- Identification of Entity Responsible for the Treatment
- Personal Data Categories
- Personal Data Origin
- Goals for Treatment of Personal Data, Legal Basis for Treatment and Conservation Periods
- Automatic Decisions (“Profiling”)
- Categories of Personal Data Recipients
- Personal Data Transfer to Other Countries
- Personal Data Holder Rights
- Contact Us!
“Full House Partners
” to ensure the protection of personal data holders, establishing guidelines relative to
rights and to the treatment and open circulation of personal data.
Throughout its activity and within the scope of this site, www.fullhouse-partners.com, Full House Partners gathers and processes personal data from various singular persons who register within the site and to whom Full House Partners provides the following services:
a) Strategic consultancy;
c) Content creation;
This Policy describes the way in which Full House Partners treats the personal data of its users (collectively referred to as “data holders ”).
In an auxiliary way, Full House Partners proceeds equally to the treatment of personal data of other people who assume responsibility for the users, on the relevant legislative terms. In these situations, the treatment is limited to the personal identification and contact data and its foundation lies in the fulfillment of legal obligations to which Full House Partners is subject, for example, if the user is incapacitated to manifest their will and the law assumes such role, in benefit towards the participant, to a third party. This policy also applies to the treatment of this personal data, particularly the dispositions referring to “Conservation Periods”,“Categories of Personal Data Recipients”,“Transfer of Personal Data to Other Countries”, and “Rights of Personal Data Holders”.
2. Identification of Entity Responsible for the Treatment
The company Diligentshield, LDA, headquartered in Rua Almeida Garret, N. 18, 2795-012, Linda a Velha, NIF being 516 154 770, is considered the “Entity Responsible for the Treatment” , or, the person who determines the purposes and means of holders ’ personal data treatment
3. Personal Data Categories
When conducting their activity, Full House Partners may proceed to personal data treatment as integrated within the following categories:
- Identification Data, such as, gender, profession, name, age or date of birth, national identification number, taxpaying number, foreign taxpaying number if applicable, nationality and place of birth, academic formation data, among others;
- Contact Data, such as, home address, email address, phone contacts, among others;
4. Personal Data Origin
The personal data which Full House Partners gathers is mostly data provided by the data holders upon their
registering on the website, www.fullhouse-partners.com, property of of Full House Partners, and throughout
the period during which the data holders remain users of the aforementioned website.
Full House Partners gathers personal data through various communication channels, including telephone, email, and printed or online forms
5. Goals for Treatment of Personal Data, Legal Basis for Treatment and Conservation Periods
Full House Partners treats data holders’
personal data for diverse motives, justified by data protection laws
applicable in the European Union and in Portugal..
Full House Partners treats users ’ personal data for the following goals:
- Usage and management of the site,www.fullhouse-partners.com;
- Provided services disclosure
- Provision of scientific education services like workshops, speeches, and multimedia presentations;
- Compliment and complaint management.
Full House Partners treats its users
personal data based on the performance of services contracted by users,
for fulfillment of legal obligations to which Full House Partners is subject, for the protection of user interests
and/or for the effect of legitimate interests pursued by Full House Partners or thirds, except if the interests or
rights and fundamental freedoms of the holder prevail, demanding personal data protection, especially if the
holder is a child.
Users’ personal data are conserved throughout the duration of the contractually established relation with Full House Partners and until 10 (ten) years since the end of that relation, being that in certain situations the conservation period may be superior, in case that enlargement is legally justified and sustained. This period was defined bearing in consideration the applicable laws in personal data matters and regarding the eventuality of Full House Partners having the necessity to present proof in whichever litigation or potential litigation between you and the data holders.
6. Automatic Decisions (“Profiling”)
Full House Partners does not resort to technology for decision-making exclusively based on automated
treatment of data holders’ personal data.
Without injury, Full House Partners may resort to technologies which permit the definition of a profile about the data holder, however, never in a totally or exclusively automated way and without it implying any legally relevant consequences (even if positive) for the data holder.
7. Categories of Personal Data Recipients
Full House Partners may share data holders’ personal data with entities which provide services to Full House Partners and that in the scope of providing said services may proceed to the treatment of personal data according to Full House Partners’s instructions, such as:
- Companies which provide digitalization and documental archive services;
- Attorneys, financial auditors, and other consultants who provide consultancy services for Full House Partners
In transmissions of personal data to their service providers, Full House Partners guarantees that the
subcontracting entity is bound by a subcontracting deal which obliges them to personal data treatment in
accordance with legislation regarding personal data protection.
Full House Partners may still share data holders ’ personal data with third-party entities (i) in virtue of requirement or legal notification to the effect, as long as it is properly based and legally sustained; (ii) in case of solicitation by a public authority, as long as it is properly based and legally sustained; (iii) in the sequence of an expressed request from data holders relative to their own respective data, within their rights, particularly, the portability right; (iv) in fulfillment of legal and/or regulatory obligations.
