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PRIVACY NOTICE

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Privacy Notice

Last Update: December 2023

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This privacy notice provides you with details of how we collect and process your personal data through your use of our website www.pogo-consulting.com.

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By providing us with your data, you warrant to us that you are over 13 years of age.

 

POGOPOHL UNIPESSOAL LDA (“we”, “us”, or “our”) is the data controller and we are responsible for your personal data.

 

If you have any questions regarding the processing of your personal data or interest to exercise your rights, you can reach us at any time via email (see below).

 

Contact details:

 

Full name of legal entity: POGOPOHL - UNIPESSOAL LDA

Email address: hi@pogo-consulting.com

Postal address: Travessa do Cavaco, n. 22, Évora, 7000-681, Portugal

 

1. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual.

 

We may process the following categories of personal data about you:

 

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media, or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance, or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to your communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

  • Customer Data that includes data relating to any request for proposal or contracting of our services such as your name, title, company, phone number, and contact details. We process this data to offer you the services that you requested information about or to provide you the service that you hired. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter such a contract.

 

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our services, to develop them, to grow our business and to decide our marketing strategy.

 

Sensitive Data: We do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

 

Automated decision making: We do not carry out automated decision making or any type of automated profiling.

 

Information about other people: If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

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2. HOW WE COLLECT YOUR PERSONAL DATA

 

We may collect data about you by you providing the data directly to us and it may include:

 

  • When you or your organization seek our services,

  • When you or your organization offer to provide, or provides services to us,

  • When it is provided to us by a third party because you or your data are subject of our services,

  • When you correspond with us by filling in our forms, email, or other electronic means, or in writing or in conversations with us.

 

If you fail to provide personal data: Where we need to collect personal data by law or to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

 

 

3. DISCLOSURES OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below:

 

  • Other companies in our group for the purposes of providing you with our services,

  • Third parties including certain services providers we have retained in connection with the services we provide, such as consultants, experts, business analysts,

  • Service providers who provide needed services to us like IT and system administration services.

 

4. INTERNATIONAL TRANSFERS

 

When we transfer your personal data to other countries, we will use, share, and safeguard that information as described in this Privacy Notice. To provide our services, we may transfer the personal information we collect to countries outside of the EEA which do not provide the same level of data protection as the country in which you reside and are not recognized by the European Commission as providing an adequate level of data protection. We only transfer personal data to these countries when it is necessary for the services we provide you, or it is necessary for the establishment, exercise, or defense of legal claims or subject to safeguards that assure the protection of your personal data, such as European Commission approved Standard Contractual Clauses.

 

For further information, including obtaining a copy of the documents used to protect your information, please contact us via email (see email address on the Contact Details section at the introduction of this Privacy Notice).

 

5. DATA SECURITY

 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.

 

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

 

6. DATA RETENTION

 

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm form unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

 

7. YOUR LEGAL RIGHTS

 

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to

portability of data and (where the lawful ground of processing is consent) to withdraw consent.

 

If you wish to exercise any of the rights set out above, please email us (see email address on the Contact Details section at the introduction of this Privacy Notice).

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to seep up our response.

 

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are base. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

8. THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

9. CHANGES TO OUR PRIVACY NOTICE

 

We reserve the right to update and change this Privacy Notice from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Privacy Notice in the future will be posted on this page, and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.

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