Privacy policy

Privacy policy

In accordance with the provisions of the Data Protection Law, approved by Law No. 58/2019 of 8 August (hereinafter referred to as the “DPL”), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “GDPR”), the company XX, with tax identification number XX, having its registered office at XX, in XX, registered with the Commercial Registry Office of XX (hereinafter referred to as the “Company”), implements this Privacy Policy regarding the processing and protection of personal data.


Terms not defined in this Privacy Policy (such as “Portal” or “User”) have the same meaning as in our Terms and Conditions.


  1. DATA OF THE CONTROLLER

Under the terms of Article 4 of the GDPR, a “Controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.


In this case, the Controller will be the Company.

  • Email: XX
  • Portal: www.lookinclub.pt

  1. TREATMENT

The personal data collected by the Company will be processed in accordance with the regulatory and legal provisions in force.


In this regard, the Company seeks to ensure that its internal procedures comply with the legal obligations set out in the LPD and the GDPR, and that the personal data of its employees, Users, customers, Members, Partners, suppliers or service providers, and of any other data subjects whose personal data the Company processes in the course of its activity, are processed in accordance with the applicable regulatory and legal standards and kept secure.


In the course of its daily activities, the Company may collect, process and store personal data.


In accordance with European and Portuguese legislation on the protection of personal data, such data must be obtained and processed in a fair, lawful and transparent manner.


The Company is committed to ensuring that its team has adequate knowledge of legislation and personal data protection practices, so that it can anticipate and identify any personal data protection issues that may arise.


  1. APPLICATION

This Privacy Policy applies to:

  1. to anyone visiting the www.lookinclub.pt Portal, owned by the Company;
  2. those who voluntarily communicate with the Company or with the Portal via email, chat, or who complete any data collection form;
  3. those who request information about the Society’s or the Portal’s products and services, or who ask to take part in any of its commercial activities; and
  4. to anyone who uses any other service of the Company or the Portal in situations where such use involves the communication of or access to data for the provision of its services.

  1. USE AND ACCEPTANCE

The use of the Company’s products and services or of the Portal requires the explicit acceptance of this Privacy Policy.


Except through legal representation, no User may use another person’s identity or disclose their personal data. The data that Users provide to the Company or on the Portal must be personal, correspond to their own identity, be current, complete, accurate and truthful, and must be kept up to date at all times.


The User shall be solely liable for any direct or indirect damage caused to the Company or to third parties through the use of their own data or third-party data when such data is false, incorrect, outdated, inappropriate or irrelevant.


The User who provides personal data to the Company declares that they are of legal age, in accordance with the provisions of the applicable Portuguese legislation (in particular Article 16 of the LPD). Any data provided in relation to a minor will require the prior consent or authorisation of their parents, guardians or legal representatives, who will be considered responsible for the data supplied by the minors in their care.


  1. PURPOSES AND LEGAL BASIS FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA

The Company informs Users of the existence of various processing operations and databases in which the personal data provided are collected, stored and processed.

As the Data Controller, the Company ensures that all personal data:

  1. They are obtained for specific, lawful and clearly defined purposes;
  2. They are compatible with the purposes for which they were obtained.
  3. They are kept with appropriate security measures, implemented or to be implemented, to protect against unauthorised access, or the alteration, destruction or disclosure of any personal data held by the Company as Data Controller;
  4. They are kept accurate, complete and up to date, when necessary;
  5. They are not collected if they are excessive;
  6. They will not be transferred to third parties, except in cases where there is a legal obligation; and
  7. They are kept only for as long as necessary.

The purposes of the aforementioned collection and processing of personal data are as follows:


  1. Cookies

The cookies used by the Company for browsing on the Portal are stored on the User’s terminal device and collect information when the User visits the Portal, for technical, analytical and behavioural purposes and, in particular, with the aim of (i) improving its usability, (ii) understanding the User’s browsing habits or needs in order to adapt to them, and (iii) obtaining information for statistical purposes.


The legal basis for processing personal data related to cookies is consent for analytical and behavioural purposes. Technical or functional cookies are excluded.


Users can configure their browser so that the reception of all or some cookies is disabled or blocked. If the User chooses not to accept these cookies this does not prevent access to the information on the Company or the Portal, although the use of some services may be limited.


If, once consent has been given for the reception of cookies, the User wishes to withdraw it, those cookies stored on the User’s terminal equipment must be deleted using the options available in the different browsers.


All information about cookies used by the Company is available for consultation in the Cookies Policy.


  1. Member registration

When the User decides to register on the Portal as a Member, the collection and processing of the data requested at the time of registration is carried out for the purpose of enabling that User’s membership and, in that capacity, managing their relationship with the Portal and the Company.


The legal basis for processing in these situations is the consent given at the time of joining, as well as the legitimate interest in fulfilling the User’s wish to become a Member.


  1. Email or communication with the Company

When the User sends an email to the Company or communicates personal data through the Portal or by another means – namely via a contact form – the purpose of the collection and processing of such data by the Company is to analyse any questions and requests for information that arise in relation to its products and services.


The legal basis for processing in these situations is the consent given at the time the email is sent or when contacting the Company, as well as the legitimate interest in responding to the requests made by the User.


