Privacy policy

This policy explains what personal data we collect, why we collect it, how long we keep it, and what rights you have. All processing is carried out in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the GDPR) and the rest of the data protection legislation in force.

The data controller is [TO BE CONFIRMED: the company's legal name] SUCCESSPIGMENT LDA, registered under number 510 771 840, with its registered office and place of business at Rua Cónego Maio 152C, 3810-089 Aveiro, Portugal [TO BE CONFIRMED: it is assumed that the registered office is the same address], hereinafter referred to as "contágio".

contágio adopts the technical and organisational measures needed to ensure that the processing of personal data is lawful, fair, transparent and limited to the purposes authorised.

Last updated: [TO BE CONFIRMED: the date this version takes effect]

Personal data means any information, of any kind and on any medium, including sound and image, relating to an identified or identifiable natural person — for example, a name, an address or an email address.

A natural person is identifiable if they can be identified, directly or indirectly, in particular by reference to a name, an identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

In the course of its business, contágio processes the personal data needed to provide services and supply products, in particular the name, address, telephone number and email address, in line with the detailed information made available to data subjects at each point.

We collect your personal data by telephone, in writing and through our website, obtaining the data subject's prior consent wherever that is required. The data may be processed by automated or non-automated means and is stored in databases created for that purpose. Under no circumstances is it used for a purpose other than the one for which it was collected or consented to.

Traffic data, geographic location and profiling data are likewise processed for marketing purposes or to publicise offers of contágio's goods or services, but only where the data subject has authorised it.

We use your personal data to give you access to our website, to produce usage statistics, to improve and develop the site, to provide you with services, to answer requests and messages, to send you our newsletter if you have subscribed to it, and to analyse the data in aggregate form in order to assess our business.

Under Article 6 of the GDPR, data is collected and processed where at least one of the following applies:

• the data subject has given consent to the processing of their personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is party, or for pre-contractual steps taken at the data subject's request;
• processing is necessary for compliance with a legal obligation to which contágio is subject;
• processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• processing is necessary for the purposes of the legitimate interests pursued by contágio or by a third party, except where the data subject's interests or fundamental rights and freedoms override them, in particular where the data subject is a child.

As a data subject, and under Article 15 and the Articles that follow it in the GDPR, you have the following rights:

• Right of access — to obtain from contágio confirmation as to whether data concerning you is being processed and, if so, to access that data.
• Right to rectification — to have incomplete or inaccurate data concerning you corrected.
• Right to erasure — to ask for your personal data to be deleted where it is no longer necessary for the purpose for which it was collected or processed, or where you have withdrawn consent and there is no other basis for the processing. This right does not apply where a legal obligation has to be met.
• Right to object — to object to the processing of your personal data whenever it is carried out for direct marketing purposes.
• Right to withdraw consent — at any time, without affecting the lawfulness of processing carried out on the basis of consent given beforehand.
• Right to portability — where technically feasible, to ask for your data to be transmitted to another controller.

Data may be retained, even after one of these rights has been exercised, for the establishment, exercise or defence of legal claims.

To exercise these rights, or for any other question about the protection and processing of your data, please contact us in writing using the contact details given below. Proof of the data subject's identity will always be requested.

If at any point you consider that your rights have not been properly upheld, you may lodge a complaint with the Comissão Nacional de Proteção de Dados, the Portuguese data protection authority, at www.cnpd.pt.

The entity responsible for processing your personal data, which determines the purposes and means of that processing, is contágio. You can reach it at:

• email: legal@contagio.pt
• place of business: Rua Cónego Maio 152C, 3810-089 Aveiro, Portugal

The data protection officer makes sure the processing complies with the legislation in force, checks that this policy is being followed, and sets clear rules for handling personal data, so that whoever entrusts us with their data knows how it is handled and what rights they have.

You can address any communication about the processing of personal data to them at:

• email: legal@contagio.pt
• [TO BE CONFIRMED: the name of the data protection officer, and confirmation that the appointment still stands] Humberto Carvalho — Rua Cónego Maio 152C, 3810-089 Aveiro, Portugal

The retention period varies according to the purpose for which the information is processed. There are legal requirements that oblige us to keep certain data for a minimum period. Where no specific legal requirement applies, data is kept only for the minimum period needed to pursue the purposes that led to its collection or subsequent processing, as set out in law.

In the course of its business, contágio may call on third parties to provide certain services, which sometimes means those parties have access to personal data of clients and users. Where that happens, we take the appropriate measures to ensure those parties offer sufficient guarantees, and this is duly secured by contract.

Any processor handles personal data in the name of and on behalf of contágio, adopting the technical and organisational measures needed to protect it against accidental or unlawful destruction, accidental loss, alteration, disclosure, unauthorised access and any other form of unlawful processing. In every case, contágio remains responsible for the personal data made available to it.

Providing certain services may involve transferring your data outside Portugal, including outside the European Union or to international organisations. Where that is the case, contágio complies strictly with the applicable legal provisions, in particular as to the adequacy of the destination country's data protection regime and the requirements applying to such transfers, including, wherever applicable, entering into the appropriate contractual instruments.

[TO BE CONFIRMED: the list of categories of processors actually used (hosting, email delivery, analytics, forms) and where they are located]

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[TO BE CONFIRMED: the final list of cookies and third-party services used on the new site (analytics, maps, fonts, forms) and their retention periods]