PREAMBLE
This Privacy Policy, refered to << Policy >>, pretends to inform you about the following items:
1 – Modulus is a brand of Modulus Premium, Lda.
2 – The commitments adopted by Modulus Premium, Lda. in regards to the protection of personal information, according, following the Regulamentation (UE) 2016/679, about the protection of personal data in regards to the processement of Personal Data and the free circulation of such data. Such commitements are adopted as the base General Data Protection Regulation « GDPR » ; and
3 – About the ways Modulus Premium, Lda. handles your Personal Data, in particular, Personal Information obtained in digital format, namely, via websites, applications or other platforms
1.DEFINITIONS
« Personal Data » – any data related to the owner of the data that allow for such owner to be identified..
« Data Owner » – any singular person, identified, or identifiable to whom the data is related to. The person can be identified, directly or indirectly, namely, by the name, national identification, fiscal identification, locations data, online identifiers (such as; IP and logs). The identification may also take place through factos of physical identity, physiological, genetic, mental, economic, cultural or social. The user of the website, aplication sand other digital platforms, considers itself owner of the The user of the website, applications and digital platforms is considered as Data Holder in relation to in relation to Modulus Premium, Lda. .
« Controller » – internal entity of Modulus Premium, Lda. that defines the objectives and means of the Treatment of Personal Data.
« Subcontractor » – an entity external to Modulus Premium, Lda. which processes the Personal Data on behalf of the Company.
« Processing » – any transaction made in the Personal Data, by means of automatic or not, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, dissemination by transmission, dissemination or, alternatively, harmonization or association, restriction, elimination or destruction. Any other operation contemplated under the terms of the GDPR is also considered to be the Treatment of Personal Data.
2. WHICH COMMITMENTS UNDERTAKEN BY MODULUS PREMIUM, LDA ON THE PROTECTION OF PERSONAL DATA?
Modulus Premium, Lda. Guarantees the complete protection of the Personal Data in accordance with the rules set forth in the GDPR, with respect to all the procedures and obligations therein, especially with respect to the Treatment of Personal Data of the users of the websites, applications and digital platforms (eg visitors, customers, prospects, job seekers, etc.).
2.1. CONFORMITY PROGRAM FOR THE PROTECTION OF PERSONAL DATA
Modulus Premium, Lda. Has developed and implemented tools and procedures to ensure the effective protection of Personal Data.
Modulus Premium, Lda. Has adopted and implemented various internal policies and procedures aimed at raising the awareness of its employees, suppliers and partners on the protection of Personal Data.
2.2. PRINCIPLES OF PROTECTION OF PERSONAL DATA
Processing of Personal Data
Modulus Premium, Lda. Undertakes to treat your Personal Data in accordance with the following principles:
- Your Personal Data is processed legally, impartially and in a transparent manner, thus ensuring the principles of legality, impartiality and transparency;
- Your Personal Data is collected and processed for specific, explicit and legitimate purposes and is not processed differently and is incompatible with the purposes for which it was collected, thus ensuring the principle of limitation of purpose;
- Your Personal Data is collected and maintained appropriate, relevant and limited to what is strictly necessary, taking into account the purposes for which it is processed, thus respecting the principle of data minimization.
- Your Personal Data must be true and, whenever necessary or understood, must be rectified and updated, thus respecting the principle of rigor.
Prcessing Safety
Modulus Premium, Lda. Has defined technical and procedural measures to effectively implement the principles of protection of Personal Data in order to comply with the RGPD, thereby protecting the rights, freedoms and guarantees of the Personal Data Holders from the outset collection and consequent treatment.
3. INFORMATION CONCERNING THE PROCESSING OF PERSONAL DATA BY MODULUS PREMIUM, LDA.
3.1. HOW THE MODULUS PREMIUM, LDA. GET YOUR PERSONAL DATA?
Through the collection carried out in the commercial establishments that it exploits and through its websites, applications and digital platforms in which the user makes available and consents to the respective collection.
