PRIVACY AND COOKIES POLICY
This Site collects some Personal Data from Users.
Owner and Data Controller
Brasfone Lda, EN 125 Sto Rio Seco 200c 8005-540 Faro
Owner contact email: brasfone@brasfone.pt
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; Cookie.
Full details on each type of Personal Data collected are provided in dedicated sections of this privacy policy or by specific explanatory texts displayed prior to Data collection.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.
Unless otherwise specified, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its Services. In cases where this Application specifically states that some Data is not mandatory, Users are free to stop communicating this Data without any consequences for the availability or operation of the Service.
Users who have doubts about which Personal Data are mandatory are invited to contact the Owner.
Any use of cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application will be for the purpose of providing the Services requested by the User, in addition to the other purposes described in this document and in the Cookie Policy , if available.
Users are responsible for any Personal Data of third parties that are obtained, published or shared through this Service (this Application) and confirm that they have the authorization of the third parties to provide the Data to the Owner.
Method and place of data processing
processing method
The Owner will take appropriate security measures to prevent unauthorized access, unauthorized disclosure, alteration or destruction of the Data.
Data processing is carried out using computers and / or enabled IT tools, following organizational procedures and means strictly related to the indicated purposes. In addition to the Owner, in some cases, the Data may be accessed by certain types of persons in charge, involved with the operation of this Service (this Application) (administration, sales, marketing, legal administration of the system) or external persons (such as third-party providers of technical services, postmen, hosting providers, IT companies, communication agencies) appointed, when necessary, as Data Processors by the Owner. The updated list of these parts can be requested from the Owner at any time.
Legal basis for processing
The Owner may process the Personal Data relating to the User if one of the following hypotheses applies:
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Users have given their consent for one or more specific purposes; Note: According to some legislations, the Owner may be allowed to process Personal Data UNTIL the User objects to this (“opt-out”), without having to rely on consent or on any other legal basis below. This however does not apply whenever the processing of Personal Data is subject to European data protection legislation;
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the provision of the Data is necessary for the fulfillment of a contract with the User and/or any pre-contractual obligations of the User;
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the processing is necessary for the fulfillment of a legal obligation to which the Owner is subject;
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the processing is related to a task that is carried out in the public interest or in the exercise of an official authorization in which the Owner is vested;
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the processing is necessary for the purpose of legitimate interests pursued by the Owner or a third party;
In any case, the Owner will gladly collaborate to clarify the legal basis that applies to the processing, and in particular if the provision of Data is a mandatory requirement by force of law or contractual, or a requirement necessary to enter into a contract.
Place
Data is processed at the Owners' headquarters of operation, and in any other places where the parties involved with the processing are located.
Depending on the User's location, data transfers may involve the transfer of User Data to a country other than your own. To find out more about where such transferred Data is processed, Users can check the section containing details on the processing of Personal Data.
Users also have the right to be informed about the legal basis of transfers of Data to countries outside the European Union or to any international organizations governed by public international law or formed by two or more countries, such as the UN, and about the security measures taken by the Owner to protect your Data.
If any such transfers occur, Users can find out more by checking the relevant sections of this document or asking the Owner using the information provided in the contact section.
retention period
Personal Data will be processed and stored for as long as necessary for the purposes for which it was collected.
Therefore:
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Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be kept until such contract has been completely fulfilled.
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Personal Data collected for purposes related to the Owner's legitimate interests will be kept for as long as necessary to fulfill those purposes. Users will be able to obtain specific information about the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to keep the Personal Data for a longer period whenever the User has given his authorization for such processing, as long as such authorization has not been withdrawn. In addition, the Owner may be obliged to keep the Personal Data for a longer period on all occasions when he is obliged to do so for the fulfillment of a legal obligation or in compliance with an order from an authority.
As soon as the retention period expires, the Personal Data will be erased. In this way, the right to access, the right to erase, the right to correct and the right to data portability cannot be required to be fulfilled after the expiry of the conservation period.
Purposes of processing
Data relating to the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Tag management, Statistics and Thermal mapping and session recording.
Users can obtain additional detailed information about such processing purposes and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information about the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Statistics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to track User behavior.
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Google Analytics (Google LLC)
Google Analytics is a web analytics service provided by Google LLC (“Google”). Google uses the collected data to track and examine the use of this service (this Application) to prepare reports on activities and share them with other Google services.
Google may use the collected data to contextualize and personalize ads from its own advertising network.
Personal Data collected: Cookie; Usage data.
