Privacy Policy

WHO ARE WE?

The Personal Data Protection Act (hereinafter "LPDP") and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, onwards "GDPR") ensure the protection of natural persons with regard to the processing of personal data and the free movement of such data.

This privacy and data protection policy ("Privacy Policy") concerns the processing of personal data performed by SIMPLY B and collected through the website WWW.SIMPLYB.PT

From now on, this website will additionally be referred to as "Platform":

SIMPLY is committed to protecting the personal data ("Personal Data") of its customers and users, hereinafter referred to as "Users" or individually as "User", made available on the Platform, adopting a policy subject to high standards regarding privacy and which is strict ly in maintaining the confidentiality, loyalty and integrity of personal data.

In this context, they have developed the Privacy Policy, which aims to make known to its Users the situations in which they process Personal Data, namely how and why they are collected, to those who disclose, how they protect their privacy when they visit or use the services made available on the Platform, as well as their rights in relation to the processing of Personal Data performed.

The collection and processing of Personal Data made by SIMPLY B comply with the provisions of the legislation of protection of personal data in force, in particular with the GDPR and LPDP.

WHAT IS PERSONAL DATA?

Personal Data means any information of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person. A person who can be identified directly or indirectly, in particular by reference to an identification number or other specific elements of his physical, physiological, psychological, economic, cultural or social identity, shall be considered identifiable.

OTHER IMPORTANT SETTINGS:

Supervisory Authority - an independent public authority established by a Member State of the European Union, with responsibility for monitoring the application of the GDPR and the LPDP, in order to defend the fundamental rights and freedoms of natural persons in relation to the processing and facilitating the free movement of data within the European Union. In Portugal, the supervisory authority is the National Data Protection Commission ("CNPD").

Consent - expression of will, free, specific, informed and explicit, by which the data subject accepts, by means of an unequivocal positive statement or act, that the Personal Data concerning him is processed for a particular purpose.

Data protection officer ( "DPO") - a person or entity appointed to ensure, in an organization, the conformity of the processing of personal data with the GDPR, ensuring efficient communication with the holders of personal data and cooperation with the supervisory authorities concerned.

Controller - natural or legal person, public authority, agency or other body that, individually or in conjunction with others, determines the purposes and means of processing Personal Data.

LPDP - Law No. 58/2019 of 8 August ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 of Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data

GDPR - General Data Protection Regulation (EU) of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data.

Processor - natural or legal person, public authority, agency or other body that treats personal data on behest SIMPLY B, as controller.

Personal Data Holder - identified or identifiable natural person to whom the Personal Data collected on the Platform relates, i.e. the Users of the Platform.

Processing(s) - operation or set of operations carried out on personal data or on sets of personal data, by automated or non-automated means, such as the collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, payment or destruction.

Third-party - natural or legal person, public authority, service or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

SIMPLY B is the Controller of your Personal Data collected through the website, within the framework of the GDPR.

As controller, you reserve the right to subcontract other entities to carry out this processing on your behalf and on your behalf.

1. The PROTECTION OF THE PRIVACY OF PERSONAL DATA IS A COMMITMENT OF SIMPLY B

The protection of the privacy of personal data is a fundamental commitment of SIMPLY B, to the holder of personal data (also, "holder") who uses digital platforms and email marketing management services SIMPLY B. This document serves to explain what personal data we collect, for what purposes we use it, how we treat it, with whom we share it, how long we keep it, as well as how to contact it in order to exercise your rights.

2. DATA PROTECTION OFFICER

The email marketing provider used by SIMPLY B has a Data Protection Officer (EPD) who provides information and advises on treatment-related issues, cooperating with the CNPD (National Data Protection Commission). Access to SIMPLY B's Data Protection Officer can be done by request via porto@simplyb.pt.

3. WHAT KIND OF INFORMATION DOES SIMPLY B COLLECT?

SIMPLY B collects information in two different contexts:

1.Anonymous data is stored while the personal data subject or SIMPLY B management team visits the digital platforms, with the aim of improving their functioning, including the optimization and prioritization of content.

2. Personal data are provided voluntarily by the holder at the time of registration or subscription. These are processed automatically, and the information of the personal data subject is collected in an encrypted and managed way securely, in a data center in Portugal.

4. WHO IS THE HOLDER OF PERSONAL DATA?

The holder of personal data is the natural/legal person to whom the data relates, who uses and/or used the digital platforms and/or web marketing services offered by SIMPLY B via email marketing platform and to which the natural/legal person authorized their data management.

