Privacy Policy
1 – WHAT IS PERSONAL DATA AND WHAT CATEGORY OF DATA DO WE PROCESS?
What is personal data?
Personal Data is any information, of any nature and on any medium (e.g. sound or image), relating to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, for example, by name, identification number, location data, an electronic identifier or other elements that make it possible to identify that natural person.
Who are the holders of personal data?
The Client or User, a natural person, to whom the data relates and who has used the services or products of Trinta-por-uma-linha. The Client will be the person who enters into the contract with Trinta-por-a-linha or with one of its labels (Busílis e Tropelias & Companhia) the User is the person who uses the services or products of Trinta-por-uma-linha, but which may not correspond to the Client. For instance:
– In the business segment, the contract with Trinta-por-uma-linha is in the name of the company, but the Users are the customers or employees of that company;
– In the private segment, a Customer will be able to purchase several products and services.
In this regard, TRINTA-POR-UMA-LINHA informs that it also protects personal data and respects the rights of customers and users.
What categories of personal data do we process?
The categories of data we process are as follows:
Base data
Examples: ID and contacts and other identifying data
Civil or tax identification numbers, payment details, billing address, telephone contact and email address; date of birth, gender, your professional activity and IP (if you have registered on the internet)
Service
Products and services purchased or subscribed to
2 – WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
The person responsible for the collection and processing of your personal data will be the company Trinta-por-uma-linha that provides you with the service or product and that in this context decides what data is collected, means of processing and purposes for which the data is used.
3 – ON WHAT BASIS CAN WE PROCESS YOUR PERSONAL DATA?
These are the circumstances in which we process your personal data:
Assent
When you have your express consent – in writing, orally or through the validation of an option – and prior and if that consent is free, informed, specific and unambiguous. Examples include your consent for Trinta-por-a-line to analyze the use of the services and products and to make recommendations or send marketing messages, to use your identification or service usage data to send Trinta-por-a-linha marketing messages, your consent for us to use the service information to improve our quality of service;
or
Contract execution and pre-contractual diligences
When the processing of personal data is necessary for the conclusion, execution and management of the contract entered into with Trinta-por-uma-linha, such as for the preparation of a proposal for products and/or services for the management of contacts, information and orders, for the management of invoicing, collection and payments;
or
Compliance with legal obligation
When the processing of personal data is necessary to comply with a legal obligation to which Trinta-por-uma-linha is subject, such as the communication of identification data to police, judicial, tax or regulatory entities;
or
Legitimate interest
When the processing of personal data corresponds to a legitimate interest of Trinta-por-uma-linha or of a third party, such as the processing of data for the improvement of quality of service, fraud detection and revenue protection and when our reasons for its use should prevail over your data protection rights;
4 – FOR WHAT PURPOSES AND FOR HOW LONG DO WE PROCESS YOUR PERSONAL DATA?
How long do we process your Personal Data?
Your personal data is processed by Trinta-por-uma-linha only for the period necessary for the achievement of the defined purpose or, as applicable, until you exercise your right to object, right to be forgotten or withdraw consent.
After the respective retention period has elapsed, Trinta-por-uma-linha will delete or anonymize the data whenever they should not be kept for a different purpose that may remain.
For what purposes do we process your Personal Data?
Purposes
Examples of purposes (non-exhaustive)
Marketing and Sales
– Marketing or selling new products or services
– Analysis of consumption profiles
– Adaptation and development of new products or services
Customer Management and Service Delivery
– Management of contacts, information or requests
– Complaint management;
– Invoicing, collection and payment management
Accounting, Tax and Administrative Management
– Accounting, invoicing
– Tax information, including sending information to the tax authority
Litigation Management
– Judicial and extrajudicial collection
– Management of other conflicts
Fraud detection, revenue protection, and auditing
– Detection of fraud and illegal practices
– Revenue protection and control
– Credit risk management
– Internal audit and investigation
Network and systems management
Support and improvement of networks and applications that support the service Monitoring, improvement and support of the service
Compliance with legal obligations
– Location of calls to emergency services
– Judicial requests
– Investigation, detection and prosecution of serious crimes
– Response to judicial, regulatory and supervisory bodies
Information security control
– Access management, logs
– Backup management
– Security incident management
What are the deadlines for processing and storing personal data?
