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Privacy Policy

  1. OBJECTIVE

    The main objective of this policy is to establish the rules relating to the processing of personal data carried out by KUBOO, in the legitimate exercise of its activity as a provider of Self-Storage services.

    It can be seen from this that KUBOO complies with the General Data Protection Regulation (GDPR) and the principles contained therein relating to the processing of personal data, as well as with other national and European legislation in force relating to data protection. personal.

  2. PROCESSING MANAGER / DPO (DATA PROTECTION OFFICER)

    The controller is KUBOO to the extent that it is responsible for determining the purposes and means of processing the personal data of its Customers/Users.

    The Processing Manager’s contact details are as follows:
    Address: Rua Nossa Senhora da Conceição, n.º 2, 2790-071 Carnaxide
    Telephone: +351 214.100.145
    E-mail: dpo@kuboo.pt

  3. COMMITMENT

    KUBOO undertakes to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 – General Data Protection Regulation (GDPR) and other applicable legislation on data protection , namely the national legislation that complements the GDPR, and as such to communicate in a transparent manner about the personal data collected and the type of processing it carries out, to protect the security, privacy and confidentiality of personal data, to provide appropriate mechanisms for the exercise of the rights of holders of personal data regarding the same data, to provide security systems designed to prevent the consultation, modification, destruction or addition of personal data by third parties not authorized to do so and that allow the detection of possible misappropriation of information, and organizational measures designed to maintain control of personal data by its holders.

  4. BASIC NATURE CONCEPTS

    Personal Data is any information that, regardless of its nature or support, directly or in combination with other data, allows the identification of a natural person. Therefore, Personal Data Holders are natural persons identified or identifiable, directly or indirectly, through any information that concerns them. Data Processing is an operation or set of operations carried out on personal data by manual or automated means, including, among others, collection, storage, use, copying and transfer. Some personal data are, under the General Data Protection Regulation, considered data of a sensitive nature, that is, they are classified as “Special Category Data”. KUBOO does not handle special category data, also called sensitive data.

  5. PROTECTION OF PERSONAL DATA

    KUBOO considers the protection and confidentiality of personal data to be one of the fundamental pillars in building relationships of trust with its workers, suppliers, business partners, and any other holders of personal rights who otherwise relate to it.

    In this sense, KUBOO has implemented appropriate technical and organizational measures, processes and security systems to protect personal data, in particular access control mechanisms to information systems and personal data and security systems (e.g. firewalls, antivirus).

  6. RIGHTS OF PERSONAL DATA HOLDERS

    The General Data Protection Regulation (GDPR) grants holders of personal data a series of rights that aim to protect their privacy and give them control over the use of their personal data. Below, the holder of personal data processed by KUBOO can find the list of rights conferred on them by law in this capacity, duly accompanied by a brief description of each of them.

    Right of Access (art. 15 of the GDPR), consists of the right of the data subject to obtain confirmation as to whether the personal data concerning him or her, which were provided to KUBOO, are or are not subject to processing, and in case of be, the right to access them and the respective processing conditions;
    Right to Rectification (art. 16 of the GDPR), consists of the data subject’s right to obtain from KUBOO rectification of their personal data that is inaccurate or incomplete;
    Right to Object (art. 21 of the GDPR), consists of the right of the data subject, at any time and for reasons related to their particular situation, to object to the processing of their personal data by KUBOO based on its legitimate interest or third parties;
    Right to Erasure (art. 17 of the GDPR), consists of the right of the data subject to request the erasure of personal data that is no longer necessary for the purpose that motivated its collection and processing, or to withdraw consent for all data personal data if it is the only basis for processing the data;
    Right to Portability (art. 20 of the GDPR), consists of the right of the holder of personal data to receive the personal data provided to KUBOO and the respective processing conditions, in a structured, commonly used and machine-readable format, and/or the right to demand the transmission of this data to another controller;
    Right to Limitation of Processing (art. 18 of the GDPR), consists of the data subject’s right to obtain limitation of data processing in the following situations: (a) if the accuracy of their personal data has been challenged and has done so during a period that allowed KUBOO to verify its accuracy; (b) if the processing of the data is unlawful and you oppose its deletion; (c) if KUBOO no longer needs the personal data for processing purposes, but such data is required by it for the purposes of declaring, exercising or defending a right in legal proceedings; (d) if you have exercised your right to object and during the time period of evaluation by KUBOO;
    Right not to be subject to exclusively automated decisions (art. 22 of the GDPR), consists of the right to request human intervention or contest decisions based on fully automated processing of personal data and which may produce significant effects on your legal or private life spheres , except for exceptions arising from current legislation;
    Right to submit a complaint to the CNPD, consists of the right to submit complaints to the CNPD (National Data Protection Commission), regarding the protection of your personal data and the rights related to them. https://www.cnpd.pt/cidadaos/participacoes/geral/

