If you have any questions, please contact us at [email protected], or at the postal address Rua dos Inventores S/N, Madan Parque 2825-184 Caparica, Portugal.
1. Our commitment to protecting the privacy and personal data
INSVIBLEPIXEL, Ltd. is strongly committed to compliance with the legal obligations arising from the General Data Protection Regulation (GDPR) and other current legislation relating to the protection of personal data, and the treatment of these that it will carry out.
2. General Data Protection Regulation
The new General Data Protection Regulation (GDPR), applicable from 25 May 2018, sets out the rules for the processing of personal data and the free movement of such data. It is mandatory for all organisations, public or private, throughout the European Union.
3. Responsible for the treatment and collection of data in accordance with art.4, nº7 of the RGPD
INVISIBLEPIXEL, holder of the collective entity number nº 513822224, with registered office at Rua dos Inventores S/N, Madan Parque 2825-184 Caparica, Portugal, is the entity responsible for the processing and collection of personal data transferred to it.
4. Concept of personal data
Personal data is information relating to an identified or identifiable person (data subject).
Any person who can be identified directly or indirectly, in particular by reference to an identifier, is considered identifiable. Personal data is also the collection of separate information that can lead to the identification of a particular person.
Examples of personal data are name, address, email address, ID card number, location data, IP address, cookies, telephone number, vehicle registration, physical, physiological, genetic, mental, economic, cultural, or social identity, sound, or image, which can uniquely identify a person.
4.1. Sensitive personal data
The category of sensitive personal data includes racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a person's sex life or sexual orientation.
5. Processing of personal data
The processing of personal data covers all operations, by automated or non-automated means, of collection, recording, organization, storage, adaptation, alteration, consultation, use, disclosure, transmission and/or erasure of information concerning an identified or identifiable natural person.
Regardless of the technology used to process such data, this Policy shall apply to data directly provided by the data subject.
Legitimate processing is, as a rule, provided upon voluntary, explicit, specific, and informed consent of the data subject.
6. When and how we collect personal data
Please note that it is not mandatory to provide personal data even if requested by INVISIBLEPIXEL, Lda, but if you choose not to do so, we may not be able to provide you with our services or answer any questions you may have.
We will collect personal information whenever you send us an enquiry or complete a customer form.
7. What data we collect and process
The personal data collected and processed is determined by the competence of INVISIBLEPIXEL, Lda. as an employer and for the purposes of managing its database, and may relate to:
Subsequently, other relevant data may be collected as necessary to pursue the purpose of the contact between the entity in question and INVISIBLEPIXEL, Lda.
8. Purposes of data processing
In general, INVISIBLEPIXEL, Lda uses your data for the following purposes:
• Sending information;
• Service development and improvement.
When we collect your personal data for the purposes described above or for other purposes, we will inform you in advance or at the time of collection and will seek your consent where this is necessary to legitimize the processing of your data.
9. General principles applicable to the processing of personal data
In terms of general principles regarding the processing of personal data, INVISIBLEPIXEL, Lda. undertakes to ensure that your data is:
• Object of lawful, fair, and transparent treatment;
• Collected for legitimate and explicitly determined purposes and not further processed in a way incompatible with the original purpose;
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and up-to-date whenever necessary, with appropriate measures being taken so that outdated or inaccurate data are immediately updated as soon as possible, deleted, or rectified;
• Kept in a form that permits their identification only for as long as is necessary for the purposes for which the data are processed;
• Processed in a manner that ensures their security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage, and appropriate technical or organizational measures are taken.
The data processing carried out by INVISIBLEPIXEL, Lda. is lawful when at least one of the following situations occurs:
• The data subject has provided their explicit consent to the processing of the data for one or more specific purposes by signing or accepting an online or paper form;
• The processing is necessary for contractual management to which the data subject is party, such as for example, the fulfilment of legal obligations arising from the employment contract;
• The treatment is necessary for compliance with a legal obligation to which INVISIBLEPIXEL, Lda. is subject, such as, for example, the communication of identification data to police, judicial, tax, or regulatory authorities;
• Processing is necessary for reasons of legitimate interest related to the performance of the tasks connected with its area of activity or for the protection of the interests of the data subject or of another natural person.
The data subject is entitled to withdraw his or her consent at any time. The withdrawal of consent, however, does not affect the validity of the treatment carried out by INVISIBLEPIXEL, Lda. based on the consent previously granted.
10. Time of conservation of personal data
Personal data shall be kept for the minimum period necessary to fulfil the purposes for which the information was collected.
11. Technical and Organisational Safety Measures
INVISIBLEPIXEL, Lda. by applying technical and organizational measures in order to ensure the confidentiality and security of your personal data, from misuse, interference, loss, unauthorized access, modification, or disclosure.
Access to your personal data is only allowed as described above, always on a need-to-know basis, and subject to strict contractual confidentiality obligations when processed by third parties.