Trinta-por-uma-linha processes and stores your personal data according to the purposes for which they are processed. There are cases in which the law requires the processing and retention of data for a minimum period, for example, 10 years, the data necessary for information to the Tax Authority for accounting or tax purposes.
But, whenever there is no specific legal obligation, then the data will be processed only for the period necessary to fulfill the purposes for which it was collected and preserved and always in accordance with the law, guidelines and decisions of the CNPD.
Thus, Trinta-por-uma-linha will process and keep your personal data for the period in which it maintains a contractual relationship with you.
Trinta-por-uma-linha may keep other personal data for periods longer than the duration of the contractual relationship, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that support it, but always for the period strictly necessary to achieve the respective purposes and in accordance with the guidelines and decisions of the CNPD.
Examples include contact for marketing and sales purposes, data retention in the context of invoice claim processes, exercise of warranty rights or offers that are of interest to the customer or prospect.
5 – HOW DO WE COLLECT YOUR PERSONAL DATA?
How do we collect your personal data?
We collect personal data with your consent when you purchase Trinta-por-a-linha products or services, when you download or use Trinta-por-uma-linha’s e-books, quizzes, sessions, offers, products, services and applications or when you participate in market research. The collection can be done orally, in writing or through the Trinta-por-uma-linha website.
But your personal information may also be collected from publicly accessible or other sources.
How is your personal data collected indirectly?
In order for you to better understand this indirect collection, we indicate the following cases:Other relevant information on credit risk or on identification and contact data, for collection management, fraud detection and revenue protection. Trinta-por-uma-linha may collect personal data from private entities that maintain relevant information on the credit of the holders of personal data, provided that these databases comply with the applicable data protection rules. TRINTA-POR-UMA-LINHA may also access, collect or confirm personal data on websites of the Public Administration and private entities, namely, to confirm the accuracy of your identification and contact data.
6 – DATA ANALYSIS
Cookie PolicyInformation about our use of cookies. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.
A cookie is a small file of letters and numbers that we store on your browser or on your computer’s hard drive, if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they use it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily. You can find more information about the individual cookies we use and the purposes for which we use them below:
Analytical
The services contained in this section allow the owner to monitor and analyze web traffic and can be used to track user behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the data collected to track and examine the use of this website, prepare reports on your activities and share them with other Google services. Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy – Opt-out.
Facebook Ads Conversion Tracking (Facebook, Inc.)
Facebook Ads Conversion Tracking is an analytics service provided by Facebook, Inc. that connects data from Facebook’s advertising network with actions taken on this website. Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy.
Commented Content
Content commenting services allow users to make and publish their comments on the content of this website. Depending on the settings chosen by the owner, users can also leave anonymous comments. If there is an email address among the Personal Data provided by the user, it may be used to send comment notifications about the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by a third party is installed, it may still collect web traffic data for the pages where the commenting service is installed, even when Users do not use the content commenting service.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc., allowing the user to leave comments and share them on the Facebook platform.
Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy.
Email Marketing
We collect your name and email address when you register for a webinar or event, request a free feature, or join a waitlist, via Infusionsoft (Privacy Policy). We use this data to send you emails about useful advice and industry news and to notify you about services and products you may be interested in. You can unsubscribe from our list at any time. In addition, we collect your last name and postal address when you purchase a product or course, as part of our payment provider’s card verification process and collection of sales tax.
Remarketing and behavioral targeting
This type of service allows this website and its partners to inform, optimize and serve advertising based on the user’s use of this website in the past. This activity is carried out through the tracking of Usage Data and Cookies, information that is transferred to the partners who manage the remarketing and behavioral targeting activity. In addition to any opt-out offered by any of the services below, you can opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative’s opt-out page.
Remarketing do Facebook (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that links the activity of this website to Facebook’s advertising network.
Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy – Opt-out.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that links the activity of this website to the Facebook advertising network.Personal Data collected: Cookies and email address. Place of processing: United States – Privacy Policy – Opt-out.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly on the pages of this website. Interaction and information obtained through this website are always subject to the user’s privacy settings for each social network. This type of service may still collect traffic data for the pages on which the service is installed, even when Users do not use it.