Thus, it is possible for Modulus Premium, Lda. To collect your Personal Data through the following means:
- In its commercial establishments;
- When you create a registration / account on one of your websites, applications or digital platforms;
- When you browse Modulus Premium, Lda’s websites, applications or digital platforms (ie, technical information, such as IP addresses or logs, collected through cookies or similar technologies) ;
- When you contact Customer Service by choosing the option to contact you back or when you contact a Modulus Premium customer service team and you consent to the retention of your Personal Information;
- When you subscribe to the loyalty program of Modulus Premium, Lda. ;
- When you subscribe to the “Refer a Friend” program from Modulus Premium, Lda.;
- When you purchase items, products or services online or through a direct representative (example: Vendor, Project Manager);
- When you subscribe to the newsletter provided by Modulus Premium, Lda. ;
- When you participate in a contest, marketing program, test or survey;
- When you apply for a job in the “Join Us” section or on the dedicated recruitment website;
- When you enter comments or images on social network pages owned by Modulus Premium, Lda. ;
- When, in any other way, you sends us information of a personal nature and consents to its storage and treatment;
3.2. WHY DO MODULUS PREMIUM, LDA. DO YOU NEED TO COLLECT YOUR PERSONAL DATA?
Modulus Premium, Lda. Collects your Personal Data for the following purposes:
Recruitment and Human Resources Management
Modulus Premium, Lda. Collects your Personal Data through the “candidate section” of the respective website, in order to analyze and respond to a job application. In the event that there is no action by Modulus Premium regarding the application for employment, Personal Data will be retained in accordance with the provisions of section 3.4. In case of recruitment, the Personal Data will be transferred to the competent Human Resources department in order to be processed for the purpose, in accordance with the above principles and with the Human Resources policies.
Customer Relationship Management
Modulus Premium, Lda. Collects Personal Data relating to business relationships with customers and prospective customers, and particularly:
- To allow you to navigate Modulus Premium’s digital websites, applications, and platforms using your personal online account;
- To enable you to purchase articles, products and services, more specifically, to place orders online on Modulus Premium’s websites, applications and digital platforms;
- To provide you with after-sales services related to your orders or with articles, products and services that you have purchased;
- To obtain your opinion on articles, products and services, in particular through surveys and tests;
- To allow you to participate in contests, questionnaires or other marketing programs;
- To allow you to benefit from your loyalty program;
- To establish statistical analyzes, financial, business and traffic management studies online (eg to obtain levels of use of the website, applications and digital platforms of Modulus Premium, as well as the relevance of the services provided as a way to improve their capacity to use them);
- To send information or promotional communications and advertising to Modulus Premium and / or other companies, in particular about products, campaigns and events that may be of interest to the customer, provided that (subject to prior authorization, when necessary and your right to refuse, in accordance with the legal requirements applicable to direct marketing for commercial purposes).
These notifications can be sent by email or postal mail or through a mobile service (telephone call, SMS and MMS).
Fighting fraud
Your Personal Data will be treated in such a way as to prevent third party fraud situations from occurring.
Personal Data related to your order will be treated in a way that ensures a high level of security in the transaction as a way to prevent identity theft and fraud in making payments. In order to combat fraud, payments made by credit card or any other means may be audited by Modulus Premium through methods of automatically processing the information related to the order. Modulus Premium may transfer your Personal Data to third parties, such as service providers or, when legally required, to public and / or judicial authorities. In case of outstanding balance, suspicion of fraud or attempted fraud, Personal Data will be preserved in an internal file until the situation is regularized. Under these conditions, Modulus Premium may refuse any and all business transactions until the situation is settled. In the verification of situations similar to those described above, the client will be informed individually and will have the possibility to pronounce and prove his identity.
Information deemed mandatory is marked with an asterisk in the online forms available by Modulus Premium, Lda. Without this information, the ordering / ordering of the users can not be processed. The provision of the remaining information is optional.
3.3 LEGAL BASIS OF PROCESSING
The processing operations carried out in relation to the Personal Data of the clients by Modulus Premium, Lda. Are based on:
- In your legitimate interest in delivering sales, protecting your activities, products and services, as well as better identifying your customers preferences as a way to personalize offers and highlight articles, products and / or services that best fit your needs;
- In the need to execute the contracts signed with its customers for the sale of articles, products and / or services;
- When the Treatment is required by the legislation in force; and
- When explicit consent is acquired.
Modulus Premium, Lda. Also has a legitimate interest in conducting recruitment operations to manage its activities in the best possible way. In this sense, Modulus Premium collects all necessary data on interested candidates.
