These principles reflect our commitment to transparent communication of the personal data that we process and under what conditions. As part of its business, KUBOO, SA, a public limited company under single registration and VAT number 514 580 321, having its registered office at Rua Diogo Dias, 129, 1º andar, Bairro do Rosário 2750-161 Cascais, with a share capital of €55,707.50 (hereinafter “KUBOO”) collects from its Customers/ Users personal data related to them, whether in person or remotely through its website, ensuring that it is processed in keeping with the rules on protection of privacy arising from Regulation (EU) 2016/679 and other applicable Portuguese legislation.
The collected data correspond to data that is provided by the Customers/ Users on a voluntary and optional basis.
KUBOO collects personal data in order to respond to requests for information by data subjects and also for communication and marketing purposes, with the consent of their holders, thus enabling KUBOO to inform and disclose its products and services, news and other useful information using the contact details provided by the data subjects.
THE ENTITY RESPONSIBLE FOR DATA PROCESSING
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.
WHAT PERSONAL DATA DO WE COLLECT AND PROCESS
Personal data is any information that (regardless of its nature or support), in a direct manner or in combination with other data, can identify a natural person. The personal data collected are the identity, address, profession, e-mail address, telephone, cookies and usage data, which are provided by the Customers/ Users, in particular by filling in forms and through the website. Customers interested in obtaining commercial offers or information about KUBOO and its services may share personal data via the KUBOO website, e-mail addresses or social networks. These data will be used exclusively within the context of the business of KUBOO, which, however, guarantees appropriate levels of security and protection of personal data of the Customers/Users that have adhered to it. To that end several security measures have been adopted to protect personal data against their disclosure, loss, misuse, alteration, or unauthorised access, and against all other unlawful forms of processing.
Subscription of newsletters is optional, free of charge and will take place during the period the subscriber intends, and it is subject to confirmation by email sent to the Customers/ Users as a means of confirming that the request was actually made by the data subject of the personal data transmitted to KUBOO. Access to the website is not subject to collection of personal data or to subscription of newsletters. Furthermore, when emails are sent, statistical data will be collected that allow a better understanding and adaptation of the service to the behaviour of each subscriber. Personal data of minors will not be actively collected, so if you suspect that data of this nature have been unintentionally collected please contact us via email at to the address firstname.lastname@example.org.
HOW WE PROCESS THE PERSONAL DATA
Additionally, the monitoring systems of the web hosting may record user information, such as the browser, make, model, and version, operating system, origin of the visit, date and time of access, IP address, Internet service provider and geographical zone of access. This information will be used for purely statistical purposes and improvement of the users’ experience of the website. For the purposes of monitoring and analysis of the use of our digital channels, we use the following third parties as service providers:
– Google Analytics; a web analysis service provided by Google, which tracks and monitors the traffic of the website, data that may be shared with other Google services. Google may also use the data collected to contextualise and personalise its own advertising network.
PERIOD OF DATA RETENTION
The processing of data by KUBOO will continue as long as necessary for the commercial relationship established with its Customers. Once the commercial relationship ends, the personal data of its customers will be maintained during the mandatory legal periods or until, in accordance with the law, the rights arising therefrom are subject to the statute of limitation.. In any case, on termination of the relationship with customers the data are no longer processed for commercial purposes.
RIGHTS OF THE DATA SUBJECT
Under applicable law, Customers, data subjects, have the following rights:
(a) Information, is the right of Customers to be informed by KUBOO, among other things, about the purpose of the processing of data, to whom they may be communicated, what rights they have and under what conditions they can exercise them, as well as what the data they are obliged to provide;
(b) Access, is the Customers’ right of access to their personal data that they have provided, without restrictions, without excessive delay or expense, as well as knowing any available information as to the source of such data;
(c) Rectification, or the right of Customers to require that their data be accurate and up- to-date, and they may request KUBOO to rectify them;
(d) Cancellation, consists of the right of Customers to demand the removal of their personal data from KUBOO’s records when they cease to be used for the purposes for which the data were collected, without prejudice, however, to retention periods imposed by law;
(e) Opposition, or the right of Customers to contest, upon request and free of charge, the processing of their personal data for direct marketing purposes;
(f) Portability, is the right of Customers to receive the personal information they have provided to KUBOO, in a structured format in general use and automatic reading, and to transmit those data to another data controller.
(g) Restriction of Processing, is the right that Customers have, in certain circumstances, to ask KUBOO to restrict the processing of their data, in particular; a) when they challenge the accuracy of their personal data, during a period enabling KUBOO to check their accuracy; b) if the processing is unlawful and the Customer objects to the erasure of the data, requesting, in consideration thereof, limitation of their use; c) when KUBOO no longer needs the personal data for processing purposes, but those data are requested by the Customer for the purposes of declaration, exercise or defence in legal proceedings;
(h) Complaints to the CNPD consist of the right to submit, without prejudice to any other means of administrative or judicial appeal, a complaint to a supervisory authority, in particular in the Member State of residence, of their workplace or of the place where the infringement was allegedly committed, if the data subjects consider that the processing of the personal data that concerns them violates the General Data Protection Regulation (Regulation (EU) 2016/679) and other applicable Portuguese legislation. In Portugal the supervisory authority is the National Data Protection Commission (“CNPD”).
Customers may exercise any of their rights, including access to their data, or request their correction or elimination, or oppose their processing under the law, via email to the address email@example.com or by letter addressed to KUBOO’s contacts. KUBOO will answer requests within 30 days, except for particularly complex applications. In these cases, KUBOO shall inform the data subjects of the need to extend the period for reply by a further period of no more than 30 days and the respective justification.