Privacy policy

Last updated on 11 November 2020

 

 

1 - WHAT IS PERSONAL DATA AND WHAT DATA CATEGORY DO WE PROVIDE?

What is Personal Data?

Personal Data is any information, of any nature and on any medium (eg sound or image), relating to an identified or identifiable natural person. 
An identifiable person is a person who can be identified directly or indirectly, for example by name, identification number, location data, an electronic identifier or other element that allows identification of that natural person.

Who are the holders of Personal Data? 
Personal Data is the property of the Customer or User, a natural person, to whom this data relates and who has used Location Available services or products. The Customer is the person who concludes the contract with Location Available and the User is the person who uses Location Available services or products, which may or may not correspond to the Customer.

In this regard, Location Available 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 treat are as follows:


 

Base data

Examples

Identification and contacts

Civil or tax identification numbers, payment details, billing address, telephone contact and email address; date of birth, gender, professional activity and IP (internet protocol, if you registered there)

Service

Products and services purchased or subscribed

 

2 - WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR PERSONAL DATA?

The person responsible for the collection and processing of your personal data will be Location Available, which provides you with the service or supplies the product and which, in this context, decides which data is collected, means of treatment and purposes for which the data are used.

3 - WHAT BASIS CAN WE TREAT YOUR PERSONAL DATA?

These are the circumstances in which we can process your personal data:

Consent
When you have given your express consent - in writing, orally or through the validation of an option -, prior and if that consent is free, informed, specific with regard to the purpose and unambiguous. Examples are your consent for Location Available to analyze the use of services and products and make recommendations or send marketing messages using your identification or service usage data to send Location Available marketing messages; use customer service information to improve our quality of service;



or 

Contract execution and pre-contractual steps


When the processing of personal data is necessary for the conclusion, execution and management of the contract concluded with Location Available, such as for the preparation of a proposal for products and / or services, at the request of the data subject, for the management of contacts, response to other requests, for billing, collection and payment management;



or 

Compliance with legal obligation

When the processing of personal data is necessary to fulfill a legal obligation to which Location Available 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 Location Available or third parties, such as the processing of data to improve the quality of service; the detection of fraud and revenue protection, unless the holder's fundamental interests or rights and freedoms that require the protection of personal data prevail, especially if the holder is a child.

4 - FOR WHAT PURPOSES AND HOW LONG DO WE TREAT YOUR PERSONAL DATA?

How long do we process your Personal Data?


Your personal data are processed by Location Available only for the period of time necessary to achieve the defined purpose or, depending on what is applicable, until you exercise your right to object, the right to be forgotten or withdraw your consent.


After the respective conservation period has elapsed, Location Available will delete or anonymize the data whenever the data should not be kept for a different purpose that may exist. 


For what purposes do we treat your Personal Data?

Purposes

Examples of purposes (not 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
- Complaints management;

- Billing, collection and payment management

Accounting, Tax and Administrative Management

- Accounting, billing

- 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 illicit 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

- Call location for emergency services
- Judicial requests

- Investigation, detection and prosecution of serious crimes 
- Response to judicial, regulatory and supervisory entities

Control of information security

- Access management, logs

- Backup management

- Security incident management

 

 


What are the deadlines for processing and preserving personal data?


Location Available treats and preserves your personal data according to the purposes for which they are processed.

There are cases in which the law requires the processing and conservation of data for a minimum period of time, for example, 10 years in the case of data necessary for information to the Tax Authority, for accounting or tax purposes. 

But, whenever there is no specific legal obligation, the data will be processed only for the period necessary to fulfill the purposes that motivated its collection and preservation and always in accordance with the law, guidelines and decisions of the National Data Protection Commission (CNPD).

Thus, Location Available will process and maintain your personal data for as long as it maintains a contractual relationship with you.

Location Available may keep other personal data for periods longer than the duration of the contractual relationship, either based on your consent, either to ensure rights or duties related to the contract, or because it has legitimate interests that justify it, but always for the strictly period necessary for the realization of the respective purposes and in accordance with the guidelines and decisions of the CNPD.

Examples are contact for marketing and sales purposes, data preservation within the scope of invoice claim processes, exercise of warranty rights or offers that are of interest to the customer.

5 - HOW DO WE COLLECT YOUR PERSONAL DATA?

How do we collect your personal data?

We collect personal data upon your consent when you purchase Location Available products or services, when you download or use Location Available e-books, quizzes, sessions, offers, products, services and applications or when you participate in market research.

The collection can be made orally, in writing or through the Location Available website.
But your personal information may also be collected from sources accessible to the public or other legally permissible sources. 



