Privacy Policy

The User must carefully read this Privacy Policy, which for its ease of understanding is clearly and simply written, which allows to determine, freely and voluntarily, whether or not to make your personal data available to SUEBI – Digital Labs, Lda. (Hereafter, “SUEBI”). 

You warrant that the data you provide to SUEBI is true, accurate, complete and up to date. For this purpose, the User is responsible for the accuracy of all the data sent, and will keep the information properly updated, to respond to any real situation. 

Similarly, and if applicable, you warrant that you have informed third parties about which you have provided personal data of all aspects of this Privacy Policy. You further warrant that you have obtained your authorization to make third party data available to SUEBI for the purposes referred to in this Privacy Policy. 

In any event, the User will be liable for any false or inaccurate information provided through the Website or other means, and for direct or indirect damages or losses caused to SUEBI or third parties. 

1. INTRODUCTION 

1.1 You are informed by this Privacy Policy that any personal data you make available through the SUEBI Website (hereinafter the “Website”) will be processed by SUEBI, as well as any data derived from navigation and other data that you may provide in the future. 

2. RESPONSIBLE FOR TREATMENT IDENTIFICATION 

2.1 This website is owned and managed by SUEBI – Digital Labs, Lda. as controller, based in Rua Augusto Rosa, 79, 4000-098, Porto, Portugal and with VAT ID PT515725994. 

2.2 By using this Website, you consent to the terms described in this Privacy Policy (“Policy”). 

3. INFORMATION ON THE PROCESSING OF PERSONAL DATA

3.1 The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (“RGPD”) and Law No 58/2019 of August 8th ensure the protection of individuals with regard to the processing of personal data and the free movement of such data within the European Union.

3.2 “Personal data” means any “information relating to an identified or identifiable natural person (“the data subject”). Identifiable a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, ID number, location data, electronic ID or one or more physical, physiological, genetic, mental, economic, cultural or social identity elements for that person.”

3.3 Personal data provided by the User via the Website will be processed in accordance with the personal data protection law, under which SUEBI is responsible for processing.

3.4 Personal data on racial or ethnic origin, political opinions, religious or philosophical beliefs, political opinions, trade union membership, health and sex life information, genetics, biometric data or sexual orientation data won’t be requested.

3.5 Under no circumstances will SUEBI transfer personal data provided by Users through this Website to third parties (SUEBI Partners) without the express prior consent of the Users. This consent will always be free and substantiated in a clear and unambiguous positive notice. The User may always consult the Privacy Policy of these entities, not being responsible SUEBI for how information is used and processed by these third party entities.

3.6 Personal data may be used by SUEBI, as well as its Partners, to send information about products, services, promotions or other direct marketing actions under your express consent.

3.7 Providing personal data is, under all circumstances, optional. If you wish to object to the processing of your personal data for direct marketing purposes, you may do so at any time at privacy@suebidigital.com.

3.8 The SUEBI may, however, transmit the data to recipients such as entities to whom the data must be provided by law, such as law enforcement, regulatory, court, governmental or other public authorities, or entities providing cloud services and maintaining information systems, banking, payment intermediaries, and online contract processing and management systems.

3.9 SUEBI may also have to transfer your personal data to a third country outside the European Economic Area which is not on the list of countries that the European Union has considered to have adequate levels of personal data protection. In such cases, SUEBI will ensure that data transfers are carried out in strict compliance with applicable legal standards or by obtaining the prior express consent of the data owner.

4. PURPOSE OF PERSONAL DATA TREATMENT

4.1 Personal data processed through the Website will only be used for the following purposes:

i. Availability of the website and its features;
ii. Creation and management of the User account;
iii. Security of information systems and optimization of services;
iv. Promotional communication, direct marketing via email, SMS or phone, own and third parties and/or market studies;
v. Subscription of newsletter to send articles or information of products/services of Partner Entities via email marketing actions;
vi. Article update notification and/or promotional, communications via Push Notifications.

4.2 The legal basis for the processing of personal data for such purposes is the performance of a contract, the fulfillment of a legal obligation and the express consent of the data subject.

4.3 Failure to respond to data marked as mandatory implies inability to respond to the data subject’s request.

5. STORAGE TIME

5.1 SUEBI will retain personal data only for as long as necessary for the purposes for which it was collected.

6. SECURITY MEASURES

6.1 SUEBI has implemented appropriate technical and organizational security measures to ensure the security of personal data provided to you by the User, in order to prevent unauthorized alteration, loss, processing and/or access, taking into account the current state of technology, the nature of the stored data and the risks to which it’s exposed. Measures taken include data encryption and security of applications that process such data.