5. Rights of the holder of personal data

SIMPLY B guarantees users, as Personal Data Holders and at any time, the right of access, rectification, updating, limitation, and payment of their Personal Data, the right to opposition and withdrawal of consent, without compromising the lawfulness of the processing carried out under this Consent, as well as the right to the portability of the data :

1. Right to information: SIMPLY B clearly expresses its policy, at the time of account creation and/or registration or in any type of form;

2. Right to access and rectification: you can access and edit your data directly and independently by following the available "edit" link or request such action from the SIMPLY B management team for this purpose;

3. Right to limit or oever the processing of your data: you have in each message the possibility to limit/ocher in the "remove" link;

4. Right to forget:you must request the complete removal of your data by sending an email message to porto@simplyb.pt with your IDENTIFICATION and a removal request.

5. Right to portability: You may request the receipt of personal data that you have provided, in a structured format, commonly used, and automatic reading. You also have the right to request that they be transmitted to another Controller, provided that this is technically possible.

In such cases, SIMPLY B ceases to process personal data unless they have legitimate reasons to perform such Processing, and these prevail over the interests of users.

• Right to withdraw the Consent provided: In cases where the Treatment is based on the legitimacy of the Consent, the User may withdraw it at any time.
• Right to lodge complaints with the supervisory authority: If the User wishes to lodge any complaints regarding matters relating to the Processing of Personal Data, he/she may do so with the National Data Protection Commission, the competent Supervisory Authority in Portugal.

For more information, you should access www.cnpd.pt.

6. Under what CIRCUMSTANCES DO we communicate users' personal data?

SIMPLY B uses other entities to provide certain services. If this provision of services may imply access by these entities to users' personal data. This will be the case for SIMPLY B suppliers or service providers(e.g., entities providing services such as email marketing platforms, consulting professionals and others that may be subcontracted to establish contacts in accordance with the user's consents).

In such cases, SIMPLY B ensures through contracts and clauses for Personal Data Processing that any Subcontracting entity that treats the Personal Data on behalf and on its behalf offers guarantees of proper technical and organizational measures so that the Processing meets the requirements required by the GDPR and LPDP or other law applicable to the matter, ensuring the confidentiality and security of data, including compliance with the rights of Personal Data Subjects.

SIMPLY B may also transmit Users' Personal Data to third parties, where they deem such communications of data as necessary or appropriate (i) in the light of applicable law, (ii) in compliance with legal obligations/court orders, (iii) to respond to requests from public or governmental authorities and other administrative authorities, (iv) when it appears necessary to comply with a legal, regulatory or other obligation, as well as (v) ensure the security of Personal Data Subjects, or otherwise prevent fraudulent conduct.

As a rule, User Personal Data is not transferred to third countries (outside the European Union) and is kept on servers located within the European Union. However, if subcontractors transfer data to third countries, SIMPLY B will implement the necessary and appropriate measures in the light of applicable law to ensure the protection of personal data subject to such transfer, strictly complying with legal provisions.

7. HOW DOES THE WEBSITE AND WEB MARKETING PLATFORM SUBSCRIBED BY SIMPLY B PROCESS DATA?

1. Information we collect

a) Information collected voluntarily in certain parts of our Website or web marketing platform. For example, we may ask for a name, email, mobile phone and/or data that identifies you before the platform in order to register with an authorized account of the company providing SIMPLY B's web marketing services or at the time of subscription/submission of an online form. We may also collect information such as your opinion, occupation and contact when you participate in events, surveys or promotional actions. In these cases you can always choose to add additional information on an optional basis, and we keep a copy of the data provided in these interactions. The personal information we ask for and why we do so will be clearly explained at the time of the request.

b) The information we collect automatically through our website: when you visit our website we automatically collect certain information from the device, which for the purposes of processing is anonymous data. The information we collect may include IPs, operating system, browser type, browser activity and other information related to aspects of the infrastructure used and how it interacts with our services/website. This can be collected in log form or in the form of cookies (see 7.4).

c) The information we collect automatically when sending communications (e.g. email, sms, push, etc.): when you receive a message from us or from the web marketing platform subscribed to by us, we may automatically collect information that allows you to identify your interactions with it. The information we collect may include IPs, operating system, browser type, browser activity and other information related to aspects of the infrastructure used, e.g. mobile operator, time of reception on the phone and terminal type. This can be collected in log form or in the form of cookies (see 7.4).

2. Use of personal information

a) The web marketing platform used by SIMPLY B may use the information it collects for several reasons:

- in the processing of transactions and in the provision of accounts via SIMPLY B

- in response to your requests in order to provide information or access to services when requested by you

- to manage the Website, administration and security systems

- to improve the navigation and content of the platform/website

- to identify problems on SERVERS, networks or IT equipment

- to provide, operationalize, optimize and maintain our services

- to send marketing information, taking into account your preferences -in recruitment processes in case you have applied for a position at SIMPLY B

- in the compilation of statistical data on the use of our services in order to enable a better understanding of visitors' preferences

- to conduct research to develop/improve our products and services

- to customize content on the website and authorized platform

- in the execution of contact or other legal requirements

In addition, we may combine personal information with other information in order to provide better segmentation and personalization of messages sent by the platform or a better browsing experience.

