PRIVACY POLICY

1. IDENTITY AND CONTACT DETAILS OF THE PERSON RESPONSIBLE FOR PROCESSING THE PERSONAL DATA

In compliance with the provisions of the Regulation (EU) Nº 2016/679 concerning the protection of individuals with regard to the processing of personal data and the free circulation of such data (“RGPD”), we inform you that the company “SOLIDCALC, LDA.” (hereinafter referred to as “E-Commerce Connect”) will be the entity responsible for the processing of your personal data.

For the purposes of this privacy policy, the term “users” shall be understood as all those individuals who provide their personal data to E-Commerce Connect through our website www.ecommerceconnect.pt by (i) subscribing to our Newsletter as well as (ii) for us to contact them via the contact form. In this Privacy Policy we provide users the general information about how E-Commerce Connect will use their personal data through the use of our web page, to whom we may communicate them, its storage period or the different rights granted by law to protect their privacy. In the case of requesting or contracting any service offered by E-Commerce Connect through the platform, all applicable privacy information will be included.

Any doubt about the protection of your personal data should be addressed to:

• Contact email address: organizacao@ecommerceconnect.pt

2. PURPOSES AND LEGITIMATION OF THE PROCESSING OF PERSONAL DATA

We shall now indicate the legal basis that allows us to treat the users’ personal data according to the use we are going to give in each case.

• Legitimate interest:

E-Commerce Connect will need to treat the personal data of users who contact us through our web page, to assist them and respond to their questions, doubts or requests, based on legitimate interest.

• Consent for sending Newsletter and commercial information:
  • When a user has asked us to do so, we may use his personal information to send him our Newsletter, through the email address stated by the user.
• In addition, when a user has given us express consent, E-Commerce Connect will use his/her personal data to send him/her commercial communications about our events, promotions or contests; as well as about products and services of other entities of the Group of which we form part, or of third parties (for example, those of our business partners), always related to the sector of electronic commerce, e-retail and SAAS Ecommerce Solutions (among others, human resources services, project incubation and coworking, generation of clients or leads, obtaining financing and internationalization for technological projects).

We may send these communications to you by any means, including automated means.

At any time, if a user does not wish to continue receiving the Newsletter or any kind of commercial communication, it will be enough to indicate so via the link provided for this purpose in each Newsletter, or through an e-mail to organizacao@ecommerceconnect.pt.

• Fulfilment of a contractual relationship:

In those cases where a user contracts a service through our platform, we will need to treat his personal data, as it is essential information to formalize, manage and comply with the contract that he wants to formalize, as well as to provide him with the services he has requested. In that case, the user shall be informed and asked for the necessary consents of the treatments, purposes, addressees, rights and all the extremes required by the current data protection regulations.

• Fulfilment with legal obligations:

There will also be times when we must use users’ personal data to comply with certain legal obligations that apply to us; in these cases, and to the extent possible, we will inform you of this and the rule that imposes it on us.

3. TO WHOM WE MAY PROVIDE THE USERS’ PERSONAL DATA

E-Commerce Connect is the entity legally responsible for the collection, use, conservation and deletion, where appropriate, of the personal data of users. Therefore, as a general rule, they will only be used by us and will not be transferred to any third party.

In addition, in some cases we may also have to facilitate the users’ personal data to those third parties to whom we are legally bound, as for example to Courts and Tribunals or to State Security Forces and Bodies.

However, we would like to inform users that E-Commerce Connect has the cooperation of third-party service providers acting as responsible for treatment, processing personal data in the name and on behalf of E-Commerce Connect.

E-Commerce Connect follows appropriate criteria for the selection of service providers in order to fulfil its data protection obligations and undertakes to subscribe with them the corresponding data processing contract, by means of which it will impose on them, among others, the following obligations: to implement appropriate technical and organizational measures; to process personal data for the purposes agreed upon and solely on the basis of the documented instructions of E-Commerce Connect; and delete or return the data upon completion of the services.

