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DATA PROTECTION AND PRIVACY POLICY

POR:TA ASSOCIAÇÃO PARA A PROMOÇÃO DAS ARTES E DA CULTURA (hereinafter “POR:TA”), a non-profit association with headquarters at Rua de São Bernardo 26, 1200-825 Estrela, Lisbon, Portugal, with the with the registration number no. 516611542, in the execution of its activities regarding access to and use of it’s website https://www.portaassociation.com  (hereinafter “Website”), processes personal data, meaning any information relating to an identified or identifiable natural person (henceforth “Data subject(s)”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

In the cases where POR:TA determines the purposes and means of the processing of personal data within the performance of its activities it shall be considered as a controller, ensuring full compliance with Data Protection Legislation.

According with the aforementioned Legislation, POR:TA stands for the processing of personal data pursuant to all applicable principles: Principle of Lawfulness, Principle of Fairness and Transparency; Principle of Purpose Limitation; Principle of Data Minimisation; Principle of Accuracy; Principle of Storage Limitation; Principle of Integrity and Confidentiality.

In full accordance with the principles outlined above, POR:TA fully respects the data protection rights of Data Subjects. Hence, Data Subjects may contact POR:TA to obtain any information related to the processing of personal data, using the contacts provided in Paragraph 10.

For the foregoing, this Data Protection and Privacy Policy is established in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and other related legislation applicable (hereinafter “Data Protection Legislation”) POR:TA undertakes any and all data processing operations in accordance with the following paragraphs:

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

The personal data of Data Subjects will be processed by POR:TA with the following legal basis: (i) Consent; (ii) Compliance with a legal obligation; (iii) Defence of vital interests of the Data Owner; (iv) Legitimate Interests. 

Taking into account the abovementioned, the collection of personal data on the basis of the grounds of lawfulness set forth will be for the purposes of the Website as described in Paragraph. Hence, the non-collection of personal data will imply the impossibility of providing the Website’s functionalities.

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2.PROCESSING OF PERSONAL DATA ON THE WEBSITE

Within the scope of the website, POR:TA processes the Data Subject's personal data as follows:

  • Purpose: Website Management; Data Processing Activities: Analysis and processing of Web Browsing Data; Legal Basis: Execution of the Website´s Terms and Conditions; Retention Period For 3 months after the user’s last visit to the Website; 

  • Purpose: Newsletters; Data Processing Activities: Sending Newsletters; Legal Basis: Consent; Retention Period 1 year after the last visit to the Digital Channel; 

  • Purpose: Donation; Data Processing Activities: Donation Form for accepting donations made via the website; Legal Basis: Consent and Legal Obligation; Retention Period 10 years after the donation; 

  • Purpose: Contacts; Data Processing Activities: Analysing and responding to Contact Forms received through the Website; Legal Basis: Consent; Retention Period:1 year after the las contact;

  • Purpose: Commercial Activities and Marketing Purposes; Data Processing Activities: Direct Marketing Communications; Legal Basis: Consent; Retention Period: 1 year after the last visit to the Digital Channel. 

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3.PERSONAL DATA PROCESSED ON THE WEBSITE

In accordance with the said purposes POR:TA, processes the following personal data information:

  • Web Browsing Data [such as name, email, user account, demographic data, company function, username, password, creation date, access validity, log in and out, electronic identifier (Mac, IP), connection start date/time, connection end date/time, place of origin of web browsing, URL visited, social network address, history of interaction on social networks or host name].

  • Contact details: Email

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4. PROCESSING METHODS

The processing of personal data will be executed automated and manually by computer tools, which are strictly related to the mentioned purposes and, in any case, guaranteeing the security and confidentiality of personal data.

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5.DISCLOSURE AND TRANSMISSION OF PERSONAL DATA

Regarding the disclosure and transmission of personal data, POR:TA’s employees will process personal data and, as a result, they can access to the personal data of Data Subjects. The referred POR:TA employees will solely process the personal data of Data Subjects for the purposes specified in this Policy and in strict compliance with current or future Data Protection Legislation.

Third parties who may process personal data on behalf of POR:TA may also access to personal data of Data Subjects as subcontractors, including without limitation the providers of IT services required for the operation of information systems, outsourcing service providers or cloud computing services, professionals and consultants.

Data Subjects have the right to obtain a complete and up-to-date list of the subcontractors (if any) elected by POR:TA and for this purpose they shall submit a specific request to POR:TA under the terms specified in Paragraph 10 of this Policy.

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6.INTERNATIONAL TRANSFERS

POR:TA may transfer Your Personal Data outside the European Economic Area ("EEA") to locations that may not guarantee the same level of protection. However POR:TA only transfer Your Personal Data outside the EEA:

 

  • When the transfer is made to a location or by a method or in circumstances that the European Commission considers to ensure adequate protection of  Personal Data;

  • When standard data protection clauses approved by the European Commission or a competent data protection supervisory authority have been implemented; or,

  • When none of the above apply, but the law may still allow such transfer, for example, if it is necessary for the declaration, exercise or defence of a right in a judicial proceeding.

 

You may request detailed information on the security measures that POR:TA has implemented regarding Personal Data transfers outside of the EEA and, where applicable, a copy of the standard data protection clauses in force at POR:TA through the terms specified in Paragraph 10 of this Policy.

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7.DATA SUBJECTS RIGHTS

In accordance with current or future Data Protection Legislation, POR:TA informs you that the Data Holders, have the right to, where applicable: (i) request access, rectification, limitation, opposition, portability and erasure of their personal data, (ii) lodge a complaint with the competent control authority - in Portugal, the National Data Protection Authority  ("CNPD") - or (iii) obtain redress and/or compensation, if they consider that the processing performed violates their rights and/or the applicable legislation on the protection of personal data and privacy.

Where the legal grounds for processing your personal data are consent or legitimate interest, you may withdraw or object to the processing at any time, without detrimental consequences, without compromising the legality of the processing carried out in the meantime. In the event of consent being withdrawn or express opposition, POR:TA shall immediately cease processing your personal data for the purpose in question, unless the data needs to be processed in order to comply with legal and/or contractual obligations.

You may at any time, in writing, exercise the rights enshrined in the Data Protection Legislation and other applicable legislation through the methods described in Paragraph 10 of this Policy.

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8.CONFIDENTIALITY AND SECURITY

To ensure the security and confidentiality of the collected personal data collected, POR:TA uses protected databases including, but not limited to, adequate firewalls and passwords, in accordance with current and future Data Protection Legislation and other applicable legislation. Access to personal data is only possible for authorized employees who have an effective need to use the data, in accordance with the principles of security and confidentiality. Violations of the present Data Protection and Privacy Policy by POR:TA employees may result in disciplinary action. Compliance with standards and procedures by POR:TA‘s staff is monitored and verified periodically.

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9.COOKIES

With regard to the processing of Personal Data that POR:TA performs through the use of cookies, please consult the POR:TA Cookie Policy and customize your settings according to your preferences.

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10.HOW TO CONTACT POR:TA FOR DATA PROTECTION AND PRIVACY MATTERS

Data Subjects may exercise their rights by contacting POR:TA by sending an email to por.ta@portaassociation.com

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