In all cases, it is noted that Modulus Premium, Lda. Treats only Personal Data if,:
- The Holder has given express authorization for the Processing of his Personal Data for one or more specific purposes; or
- Treatment is necessary for the proper execution of a contract in which it is a party;
- Treatment legally enforceable; or
- Treatment is necessary for the fulfillment of the legitimate interests of Modulus Premium, Lda., Except where the interests or rights and fundamental freedoms of the Data Holder are not superimposed on those interests, especially if the Data Holder is a child.
3.4 HOW LONG DOES MODULUS PREMIUM, LDA KEEP YOUR PERSONAL DATA?
Modulus Premium, Lda. Maintains your Personal Data in accordance with the periods of conservation imposed by the legislation and regulations in force, namely taking into account its activities.
Modulus Premium may store your Personal Data for the following periods:
- When you contact us to request information, we will store your personal data for as long as it takes to process and effect your request;
We store your personal data used for direct marketing until you cancel the authorization or request us to dispose of it under applicable law. In such a case, Modulus Premium will only preserve the information necessary to secure your right to object in accordance with regulations and regulations. Applicant-related Personal Data is stored for one year after your last visit to the candidate’s space.
The cookies used by Modulus Premium, Lda. Are stored until you remove them from your browser.
3.5 WHO ARE THE RECEIVERS OF YOUR PERSONAL DATA?
Modulus Premium, Lda. Employees responsible for customer support management, sales and business management and Information Technology can only access your Personal Data by strict necessity.
Likewise, only the services responsible for the recruitment and management of Modulus Premium Human Resources will have full or partial access to the Personal Data related to candidates, by strict necessity.
Modulus Premium, Lda. Does not share your Personal Data with third parties, except for service providers, in accordance with the provisions of section 5, especially for purposes of combating fraud, payment management, hosting, IT administration and customer support. Some of these service providers are located outside the European Economic Area, in particular in the United States.
Modulus Premium, Lda. May also transmit your Personal Information to other entities of the Modulus Premium Group and to its potential service providers for remote access purposes to support information systems, accommodation, etc. which may be located outside the European Economic Area, in particular in the United States.
Modulus Premium, Lda. May transfer Personal Data to third parties in accordance with requests from public judicial authorities with legal powers for this purpose, in accordance with the legal regulations in force.
Modulus Premium, Lda. Guarantees the confidentiality and security of the Personal Data during the transfer to the above mentioned recipients.
Because some countries may not have the same data protection laws as the country from which you initially provided your Personal Data, Modulus Premium guarantees that they are protected according to the most stringent rules in force.
4.ABOUT COOKIES
What are cookies?
Digital websites, applications and platforms may use cookies or similar technologies to enhance your browsing experience. Cookies constitute information stored on your personal equipment on the sites you visit. Sometimes they are stored in a plain text file, accessed by a server that reads and registers the information.
Sites may only read and write cookies held by them.
Our use of cookies
When you browse our websites, we use cookies to “recognize” your browser, only during your visit (“session cookie”) or during all your visits (“permanent cookie”). On our website, cookies are used for the following purposes:
- For technical reasons (identifying sessions, keeping settings or shopping carts, etc.) to, for example, adapt the presentation of the website, application or digital platform to your device;
- For statistical analyzes and effects of online traffic management, for example, to improve the usability of a website, application and digital platform and the relevance of our services;
- To redefine your audience and provide you with marketing content on other websites;
- For geolocation purposes by using specific functions, such as store address recommendations and products available at the nearest point of sale.
Other cookies
Third-party cookies
If authorized in your cookie settings (see the cookie settings section below), third parties (advertising agencies, internet analytics companies, etc.) will set up / read cookies when browsing our website, applications and digital platforms.
The use of these cookies is governed by the privacy policies.
These cookies are used by these companies during the life of cookies to determine and distribute relevant advertising content reflecting their main interests based on their knowledge of their browsing habits on our website, applications and digital platforms.
Social networks
To allow you to share content or comments about our products and / or services, our website, applications and digital platforms may include social networking components (buttons, plug-ins, etc.).
These components are used by social networks to track your browsing habits and will only work if your browser is connected to the social network in question (but you do not have to use the ‘share’ button, for example).
The social networks you use determine the terms governing your use of the information they obtain and Modulus Premium has no control over the use of this information. We recommend that you review their privacy policies, which will specify how they use this data and what you can do to increase the confidentiality of your account.
Shared devices
Since cookies are linked to the device and the browser used, you can not determine the identity of the device user. Therefore, some services and advertising offered on this device may not match your use (the settings / browsing habits of other device users may influence the content you offer).