6.2 SUEBI guarantees the confidentiality of data provided through the Website. Data collection is safe and secure, preventing loss, manipulation or alteration.

6.3 All data is entered into a Secure Server (256-bit SSL Encryption). You can check in your browser if a website is secure if the address starts with https (instead of http) or through a lock symbol, bearing in mind that internet security measures aren’t impregnable.

6.4 User’s personal data are treated with the level of protection legally required to ensure their security, taking into account the most advanced techniques, application costs and the nature, scope, context and purposes of the processing, as well as risks, of varying probability and severity, to the rights and freedoms of the data subject.

6.5 When processing personal data to SUEBI, it undertakes to:

• Store them by means of legally enforceable security measures of a technical and organizational nature to ensure their safety, thereby preventing unauthorized alteration, loss, treatment or access, in accordance with the state of the art at any given moment, nature of the data and the possible risks to which they are exposed;
• Use access control mechanisms for information systems and data and action recording mechanisms performed by employees, customers and other users of the information systems;
• Use encryption, pseudonymization and anonymization mechanisms for personal data;
• Implement physical security measures to protect facilities;
• Make sure that the data are processed only by employees whose intervention is necessary to satisfy the request of the data subject, being bound by the obligation of confidentiality and confidentiality. Should personal data be disclosed to third parties for such purposes, they are required to maintain appropriate confidentiality.

6.6 Despite the protection measures described here, the Internet is not a 100% secure means of communication and therefore IT’S not possible to guarantee the security of the information transmitted by this means. Personal data is collected on an open network and, as a result, may circulate on the network without security, and may be seen and used by unauthorized third parties.

7. EXERCISE OF RIGHTS

7.1 Under the RGPD and Law No. 58/2019 of August 8th, the User may exercise, at any time and free of charge, rights of access, rectification, deletion, limitation, by written request addressed to the SUEBI by the following means:

• By post to: Rua Augusto Rosa, 79, 4000-098, Porto, Portugal;
• By email to: privacy@suebidigital.com.

7.2 In this exercise of rights, the User must specify the claim, which will be met in due time, within the legal deadlines if the identity of the data subject is confirmed.

7.3 In the specific case of wishing to exercise the right of objection, no longer receiving marketing communications may, at any time, exercise it as follows:

• By clicking on the link for that purpose (usually referred to as “Unsubscribe”) in any email message you receive as a result of your registration on this Website;
• Sending an email to privacy@suebidigital.com with the subject “Remove”; 
• Or by post to Rua Augusto Rosa, 79, 4000-098, Porto, Portugal.

8. OTHER WEBSITES AND LIMITATIONS OF LIABILITY

8.1 The Website may contain links to other portals that aren’t covered by this Privacy Policy. If you access other websites or online content using such links, you should be aware that those websites may collect personal data in accordance with their privacy policies.

8.2 Under no circumstances will SUEBI be liable, directly or indirectly, for any damage or loss caused, or allegedly caused, to the User or other parties in connection with the use of the content, goods or services available on any of these portals.

9. RESPONSIBLE FOR PERSONAL DATA PROCESSING

SUEBI has designated a personal data protection officer (“DPO”) who can be contacted in writing at privacy@suebidigital.com. The User has the right to request:

• Access to personal data concerning you;
• Rectification of personal data;
• Deletion of personal data;
• Limitation of processing as regards the data subject;
• Right to object to treatment;
• Right to data portability;
• Right to withdraw consent at any time;
• Right to complain to a supervisory authority – National Data Protection Commission (CNPD).

10. CHANGES TO PRIVACY POLICY

10.1 SUEBI reserves the right to revise its Privacy Policy whenever it deems it appropriate due to any legislative or commercial changes. These will be binding as soon as they are posted on the Website, so please check back periodically for the most up-to-date version at any time.

10.2 For additional information about our Privacy Policy, please email us at privacy@suebidigital.com.

11. CONTROL AUTHORITY

11.1 Under the terms of the law, the data subject has the right to make a complaint to the competent supervisory authority which, without prejudice to another being identified, will be the National Data Protection Commission (CNPD) www.cnpd.pt regarding matters concerning the exercise of your rights and the protection of your personal data.

11.2 Any additional information regarding privacy protection can be obtained from CNPD – Data Protection Commission – Av. D. Carlos I, 134 – 1. 1200-651 Lisboa – Tel: +351 213928400 – Fax: +351 213976832 – email: geral@cnpd.pt.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE WEBSITE.