Although transmission of data via the Internet or website cannot guarantee total security against intrusion, INVISIBLEPIXEL, Lda. provides its best efforts to implement and maintain physical, electronic, and procedural security measures to protect your personal data in compliance with applicable data protection requirements.
12. Transfer of personal data
The data collected by INVISIBLEPIXEL, Ltd. are not shared with third parties without the prior consent of the holder, except in the following situations:
• Public authorities, INVISIBLEPIXEL, Lda. is obliged to disclose personal data to the Social Security, the Authority for Working Conditions, and the Authority for Working Conditions;
• Legal obligations to disclose personal information in order to comply with requests from judicial authorities and/or judicial orders.
The personal data provided to INVISIBLEPIXEL, Lda, necessary within the scope of its duties and powers as an employer, will not be marketed to third parties.
Data subject rights
The holder of personal data has rights to information, access, and rectification or erasure of personal data. They also have the right to data portability and the right to limit or oppose the processing of their data, within the scope and under the terms of the GDPR and other applicable legislation.
13. Right to rectification of personal information
The data subject has the right to request, at any time, the rectification of inaccurate or incomplete personal data about him or her.
14. Right of access to personal data
INVISIBLEPIXEL, Lda. guarantees the means to access your personal data, so you have the right to obtain from INVISIBLEPIXEL, Lda. the following information:
• The purposes of data processing;
• The categories of personal data concerned;
• The recipients or categories of recipients to whom the personal data have been or will be disclosed;
• The retention period of the personal data;
• Request rectification, erasure, or restriction of or objection to the processing of personal data;
• File a complaint with the CNPD (National Commission for Data Protection) or another supervisory authority.
15. Right to erasure of personal data ("Right to be forgotten")
The data subject has the right to demand from INVISIBLEPIXEL, Lda. the erasure of their data when one of the following grounds applies:
• Your data is no longer necessary for the purpose for which it was collected or processed;
• If you withdraw the consent on which the data processing is based;
• If you object to the processing under the right to object and there are no legitimate interests justifying the processing;
• If the data is processed unlawfully.
Under applicable legal terms, INVISIBLEPIXEL, Lda. has no obligation to delete personal data to the extent that the processing is necessary for the performance of a contract to which the data subject is a party or to comply with a legal obligation to which INVISIBLEPIXEL, Lda. is subject or for the purposes of the declaration, exercise, or defence of a right in a legal proceeding.
The data subject may withdraw, at any time, the consent he or she has given for the processing of his or her personal data within the scope of the GDPR. The withdrawal of consent shall not affect the validity of the processing of personal data that has hitherto been carried out based on the consent previously given.
16. Right of portability of personal data
The holder of the data has the right to request and receive personal data concerning him/her that he/she has provided to INVISIBLEPIXEL, Lda. in a structured and easy-to-read format, as well as the right to transmit this data to another controller.
The right of portability does not include personal data that are generated as a consequence or result of the analysis of the processing of the data in question, only those personal data that the data subject has expressly granted.
17. Right to object to the processing
The holder of the data has the right to object at any time to the processing of their personal data that is based on the exercise of the legitimate interests of INVISIBLEPIXEL, Lda or when the processing is carried out for purposes other than those for which the personal data were initially collected.
INVISIBLEPIXEL, Lda will cease processing the data, unless it presents imperative and legitimate reasons for this treatment to prevail over the interests and rights of the holder, such as for the purposes of declaration, exercise, or defence of a right of INVISIBLEPIXEL, Lda in a lawsuit.
18. Right to limitation of the processing of personal data
The holder of the data has the right to obtain, from INVISIBLEPIXEL, Lda, the limitation of the treatment of their data, if one of the following situations applies (limitation consists of inserting a mark in the personal data kept with the aim of limiting its treatment in the future):
• If you contest the accuracy of the personal data, for a period that allows INVISIBLEPIXEL, Lda. to verify its accuracy;
• The processing is unlawful, and the data subject opposes the erasure of the data and requests the restriction of their use instead;
• If INVISIBLEPIXEL, Lda. no longer requires your data for processing purposes, but such data is required by you for the purposes of stating, exercising or defending a right in legal proceedings;
• Where he or she has opposed the processing until it is established that the legitimate reasons of the controller override those of the data subject.
19. Procedure for the exercise of rights
The right of access, the right of rectification, the right of erasure, the right to limitation, the right of portability and the right of opposition may be exercised by contacting INVISIBLEPIXEL, Lda. via email: [email protected], letter or telephone contact:
Rua dos Inventores, S/N, Madan Parque
2825-184 Caparica – Portugal
Telephone contact: 21 043 8600
You also have the right to lodge a complaint with the national supervisory authority: www.cnpd.pt.
21. Applicable law and jurisdiction