You can choose the level of confidentiality of your device when deciding who can use it (people authorized to access the device) and change its settings (in particular, the cookie settings).
Cookie settings
You can change your cookie settings at any time by finding several options as described below.
The settings you choose may affect your browsing experience and the operation of some services that require the use of cookies. In this regard, we reject any responsibility for the consequences of the limited operation of our services caused by the deactivation of cookies on your device (inability to define or read a cookie).
Computers (PC)
You can manage cookies through various options in your browser settings, to allow or block cookies, in general or for specific actions, at any time. Cookies are managed differently in each browser.
Visit your browser’s link to learn more:
- Cookie management in Google Chrome:
https://support.google.com/chrome/answer/95647?hl=en - Cookie management in Internet Explorer:
http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11 - Cookie management in Mozilla Firefox:
https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored - Cookie management in Safari:
https://support.apple.com/en-gb/HT201265 - Cookie management in Edge:
https://privacy.microsoft.com/pt-pt/windows-10-microsoft-edge-and-privacy
For all other devices (smartphones, tablets, smart devices), see the help menu in your browser.
Industry-specific platforms
Some industry-specific platforms allow you to manage cookies online. For example, the website YourOnlineChoices is offered by various digital advertising companies (members of the European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau (IAB) France.
For companies registered on this platform, you can enable or disable behavior-based advertising cookies:
http://www.youronlinechoices.com/uk/your-ad-choices
This will not prevent the display of advertising on the site you visit, but will prevent registered companies from collecting and using data for behavioral advertising purposes.
Other Tools
In addition to the above solutions, third-party companies have developed tools (browser plug-ins or add-ons) to manage the collection and use of cookies.
5. SECURITY MEASURES
Modulus Premium, Lda. Has implemented all appropriate technical and organizational measures to ensure a level of security of Personal Data appropriate to the risk and, in particular, to protect Personal Data against destruction, loss, alteration, unauthorized disclosure or accidental access or illegal.
Any employee of Modulus Premium, Lda. Who, during his work, may have access to his Personal Data will keep them strictly confidential.
6. EXERCISE OF YOUR RIGHTS
You may at any time, in accordance with the rules applicable to the protection of Personal Data, exercise your rights to access, rectify, delete and transfer your Personal Data and also your rights of restriction and opposition to the Treatment of Your Data Personal.
You also have the right to object to the Treatment of your Personal Data for the purpose of marketing right and thus to request to stop receiving promotional communications from Modulus Premium and / or other entities of Modulus Premium at any time.
When the Treatment is based on your express authorization, you have the right to revoke your authorization at any time.
To do so, you must submit the request at our counters by e-mail to [email protected] sent with receipt notice or by registered letter and with receipt notice to ‘Modulus Premium – Rua Duarte Pacheco Pereira 5ª, 2795-072 Linda-a-Velha, Portugal.
The request addressed by the client will be evaluated and answered within a maximum period of 30 days.
In order to enable us to respond to your request, you must provide us with the following identifying information: name, surname, email or address and any other information necessary to confirm your identity.
You also have the right to complain to the Supervisory Authority in case of violation of the rules applicable to the protection of Personal Data, in particular the RGPD.
7. PERSONAL DATA OF CHILDREN
Modulus Premium, Lda. Does not pretend to collect personal data of children. If information about a child has been collected by the site without the consent of the holder of the child’s parental responsibility, we inform you that the legal representative of the child may exercise the rights of the child on your behalf. In this case, we ask that you contact us.
8. CHANGES TO OUR PERSONAL DATA PROTECTION POLICY
The Personal Data Protection Policy may be changed by Modulus Premium at any time.
If Modulus Premium, Lda. Intends to adjust the Policy (eg, if Modulus Premium intends to use your Personal Data in a manner other than that stipulated in the Policy in force at the time of data collection), a notice of such changes to a revised version of the current Policy and the revised version will become effective when it is published.
Modulus Premium, Lda. Will publish such changes on the Personal Data Protection Policy page, informing the customer through a message when accessing the website, application or digital platforms.
We remind you that Modulus Premium, Ltd. is committed not to process your personal data in a manner inconsistent with the initial objectives referred to above, except when it complies with current standards.
9. QUESTIONS / CONTACT
For any questions or comments relating to our Policy or how Modulus Premium collects and uses your Personal Data and to exercise your rights in connection with your Personal Data collected, please contact us at [email protected].