IMAGINE Portugal is aware of the implications and its responsibility to comply with the changes made in the field of personal data protection, in particular in effect from 25 May 2018 in accordance with the General Data Protection Regulation, approved by Regulation ( EU) 2016/679 of 26 April 2016.

IMAGINE Portugal is therefore committed to ensuring the protection of all personal data made available. Accordingly, it has adopted various security measures, both technical and organizational, in order to protect personal data against any form of illicit treatment.

IMAGINE Portugal is also committed to continually improving procedures and techniques implemented to protect personal data, considering and relying on all suggestions made by site users.

This Privacy Policy applies only to IMAGINE Portugal treatment of personal data collected through its website or commercial and promotional actions.
 

1. Purpose of treatment:
Personal data is only collected for the following purposes:

• Reply to contact request from customers or potential customers;

• Commercial management;

• Contract execution and billing

• Improvement or customization of our services;

• Sending of newsletters and other promotional actions. Customers can cancel email newsletter service subscription by clicking on the newsletter link we send by email.

 

2. Personal data collected:
The data collected is limited to name, email address and telephone number, Tax ID, address, city, zip code, country, and will be used for the purposes provided in this policy, and can be obtained from:

• Website contact form;

• Collected in-person.

 

3. Consent:
Prior to sending the first promotional message or newsletter, subscriber will be required and must express consent to such messages.

This consent will be requested via email and the subscriber will only receive messages if they respond positively. If the answer is negative, data will be deleted.
 

4. Conservation Period:
The personal data collected will be kept as long as the authorization for such exists, in the situations where personal data requires authorization. All other personal data will be kept as long as the conservation period is legally binding or necessary to carry out the contract.

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5. Rights of holders:
In accordance with current legislation on the protection of personal data, we inform that the data subject is guaranteed:

- Right to be informed:

• When collecting personal data:

            a. Contact details of the controller
            b. Of treatment purposes
            c. Conservation time limit
            d. Your rights as holders of personal data
            e. Access to supervisory authority to forward a complaint (and its contacts)
            f. Information on (possible) existence of automated and/or profiling decisions. 

• Ask what information IMAGINE Portugal has about them and why;

• Knowledge of data storage and how the data is processed;

• Be informed of how IMAGINE Portugal fulfills its data protection obligations.

 

- Right of access:

• Confirmation of whether or not your personal data is processed;

• Inquiry on how to access your data;

• Provision of a copy of the personal data processed, preferably in exportable format.

 

- Right to correct, delete and block:

• Be informed on how to keep data updated;

• Obtain rectification of outdated, incorrect or incomplete data;

• Deletion possibility  of unnecessary personal data for the purpose;

• Block processing of this data to verify accuracy or opposition.

 

- Right to limitation:

• Question accuracy of personal data, during a period, allowing the controller to verify its precision.

 

- Right to removal 

• Removal request of your data and permanent elimination of data that does not conflict with legal obligations.

 

- Right to Portability:

• Request portability of your data;

• Possibility of requesting your personal data in a commonly used, or frequently used, format in order to operate the transfer to another organization, even if a competitor.

 

Exercise of rights by holders can be done through the email address imaginejewellery.socialmedia@gmail.com

6. Third Party Entities:
In general, personal data collected on the IMAGINE Portugal website is not transferred to third parties unless in compliance with a legal obligation.

If data is transmitted to third parties, IMAGINE Portugal retains joint responsibility with subcontractors for the processing of personal data in a fair, lawful and transparent manner. The subcontractor may only process personal data in accordance with the instructions set by IMAGINE Portugal and always in strict compliance with the law and the purposes entrusted under contract.

The transmission of personal data to subcontractors will only be carried out within the framework of contractually established relationships with IMAGINE Portugal and only and when justifiable.

In order to ensure the confidentiality and security of data, IMAGINE Portugal will take legally foreseen measures to ensure that the subcontractor offers sufficient guarantees to protect personal data. IMAGINE Portugal will ensure that the subcontractors are a reputable entity, guaranteeing the necessary technical and organizational data to protect personal data against accidental or unlawful destruction, accidental loss, alteration, diffusion or unauthorized access, as well as, against any other form of unlawful processing, agreed upon by contract formalization between IMAGINE Portugal and the subcontractor. The subcontractor will undertake to act only upon the instructions of IMAGINE Portugal regarding the processing of personal data.

IMAGINE Portugal subcontractors will only process personal data for the purposes defined and agreed between the parties, and shall ensure that data retention, when necessary and applicable, meeting the deadlines set by law and/or by contractually.

Upon collection of data, personal data holders should be informed of possible sharing with IMAGINE Portugal subcontractors, with identification of the organization, their contact, and the purpose of such sharing.

When data is transferred to a IMAGINE Portugal subcontractor in a non-EU third country, they must maintain a level of data protection equivalent to the protection enforced by European legislation, in particular, that provided for in Regulation ( EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

In the case of international data transfers, at least one of the following procedures must be followed:

• Individual contract or standard contractual clauses adopted directly by the European Commission or a supervisory authority;

• Subcontractor's participation in a system or standard of recognized certification by the EU to ensure an adequate level of protection;

• Recognition that the subcontractor's binding corporate rules guarantee an adequate level of data protection, issued by the supervisory authorities.

• Existence of an adequacy decision concerning the third country, territory or sector specific to that third country, or concerning the international organization concerned.

 

The rules for cross-border data transfers will not apply when occasional transactions necessary to execute a contract, or in the context of litigation (judicial, administrative, or in terms with regulatory entities or the like) are concerned.

7. Principles, Security and Rights:
The following are internal security and privacy rules:

• Process data lawfully and fairly, gathering only the information necessary and relevant to its intended purpose;

• Do not use the data collected for an incompatible purpose with the collection;

• Ensure express consent of the data holder whenever required;

• Guarantee data deletion right when requested by the holder, free of charge;

• Have security systems that prevent consultation, modification or destruction of data by an unauthorized person and that detect intentional or unintentional deviation of information.

 

8. Links to Partner Sites
The IMAGINE Portugal site may contain links to third parties/partner sites. The referred sites are not under Company control and as such IMAGINE Portugal is not responsible for the content of any these sites. When accessing other websites, IMAGINE Portugal website users are recommended to refer to pages within those websites that refer to their privacy policies.
 

9. Cookies:
When browsing the IMAGINE Portugal website, the cookies used do not collect identifying information. General information is collected, namely on how users reach and use the sites. The information collected is used for the purpose of tracking the number of visits and statistical studies, as well as to ensure that the site works correctly, facilitates navigation and improves user experience.

The use of cookies allows the browsing of the website to be constantly optimized, providing a high quality experience that will exceed the quality of the previous visit by the user. You can consult our Cookie Policy here.
 

10. Amendment of Privacy Terms and Conditions:
This Privacy Policy may be subject to change or revision, without prior notice, due to legislative or regulatory requirements in accordance with applicable law.
Since this Privacy Policy may be revised at any time, IMAGINE Portugal recommends its users to review them periodically.
 

Version: 1.0 (20/12/2019)