Privacy Policy

Last update on November 11, 2020

1 – WHAT IS PERSONAL DATA AND WHAT CATEGORY OF DATA WE HANDLE?

What is Personal Data?

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

Who are the holders of Personal Data?
The Personal Data is owned by the Client or User, a natural person, to whom this data relates and who used Location Available's services or products. The Client is the person who enters into the contract with the Location Available and the User is the person who uses the services or products of the Location Available, which may or may not correspond to the Client.

In this regard, Location Available informs you that it also protects personal data and respects the rights of customers and users.

What categories of personal data do we handle?
The categories of data we handle are as follows:

Base data	Examples
Identification and contacts	Civil or fiscal identification numbers, payment data, billing address, telephone number and email address; date of birth, gender, professional activity and IP (internet protocol, if you registered it)
Service	Products and services purchased or subscribed

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 Location Available, which provides the service or supplies the product and which, within this scope, decides which data is collected, the means of processing and the purposes for which the data is used.

3 – ON WHAT BASIS CAN WE TREAT YOUR PERSONAL DATA?

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

Consent
When you have given your express consent – in writing, orally or by validating an option – prior and if such consent is free, informed, purpose-specific and unambiguous. Examples are your consent for Location Available to review the use of services and products and to make recommendations or send marketing messages; use your identification or service usage data to send Location Available marketing messages; use 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 execution, execution and management of the contract entered into with the Location Available, for example 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 managing 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 the 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 the Location Available or third parties, such as the processing of data to improve the quality of service; the detection of fraud and protection of revenue, unless the interests or fundamental rights and freedoms of the data subject that require the protection of personal data prevail, in particular if the data subject is a child.

4 – FOR WHAT PURPOSES AND FOR HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

How long do we treat your Personal Data?

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

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

For what purposes do we process 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, 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 - Protection and control of revenue - 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 - Court orders - Investigation, detection and prosecution of serious crimes - Response to judicial, regulatory and supervisory entities
Information security control	- Access management, logs - Backup management - Security incident management

What are the deadlines for processing and retaining personal data?

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

There are cases where 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, the guidelines and decisions of the National Data Protection Commission (CNPD).

Thus, Location Available will process and maintain your personal data for the period in which 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, or to ensure rights or duties related to the contract, or because it has legitimate interests that underlie it, but always for the period strictly necessary for the achievement of the respective purposes and in accordance with the guidelines and decisions of the CNPD.

Examples are contacting for marketing and sales purposes, preserving data within the scope of invoice claims, exercising warranty rights or offerings that are in the customer's interest.

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 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.

Collection can be done orally, in writing or via the Location Available website.
But your personal information may also be collected from publicly accessible or other legally permissible 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 about credit risk or about identification and contact details, for collection 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 the personal data, provided that these bases comply with 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 (signatures) to differentiate you from other users of our website. This helps us to provide a good experience when browsing our site and also allows us to improve our site.

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 visitor numbers and see how visitors move around our site when they use it. This helps us to improve the way our site works, for example by ensuring that users find what they are looking for with ease. You can find more information about the individual cookies we use and the purposes for which we use them below:

analytics

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 collected data to track and examine the use of this website, prepare reports on its activities and share them with other Google services.

Google may use the data collected to contextualize and customize ads from its own ad network.
Personal Data Collected: Cookies and Usage Data.
Processing location: United States- Privacy Policy- Refuse.

Facebook Ads Conversion Tracking (Facebook, Inc.)

Facebook Ads Conversion Tracking is an analytics service provided by Facebook, Inc. that connects Facebook ad network data with actions taken on this site.

Personal Data Collected: Cookies and Usage Data.
Processing location: United States - Privacy Policy.

Commented Content

Content comment services allow users to make and post 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, this may be used to send notifications of comments about the same content. Users are responsible for the content of their own comments.

If a third-party-provided content review service is installed, it may still collect web traffic data for pages on which the review service is installed, even when users do not use the content review 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.
Processing location: United States - Privacy Policy.

