Privacy Policy

DATA PROTECTION POLICY

1. BLUG commits to protect your personal information

BLUG is committed to protect your personal data and your privacy. We encourage you to carefully read this Data Protection Policy This Data Protection Policy informs you of our data protection and privacy practices and the way your personal data are collected online and how that data is used by BLUG. This policy will be readily available on our home page and at the bottom of each page of this Website. BLUG strongly supports the fundamental rights to privacy and Data Protection as well as compliance with national and international privacy laws. BLUG commits to maintain confidential any personal data and to strictly limit any disclosure in accordance with applicable local laws and regulations. This policy is applicable to all BLUG Group entities for the collection, processing, use, transmission, transfer and storage of personal data unless a national legislation imposes to some of them specific data protection rules.

2. How do we process your personal information?

BLUG respects the rights of each individual or candidate to have his privacy and personal data protected. BLUG will observe the following principles when processing your personal data: 1. Processing your personal data fairly, lawfully and in a transparent manner; 2. Collecting your personal data for specified, legitimate purposes and not processing further in ways incompatible with those purposes; 3. Collecting your personal data which is relevant to and not excessive for the purposes for which it is collected and used.  We may render personal data anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses; 4. Maintaining your personal data accurate, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete; 5. Keeping your personal data only as long as it is necessary for the purposes for which it was collected and processed; 6. Processing your personal data in accordance with the individual’s legal rights; 7. Taking appropriate technical and organizational security measures to keep your data safe and prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal data; 8. Processing your personal data only if it is lawful in accordance with a legal basisi including if you have unambiguously given your consent to such process.

3. Why do we collect your personal information?

BLUG may collect personal data from you to complete following operations: •  profile creation; •  information requests; •  subscriptions to newsletters and sending those letters; •  job applications.

4. What data is collected?

BLUG collects and uses your personal data with appropriate notice and consent when it is required, and after having informed you in a proper way. Personal data means any information relating to an identified or identifiable natural person (‘Data subject’). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This Policy does not cover personal data rendered anonymous. Personal data is rendered anonymous if individual persons are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or work. If personal data rendered anonymous become no longer anonymous (i.e., individual persons are again identifiable), or if pseudonyms are used and allow identification of individual persons, then this Policy will again apply. It is always up to you whether to pass personal data on us, although if you elect not to do so, we reserve the right not to register you as a user or not to provide you with any services. The types of personal data we collect from you may include: • your name, surname, age, company, email address, phone number; • educational and employment background, and job interest data (for candidates); • your BLUG user ID and password (where applicable); • IP address.

5. How  we use your data?

We gather and use personal data for the following purposes: Browsing and Searching: We collect certain personal data when you visit the website or click on the various links for services. We collect those data to improve your web user experience for your next visits (ex: country selection, language), to help run the sites more efficiently, to gather broad demographic information, to monitor the level of activity on the websites, and to evaluate the effectiveness of our advertising. See also our Cookies Policy for our use of cookies.   Newsletters and promotional e-mails: We collect personal data when you ask to receive newsletters. We use those data to provide you the information you request.   Contact information: If you contact us, we keep a record of your correspondence or comments, including personal data, in a file specific to you. We use these data to help us provide you better service in the event you contact us again.   Recruitment: we process personal information of candidates to manage the recruitment process . We’ll keep your personal data for the duration needed to complete the purpose for which they were collected.

6. What do we do with your Personal data?

If you do disclose personal data to us, directly or not, we will: • not sell or rent it to a third party without your permission

• take commercially reasonable precautions to protect the personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction;
• not process the personal data except:> in the aggregate with other data in such a way so that your identity cannot reasonably be determined (for example, statistical compilations); > as required by law, for example, in response to a subpoena or search warrant; > to outside auditors who have agreed to keep the data confidential; > as necessary to protect the rights, safety, or property of BLUG, its users, or others; this may include (for example) exchanging information with other organizations or public authorities for identification, fraud protection and/or risk reduction.

7. Your consent

By providing us with your personal data and/or using the websites and/or entering into a contract with us, you consent to our processing your personal data for the purposes described in article 3. You also consent to our transferring your personal data to countries or jurisdictions which do not provide the same level of data protection as the EU, if necessary for the above purposes. If we do make such a transfer, we will provide appropriate safeguards to ensure that your personal data is duly protected. If you provide us with personal data about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal data including sensitive personal data and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed. We do not process personal data of minors under 16 without the express consent of their parents or legal representatives.

