We recommend that You read it carefully and on a frequent basis to fully understand this along with our privacy overview, which highlights key points about our current privacy practices.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- We, Us, Our refers to Associação Portuguesa de Aplicações Digitais. For the purpose of the GDPR, the Associação Portuguesa de Aplicações Digitais is the Data Controller.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: Portugal
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Associação Portuguesa de Aplicações Digitais as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
- Service refers to the Website.
- Service Provider means any natural or legal person who processes the data on behalf of the Associação Portuguesa de Aplicações Digitais. It refers to third-party companies or individuals employed by the Associação Portuguesa de Aplicações Digitais to facilitate the Service, to provide the Service on behalf of the Associação Portuguesa de Aplicações Digitais, to perform services related to the Service or to assist Us in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to https://www.apad.pt/
- You, Your means the individual accessing or using the Service. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject.
The Data Controller of your Personal Data in relation with the use of the Service is Associação Portuguesa de Aplicações Digitais […].
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
- Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Us
- Functionality Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
- Type: Persistent Cookies
- Administered by: Third-Parties
- Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
Use of Your Personal Data
We may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Express Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- For legal purposes: Processing Personal Data is necessary for compliance with a legal obligation to which We are subject.
- For contractual purposes: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- For security purposes:To prevent and detect malicious or unsafe activities and to monitor all actions that could cause fraud or in the commission of a criminal offense related to the usage of the Service.
- For statistics and research purposes.
- For marketing and commercial purposes.
- For non-marketing purposes.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Us.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to help support and maintain Our Service.
- With the companies that are part of the Association;
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Disclosure of Your Personal Data
Other legal requirements
We may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Association
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect against legal liability
Security of Your Personal Data
We have taken the necessary steps to maintain the required security level, according to the nature of the personal data processed and the circumstances of the processing, in order to avoid to the extent possible and always in accordance with the state of the art, its alteration, loss or unauthorized access or processing.
We may use third-party Service providers to monitor and analyze the use of our Service.
Your Rights under the GDPR
We undertake to respect the protection of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data, where possible. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
- You have the right to unsubscribe to any marketing communication.
You can anytime object to profiling by sending us an email to: […]
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition free of charge and at any time by contacting Us by email at email@example.com. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have also the right to complain to the Portuguese Data Protection Authority about Our collection and use of Your Personal Data.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We exercise no influence on how these third parties process your personal data.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this.
We will in no event modify our policies or practices to make them less effective in the protection of the Data Subjects personal data.
By email: firstname.lastname@example.org