How is the indirect collection of your personal data done? 
In order to better understand this indirect collection, we recommend the following cases:

Other relevant information about credit risk or identification and contact details, for collections management, fraud detection and revenue protection.
Location Available may collect personal data from private entities that maintain relevant information about the credit of the holders of personal data, provided that these databases respect the applicable data protection rules. Location Available 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 details.

6 - DATA ANALYSIS

Cookies Policy

Information about our use of cookies.

Our website uses cookies (connection testimonies) to differentiate you from other users of our website. This helps us to provide a good experience when you browse our website and also allows us to improve it.

A cookie is a small file of letters and numbers that we store on your search engine (browser) or on your computer's hard drive, if you agree.

The cookies we use are “analytical” cookies. They allow us to recognize and count the number of visitors and see how visitors move through our site, 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:

Analytics

The services 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, to prepare reports on its activities and to share it with other Google services.

  • Google may use the data collected to contextualize and personalize the ads for its own advertising network.
  • Personal Data collected: Cookies and Usage Data.
  • Processing location: United States- privacy policyRefuse.

 

Conversion Tracking for Facebook Ads (Facebook, Inc.)

Conversion tracking for Facebook Ads is an analytics service provided by Facebook, Inc. that connects data from Facebook's advertising network with actions taken on this site.

  • Personal Data collected: Cookies and Usage Data.
  • Processing location: United States - privacy policy.

Commented Content

Content commenting services allow users to make and post their comments on the content on this site.

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 can be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.

If a third-party content commenting service is installed, it can still collect web traffic data for 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 users to leave comments and share them on the Facebook platform.

  • Personal Data collected: Cookies and Usage Data.
  • Processing location: United States - privacy policy.

Email Marketing

We collect your name and email address when you register for a webinar or event, request a free resource or join a waiting list, via ActiveCampaign (privacy policy).

We use this data to send you emails about useful advice and industry news and to notify you of 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 and sales tax collection process.

Remarketing and behavioral targeting

This type of service allows this site and its partners to inform, optimize and serve advertising based on the user's use of this site in the past.

This activity is carried out by tracking Usage Data and Cookies, information that is transferred to the partners that manage the remarketing and behavioral segmentation activity.

In addition to any deactivation offered by any of the services below, the user can deactivate the use of cookies by a third party service by visiting the deactivation page of Network Advertising Initiative.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a behavioral remarketing and segmentation service provided by Facebook, Inc. that links the activity of this website to the Facebook advertising network.

  • Personal Data collected: Cookies and Usage Data.
  • Processing location: United States - privacy policyRefuse.

Personalized Facebook audience (Facebook, Inc.)

Facebook Personalized Audience is a remarketing and behavioral segmentation service provided by Facebook, Inc. that links the activity of this website to the Facebook advertising network.

  • Personal Data collected: Cookies and e-mail address.
  • Processing location: United States - privacy policyRefuse.

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.

The interaction and information obtained through this website are always subject to the user's privacy settings for each social network.

This type of service can 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.
  • Processing location: United States - privacy policy.

Like button on Facebook 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.
  • Processing location: 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.
  • Processing location: United States - privacy policy.

How to provide or withdraw consent for the installation of cookies

In addition to what is specified in this document, the user can manage cookie preferences directly on his own search engine and prevent - for example - third parties from installing cookies.

Through search engine preferences, it is also possible to exclude cookies installed in the past, including cookies that may have saved the initial consent for the installation of cookies by the respective websites.

Users can, for example, find information on how to manage cookies on the most used search engines: Google ChromeMozilla FirefoxApple Safari and Microsoft Internet Explorer.

Regarding 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 above, the owner informs that users can follow the instructions provided in the initiatives subsequently linked by EDAA (EU) for 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 resources, 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 recorded the interaction with this website (system logs) using other personal data (such as the IP address) for that purpose.

Changes to this privacy policy

The owner reserves the right to make changes to this privacy policy at any time, notifying users on this page and possibly within this site and / or - as far as technically and legally possible - sending a notice to users through any information contact.

If the changes affect the processing activities carried out based on the user's consent, the owner must collect new consent from the user, when necessary.

Website Owner and Responsible for Data Processing

Location Available, Lda.

NIPC PT 508 509 645.

Rua Alfredo Gomes de Azevedo, 71

Trofa

 

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, we request that the user consult the privacy policy of the respective third party services listed in this document.

Given the objective complexity surrounding the identification of technologies based on cookies, users are encouraged to contact the owner if they wish to receive more information about the use of cookies by this website.

7 - WHAT ARE YOUR DATA PROTECTION RIGHTS AND HOW DO YOU EXERCISE THEM?

What are your rights? 