8. Links to third-party websites

BLUG websites or services may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the BLUG website. BLUG does not control those third-party websites or their privacy practices, which may differ from BLUG practices. We do not endorse or make any representations about third-party websites. The personal data you choose to provide to or that is collected by these third parties are not covered by the BLUG Data Protection Policy. We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your personal data.   We may also provide social media links that enable you to share data with your social networks and to interact with BLUG on various social media sites. Your use of these links may result in the collection or sharing of data about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the data that may be collected, used, and shared by those sites.   If you post, comment, indicate interest, or share personal data, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal data you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor BLUG have control over. BLUG is not responsible for the personal data you choose to submit in these forums   9. Your Data protection rights

• Right of access

As data subjects you may inquire as to the nature of the personal data BLUG owned about you. You will be provided access to your personal data regardless of the location of the data processing and storage.

• Right to rectification

If your personal data is inaccurate or incomplete, you may request that the data be amended.

• Right to object

You have the right to object at any time to the processing of your personal by BLUG.

• Right to erasure

You can ask for the deletion of your personal data when it is allowed by applicable data protection laws and regulations.

• Right to restriction of processing

You have the right to require a restriction of the processing of your personal data when it is authorized by applicable data protection laws and regulations.

• Right to data portability

If you meet the conditions settled by the applicable data protection laws and regulation, you   have the right to receive a subset of your personal data and to transmit them from BLUG to another data controller. You can also require the direct transmission from BLUG to another controller when it is technically feasible.

• Right to lodge a complaint

You have the right to lodge complaint with the competent supervisory authority. All requests for aforementioned rights may be sent to the contact name available on each BLUG website.   All requests and any questions regarding this Data Protection Policy may be sent to the BLUG Data Protection Officer at lourenco@blug-group.com or by post mail at: BLUG Data Protection Officer BLUG Group, Rua Diogo do Couto, 1 – 9º Fte  1100-194 Lisbon . Portugal.

12. Change in this Data Protection Policy

BLUG reserves the right to modify this privacy statement as needed, for example, to comply with changes in laws, regulations, BLUG practices and procedures, or requirements imposed by data protection authorities.   In this case, BLUG will inform BLUG candidates and other persons of any material changes in this policy. BLUG will post all changes on relevant internal and external websites.   Last update: June 15th, 2020.

LEGAL NOTICES AND TERMS OF USE

Information regarding the company operating the Website

We inform you that the website www.blug-group.com (the “Website”) is operated by BLUG LDA (NIPC 505494906) Rua Diogo Couto, 1 – 9º Fte – 1100-194 Lisboa – Portugal – Tel. 213918120. You may obtain further information on BLUG in the section “Who we are” and “What we do” of the Website or by sending an e-mail to the following e-mail address lourenco@blug-group.com. “You” and “Your” means you as the user of our Website.

The Publication Director of the Website is Mr. Lourenço Lucena, Chief Executive Officer.

We have set out the terms under which we are providing You with access to our Website. These include the terms and conditions that govern: • Your use of the Website (including Your rights to link to the Website) as set out in these (the “Terms of Use”); • Our use of cookies on the Website (see our separate “Cookies Policy”; and • How we will use and protect information about You (see our separate “Privacy Policy”).

Collectively these documents are termed as the “Terms and Conditions”.

Use of this website

The access to and use of the Website implies Your full acceptance and undertaking to abide entirely by You the Terms and Conditions.

You should read all the Terms and Conditions prior to using the Website. You should also save and/or print out a copy of these Terms and Conditions for future reference. However, please note that we may change our Terms and Conditions from time to time, therefore we recommend You reading the Terms and Conditions each time You access the Website.

The revised Terms and Conditions will be available via the Website. You will be deemed to have accepted any changes to the Terms and Conditions after You have been notified of the changes on our Website home page and You continue to access or use the Website.

You are not permitted to use, or cause others to use, any automated system or software to extract content or data from our Website for commercial purposes. If You do not agree to these Terms and Conditions, You should not use the Website.

Access to our Website is permitted on a temporary basis. We update our Website regularly and so may change the content at any time without notice to You. We reserve the right to withdraw, vary or suspend the service at any time without notice.

You are responsible for making all arrangements necessary to access this Website. You are also responsible for ensuring that all persons accessing our Website through Your internet connection are aware of these Terms and Conditions.

Please note that use of our Website is subject to Your computer and/or portable device complying with our minimum standard technical specification and compatibility notice. You are advised to check this specification to ensure that Your computer and/or portable device is compatible with our products and services and we shall not be liable for any failure arising in the Website which arises from incompatibility (including, without limitation, minimum storage and memory requirements from time to time).

You agree not to use the Website for fraudulent purposes, and not to perform any conduct that may damage the image, interests and rights of BLUG Group or third parties. You also agree not to take any action in order to damage, disable or overburden the Website, or hinder, in any way, the normal use and operation. We inform You that in the event of breach of the contents of this Terms and Conditions, Privacy Policy or Cookies Policy, we reserve the right to limit, suspend or terminate Your access to the Website, taking any technical measures necessary for that purpose.

Reliance on information posted

Materials posted on our Website are not intended as advice and should not be relied upon as such. We therefore disclaim all liability and responsibility arising from any reliance placed on such information to the fullest extent permissible by local law.

