Privacy Policy

1. INTRO

The General Data Protection Regulation (GDPR) is a European regulation, approved by the European Parliament and the European Council, which considers the PROTECTION of individuals with regard to the processing of their personal data a fundamental right, regardless of nationality or place of residence, thus contributing to the realization of an area of freedom, security and justice and to an economic and social union of the citizens of the European area.

With its entry in effect, it is necessary to adopt a set of internal procedures aimed at safeguarding the processing of personal data, as well as adapting the processing of personal data to the new rules.

In turn, on August 08, 2019, Law No. 58/2019 was published, which ensures the implementation, in the national legal system, of the RGPD, and which also imposes rules on the processing of personal data.

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda. considers the PROTECTION of personal data concerning its employees, suppliers and customers, and all the people who contact it by any means, to be fundamental. It has established a set of standards and good practices aimed at the execution of the obligations contained in the diplomas identified above and, as such, the defense of the rights of the holders of the personal data it processes.

Measures have also been established regarding the use of cookies on the WEB pages which are also included in this PRIVACY AND DATA PROTECTION POLICY.

Transitional rules have also been included to cover the processing of personal data in the exceptional phase of the COVID-19 pandemic, which will be in effect as long as needed.

The internal rules and procedures established and approved in this DATA PRIVACY AND PROTECTION POLICY have therefore been implemented and are in effect as of this date.

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will maintain updates of the principles and good practices contained in this PRIVACY AND DATA PROTECTION POLICY, reserving the right to change it whenever necessary.

2. WHAT IS PERSONAL DATA

Personal data means information of any kind and on any medium, including sound and image, relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly and indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. The personal data collected and processed may be:

3. RESPONSIBLE FOR COLLECTING AND PROCESSING PERSONAL DATA

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda is responsible for the collection and processing of Customers’ personal data, under the terms of paragraph 7 of article 4 of the GDPR, and it is up to it to decide in the context of the provision of Services to the Customer, which personal data are collected, the means of processing the data and the purposes for which they are used, which are identified in the following paragraph.

4. PURPOSE OF DATA COLLECTION

The personal data collected by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda in conclusion and execution of the contract are for the purpose of: administrative management of customers, billing and collection of services, marketing of products of the company or group companies and, in contracts involving the subscription of telecommunications services, retention of traffic / location data, management of requests of Law 32/2008, of 17 July. The use of the Customer’s personal data for other purposes always requires the prior and express consent of the Customer.

5. LIABILITY FOR DATA DISCLOSED TO THIRD PARTIES

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda may, in the exercise of its activity and within the scope of the services it provides, subcontract third parties for the pursuit of the purposes described above, which may imply access by these entities to personal data of its Customers. When and if this happens Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda. takes the appropriate organizational and human measures at that level.

The Third Parties subcontracted by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda. are obliged, under the terms of the law, as well as by virtue of a previously signed agreement (with the Third Parties), to implement 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 processing, as well as being bound by special duties of professional secrecy and confidentiality.

Outside the scope described above, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda. will only transmit the personal data of its Customers to Third Parties, when:

5.1. It is obliged to do so by virtue of a legal provision and only to the strict extent of its obligations;

5.2. In order to provide some features and provide a high level of service, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda may share user data with third parties.

In any case Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda remains responsible for the personal data provided by Customers.

The provision of certain services by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda may involve the transfer of personal data outside Portugal. In these cases, the company declares that it will strictly and rigorously comply with the determination of the suitability of the country of destination of the information with regard to the protection of personal data and the requirements applicable to such transfers, under the terms legally provided.

6. PROCESSING OF PERSONAL DATA FOR SPECIFIC PURPOSES

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda only processes the Customer’s traffic and location data strictly necessary for the billing and collection of the Services provided, keeping and preserving them for the period of time necessary to fulfill such purpose. The aforementioned personal data will not be communicated to Third Parties by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda except in the situations expressly provided for in Law no. 32/2008, July 17, which regulates the conservation and transmission of traffic and location data relating to natural persons and legal persons, as well as related data necessary to identify the subscriber or registered user for the purpose of investigation, detection and prosecution of serious crimes by the competent authorities.

7. CONDITIONS FOR COLLECTING PERSONAL DATA

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda only collects and processes the personal data of Customers with their express consent, according to each of the specific purposes of the treatment in question, under the terms provided for in the Personal Data Protection Law. The consent provided by the Clients may be withdrawn by them at any time, free of charge. There are, however, personal data that are indispensable for the provision of the Services by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda (mandatory data), and Customers are duly and previously informed of this same need and the consequences of not providing such data. If the personal data, considered indispensable, is not provided by Clients or prove to be insufficient, incorrect or outdated, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will not be able to provide the subscribed Service(s), in which case Customers assume full and exclusive responsibility for the insufficiency or incorrectness of the data transmitted.

8. RETENTION PERIOD OF PERSONAL DATA

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will only keep Customers’ personal data for the period of time strictly necessary to allow:

a) The provision of Service(s);

b) Compliance with the legal obligations to which Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda is bound;

c) Pursuit of the purposes of collection and/or processing;

d) The exercise of Clients’ rights and the fulfillment of the corresponding obligations. In cases where the National Commission for the Protection of Personal Data (CNPD) authorizes the retention of Customers’ personal data for periods longer than the duration of the service provision contract, given the specific purpose of the processing in question, the Customer will be timely and duly informed of that purpose and the period of retention in question. After expiry of the retention/saving period, under the terms set out above, the personal data of the Customers will be permanently deleted by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda.