Twitter Tweet Button and Social Widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services that allow interaction with the Twitter social network provided by Twitter, Inc.Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy. Facebook Like Button and Social Widgets (Facebook, Inc.)The Facebook Like button and social widgets are services that allow interaction with the Facebook social network provided by Facebook, Inc.Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy.
LinkedIn Button and Social Widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services that allow interaction with the LinkedIn social network provided by LinkedIn Corporation.Personal Data collected: Cookies and Usage Data.Place of processing: United States – Privacy Policy.
How to provide or withdraw consent to the installation of cookies
In addition to what is specified in this document, the user can manage cookie preferences directly in their own browser and prevent – for example – third parties from installing cookies. Through your browser preferences, you can also delete cookies that have been installed in the past, including cookies that may have saved your initial consent to the installation of cookies by this website.
Users can, for example, find information on how to manage cookies in the most used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
With regard to Cookies installed by third parties, Users can manage their preferences and withdraw their consent by clicking on the related deactivation link (if provided), using the means provided in the third party’s privacy policy or by contacting the third party.
Notwithstanding the foregoing, the Owner informs that Users may follow the instructions provided in the initiatives subsequently linked by the EDAA (EU), the Network Advertising Initiative (USA) and the Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. These initiatives allow users to select their tracking preferences for most advertising tools.
The Owner therefore recommends that Users make use of these features in addition to the information provided in this document.
System Logs and Maintenance
For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with this website (system logs) using other personal data (such as IP address) for this purpose.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying users on this page and possibly within this website and/or – as far as technically and legally possible – by sending a notice to users via any contact information. If the changes affect processing activities carried out on the basis of your consent, the owner must collect new consent from you where necessary.
Data Owner and Controller
TRINTA-POR-UMA-LINHA,Largo Eng. António de Almeida, 30 – 3.º Andar – Sala DD3 – 4100-065 PortoOwner’s contact e-mail: joaomanuelribeiro30@gmail.com
As the installation of third-party cookies and other tracking systems through the services used on this website cannot be technically controlled by the owner, any specific references to cookies and tracking systems installed by third parties should be considered indicative.
For complete information, please refer to the privacy policy of the respective third-party services listed in this document. Given the objective complexity surrounding the identification of Cookie-based technologies, Users are encouraged to contact the Owner if they wish to receive further information about the use of Cookies by this Website.
7 – WHAT ARE YOUR DATA PROTECTION RIGHTS AND HOW TO EXERCISE THEM?
What are your rights?
See below for your rights and the details of what is safeguarded in each one.
Right of access
Right to obtain confirmation of which personal data are processed about them and information about them, such as the purposes of the processing, the retention periods, among others. Right to see or obtain a copy, for example, of invoices, written agreements or support requests you have made.
Right to rectification
Right to request the rectification of your personal data that is inaccurate or request that incomplete personal data be completed, such as address, VAT number, email, telephone contacts, or others.
Right to erasure or “right to be forgotten”
Right to obtain the erasure of your personal data, provided that there are no valid grounds for its conservation, such as cases in which Trinta-por-uma-linha has to retain the data to comply with a legal obligation to preserve it for the investigation, detection and prosecution of crimes or because a judicial process is underway.
Right to portability
Right to receive the data you have provided to us in a commonly used and machine-readable digital format or to request the direct transmission of your data to another entity that becomes the new controller of your personal data, such as receiving your invoices or transmitting your contacts to the new controller, but in this case only if it is technically possible.
Right to withdraw consent or right to object
Right to object to or withdraw your consent at any time to data processing, such as in the case of data processing for marketing purposes, provided that there are no legitimate interests that override your interests, rights and freedoms, such as the defence of legal claims.
Right of limitation
Right to request the restriction of the processing of your personal data, in the form of:
Suspension of processinglimitation of the scope of processing to certain categories of data or purposes of processing.
Right to complain
Right to lodge a complaint with the supervisory authority, the CNPD, in addition to the company or the DPO.
How can you exercise your rights?
The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged in view of the costs.
The information must be provided in writing, but if you request it, it may be provided orally. In this case, Trinta-por-uma-linha must verify its identity by means other than oral.
The response to requests must be provided within a maximum period of 30 days, unless it is a particularly complex request.
