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Portobello is concerned about your privacy. Consequently, we protect your personal data, which is collected in order to facilitate the development of our activities and, especially, to keep a good relationship with you. We are aware that by collecting your data these are under our responsibility. Therefore, we have elaborated this Policy to let you know how your personal data is treated, and to guarantee you transparency in all actions we take..
Henceforth, we emphasize that if you do not have enough time available to fully read this Policy, or in case you have any doubts, you can get in touch through the email: email@example.com.
When you use our website nd/or provide your personal data, we consider that you have understood this policy.
We have elaborated this policy in an easy and objective way in order to reach the main recipient: you!
However, we would like you to get familiarized with the following terms:
In order to carry our activities and keep our relationship with you, we need to collect your personal data. Most times you provide us with your personal data in the following situations:
|Situation||Personal data provided|
|User registration||Name, address, email, phone number|
|Subscribing to our newsletter||Name, address, email, phone number|
|Participation in contests and promotions||Name, address, email, phone number|
|Using the tab ‘contact’ in the website||Name, address, email, phone number|
Conversely, there are situations in which we collect personal data from your activities (online or off-line) in other sources that store those personal data you decided to make known (e.g.: information from your media profile and social network). Personal data you do not provide, but which we treat from your activities in our website, are usually collected through automated technologies, such as cookies and web beacons, in the following situation:
|Situation||Personal data collected|
|During and after accessing/ using our website||
Your personal data are used to meet different objectives, depending on the situation in which they are collected. Most times, the aim has to do with the relationship we keep with you after your interaction in our virtual environment and the methods we use to personalize your experience while you use our website.
|User registration||Possibilitar que você mantenha usuário cadastrado no nosso site; realizar a gestão da sua conta e das atividades do site que optou por participar; veicular conteúdos publicitários e de marketing do Grupo Portobello; interagir e se comunicar com você.|
|Subscribing to our newsletter||Remeter conteúdos informativos e de marketing relacionados aos nossos produtos e à nossa atuação; manter dados analíticos e estatísticos sobre a interação com os conteúdos que remetemos.|
|Participation in contests and promotions||Executar atividades relacionados ao concurso ou promoção com os quais você decidiu interagir (ex.: realizar um sorteio, remeter e-mails sobre a promoção, lhe conceder um benefício para aquisição de determinado produto); realizar ações de marketing e publicidade.|
|Using the tab ‘contact’ in the website||Responder as suas solicitações e pedidos; atender aos seus direitos; receber as suas sugestões.|
|During and after accessing/ using our website||To accomplish marketing activities by analyzing which of our products might interest you; to provide personalized content and/or services according to your profile and characteristics; to personalize your experience while using our website; to keep and, in some cases (read the section ‘who do we share your personal information with?’) to share analytical and statistical data about the accesses and the characteristics of visitors in our website so that the results of our interaction with you can be quantified and traced.|
Besides the aims specified above, we would like to inform you that we treat your personal data with the support of the following legal basis from GLDP:
We keep your personal data stored until the aim (information provided in the items above) to which they were collected is reached. After the aim is reached, your personal data is removed. However, you can ask for your personal data to be removed at anytime, especially in the following cases: a) you decide to cancel the consent you gave us; b) you consider that unnecessary and excessive personal data are being treated; c) you consider that we do not fulfill the regulations of the GLDP.
Every time you request your personal data to be removed, we will do the possible to assist your demand. However, in some circumstances your personal data will not be removed, especially in the cases in which personal data are treated because the Law itself forces us to do so (e.g.: if you ask for the removal of the IP address within the period of 6 months after having accessed our website, we cannot remove it because the Law states that we must keep it for 6 months)
We understand that from the moment we collect your personal data, we are entirely responsible for treating and storing them according to the rigid protocols of cyber security. The following are part of the actions we take to keep your data safe: a) protection against unauthorized access; b) restricted access, only allowed to our employees, suppliers and partners who really need to access them due to the roles they perform; c) demanding via contract that all our employees, suppliers and partners should have appropriate knowledge about data protection and act according to the GLDP; d) the Management System of Data Protection and Privacy of Information - SGPD/SGPI; e) frequent security check of our internal systems of storage (including tests against invasions of hackers); f) complementary technical measures and automated security control, based on the best practices related to information safety, following the patters ISO27001/27701, NIST and OWASP.
We share your personal data with companies from the same business group and other brands controlled by us:
We also share your personal data with: a) our suppliers and partners, which are often hired to treat part of some personal data we collect (in these cases we always demand, in contract, that your data are protected and kept secret, under constant safety, physical and cybernetic); b) social media; c) authorities and public institutions legally involved in our internal processes; d) our franchisees and distributors; e) in case of fusions or acquisitions, for the companies involved in the corresponding negotiations.
If you need more information about your personal data sharing, do not hesitate to contact us - firstname.lastname@example.org
We transfer your personal data to other countries only when we hire third parties to storage certain data and, specifically, when these third parties keep their servers in other countries. We demand contractually that these third parties must adopt appropriate patterns, which are able to guarantee physical and cybernetic safety to your personal data and your privacy.
For the fulfillment of the GLDP you can request your rights, stated below, to be accomplished at anytime. You just have to send us an email email@example.com or access the tab “Contact us” in our website.
In addition to the actions we implement in our internal control to protect your personal data, it is essential that you also keep them safe. We recommend you not to share or keep your ID/user and password logged in to our website in public places (shared computers, use of free Wi-Fi networks in malls, airports or cafés, for example, i.e., places in which cyber security may not be appropriate). We recommend you not to choose the option of reminding your username or password while using the website or the applications. Furthermore, always make sure that you have logged out when you are no longer using our features, especially if your equipment is shared or if you have accessed our website from public equipment.
It is important to remember that sensitive personal data must not be inserted in text fields while you use our website, since none of the features in this virtual environment demands the insertion of such data.
We also expect you to understand this Policy and if you have something to contribute, please send us a message: firstname.lastname@example.org.
We have stated above, but it is worth repeating: you can contact us at anytime, in order to:
Just send an email to: email@example.com.
You are invited to read this Policy periodically, since it may be updated in order to improve the relationship we have with you, and enhance the actions we implement in order to keep your data safe and your rights assisted.
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