    Holders of personal data may exercise their rights regarding the protection of personal data identified above and briefly described by contacting KUBOO via email at dpo@kuboo.pt.

    KUBOO will respond to the request to exercise the right/s within 30 (thirty) days. In the case of particularly complex requests, KUBOO will inform the holder of the personal data of the need to extend the response period for a maximum additional period of 60 (sixty) days, which will be duly substantiated, with the reason justifying the extension of the period.

  7. CATEGORIES AND TYPES OF PERSONAL DATA PROCESSED BY KUBOO

    Below is presented the categories and types of personal data we process and the means of collecting personal data.

    Identification Data: First Name, Personal Identification Document Number, Tax Identification Number, Social Security Number, Signature;
    Contact Data: Address, Telephone, Email;
    Biographical Data: Date of Birth, Sex, Nationality, Birthplace;
    Financial Data: Monthly Salary, IBAN and NIB of Bank Account, Debit/Credit Card Number;
    Professional Data: CV, Certificate of Academic Qualifications;
    Opinions and Preferences: Comments on Social Media;
    Website Use: Pages visited, Information about the Equipment Used (e.g. IP address, geographic location, browser used).

    Data Provided by the Data Holder: Provided directly by data subjects (workers, suppliers, customers, business partners), when filling out the quote request form at kuboo.pt, via email, via telephone call, on SEPA direct debit authorization form;
    Data Obtained Through Third Party Entities: IEFP;
    Cookies: Collected through the use of the KUBOO website. For more information about the type of cookies used and the data collected, see the Cookies Policy published on the website kuboo.pt.

  8. HOW DOES KUBOO TREAT PERSONAL DATA?

    The processing of personal data corresponds to the operation or set of operations that are carried out on personal data, namely collection, organization, storage, use, rectification, deletion, consultation, copying and transfer.

    Data processing is carried out physically and/or digitally by KUBOO, intended for analysis, decision-making, management and proof of operations arising from and related to the execution of contracts concluded within the scope of its activity, compliance with legal obligations to which KUBOO and/or Personal Data Holders are obliged, to pursue their legitimate interests, to declare, exercise or defend a right in a judicial proceeding or whenever personal data is requested by courts when acting in the exercise of their jurisdictional function.

    KUBOO only processes personal data based on one of the legal grounds legally contemplated and subject to prior information from the respective holders.

    Data processing is always carried out by KUBOO in a lawful, legitimate, transparent manner and strictly necessary for the specific purposes.

    Consent of Personal Data Holders:
    KUBOO may process personal data for purposes other than those contemplated in the previous paragraph when it obtains due prior consent from the holders, expressed in writing, through informed, free action and for specific purposes from the holder of the personal data.

    Obligation to Provide Personal Data:
    Within the scope of KUBOO’s contractual and commercial relations, it is mandatory and necessary to present and collect certain personal data from workers, suppliers, business partners and any other holders of personal rights who otherwise relate to it, to fulfil obligations contractual, pre-contractual or other measures arising from current legislation.

    In general, if such data is not present and provided, KUBOO will initially have to refuse to conclude a contract that enters into labor, commercial or professional relationships between the parties.

  9. PROCESSING PURPOSES AND LAWFULNESS FUNDAMENTALS

    Below is presented, on the one hand, the purposes of processing, on the other hand, the form used to achieve this purpose and also the legal basis for the intended purposes.