See below your rights, as the data owner, and the respective content

Right of access

Right to obtain confirmation of what personal data are processed and information about them, for example, what are the purposes of the treatment, which are the storage periods, among others. Right to view or obtain a copy, for example of invoices, written agreements or support requests you have made.

Right of rectification

Right to request the rectification of your personal data that are inaccurate or to request that incomplete personal data be completed, such as the address, TIN, email, telephone contacts, or others.

Right to erase data or “right to be forgotten”

Right to obtain the deletion of your personal data, as long as there are no valid grounds for its conservation, such as the cases where Location Available has to keep the data in order to comply with a legal preservation obligation for investigation, detection and prosecution crimes or because a lawsuit is in progress.

Right to portability

Right to receive the data you have provided to us in digital format for current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new person responsible for your personal data, such as receiving your invoices or transmit your contacts to the new responsible, but in this case only if it is technically possible.

Right to withdraw consent or right to object

Right to object or withdraw your consent, at any time to a data processing, as in the case of data processing for marketing purposes, as long as there are no legitimate interests that prevail over your interests, rights and freedoms , such as defending a right in a judicial process.

Right of limitation

Right to request to limit the processing of your personal data, in the form of:

  1. Suspension of treatment
  2. Limiting the scope of processing to certain categories of data or processing purposes.

Right to complain

Right to complain to the supervisory authority, CNPD, in addition to the company or the DPO.

How can you exercise your rights?

The exercise of the rights is free, unless it is a manifestly unfounded or excessive request, in which case a reasonable fee may be charged taking into account the costs. Information must be provided in writing but, if requested, can be provided orally. In this case, Location Available must verify your 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 at the following addresses: 

Location Available

Letter:

Rua Alfredo Gomes de Azevedo, 71

4785-281 Trofa,

Mail: mail@location.com.pt

Phone: +3519110709277

 

 

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 can be passed on to subcontractors for them to handle on behalf and on behalf of Location Available. In this case, Location Available will take the necessary contractual measures to ensure that subcontractors respect and protect the holder's personal data.  
The data may also be transmitted to third parties - entities other than Location Available or subcontractors - such as companies within the Location Available group, companies with which Location Available develops partnerships, if the holder has consented - or entities to whom data must be communicated by law, such as the Tax Authority.  

Under what circumstances does Location Available transfer your data to a third country? 
Location Available may need to transfer your personal data to a third country outside the European Union and that is not on the list of countries that the EU has already considered to have adequate levels of protection of personal data. In such cases, Location Available will ensure that data transfers are carried out in strict compliance with applicable legal rules.

9 - HOW DOES LOCATION AVAILABLE PROTECT YOUR PERSONAL DATA?

Location Available 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 treatment. or illicit. 

Location Available has implemented:

  • Logical security requirements and measures, such as the use of firewalls and intrusion detection systems in your systems, the existence of a strict policy on access to systems and information and the registration of actions taken by Location Available employees on personal data customers or users (logging);
  • Physical security measures, among which stand out strict control of access to Location Available physical facilities, by employees, partners and visitors, as well as very restricted and permanently monitored access to Location Available's essential technological infrastructures;
  • Data protection means from conception (“privacy by design”) using technical means such as mask, encryption, pseudonymisation and anonymization of personal data and, also, a set of preventive measures favorable to privacy (“privacy by default”) ”);
  • Scrutiny, audit and control mechanisms to ensure compliance with security and privacy policies;
  • An information and training program for Location Available 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 ADVICE FOR THE PROTECTION OF YOUR DATA

Location Available and third party websites

 
Regarding the use and processing of personal data from Location Available websites, be sure to consult the rules on the use of cookies on the respective websites.

Location Available websites, products or applications may contain links to third party websites, products or services, which have nothing to do with Location Available or which are not covered by this Privacy Policy.

The collection or processing of personal data requested by these third parties is your sole responsibility, and Location Available 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 Location Available 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

Location Available advises caution in the exposure of your personal data and in the circulation of that data over the internet, acts that are the customer's full responsibility, since these data are not fully protected against possible violations, the adoption of complementary security measures, the maintenance of equipment (PCs, tablets or mobile phones) and programs properly updated and configured with firewalls and protection against malicious software (eg, antivirus), the non-browsing of sites of dubious reputation or for which there is no guarantee of authenticity, the physical protection of your equipment and avoid placing access credentials on publicly accessible computers (eg, internet cafes, hotels, etc.) and the use of strong and different passwords depending on each service or website.

Legal information

This privacy statement was prepared based on the provisions of multiple laws, including the information obligations provided for in arts. 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy refers only to this website, if not otherwise indicated in this document.

 

Questions or information not contained in this policy

More details about the collection or processing of personal data can be requested from the owner at any time, by emailing mail@location.com.pt.