1. What is personal data?

Personal data is any information, of any nature and in any medium, concerning an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, for example by name, identification number, location data, electronic identifier or other elements that allow the identification of that natural person.

The privacy and protection of the personal data of all customers and users of the services provided by Neovictus Lda. at all times is an essential aspect of the way Neovictus Lda. operates and organises itself.

The Privacy Policy of Neovictus Lda. aims to ensure that all its Customers are aware, at all times, of the rules and principles regarding the protection and treatment of personal data, Neovictus Lda. developing all possible efforts to ensure the security of such data, in accordance with the standards and procedures defined in the applicable legislation.

In the online media of Neovictus Lda. you may find links to other websites which are external to Neovictus Lda. The provision of such links is made in good faith and Neovictus Lda. cannot be held responsible for the collection and processing of personal data carried out on these websites, nor can Neovictus Lda. be held responsible for the accuracy, credibility and functionality of websites belonging to third parties. Thus, the provision of links to other Neovictus Lda. websites does not imply any assumption of liability in relation to the same.

Neovictus Lda. also recommends that its Customers adopt complementary security measures, including the maintenance of equipment and programs properly updated and configured, the use of protection against malicious software and firewall and that they abstain from navigating in websites in relation to which they do not have the proper guarantees of authenticity.

This Privacy Policy may be amended or revised at any time and any such amendments or revisions shall be appropriately posted and communicated on Neovictus Lda.

Who are the data subjects of the personal data?

The Customer or User, a natural person, to whom the data pertains and who has used the services or products of Neovictus Lda. The Customer shall be the person who enters into the contract with Neovictus Lda. and the User is the person who uses the services or products of Neovictus Lda.

  1. Who oversees the treatment of your personal data?

The controller of your personal data will be the Neovictus Lda. entity that provides you the service or supplies the product and, in that scope, decides which data to collect, means of processing and purposes for which the data will be used.

  1. These are the circumstances in which we handle your personal data:

– Consent

When your express consent is obtained – in writing, or by validating an option on an electronic form and if that consent is free, informed, specific and unambiguous.

– Minors’ consent

In case of processing personal data of minors, who may be subject to consent, Neovictus Lda. will require that consent is provided by the holders of parental responsibilities.

– Contract performance and pre-contractual steps

Where the processing of personal data is necessary for the conclusion, execution and management of the contract concluded with Neovictus Lda., such as for the preparation of a proposal for services, for the management of contacts, information and requests, for the management of invoicing, collection and payments.

Compliance with legal obligation

Where the processing of personal data is necessary to comply with a legal obligation to which Neovictus Lda. is subject.

  1. For what purposes do we process your Personal Data?

– Marketing and Sales

– Customer and Service Management

– Accounting, Fiscal and Administrative Management

– Compliance with legal obligations

Neovictus Lda. may, in the course of its activity and within the scope of the Services it provides, subcontract third parties for the pursuit of the above-mentioned purposes, which may imply the access by these entities to personal data of its Customers. When this happens, Neovictus Lda. takes the appropriate measures so that the entities that will have access to the data offer the highest technical, organizational and human guarantees at that level. Thus, Neovictus Lda. subcontractors shall be obliged, as provided by law as well as by contract signed with Neovictus Lda., to put in place appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, dissemination, alteration, disclosure, unauthorized access and against any other form of unlawful treatment, as well as being bound to special duties of professional secrecy and confidentiality.

Outside those cases, Neovictus Lda. will only transmit the personal data of its Customers to Third Parties, when:

(a) it is obliged to do so by force of legal provision and only to the strict extent of its obligations;

  1. b) if the Customer expressly and specifically authorizes such transmission and is duly informed, in writing, about the recipients of the personal data and the purposes of the data transmitted.

What are the terms of treatment and conservation of personal data?

Neovictus Lda. processes and keeps your personal data according to the purposes for which they are processed.

There are cases in which the law obliges the treatment and conservation of the data for a minimum period of time. But whenever there is no specific legal obligation, then the data will be treated only for the period necessary for the fulfilment of the purposes that motivated their collection and preservation and always in accordance with the law, the guidelines and decisions of the CNPD.

Thus, Neovictus Lda. will treat and keep your personal data for as long as it maintains a contractual relationship with you.

Neovictus Lda. may keep personal data for periods longer than the duration of the contractual relationship, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that justify it, but always for the period strictly necessary for the realization of the respective purposes and in accordance with the guidelines and decisions of the CNPD.

  1. Collection of personal data

We collect personal data upon your consent when you purchase products or services from Neovictus Lda. The collection may be done orally, in writing or via Neovictus Lda.’s online media.

Although your personal information may also be collected from publicly available sources or other sources.

Neovictus Lda. only collects and processes Customers’ personal data with their express consent, according to each of the specific purposes of the processing concerned, as provided for in the General Data Protection Regulation (whose execution in the Portuguese legal system is ensured by Law no. 58/2019, of 8 August).

The consent provided by Customers may be withdrawn by them at any time.

There are, however, personal data which are indispensable for the provision of the Services by Neovictus Lda. and the Customers shall be duly and previously informed of this necessity and of the consequences of not providing said data.

