Privacy Policy

[Last update 18 August 2022]

• WHAT ARE PERSONAL DATA AND WHAT CATEGORY OF DATA DO WE PROCESS?

What are personal data?

Personal data are any information, of any nature and in any medium (e.g. sound or image), concerning an identified or identifiable natural person.

An identifiable person is someone who can be identified directly or indirectly, e.g. through name, identification number, location data, electronic identifier or other elements that allow the identification of that natural person.

Who are the holders of personal data?

The Customer or User, natural person, to whom the data concern and who has used the services or products of the Panela de 3 Pés. The Customer will be the person who celebrates a contract with Panela de 3 Pés and the User is the person who uses the services or products of Panela de 3 Pés, but who may not correspond to the Customer.

For example:

• In the business segment, the contract with Panela de 3 Pés is in the name of the company, but the Users are the customers or employees of that company;
• In the private segment, a Customer may purchase various products and services.

In this regard, Panela de 3 Pés also protects personal data and respects the rights of customers and users.

What categories of personal data do we process?

The categories of data we process are as follows:

• WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA??

The party responsible for collecting and processing your personal data will be Panela de 3 Pés who provides you with the service or supplies the product and that, in that context, decides which data is collected, the means of processing and the purposes for which the data are used.

• ON WHAT BASIS MAY WE PROCESS YOUR PERSONAL DATA?

These are the circumstances under which we process your personal data:

Consent: When we have your express consent – in writing, orally or by validating an option – and prior, and if such consent is free, informed, specific and unambiguous. Examples are, your consent for Panela de 3 Pés to analyze the use of services and products and make recommendations or send marketing messages, to use your identification or service usage data to send Panela de 3 Pés marketing messages, your consent for us to use customer service information to improve our quality of service;

or

Contract execution and pre-contractual diligence: When the processing of personal data is necessary for the conclusion, execution and management of the contract concluded with the Panela de 3 Pés as, e.g., for the preparation of a proposal for products and/or services for the management of contacts, information and requests, for the management of 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 Panela de 3 Pés is subject, such as, e.g., the communication of identification data to police, judicial, tax or regulatory authorities;

or

Legitimate interest: When the processing of personal data corresponds to a legitimate interest of Panela de 3 Pés or a third party, such as the processing of data for improving the quality of service, fraud detection and revenue protection and where our reasons for its use should override your data protection rights.

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

For how long do we process your personal data?

Your personal data are processed by Panela de 3 Pés only for the period of time necessary to fulfil the defined purpose or, as the case may be, until you exercise your right to object, right to be forgotten or withdraw your consent.

After the end of the respective stored period, Panela de 3 Pés will eliminate 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?

What are the deadlines for processing and storing personal data?

Panela de 3 Pés processes and keeps your personal data according to the purposes for which they are processed.

There are cases in which the law requires the treatment and conservation of data for a minimum period of time, e.g., 10 years for data necessary to inform 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 their collection and preservation and always in accordance with the law, the guidelines and decisions of the Portuguese National Commission for Data Protection (CNPD).

Thus, Panela de 3 Pés will process and keep your personal data for as long as it maintains a contractual relationship with you.

Panela de 3 Pés 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 justify it, but always for the period strictly necessary to achieve the respective purposes and in accordance with the guidelines and decisions of the CNPD.

• HOW DO WE COLLECT YOUR PERSONAL DATA?

How do we collect your personal data?

We collect personal data upon your consent when you purchase Panela de 3 Pés products or services, download or use ebooks, quizzes, session offers, products, services and Panela de 3 Pés applications, or participate in market research. Collection may be done orally, in writing, or through the Panela de 3 Pés website. But your personal information may also be collected from publicly available sources or other sources.

How is your personal data collected indirectly?

Other relevant credit risk information or identification and contact details, for collection management, fraud detection and revenue protection.

The Panela de 3 Pés may collect personal data from private parties who maintain relevant credit information about the personal data subjects, provided that these databases comply with applicable data protection rules. The Panela de 3 Pés may also access, collect or confirm personal data on government and private entity websites to confirm the accuracy of your identification and contact details.

• DATA ANALYSIS Cookie Policy

Information about our use of cookies:

Our website uses cookies to differentiate you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve it.

A cookie is a small file of letters and numbers that we store in your browser, or on your computer’s hard drive if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use are “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our site when they use it. This helps us to improve the way our site works, e.g., by ensuring that users find what they are looking for easily. You can find out more about the individual cookies we use and their purposes:

Analytical

The services contained in this section allow the owner to monitor and analyze internet traffic and can be used to track user behavior.

Google Analytics (Google Inc.)

Google Analytics is an internet analytics service provided by Google Inc. (“Google”). Google uses the data collected to track and analyze your use of this website, prepare reports about your activities, and share it with other Google services.

• Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• Personal data collected: cookies and usage data.
• Place of processing: United States – privacy policy – opt out.
  

Facebook Ads Conversion Tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions taken on this site.

• Personal data collected: cookies and usage data.
• Place of processing: United States – privacy policy.

Commented Content

Content commenting services allow users to make and post their comments on the content of this site

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, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.

If a third-party content commenting service is installed, it may still collect internet traffic data for pages where the commenting service is installed, even when Users do not use the content commenting service.

Content Commenting (Facebook, Inc.)

Facebook Comments is a content comment 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.

Email marketing

We collect your name and email address when you register for a webinar or event, request a free resource or join a waitlist, via Systeme.io (privacy policy).

We use these data to send you emails about useful advices and related news and to notify you about 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 our partners to inform, optimize and provide advertising based on the user’s past use of this site.

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 opt-out offered by any of the services below, you can opt out of the use of cookies by a third party service by visiting the Network Advertising Initiative opt-out page.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc., which links activity of this site to the Facebook advertising network.