3. Public information and websites of others

a) Social networks and widgets. Our website includes integrations with various social networks, these may collect information such as IP or use cookies(s) in order to enable its correct functioning. We warn that in this case its use is not the responsibility of SIMPLY B, and no privacy measure is guaranteed, given the technical impossibility of controlling third-party services.

b) Blog. We have our own blog and so subject to comments. Any information included in the comments is in the public domain and can be read by anyone with complete freedom. Any personal information you wish to see removed or amended should contact us for that purpose.

c) Websites of others. Our website includes links to other websites, for which we decline any responsibility. We warn that its use is not the responsibility of SIMPLY B, and no privacy measure is guaranteed.

4th Cookies

TSIMPLY B's website records cookies (text files) on the visitor's computer, which are used to account for and personalize the visit. These cookies do not collect personal information and are recorded only for as long as necessary for the purpose for which they are intended. The recording of our cookies on the computer can always be controlled through the visitor's own browser program.

a) On the website and services provided by the web marketing platform subscribed by SIMPLY B we use the following cookies:

- Essential - Without them, some features of our service (e.g. maintaining continuous customer access to your SIMPLY B account) will not be able to work.

- Performance and Features - These cookies are used to improve the performance and functionality of our website but are not essential for their use. However without them some features may become unavailable.

- Personalization and Navigation - These cookies analyze the navigation of visitors in aggregate form so that we can improve it and always present them with the most relevant information and help to understand the reactivity of communications. Typically the collected data is anonymized.

- Advertisers - Help show personalized ads to each visitor. For example, if you came to our site and showed interest in a certain feature, you may later see an ad about that feature on other sites or on your Facebook site.

b) Other tracking technologies

The web marketing platform subscribed to by SIMPLY B uses similar technologies such as pixels ("clear gifs") in order to obtain a unique identifier. These small graphics allow you to recognize that someone has visited/viewed the website or communications sent by us. In addition, from time to time, we may also use technologies such as web beacons or others that help us identify usage/navigation patterns, facilitating performance improvements or creating new features. While it does not have the ability to specifically turn off each of these tracking technologies, in general, they can be switched off by declining the use of cookies, thus hindering their operation.

c) How can I control cookies?

Modern browsers allow the blocking and deletion of installed cookies. Choose your browser and see its instructions (Chrome, Firefox, Safari, etc). For other browsers see their documentation.

8. WHAT SAFETY PROCEDURES GUARANTEE THE PROTECTION OF YOUR DATA?

The email marketing platform subscribed by SIMPLY B is designed in such a way that whenever personal information is collected or used, the data is encrypted through the SSL (Secure Socket Layer) protocol. This technology protects data, including fraudulent interception and as such, minimises the associated risk.

The email marketing service used by SIMPLY B has a Reward Program for the management of bugs and vulnerabilities.
All maintenance/interventions and physical destruction are carried out by employees and managers of the email marketing platform subscribed by TSIMPLY B. The physical Data Center where the storage of the data and services provided is certified with the ISO/IEC 27001 Certificate of Conformity.

9. HOW LONG DOES SIMPLY B TREAT AND RETAIN YOUR PERSONAL DATA?

1. The period of time during which personal data is stored and stored varies according to the purpose for which it is used, the rule being the retention of them only for the period necessary for each purpose. There are, however, legal obligations(e.g., tax) that may require the retention of Personal Data for a longer period of time and, in this case, the data will be kept only for the period necessary to comply with the legal obligation imposed.

The Personal Data collected are processed in strict compliance with applicable legislation, being stored in specific databases, created for this purpose. Such data are stored in a format that allows the identification of the Personal Data Holders.

If the processing is based on consent, SIMPLY B retains the User's Personal Data in accordance with the Consent given and/or until such Consent is revoked.

The law, therefore, determines the retention of the data for a minimum period, namely:

(a) for one year: traffic data, location data for the purpose of investigating, detaining and re-investigating serious crime.

b) for 10 years: the data necessary for information to the Tax Authority.

2. SIMPLY B processes personal data based on the legitimate interest typically for:

a) improve, maintain and develop new technological concepts;

b) ensure the security of our services and website;

c) marketing activities of the company.

SIMPLY B retains your personal data, always in accordance with the law, the guidelines and decisions of the CNPD or, whichever is applicable, until you exercise your right of opposition, right to be forgotten or revoke your consent. However, all legal and contractual obligations that define these periods will always be observable.

10. DOUBTS

To deal with matters related to the protection of personal data, you should contact SIMPLY B by e-mail: PORTO@SIMPLYB.PT