Exercise your rights through the following addresses:
TRINTA-POR-UMA-LINHA
Letter:Largo Eng. António de Almeida, 30 – 3.º Andar Sala DD3 – 4100-065 Porto
Mail:geral@trintaporumalinha.com
Phone: 2276090272
8 – TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?
Under what circumstances is your personal data communicated to other entities, subcontractors or third parties?
Your data may be transmitted to subcontractors so that they can process them in the name and on behalf of TRINTA-POR-UMA-LINHA. In this case, TRINTA-POR-UMA-LINHA will take the necessary contractual measures to ensure that the subcontractors respect and protect the personal data of the holder.
The data may also be transmitted to third parties – entities other than Trinta-por-uma-linha or subcontractors – such as companies within the Trinta-por-uma-linha group, companies with which Trinta-por-uma-linha develops partnerships, if the holder has consented – or entities to whom the data must be communicated by law, such as the tax authority.
Under what circumstances does TRINTA-POR-UMA-LINHA transfer your data to a third country?
TRINTA-POR-UMA-LINHA may have to transfer your personal data to a third country outside the European Union and that is not part of the list of countries that the EU has already considered to meet adequate levels of protection of personal data. In these cases, TRINTA-POR-UMA-LINHA will ensure that data transfers are carried out in strict compliance with the applicable legal regulations.
9 – HOW TRINTA-POR-UMA-LINHA PROTECTS YOUR DATA
PERSONAL?
Trinta-por-uma-linha has implemented the appropriate, necessary and sufficient logical, physical, organizational and security measures to protect your personal data against destruction, loss, alteration, dissemination, unauthorized access or any other form of accidental or unlawful processing.
Trinta-por-uma-linha has implemented:
Logical security requirements and measures, such as the use of firewalls and intrusion detection systems in its systems, the existence of a strict policy on access to systems and information and the recording of actions taken by Trinta-por-uma-linha employees on personal data of customers or users (logging);
Physical security measures, including strict access control to Trinta-por-uma-linha’s physical facilities, by employees, partners and visitors, as well as very restricted and permanently monitored access to Trinta-por-uma-linha’s essential technological infrastructures;
Means of data protection by design (“privacy by design”) using technical means such as masking, encryption, pseudonymization and anonymization of personal data, as well as a set of privacy-friendly preventive measures (“privacy by default”);
Scrutiny, auditing and control mechanisms to ensure compliance with security and privacy policies; An information and training program for Trinta-por-uma-linha’s employees and partners;
Access rules for Customers or Users to certain products or services, such as the introduction of a password, to strengthen control and security mechanisms.
10 – USEFUL TIPS FOR PROTECTING YOUR DATA
Trinta-por-uma-linha and third-party websites
Regarding the use and processing of personal data from Trinta-por-uma-linha websites, be sure to consult the rules on the use of cookies on the respective websites. Trinta-por-uma-linha’s websites, products or applications may contain links to third-party websites, products or services that have no relationship with Trinta-por-uma-linha or that are not covered by this Privacy Policy.
The collection or processing of personal data requested by these third parties is their sole responsibility, and Trinta-por-uma-linha cannot be held responsible, under any circumstances, for the content, accuracy, veracity or legitimacy of these websites or for the misuse of the data collected or processed through them.
We alert Trinta-por-uma-linha’s Customers and Users to this fact and to the need, before using the websites, products or applications, to read and accept the rules regarding the processing of personal data defined by these third parties.
Other advice
TRINTA-POR-UMA-LINHA advises prudence in the exposure of your personal data and in the circulation of this data over the internet, acts that are the sole responsibility of the client, since this data is not fully protected against possible violations, the adoption of complementary security measures, including the maintenance of equipment (PCs, tablets or mobile phones) and programs duly updated and configured with firewalls and protection against malicious software (e.g., antivirus), not browsing websites of dubious reputation or for which they do not have the proper guarantees of authenticity, the physical protection of their equipment and avoiding placing access credentials on publicly accessible computers (e.g., internet cafes, hotels, etc.) and the use of strong and differentiated passwords according to each service or website.
Legal information
This privacy statement has been prepared on the basis of provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates only to this website, if not otherwise stated in this document.
Information not contained in this policy
Further details on the collection or processing of personal data may be requested from the Owner at any time.
[atualização a 10 setembro 2020]