WHOM DO WE SHARE YOUR DATA WITH?

In the context of the rendering of our services or products, we may use service providers (processors), such as companies that provide technological support, network providers or hosting companies, which must have access to some of your personal data.

However, these communications are made solely and exclusively for the fulfilment of the purposes for which the data are collected and in accordance with our instructions, in strict compliance with the regulations on the processing of personal data and information security. In any case, we will share all information regarding such communications with you.

We may also communicate your personal data to third parties where:

• you have expressly consented to it; or
• the communication is made in order to comply with a legal obligation or a court order.

We will only transfer your personal data outside the European Union or the European Economic Area, i.e. to a third country, ensuring strict compliance with European legislation on the transfer of data to third countries and will provide all necessary information, including, for example, an indication of the safeguards for such transfer:

• Adequacy decisions: where the European Commission determines that a third country offers an adequate level of data protection, personal data may be sent to that country without implementing any other measures mentioned above;
• Standard contractual clauses: These contractual commitments have been adopted by the European Commission and ensure adequate protection of personal data transferred to countries outside the EEA by binding recipients of personal data to certain data protection standards, including the obligation to implement appropriate technical and security measures.

FOR HOW LONG WILL WE RETAIN YOUR PERSONAL DATA?

Your personal data will only be kept for the period of time necessary for the purposes for which they were collected or for the periods of time required by law.

Our data storage policies regarding records are fully in accordance with the current legislation. We will keep and use your information to the extent necessary to comply with our legal obligations, namely regarding taxes and income and dispute resolution.

WHAT ARE YOUR RIGHTS?

We make every effort to ensure that your personal information is accurate, up-to-date and complete in accordance with the purposes for which we use that information.

According to the GDPR, you have the right, at any time, to access and object to the processing of your personal information, as well as the right to update, correct and delete data collected by us that is incomplete, incorrect, out of date, or prohibited by law. You may exercise these rights by contacting us using the contact details provided below (“CONTACTS“).

We explain your rights briefly below:

• Right to be informed
  You have the right to obtain clear, transparent and easily understandable information about how we use your personal data.
• Data subject’s right of access
  You can request a copy of the data we hold about you.
• Right of rectification
  You have the right to rectify your personal data if it is incorrect or out of date and/or to complete it if it is incomplete.
• Right to erasure of data (“right to be forgotten”)
  This right is not absolute, as we may have legal or legitimate reasons to retain your personal data.
• Right to, at any time, object to the processing of data on the basis of consent
  You may object to the processing of data where such processing is based on consent. Withdrawing consent does not affect the lawfulness of the consent previously given.
• Right to data portability
  You have the right to receive personal data concerning you, in a structured, commonly used and machine-readable format, and the right to transmit this data to another organisation. This applies only to data you have provided whose processing is based on your consent or on a contract, and if the processing is carried out by automated means.
• Right to limit processing
  You can ask us to limit the use of your data to storage only, to stop using it for all other purposes or to retain data that should be deleted.
• Lodging a complaint to the CNPD
  You also have the right to lodge a complaint with the data protection supervisory authority in Portugal when your rights have been violated or your personal information is being used in a way that you believe is not in accordance with applicable law. The contact details of the Portuguese Data Protection Commission are available here, along with details on how to make a complaint.

HOW CAN YOU EXERCISE YOUR RIGHTS?

You can exercise any of these rights by using the contact details provided below (“CONTACTS“).

AUTOMATED INDIVIDUAL DECISIONS

We do not anticipate that any decisions which have legal or other effects on you will be made using purely automated means; however, we will update this policy if this situation changes and notify you of such changes.

HOW DO WE RESPECT THE SECURITY OF SHARED INFORMATION?

We implement the technical and organisational measures that ensure the confidentiality of your personal data, protecting it from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against other unlawful forms of data processing.

For example, we take the following measures:

• Pseudonymisation and encryption of personal data;
• The ability to ensure the ongoing confidentiality, integrity, availability and resilience of the processing systems and services;
• The ability to detect a personal data breach, resolve it and report it;
• The ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident;
• A process to regularly test, assess and evaluate the effectiveness of technical and organisational measures to ensure security of processing;
• Identification, disclosure and documentation of the roles and duties of personnel with access to personal data;
• Maintenance of a written record of all processing activities carried out, as per GDPR requirements;
• Definition and implementation of a written incident log procedure;
• Appointment of a security officer or, where appropriate, a Data Protection Officer, who shall be appointed where required by law;
• Definition and implementation of physical access controls;
• Implementation of security policies and procedures;
• Definition and implementation of a procedure for the destruction or return of personal data and documents, in a secure and confidential way (making it impossible to recover them later and certifying the absence of copies), when the contractual relationship ends (except when there is an obligation to keep personal data for an additional period, in which case the personal data and documents shall be blocked).

Any entity we outsource to will be bound by equivalent security measures, acting at all times under our duly documented instructions.

COOKIE POLICY

We use cookies on our Website. When you access the Website, various text files known as “Cookies” may be installed or stored in the memory or hard drive of your device and retain information relating to your preferences. Cookies are placed after obtaining your consent to do so [link to cookie consent form].

WHAT ARE COOKIES USED FOR?

Cookies help determine the usefulness, relevance and number of visits to a website and provide users with a faster, more efficient browsing experience by reducing the need to repeatedly enter the same information.

WHAT KIND OF COOKIES DO WE USE?

We use strictly necessary cookies and [•] cookies.

WHAT IS THE PURPOSE OF THE COOKIES WE USE?

Strictly necessary cookies: these cookies enable users to navigate on the Website and access secure areas. Without these cookies, some services that you have requested may not be offered.
[•]

COOKIE MANAGEMENT

You may at any time authorise, restrict or prohibit the cookies listed above.

You may also at any time authorise, restrict or prohibit cookies by configuring your Internet browser (Internet Explorer, Firefox, Safari, Google Chrome, Opera, etc.) as described below. Please be advised that any configuration may alter your Internet browsing and your conditions of access to services that require the use of cookies.

The configuration of each browser is different, so we advise you to consult the help menu of your browser:

For Chrome:
https://support.google.com/chrome/answer/95647?hl=es-419

For Safari:
Clear the history and cookies from Safari on your iPhone, iPad, or iPod touch – Apple Support

For Firefox:
Block websites from storing cookies and site data in Firefox | Firefox Help (mozilla.org)

For Internet Explorer:
Delete and manage cookies (microsoft.com)

For Opera:
Web preferences – Opera Help

HOW TO BE INFORMED ABOUT POSSIBLE CHANGES IN OUR PRIVACY POLICY?
As practices regarding the processing of personal data may change from time to time, this Privacy Policy will need to be updated accordingly and on a regular basis, so we advise you to check it periodically. If there is a significant change, we will inform you directly by email.

CONTACTS
If you have any questions about this Privacy Policy or want to exercise your rights to access, update or correct any personal information, please contact us through the following contacts:

Address: Rua Soeiro Pereira Gomes, Lote 1, 7B, 1600-198 Lisboa

Telephone: (+351) 918 371 846  (rede móvel nacional)

E-mail: info@genesis.studio