  1. Commercial Campaigns / Newsletters

When the User fills in forms of the Company or the Portal with a view to taking part in any commercial initiative or subscribing to a newsletter, the data collected will be processed in order to enable such participation or subscription, as well as to send commercial and advertising communications about the services of the Company or the Portal and commercial communications from other group companies or Partners, where the data subject has expressed an interest in this.


The legal basis for processing this personal data will be the User’s consent. The data subject may change their decision at any time, as often as they consider appropriate, using the means made available by the Company for this purpose.


  1. PERSONAL DATA RETENTION PERIOD

In compliance with the provisions of Article 21 of the LPD, the Company will retain personal data for only as long as is strictly necessary to pursue the relevant purpose. Once that purpose has been fulfilled, the Company may keep this data for the period during which any liabilities arising from its relationship with the User may still occur.


  1. RECIPIENT OF PERSONAL DATA

The recipients of the personal data collected by the Company or through the Portal are as follows:


  1. Employees of the Company itself, in the performance of their duties;
  2. Partners and suppliers of the Company involved in the provision of services, in situations where such involvement is necessary for that provision; and
  3. Judicial, administrative or police authorities, namely national or international public entities with supervisory and regulatory functions, where the Company is required under applicable law to provide information relating to its Users or its services.

  1. USER RIGHTS AND THEIR EXERCISE

Users may exercise the following rights recognised by the GDPR (Article 15 et seq.) at any time:


  1. Right of accessUsers have the right to obtain from the Company confirmation as to whether or not personal data concerning them are being processed and, where that is the case, the right to access their personal data and obtain information about the processing carried out.
  2. Right to obtain a copyof personal data undergoing processing.
  3. Right to rectificationUsers have the right to obtain from the Company, without undue delay, the rectification of inaccurate or incomplete personal data.
  4. Right to erasure (right to be forgotten). The user has the right to obtain from the Company the erasure of their personal data without undue delay, and the Company is obliged to erase the personal data without undue delay where one of the following grounds applies:
    1. The personal data are no longer needed for the purpose that justified their collection or processing;
    2. The User withdraws the consent they have given and on which the processing of the data is based;
    3. The User objects to the processing under Article 21 of the GDPR and there are no overriding legitimate interests that justify the processing;
    4. Personal data being processed unlawfully; and
    5. The personal data must be erased in order to comply with a legal obligation arising from the law of the European Union, of a Member State to which the Company is subject, or from a court decision.
  5. Right to restriction of processingUsers have the right to obtain from the Company the restriction of processing if any of the situations provided for in Article 18 of the GDPR applies.
  6. Right to data portabilityUsers have the right to receive the personal data concerning them, which they have provided to the Company, in a structured, commonly used and machine-readable format, provided that this data relates exclusively to the User and has been supplied by them. The User may transmit this data to another controller in the situations provided for in Article 20 of the GDPR, without the Company being able to prevent this.
  7. Right to objectThe user has the right to object to the processing of their personal data in the cases provided for in Article 20 of the GDPR.

Users may exercise their rights by sending a communication to the email XX@XX or by sending a request, accompanied by the identification number of their citizen card, addressed to the Company at the address XX, specifying the right they wish to exercise.

The Company may, whenever it deems appropriate, carry out prior verification of the applicant’s identity.

Requests to exercise rights will be answered without undue delay, within a maximum of one month from the date the request is received.

In the case of a high level of complexity of the request or a large number of requests, the response period may be extended by up to two months.

If the response period is extended, the Company will inform the data subject, within a maximum of one month from the date of receipt of the request, of the reasons for the delay in responding to the request.

If the Company does not follow up on the request submitted by the data subject, it shall inform them without delay and, at the latest, within one month from the date of receipt of the request, of the reasons for not taking action and of the possibility of lodging a complaint with a supervisory authority and bringing legal proceedings.

In cases of manifestly unfounded or excessive requests, particularly due to their repetitive nature, the Company reserves the right to require the payment of a fee for the resulting administrative costs or to refuse to comply with the request.

  1. Supervisory authority

Users and/or customers may contact the relevant local supervisory authority if they believe that the processing of their personal data has not been carried out in accordance with the legislation in force.


The data protection supervisory authority in Portugal is the National Data Protection Commission (CNPD), whose contact details are available on its website: https://www.cnpd.pt.


  1. INTERNATIONAL DATA TRANSFER

The Company will not carry out any transfer of personal data to a third country in respect of which the European Commission has not issued a decision stating that the country ensures an adequate level of protection or, failing that, has not adopted appropriate safeguards (generally, standard clauses).


The Company accepts no responsibility for the User’s failure to comply with obligations relating to the GDPR or the respective data protection regulations in connection with the User’s activities and which are related to the performance of the contract or business relationships that link the User to the Company. Each party shall assume responsibility arising from its own failure to comply with the contractual obligations of this Privacy Policy, as well as with the applicable regulations.


  1. CHANGES

This Policy may be updated periodically or amended whenever necessary or whenever there is a change in legislation, with a notice of such changes being published in a revised version of this Policy, which shall take effect upon its publication.

The Company will notify the holders of Personal Data of any changes to the policy using the contact details they have provided.

  1. CONTACTS

For more information about the processing of your data, or if you have any questions about data protection, you can contact the Society at the following email address: XX@XX

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