Place of Processing: USA – Privacy Policy – opt out. Privacy Shield Participant.
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Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar obeys generic Do Not Track headers. This means that your browser can tell the HotJar script not to collect any of your data. This setting is available in most browsers. Find as option selection information here.
Personal Data collected: Cookie; Usage data.
Place of processing: Malta – Privacy Policy – opt out.
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tag management
This type of service helps the Owner to centrally manage the tags or scripts needed by this Application. As a result, User Data flows through these services and there is the possibility of retaining this Data.
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Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Usage Data.
Place of Processing: USA – Privacy Policy. Privacy Shield Participant.
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Thermal mapping and session recording
Users' rights
Users will be able to exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the rights to do the following:
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Withdraw your consent at any time. Users have the right to withdraw their consent in cases where they have previously given their consent to the processing of their Personal Data.
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Object to the processing of your Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Additional details are provided in the dedicated section below.
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Access your Data. Users have the right to know whether their Data is being processed by the Owner, to obtain disclosures about certain aspects of the processing and to obtain a copy of the Data being processed.
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Check and ask for correction. Users have the right to verify the accuracy of their Data and to ask for it to be updated or corrected.
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Restrict the processing of your Data. Users have the right, under certain circumstances, to restrict the processing of their Data for any purpose other than their storage.
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Have your Personal Data erased or otherwise removed. Users have the right, under certain circumstances, to obtain the deletion of their Owner Data.
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Receive your Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, have it transmitted to another controller without any hindrance. This determination applies subject to the Data being processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party or on pre-contractual obligations of the User.
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File a complaint. Users have the right to lodge a complaint with their competent data protection authority.
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Details on the right to object to processing
In cases where Personal Data are processed for a public interest, in the exercise of an official authorization in which the Owner is invested or for purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a reason related to your particular situation to justify the objection.
Users should be aware, however, that if their Personal Data is processed for direct marketing purposes, they can object to such processing at any time without providing any justification. Users can consult the respective sections of this document.
How to exercise these rights
Any requests to exercise the rights of Users can be directed to the Owner through the contact details provided in this document. These requests may be exercised at no cost and will be attended to by the Owner as soon as possible and in all cases within a period of less than one month.
Additional Information about Data Collection and Processing
legal action
Users' Personal Data may be used for legal purposes by the Owner in court or in the steps leading to possible legal action arising from improper use of this Service (this Application) or related Services.
The User declares to be aware that the Owner may be obliged to disclose Personal Data upon request by government authorities.
Additional information about the User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information about specific services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (system logs) or use other Personal Data (such as IP address) for this purpose.
Information not contained in this policy
More details about the collection or processing of Personal Data can be requested from the Owner, at any time. Please see contact information at the top of this document.
How Do Not Track Me Requests Are Handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services you use honor “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time, by notifying its Users on this page and possibly within this Service this Application and/or – to the extent technically and legally feasible – by sending a notice to the Users through any contact information available to the Owner. It is highly recommended that this page be consulted several times regarding the latest modification described at the bottom.
In case the changes affect the processing activities carried out based on the User's consent, the Owner will collect new consent from the User, where required.
Personal Data (or Data)
Any information that directly, indirectly or in connection with other information – including a personal identification number – allows the identification or identifiability of a natural person.
Usage Data
The information automatically collected through this Application (or third-party services engaged in this Service (this Application)), which may include: IP addresses or domain names of computers used by Users using this Application, URI (Uniform Identifier of Resource), the date and time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code that indicates the status of the response server (positive result, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User, the various details of time per visit (for example, the time spent on each page within the application) and the details of the path followed within the application, with particular reference to the sequence of pages visited and other parameters about the operating system of the User's device and/or IT environment.
User
The person using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refer.
Data Processor (or Data supervisor)
The natural or legal person, public administration, agency or other body that processes the Personal Data on behalf of the Controller as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public administration, agency or other body that, alone or together with others, determines the purposes and means of processing Personal Data, including security measures related to the operation and use of this Service (this Application). The Data Controller, unless otherwise specified, is the Owner of this Service (this Application).
This App
The means by which the User's Personal Data is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this website/application.
European Union (or EU)
Unless otherwise specified, all references made in this document to the European Union include all current member states of the European Union and the European Economic Area.
cookie
Small units of data stored on the User's device.
legal information
This privacy statement has been prepared based on provisions of multiple laws, including Arts. 13/14 of Regulation (EU) 2016/679 (GDPR – General Data Protection Regulation).
This privacy policy applies only to this Application, if not otherwise stated in this document.info