Marketing via email

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 website and its partners to inform, optimize and serve advertising based on the user's past use of this website.

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

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

Facebook Remarketing (Facebook, Inc.)

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

Personal Data Collected: Cookies and Usage Data.
Processing location: United States - Privacy Policy- Refuse.

Customized Facebook Audience (Facebook, Inc.)

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

Personal Data Collected: Cookies and email address.
Processing location: United States - Privacy Policy- Refuse.

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 is 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 you to interact with the Twitter social network provided by Twitter, Inc.

Personal Data Collected: Cookies and Usage Data.
Processing location: United States - Privacy Policy.

Facebook Like Button and Social Widgets (Facebook, Inc.)

The Facebook Like Button and Social Widgets are services that allow you to interact 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 you to interact 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 in their own search engine and prevent - for example - third parties from installing cookies.

Through the search engine preferences, it is also possible to delete 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 in the most used search engines: 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 can follow the instructions provided in the initiatives subsequently linked by the EDAA (EU), by Network Advertising Initiative (USA) and by 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 recorded the 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 technically and legally possible - sending a notice to users via any information of contact.

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

Website Owner and Data Processing Officer

Location Available, Ltd.

NIPC PT 508 509 645.

Rua Alfredo Gomes de Azevedo, 71

trophy

Mail: mail@location.com.pt
Telephone: +351911070927

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 ask that you consult the privacy policy of the respective third-party services listed in this document.

Given the objective complexity around identifying cookie-based technologies, users are encouraged to contact the owner if they wish to receive more information about the use of cookies by this site.

7 – WHAT ARE YOUR DATA PROTECTION RIGHTS AND HOW TO EXERCISE THEM?

What are your rights?

See below your rights, as data owner, and its content

right of access

Right to obtain confirmation of which personal data are being processed and information about them, such as the purposes of the processing, the terms of retention, among others. Right to view or obtain a copy, for example, of invoices, written agreements or support requests you have made.

right of correction

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

Right to data erasure or "right to be forgotten"

Right to have your personal data erased, as long as there are no valid grounds for its preservation, such as in cases where Location Available must keep the data in order to comply with a legal obligation to preserve it for investigation, detection and prosecution crimes or because a court case is in progress.

right to portability

Right to receive the data you have provided 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 contact details to the new person responsible, but in this case only if technically possible.

Right to withdraw consent or right to object

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

Limitation right

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

Treatment suspension
Limitation of the scope of processing to certain categories of data or processing purposes.

right to complain

Right to file 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, unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged taking into account the costs. Information must be provided in writing but, if requested, may 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 through the following addresses:

Location Available

Letter:

Rua Alfredo Gomes de Azevedo, 71

4785-281 Trophy,

Mail: mail@location.com.pt

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

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

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 recording of actions taken by Location Available employees on personal data of customers or users (logging);
Physical security measures, including strict control of access to the physical facilities of Location Available, by employees, partners and visitors, as well as very restricted and permanently monitored access to the essential technological infrastructures of Location Available;
Means of data protection by design ("privacy by design") using technical means such as mask, encryption, pseudonymization 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;
Rules of access for Customers or Users to certain products or services, such as the introduction of a password, to allow the reinforcement of 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's websites, be sure to consult the rules on the use of cookies on the respective websites.

Location Available's websites, products or applications may contain links to third-party websites, products or services that are unrelated to Location Available or 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's Customers and Users to this fact and to the need, before using the websites, products or applications, to read and accept the rules relating to the processing of personal data defined by these third parties.

Other advice

Location Available advises prudence in the exposure of your personal data and in the circulation of this data over the internet, acts that are the customer's full responsibility, 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 (eg, antivirus), not browsing sites with dubious reputation or for which they do not have the proper guarantees 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 passwords that are differentiated according to each service or website.

legal information

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

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

Questions or information not contained in this policy

Further details on the collection or processing of personal data can be requested from the owner at any time, via email at mail@location.com.pt.