In particular, E-Commerce Connect may contract the provision of services by third-party service providers performing their activity, including, but not limited to, in the following areas: logistics services, legal advice, companies providing technological services, companies providing computer services, providers of instant messaging services, infrastructure management and maintenance of infrastructures and call centre service companies.

4. PERIOD DURING WHICH THE PERSONAL DATA WILL BE PRESERVED OR THE CRITERIA USED TO DETERMINE IT

E-Commerce Connect will retain the personal data provided by users for as long as it is necessary for the purpose for which it was provided. That is to say, during the time that we need to deal with your queries or doubts, or as long as you are subscribed to our Newsletter, or while your authorization to send you possible commercial communications is in force.

After that, E-Commerce Connect shall retain the users’ personal data but duly locked, for the legally established periods, in order to deal with any possible claims that may be made, at the disposal of the competent Public Administrations and Courts and Tribunals, or in order to comply with the legal obligations that may be required of us at any given time. Once these legal deadlines have passed, we will remove them once and for all.

5. USER RIGHTS AT THE LEVEL OF PERSONAL DATA PROTECTION

The user can exercise his rights of access, rectification, deletion, limitation of treatment, opposition and portability of his/her personal data in the terms established in the current legislation. To do so, you can apply directly by sending a request to the email address organizacao@ecommerceconnect.pt, providing a copy of your National Identity Document or equivalent identification document in both cases.

Right	Content
Access	The user shall be able to obtain confirmation as to whether E-Commerce Connect is processing his personal data or not. In such a case, he shall be able to access his personal data.
Rectification	The user shall have the right to request the rectification of his personal data when they are inaccurate.
Deletion	The user may request the deletion of his personal data when, among other reasons, they are no longer necessary for the purposes for which he provided them to us.
Opposition	On certain occasions, mainly when E-Commerce Connect is using your personal data for our legitimate interest, the user may object to the processing of his data. In such a case, and unless for legitimate reasons it is not possible, as otherwise provided (such as, for example, by the exercise or defence of potential claims), we will no longer process your personal data.
Limitation of processing	The user shall have the right to, under certain circumstances, request the limitation of the processing of his personal data.
Portability	The user, in those cases in which the treatment of his personal data is based on the consent or a contractual relationship, shall be able to request portability in order to transmit them to other responsible parties, in a format of common use and mechanical reading.

6. USERS’ RIGHT TO WITHDRAW CONSENT

Without prejudice to the custody and blocking obligation that E-Commerce Connect is legally required to observe in relation to the personal data of our users, the user may withdraw his consent provided to the processing of his personal data. The user shall be able to carry out the foregoing at any time, free of charge, and without this implying any damage or detriment to the possible contractual relationship that may be maintained with E-Commerce Connect.

7. USERS’ RIGHT TO FILE A COMPLAINT WITH THE SUPERVISORY AUTHORITY.

If a user believes that we have not treated his personal data in accordance with the applicable regulations and especially when he has not obtained satisfaction in the exercise of his rights, he can file a complaint with a supervisory authority of the relevant Member State of the European Union. In the case of a user located in Portugal, the latter may submit his claims or complaints to the Comissão Nacional de Proteção de Dados whose website is www.cnpd.pt.

8. ACCURACY OF THE DATA PROVIDED BY THE USER

Users warrants that the information provided is true, accurate, complete and up to date, and shall be liable for any direct or indirect damage or injury that may be caused to E-Commerce Connect or any third party as a result of a breach of such an obligation.

9. CHANGES TO THE PRIVACY POLICY

E-Commerce Connect may update this privacy policy at any time. In such a case, if such update implies a relevant and substantial change in the legal terms and conditions regarding privacy, an updated version of the Privacy Policy will be sent to the user, through the email address that he has provided to us. Also, the user will be able to access the Privacy Policy at any time through our website.