If the personal data, considered indispensable, are not provided by the Customers or prove to be insufficient, incorrect or out of date, Neovictus Lda. shall not be able to provide the Service(s) contracted, in which case the Customers shall assume full and exclusive responsibility for the insufficiency or inaccuracy of the data transmitted.

  1. What are your rights?

Right of access

Right to obtain confirmation as to which of your personal data are being processed and information about them, such as the purposes for which they are being processed, their retention periods, among others.

Right of rectification

Right to request that your personal data that is inaccurate be rectified or to request that incomplete personal data be completed (such as address, VAT, email, telephone contact details, among others).

Right to erasure or to be “forgotten”

Right to obtain the erasure of your personal data, in cases where this is legally possible and provided there are no valid reasons for its retention, such as for example where the data must be retained in order to comply with a legal obligation.

Right to portability

Right to receive the data you have provided in a digital format for current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new responsible for your personal data.

Right to object and automated individual decisions

Right to object or withdraw your consent at any time to a data processing in cases where this is legally possible (such as in the case of data processing for marketing purposes).

Right of limitation

Right to request the limitation of the processing of your personal data, in cases where this is legally possible, in the form of:

– Suspension of processing

– Limitation of the scope of processing to certain categories of data or purposes of processing.

Right to complain

Right to lodge a complaint to the supervisory authority, the CNPD.

How can you exercise your rights?

The exercise of the rights is free of charge, except if it is a manifestly unfounded or excessive request, in which case a reasonable fee may be charged taking into account the costs. Neovictus Lda. shall confirm proof of your identity and may request additional information as necessary.

Requests shall be answered within 30 days at the latest unless the request is particularly complex (in which case the 30 day period indicated above may be extended to 2 months).

You can exercise your rights by contacting the following addresses:

Entity: Neovictus Lda.

Address: Campus Politécnico, 10 – BioBip, 2.4, 7300-555 Portalegre

Email: neovictus@neovictus.com

  1. How does the Entity protect your personal data?

Neovictus Lda. applies the necessary technical and organizational measures to ensure that, by default, only personal data of Customers required for each specific purpose of treatment will be treated, and these measures are periodically reviewed and updated by the responsible department.

Neovictus Lda has in place appropriate logical, physical, organisational and security measures necessary and sufficient to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Where it is necessary to communicate personal data of its Customers to Third Parties, Neovictus Lda ensures that:

(a) the sharing of personal information complies with the legal regulations in force;

  1. b) the transmission is made with security;
  2. c) the third parties are contractually obliged to observe the duties of confidentiality and secrecy and to assure the security of the personal data that, for that purpose, are communicated to them, not being able to use such data for any other purposes, for their own benefit or for the benefit of third parties, nor to correlate them with other data that are in their availability.

COOKIE POLICY

Neovictus Lda. uses cookies on its website to enhance the performance and user experience of its website.

What are cookies?

Cookies are small text files stored in the Customer’s computer through the internet browser, storing only information related to the user’s preferences (generic information), thus not including the Customer’s personal data.

The cookies used by Neovictus Lda. observe the principles of anonymity and confidentiality and have the sole purpose of recognizing the user and are not used in any case to collect information that identifies the user, nor for direct marketing purposes. Cookies help the Neovictus Lda. website to recognize the user’s device the next time the user visits it.

At any time you can, via your internet browser, decide to be notified about the receipt of cookies and block their entry into your system.

Attention is drawn to the fact that refusal to use cookies on the website may result in the user being unable to access any of its areas and/or receive personalised information.

What are cookies used for?

Cookies are used to help determine the usefulness, interest, and number of uses of the Neovictus Lda. website, allowing faster and more efficient navigation by eliminating the need to repeatedly enter the same information.

What kind of cookies are used by Neovictus Lda.?

The cookies used by Neovictus Lda. have different functions and are distinguished in the following terms:

1 – Strictly necessary (essential) cookies: they enable navigation on the website and the use of its applications, as well as access to secure areas of the website. Without these cookies, the Service(s) subscribed to by the Client cannot be provided. Some cookies are essential to access specific areas of the Neovictus Lda. website.

2 – Analytical cookies: performance cookies to find out which pages are the most popular, which link between pages is the most effective or to determine why some pages are receiving error messages. These cookies are only used for statistical analysis purposes and never collect personal information.

3 – Functionality Cookies: store the user’s preferences regarding the use of the website, so that it is not necessary to re-configure the website each time you visit.

Cookies can be:

Permanent: they are stored for a variable period of time in the internet browser of your access devices and are used each time you visit the website again. They are normally used to direct browsing according to the user’s interests, allowing us to provide a more personalised service.

Session Cookies: These are temporary and remain in the cookies of your internet browser until you leave the website. The information obtained allows us to identify problems and provide a better browsing experience.

How to manage cookies?

All internet browsers allow the user to accept, refuse or delete cookies, in particular by selecting the appropriate settings in their internet browser.

Once you have authorised the use of cookies, you can always disable some or all cookies from Neovictus Lda..