• Personal Data collected: cookies and usage data.
• Processing location: United States – privacy policy – opt out.

Facebook Custom Audience (Facebook, Inc.)

Facebook personalized Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. linking the activity of this site to the Facebook advertising network.

• Personal Data collected: cookies and email address.
• Processing location: United States – privacy policy – opt out.

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.

Interaction and information obtained through this website are 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 interaction 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 interaction 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 enable interaction 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 his/her own browser and prevent, e.g., third parties from installing cookies.

Through browser 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 this website.

Users can, e.g., find information on how to manage cookies in the most used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari e Microsoft Internet Explorer.

With respect to cookies installed by third parties, Users can manage their preferences and withdraw their consent by clicking on the related opt-out 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 may follow the instructions provided in the initiatives subsequently linked by the EDAA (EU), the Network Advertising Initiative (USA) and 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 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 record interaction with this website (system logs) using other personal data (such as IP address) for that 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 far as technically and legally possible, by sending a notice to users through any information of contact.

If the changes affect processing activities carried out on the basis of user consent, the owner must collect new user consent when necessary.

Owner and Data Controller

Panela de 3 Pés

Rua do Covelo, 178 – 1º 4200-238 Porto, Portugal

Owner contact email: info@panelade3pes.pt

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 the User to consult the privacy policy of the respective third-party services.

Given the objective complexity surrounding the identification of technologies based on cookies, Users are encouraged to contact the Owner if they wish to receive more information about the use of cookies by this site.

• WHAT ARE YOUR DATA PROTECTION RIGHTS AND HOW DO YOU EXERCISE THEM?

What are your rights?

See below your rights and what is safeguarded in each one.

Right of access

Right to obtain confirmation of which of your personal data are processed and information about them, such as, e.g., what are the purposes of the treatment, what are the retention periods, among others. Right to see or obtain a copy of, e.g., invoices, written agreements or support requests you have made.

Right of rectification

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

Right to data erasure or “right to be forgotten”

Right to obtain the erasure of your personal data, provided that there are no valid grounds for its conservation, e.g., cases in which Panela de 3 Pés has to keep the data to fulfill a legal obligation of preservation for investigation, detection and prosecution of crimes, or because a judicial process is in progress.

Right to portability

Right to receive the data you have provided to us in a digital format of current use and automatic reading, or to request the direct transmission of your data to another entity that becomes the new responsible for your personal data, e.g., receiving your invoices or forward your contact details to the new person in charge, 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, e.g., 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, for example, defending a right in a judicial process.

Right of limitation

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

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

Right to complain

Right to file a complaint with the control authority, the CNPD, in addition to the company or the DPO.

How can you exercise your rights?

The exercise of the 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. The information must be provided in writing, but if requested, it may be provided orally. In this case, the Panela de 3 Pés must verify the 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:

Panela de 3 Pés Letter:

Rua do Covelo, 178 – 1º 4200-238 Porto,

Portugal

Email: info@panelade3pes.pt

• TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?

Under what circumstances is your personal data communicated to other entities, subcontractors or third parties?

Your data may be transmitted to subcontractors so that they can process them under the name and on behalf of the Panela de 3 Pés. In this case, Panela de 3 Pés will take the necessary contractual measures to ensure that subcontractors respect and protect the holder’s personal data. The data may also be transmitted to third parties – entities other than the Panela de 3 Pés or subcontractors, companies with which the Panela de 3 Pés develops partnerships, in case the holder has consented – or entities to whom the data must be communicated by force of the law, such as the tax authority.

Under what circumstances does Panela de 3 Pés transfer your data to a third country?

The Panela de 3 Pés may have to transfer your personal data to a third country outside the European Union space and that is not part of the list of countries that the EU has already considered to meet adequate levels of protection of personal data. In these cases, the Panela de 3 Pés will ensure that the data transfers are carried out in strict compliance with the applicable legal regulations.

• HOW DOES THE PANELA DE3 PÉS PROTECT YOUR PERSONAL DATA??

Panela de 3 Pés 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 treatment accidental or illicit.

• USEFUL ADVICES FOR THE PROTECTION OF YOUR DATA Panela de 3 Pés websites and third parties

Regarding the use and processing of personal data on Panela de 3 Pés sites, be sure to consult the rules on the use of cookies on the respective sites. The Panela de 3 Pés sites, products or applications may contain links to third-party sites, products or services that are unrelated to the Panela de 3 Pés, or that are not covered by this privacy policy.

The collection or processing of personal data requested by these third parties is their sole responsibility, and Panela de 3 Pés cannot be held responsible, under any circumstances, for the content, accuracy, veracity or legitimacy of these sites, or for the misuse of data collected or processed through them. We alert the Customers and Users of Panela de 3 Pés to this fact and to the need, before using the websites, products or applications, to read and accept the rules regarding the processing of personal data defined by these third parties.

Other advices

Panela de 3 Pés advises prudence in the exposure of your personal data and in the circulation of these data over the internet, acts that are the full responsibility of the Customer, since these data are not fully protected against possible violations, the adoption of complementary security measures, including the maintenance of equipment (PCs, tablets or mobile phones) and softwares properly updated and configured with firewalls and protection against malicious software (e.g., antivirus), not browsing websites of dubious reputation, or for which you do not have the proper guarantees of authenticity, the physical protection of your equipment and avoiding placing access credentials on computers with public access (for example, internet cafes, hotels, etc.) and the use of strong and differentiated keywords depending on each service or site.

Legal information

This privacy policy statement was prepared based on provisions of multiple legislations, including article 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy refers only to Panela de 3 Pés websites, unless otherwise stated in this document.

Information not contained in this policy

Further details on the collection or processing of personal data may be requested to the Owner at any time.

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