1. Who is responsible for the processing of your personal data?
1.1 Your personal data are processed by SMAGRINET PROJECT - this project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 837626. You can contact us via e-mail at firstname.lastname@example.org.
2. What categories of personal data do we process?
2.1 When you fill out the contact form on our Website, or contact us via e-mail, telephone, fax or Social Media Channels, we collect:
• the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
• the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);
• your preferences regarding receiving our e-mail communications, such as newsletters, advertisements, etc;
• electronic identification data, such as IP address;
• publicly available information of your profile on Social Media Channels and any other personal data you choose to provide to us.
2.2 Whenever you leave us your business card or interact with us at fairs and events at which we are present, we may collect:
• the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function (i.e. when such information is provided by you or shown on your business card);
• your image.
3. For what purpose do we use your personal data?
3.1 SMAGRINET PROJECT processes your personal data to provide you in a personalized and efficient way with the information, products and/or services you request via the Website, e-mail, telephone, fax, Social Media Channels and fairs and events.
3.2 SMAGRINET PROJECT processes your personal data to communicate with you as a result of our contact at a trade fair and/or event or as a result of your approach via the Website, e-mail, telephone, fax or one of our Social Media Channels.
3.3 SMAGRINET PROJECT processes your personal data to perform statistical analyses so that we may improve our Website, our products and services or develop new products and services.
3.4 SMAGRINET PROJECT processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities. Your personal data may be transferred upon SMAGRINET PROJECT’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our Social Media Channels or other communication with us.
3.5 SMAGRINET PROJECT may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.
3.7 SMAGRINET PROJECT processes your personal data mentioned under clauses 2.1, 2.2 above for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of SMAGRINET PROJECT and selected partners. SMAGRINET PROJECT will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, newsletters and other advertisements.
4. Why is our processing of your personal data legitimate?
4.1 For the processing of your personal data for the purpose outlined in clause 3.1, we ask for your consent.
4.2 The processing of your personal data for the purpose outlined in clause 3.4 is necessary to allow SMAGRINET PROJECT to comply with its legal obligations.
4.3 The processing of your personal data for the purposes outlined in clauses 3.2, 3.3, 3.6 and 3.7 is necessary for the purpose of the legitimate interests of SMAGRINET PROJECT, which are:
• being able to appropriately respond to your requests for information and other requests;
• communicate your personal data to our partners in the SMAGRINET PROJECT to provide you with adequate information;
• allowing us to defend ourselves in legal proceedings;
• continuous improvements to the Website, our Social Media Channels, products and services to ensure that you have the best experience possible;
• keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;
• safeguarding our commercial and business interests and needs in light of changing market conditions.
• marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.
5. What are our quality assurances?
5.1 SMAGRINET PROJECT does its utmost to process only those personal data which are necessary to achieve the purposes listed under the purpose for processing.
5.2 Your personal data is processed only for as long as necessary for the purposes listed above or up until such time where you withdraw your consent for processing them. SMAGRINET PROJECT will de-identify your personal data when they are no longer necessary for the purposes outlined in the purpose for processing, unless there is:
• an overriding interest of SMAGRINET PROJECT or any other third party in keeping your personal data identifiable;
• a legal or regulatory obligation or a judicial or administrative order that prevents SMAGRINET PROJECT from de-identifying them.
5.3 SMAGRINET PROJECT will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of SMAGRINET PROJECT or its third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed.
6. What are your rights?
6.1 You have the right to request access to all personal data processed by SMAGRINET PROJECT pertaining to you. SMAGRINET PROJECT reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to SMAGRINET PROJECT.
6.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
6.3 You have the right to withdraw your earlier given consent under clause 4.4 for processing your personal data.
6.4 You have the right to request that personal data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by SMAGRINET PROJECT against:
• overriding interests of SMAGRINET PROJECT or any other third party;
• legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that SMAGRINET PROJECT limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings.
6.5 You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
6.6 You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
6.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to email@example.com for all data subject rights matters. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity.
SMAGRINET PROJECT will promptly inform you of having received this request. If the request proves valid, SMAGRINET PROJECT shall notify it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
If you have any complaint regarding the processing of your personal data by SMAGRINET PROJECT, you may always contact SMAGRINET PROJECT via the e-mail address mentioned in the first paragraph of this clause. If you remain unsatisfied with SMAGRINET PROJECT's response, you are free to file a complaint with the competent data protection authority, i.e. the data protection authority of the country where you reside or the Portuguese data protection authority (Comissão Nacional de Proteção de Dados). For more information, visit https://www.cnpd.pt/index.asp.