8. Personal Data Transfer to Other Countries
Full House Partners may transfer data holders
personal data to other countries. It is considered that countries
in the European Union offer the same level of personal data protection as Portugal does. Full House Partners
does not currently resort to subcontractors from, nor does it transfer data to, third-party entities headquartered
outside the European Union.
Nonetheless, when or if Full House Partners transfers, for whichever motive, personal data to entities outside the European Union, they will ensure that these people or companies agree to protect the personal data against inappropriate usage or disclosure, in conformity with the personal data protection legal regime, through the signature of subcontracting deals which are integrated by clauses approved by the European Commission or other legally adequate means.
9. Personal Data Holder Rights
As an expression of the commitment relative to the data holders ’ privacy guarantee, Full House ensures, in conformity with applicable national and community legislation, a large set of rights which may be exercised within the following terms:
Data holders may, at any point in time, contact Full House Partners and require confirmation that their personal
data are subject to treatment and, in an affirmative case, of being informed regarding: (i) the personal data
categories in question; (ii) the data treatment’
s goals; (iii) the respective period of conservation or criteria used to
determine it; (iv) the rights which assist them and the way to exercise them; (v) the origin of data which regards
them; (vi) the existence of automated decisions, including the definition of profiles.
Full House Partners may only provide the data holder ’ s information, and not personal data belonging to other people. Furthermore, in case that access negatively affects someone else ’ s right, we may not be able to provide it.
If the data holder solicits it, Full House Partners will send a copy of their personal data in treatment phase, in an electronic format. In case further copies are solicited, Full House Partners reserves the right to demand payment of a tax equivalent to the administrative costs incurred to satisfy the request.
Also known as the “forgetfulness right” , this permits the data holder to solicit the elimination or removal of their personal data when there is no imperative motive for Full House Partners to continue using it. The erasure right is not absolute, as Full House Partners may have the right or obligation to retain the information, as happens, for example, when they are subject to a legal obligation or any other valid reason to retain it.
Anytime they verify that personal data subject to treatment is not updated, is incomplete or incorrect, data holders may solicit that Full House Partners rectify this in the shortest time-frame possible.
Data holders still possess the right to: (i) receive the personal data which regards them from Full House
Partners, in a current-use and automatic-reading format; (ii) transmit the data to third parties, bearing full
responsibility; and/or (iii) solicit that Full House Partners transmit said data to third-parties. The portability right
only covers data on which the holder is part of, or data where the treatment took place through automated
Full House Partners reserves the right to refuse portability requests any time they damage third-party rights and liberties, or any time they conflict with any legal requirement.
Treatment Limitation Right
In certain situations, the data holder bears the right to
or suppress the continuous utilization of the data
holder’s information. When the treatment is limited, Full House Partners is still able to store the data holder’s
information but cannot continue actively using it.
The data holder may solicit treatment limitation of their data for an indeterminate amount of time if they mean to suspend treatment but conserve their data. This situation may occur when:
(i)The data holder disputes the data’s accuracy, causing a limited treatment for a period of time which permits
Full House Partners to verify its accuracy, or
(ii)The data holder is awaiting a response to an opposition to treatment request.
When treatment is limited, personal data will only be treated again if the data holder grants their consent, except in situations of specific treatments which are addressed within the law. Full House Partners guarantees that the data holder who solicited their data ’ s limitation is informed before the limitation to the referred treatment is annulled. Full House Partners reserves the right to limit treatment of data holders ’ data when they don ’t need it, committing themselves to conserving the data for the pre-established retention period. Full House Partners guarantees that the data holder who solicited their data ’ s limitation is informed before the respective annulment.
Full House Partners ensures the necessary means for the data holder to oppose determined treatments of
personal data for determined goalls, without harm from directives or laws-in-vigor.
The data holder may oppose treatment in the following circumstances:
(i)For motives related to their particular situation, at any given moment, opposing to the treatment of whichever personal data relative to them and based on legitimate interests. However, Full House Partners may continue treating the data holder’s data if they are able to demonstrate legitimate and imperative motives for the treatment of personal data which overpower the interests, rights, and freedoms of the data holder, or if they need the personal data to establish, exercise, or defend themselves in legal processes;
(ii)At any given moment, for direct marketing effects (including the creation of profiles related to said direct marketing).
Despite Full House Partners adopting the best practices in terms of personal data protection, data holders are
granted the right to present compllaints to the National Commission for Data Protection (https://www.cnpd.pt)
relative to the data treatment conducted by Full House Partners, through whichever mediums allowed by the
aforementioned Controlling Authority.
The described and foreseen rights in this Policy and, other legally foreseen legislative rights which are relevant may be freely exercised through contacting Full House Partners on the following contact page.
10. Contact Us!
For whichever questions relative to your data
s treatment, please contact us at:
Address: Rua Almeida Garrett, N.º18, 2795-012 Linda-a-Velha
Telephone: +(351) 917 947 374
Don’t hesitate to contact us if you are unsatisfied with any aspect relative to the way in which we gather, share, or utilize your personal data.