Intellectual and Industrial property

All intellectual and industrial property rights over all the information, images, our logo, service marks, trading names, trademarks, and other content displayed on the Website, its designs, graphics and source codes (“Materials”) are either owned by BLUG Lda or licensed to us by our licensors and Your use of the Website and Materials is subject to the following restrictions.

You may access, view and print out one copy of this Website and all Materials strictly in accordance with the Terms and Conditions. In this regard, You may only view, print out, use, quote from and cite the Website and the Materials for Your own personal, non-commercial use and on the condition that You give appropriate acknowledgement where appropriate to us.

You shall comply with the Portuguese Intellectual Property Code

The use of the Website by You does not imply the assignment of any intellectual and/or industrial property right over the Website and/or the Materials. To such effects, under this Terms and Conditions, it is expressly prohibited for the User, except in those events in which this is permitted by law or prior authorization has been granted by BLUG Group, to: • Remove any copyright or other proprietary notices contained in the Materials; • Use any Materials from the Website in any manner that may infringe any copyright, intellectual property right or proprietary right of us or any third parties; or • Reproduce, modify, display, perform, publish, distribute, disseminate, broadcast, frame, communicate to the public or circulate to any third party or exploit this Website and/or the Materials for any commercial purpose, without our prior written consent.

COOKIE POLICY

When you visit our website www.blug-group.com some cookies or other tracking technologies may be stored on your device (computer, tablet or smartphone). This Cookie Policy contains information on what cookies are, the type of cookies used by BLUG on the website www.blug-group.com and the purpose of such use, and your choices regarding cookies. This Cookie Policy should be read together with BLUG Data Protection Policy and BLUG Legal Notice and Terms of Use.

WHAT ARE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Cookies are small text files which contain an amount of data generated when you browse on a website, and installed in your internet browser. The other tracking technologies, such as web beacons, pixels or clear gifs, work similarly to cookies. Cookies and other tracking technologies are used to monitor your activity on a website by enabling us (through first party cookies) or thirds (through third party cookies) to collect information about how you use the website and enhance the way it works and your visit on our website.

There are two types of cookies: session cookies and persistent cookies.

• Session cookies are temporary and therefore automatically deleted from your device every time you close your browser; • Persistent cookies remain on your device for a period of time specified in the cookie and are activated every time you visit the website which installed it.

WHAT TYPE OF COOKIES DO WE USE AND FOR WHICH PURPOSE?

When you browse on our website, we use the following types of cookies:

1. Strictly necessary cookies

These cookies are necessary for the proper operation of the services provided on the website. They are used to provide the basic functionalities of the website, like remembering information entered in a form or allowing you to access your personal account. If you disable these cookies, you will no longer be able to use these features and the website might not work as efficiently as it should.

2. Performance cookies

These cookies are used to collect anonymous data for statistical purposes. They allow us to measure the audience on the website and analyze the way visitors browse the website (number of visitors on the website, number of visits per page, time spent on each page, areas where there are clicks, measure of the effectiveness of advertising…).

They are also used to detect browser issues or any other difficulty. These cookies help us improve our website and make your browsing experience better.

3. Third-party cookies

In some cases, we use third parties to manage our cookies. Third parties may also use their own cookies or other tracking technologies to collect information about your activity on the website, in particular to provide you with personalized advertisements on their own websites. Some social network cookies might also be installed on your device to allow you to interact on social networks, such as Facebook or Twitter. We are in no way involved on the implementation and functioning of such cookies and have no access or control overs such third-party cookies. These cookies are subject to their own cookie policies, which are accessible on each third-party website and to which we invite you to refer to. We are therefore not responsible for the data collected by these cookies and cannot provide you with further information regarding the nature of information collected by these third-party cookies.

 

YOUR CHOICE REGARDING COOKIES

You have several options to control or limit how we or third parties use cookies:

• You can choose to delete all or some cookies from your device through your browser settings; • You can choose to prevent cookies from being installed on your device through your browser settings.

To learn more on how to manage cookies usage from your browser, please follow the following links for each browser: • Internet Explorer • Chrome • Safari • Mozilla Firefox • Opera

Please note that if you choose to block or de-activate some or all cookies we use, our website might not work properly, and you might not be able to enjoy all the services and functionalities provided through the use of cookies.

If you want to learn more about cookies and how to manage them, please visit the following websites: www.youronlinechoices.eu and www.allaboutcookies.org.

You may also modify the cookies on this website on the Cookies settings page.

CONTACT US

If you have any question, comment or concern regarding this Cookie Policy and the way BLUG uses cookies and other tracking technologies, please contact us at:

BLUG GROUP Rua FDiogo Couto, 1 – 9º Fte

1100-194 Lisboa PORTUGAL

Or send us an email at: lourenco@blug-group.com