    Budget Presentation: Collection and recording of data from data subjects (Conclusion, Execution and Management of Contract – Pre-contractual Due Diligence);
    Opening a Customer File: Collection and registration of personal data from data subjects, opening a customer file (Conclusion, Execution and Management of Contract);
    Communication if necessary: Collection of personal data from data subjects, communication for administrative or operational reasons (Conclusion Execution and Management of Contract);
    Contact and Complaint Management: Reception, analysis and response to requests for information and complaints from data subjects (Conclusion, Execution and Management of Contract);
    Conclusion of Labor or Commercial Contract: Collection and insertion of personal data necessary to appear in contracts of different natures (Conclusion, Execution and Management of Contract);
    Accounting: Accounting record (Compliance with Legal Obligation);
    Document Archive Management: Storage and Organization of paper documents, in the documentary archive, which constitute mandatory evidence for possible inspection by the Tax Authority or other institutions with supervisory capacity (Compliance with Legal Obligation);
    Provision of Information to Customers: Sending information material of a different nature in the context of the provision of services by KUBOO. Sending proposals to change service conditions subscribed by data subjects (Celebration, Execution and Management of Contract and Legitimate Interest);
    Service Development: Collection and analysis of personal data with a view to developing new services or adapting existing services to meet the specific needs of members (Legitimate Interest);
    Personalization of Website Experience: Use of persistent cookies to record website browser activities and preferences (Prior, Express, Written, Explicit, Informed, Free and Specific Purpose Consent);
    Direct Marketing: Providing information or carrying out campaigns, via telephone, SMS, e-mail, to encourage the use or promote subscription to services (Prior, Express, Written, Explicit, Informed, Free and Specific Purpose Consent).

  10. OTHER FUNDAMENTALS OF LAWFULNESS

    KUBOO will also process personal data whenever necessary in the context of defending the vital interests of the data subject, in the context of declaring, exercising or defending a right in legal proceedings or whenever personal data is requested by courts when acting in the exercise of its judicial function.

  11. PERSONAL DATA PROCESSING RETENTION PERIODS

    KUBOO retains personal data for as long as necessary and as long as the legitimate purposes for which the data is processed based on due legal grounds remain.

    Below, the reasons for conservation are presented in a table, on the one hand and the conservation times on the other.

    Compliance with the Contract: Contract validity period. They are only maintained for periods longer than the term of the contract if it is necessary to ensure rights or duties related to the contract, based on KUBOO’s legitimate interest that underlies it or on consent given by the holder of the personal data;
    Legal, Fiscal or Regulatory Obligation: Legal limitation periods associated with legal, tax or regulatory obligations, or deadlines provided for in special legislation (e.g. 7 years after contractual relationship within the scope of the Money Laundering and Terrorist Financing Prevention Law).

  12. SHARING OF PERSONAL DATA

    Only employees who need the personal data collected to carry out their professional activity have access to them.

    If personal data is communicated to third parties taking into account the basis of their processing, KUBOO will inform the holders of the personal data.

    If it is necessary to use foreign service providers, KUBOO will contractually guarantee that they comply with all legal obligations regarding data protection.

  13. TECHNICAL AND ORGANIZATIONAL MEASURES ADOPTED

    KUBOO has implemented technical and organizational measures to protect the personal data of which it is the Controller. Thus, it keeps IT systems up to date, and has developed procedures that prevent unauthorized access, accidental loss and/or destruction of personal data. It regularly prepares annual training actions, in which the topic of data protection is presented, and of which it forms an integral part.

  14. REVIEW AND CHANGES TO THE PRIVACY POLICY

    KUBOO reserves the right, at any time, to introduce any changes it deems necessary to this privacy policy, in order to better adapt it to best market practices or to legislative or regulatory changes that may arise. The current version of the policy will always be the one printed for consultation at KUBOO headquarters and also on the website kuboo.pt.

    The policy will be reviewed annually or whenever necessary.

    Whenever changes are relevant and substantive, KUBOO will make all appropriate and reasonable efforts, using normal and common channels of communication and contact with data subjects, to bring such changes to its attention.