPD, tax authorities, whenever there is a legal or regulatory obligation.


As a credit intermediary, Doutor Finanças will mediate the credit application with the various partners with whom it has a binding protocol. They are, Banco CTT, SA; COFIDIS; Banco BPI, SA; ABANCA; Banco Santander Totta, SA; Caixa Geral de Depósitos, SA; Banco BIC Português, SA; BNI - Banco de Negócios Internacional (Europa), SA; Banco Primus, SA; Bankinter, SA - Sucursal em Portugal; 321 Crédito Instituição Financeira de Crédito, S.A.; Banco BNP Paribas Personal Finance, SA; Unicre Instituição Financeira de Crédito, SA; UCI; Novo Banco; Montepio crédito, Millenium BCP- BANCO COMERCIAL PORTUGUÊS, S.A.


Subcontracting entities and service providers, acting on behalf of or under instructions from Doutor Finanças.

Doutor Finanças as a linked credit intermediary, without exclusivity, is subject to bank secrecy. So, the transfer of personal data to third parties is only made when there is sufficient authorization in the context of the relationship with the client and/ or when the subcontractors in charge of Doutor Finanças also ensure compliance with the confidentiality of the personal data of customers, as well as other rules and legislation of data protection.

8.  How we protect personal data

The protection of the confidentiality and integrity of our clients' data is considered by Doutor Finanças as one of the fundamental pillars in the relationship of trust with the people who use our services.

Doutor Finanças has implemented appropriate organizational measures, processes and security systems to protect clients’ personal data from destruction, alteration and unauthorized access.

Doutor Finanças is committed to further developing security processes and systems aimed at protecting his clients' personal data.

9.  Changes to privacy policy

Doutor Finanças reserves the right at any time to make changes to the privacy policy, to adapt it to market best practices or future legislative or regulatory changes, in order, above all, to strengthen consumer rights. You can find the updated privacy policy for consultation on the

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