This Privacy Policy sets out how we, Tiago Peres, collect, store and use information about you when you use or interact with our website, tiagoperes.eu (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1 December 2019.
If you have any questions about our Privacy Policy, please contact us by sending an email to me@tiagoperes.eu

Contents

. Our details
. Information we collect when you visit our website
. Information we collect when you contact us
. Disclosure and additional uses of your information
. How long we retain your information
. How we secure your information
. Transfers of your information outside the European Economic Area
. Your rights in relation to your information
. Your right to object to the processing of your information
. Sensitive Personal Information
. Changes to our Privacy Policy
. Additional Information

Our Details

• Data controller

The data controller in respect of our website is Tiago Peres.
You can contact the data controller by sending a message from a specific form or sending an email to me@tiagoperes.eu.
If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

• Web server log information

We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our server is located in Portugal.
Use of website server log information for IT security purposes
Our third party hosting provider stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

• Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies, including essential, functional and analytical cookies. For further information on how we use cookies, please see our cookies policy.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features.

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

• Email

When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, email and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is based in the Portugal.
Emails you send us will be stored inside the European Economic Area.

• Contact form

When you contact us using our contact form, we collect the following information: your name, email address and any information you include in the message field. We also collect your acceptance to allow us to save the data you’re sending through it.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Messages you send us via our contact form will be stored on our web servers in Portugal and also transferred to our email provider’s servers inside the European Economic Area.

• Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider and stored in Portugal.

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

• Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

• Telephone providers (CN),
• Email provider (PT),
• IT service providers (PT),
• Web developers (PT), and
• Hosting provider (PT).

All our service providers are located in Portugal except the mobile phone which comes from a provider in China.

Your information will be shared with these service providers only where necessary to enable us to run our business.

• Disclosure of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of Portugal or if they have been integrated into Portugal’s legal framework (for example in the form of an international agreement which Portugal has signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into Portugal’s legal framework, we have a legitimate interest in complying with these obligations.

• Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to Google Inc.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partners page of Google’s privacy policy
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service and allowing the Google Analytics to work on our website
You can opt out of Google Analytics by installing the browser plugin here

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers

Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Our business partners are located in Europe.

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

• Specific retention periods

Correspondence and enquiries: when you make an enquiry or contact us by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point we will delete your information.

• Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

• Measures taken to secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;and
• verifying the identity of any individual who requests access to information prior to granting them access to information.
  

• Transmission of information to use by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below.

We will also transfer your information outside the EEA or to an international organisation in the unlikely event that we are required to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

• Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers.
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here.

• Contact form

Information you submit via our contact form is stored on our server in Portugal but is also forwarded to our email address and transferred outside the European Economic Area. For more information, please see ‘Email’ immediately above.

• Your rights

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise in our GDPR Privacy Center  or sending an email to me@tiagoperes.eu:

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

• Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

• What is “Sensitive Personal Information“

“Sensitive personal information” is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

• Out policy on Sensitive Personal Information

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

• Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

• Major changes to our Privacy Policy

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

• Children’s privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to me@tiagoperes.eu

• Copyright

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.