9. CUSTOMERS’ RIGHTS IN RELATION TO THEIR PERSONAL DATA

In accordance with the provisions of the Personal Data Protection Act, the Customer is guaranteed the right to access, correct, update and delete his personal data, free of charge, as the holder of the personal data. In any of the above cases, the Customer may exercise his legitimate rights by sending written communication to the e-mail contact indicated below.

10. UNSOLICITED ELECTRONIC COMMUNICATIONS FOR DIRECT MARKETING PURPOSES

The contact details of the Customer, who is a natural person, may be used by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda if it expressly authorizes it in the Service Order Form in direct marketing actions and promotion of services made available by itself, under the terms of Article 13 of Law no. 41/2004, 18 August, in the version conferred by Law no. 46/2012, 29 August. In the case of a Client who is a legal person, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda may send unsolicited communications for direct marketing purposes relating to goods and services provided by itself or by a company of the same Group, unless the Client expressly refuses to receive this type of communication in the future and registers on the national list of legal persons who expressly oppose the receipt of unsolicited communications for direct marketing purposes that is the responsibility of the Directorate General of the Consumer (DGC) to keep updated. In any of the above cases, the Customer shall have the right to expressly object, free of charge, via e-mail, to the sending by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda of electronic communications for direct marketing purposes, by sending written communication of this content to the e-mail contact indicated below.

11. COOKIE DATA

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda uses cookies on its website to improve its performance and user experience. Cookies are small text files stored on the Client’s computer through the internet browser, storing only information related to the user’s preferences (generic information), thus not including the user’s personal data. The cookies used by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda observe the principles of anonymity and confidentiality and have the sole purpose of recognizing the user, not being used in any case to collect information that identifies the user, nor for direct marketing purposes. Cookies help Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda website to recognize the user’s device the next time they visit it. At any time, the user can, through their internet browser (browser) decide to be notified about the receipt of cookies, as well as block their entry into their system. Attention is drawn to the fact that the refusal to use cookies on the website may result in the user being unable to access any of its areas and / or receive personalized information. Cookies serve to help determine the usefulness, interest and number of uses of the Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda website, allowing faster and more efficient navigation, eliminating the need to repeatedly enter the same information. The cookies used by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda. have different functions and are distinguished in the following terms:

11.1. Strictly necessary (essential) cookies: Allow 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 by the Customer cannot be provided. Some cookies are essential to access specific areas of Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda website.

11.2. 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 creation and analysis purposes, without ever collecting personal information.

11.3. Functionality cookies: These store the user’s preferences regarding the use of the website, so that it is not necessary to reconfigure the website each time you visit it.

11.4. Third Party Cookies: measure the effectiveness of third party applications and advertising.

Cookies can be:

Permanent: They are stored, for a variable time, at the level of the internet browser (browser) on your access devices and are used whenever the user makes a new visit to the website. They are usually used to direct navigation according to the user’s interests, allowing us to provide a more personalized service.

Session Cookies: These are temporary, they remain in your browser’s cookies until you leave the website. The information obtained allows us to identify problems and provide a better browsing experience. All internet browsers allow the user to accept, refuse or delete cookies, namely by selecting the appropriate settings in their internet browser. After authorizing the use of cookies, the user can always disable some or all of the cookies of Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda.

12. SECURITY MEASURES ADOPTED TO PROTECT PERSONAL DATA

In its organizational structure, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda has a Personal Data Protection Officer – “Data Protection Officer” – who assumes responsibility for the execution and compliance with the legal and regulatory rules applicable to the processing of personal data and who is responsible in particular for the maintenance and development of the Security Policy, Confidentiality, Secrecy and Protection of personal data.

13. PROCEDURAL AND TECHNICAL SECURITY MEASURES

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda applies the necessary technical and organizational measures to ensure that, by default, only personal data of Customers necessary for each specific purpose of treatment will be processed, which are reviewed and updated periodically by the responsible department. Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda has also implemented sufficient, necessary and appropriate technical, physical, organizational and security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, disclosure, unauthorized access and against any other form of unlawful processing. In this way, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda has adopted different security mechanisms and procedures, following the best practices in terms of information security in the systems that support the services it provides and that store the Clients’ procedural data, namely the use of firewalls and intrusion detection systems, the existence of restricted access – physical and logical – the registration of operations (logging) and respective monitoring and auditing, the collection and transmission of personal data through secure means. The personal data collected by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda are stored securely in its systems, which, in turn, are located in a datacenter of the company itself or under its management, covered by all the physical and logical security measures indispensable for the protection of personal data. Whenever it is necessary to communicate personal data of its Customers to Third Parties, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will be responsible for the personal data in question and guarantees that:

a) The sharing of personal information complies with the legal regulations in effect;

b) The transmission is carried out securely, including through the use of encryption protocols;

c) Third parties are contractually obliged to observe the duties of confidentiality and secrecy and to ensure the security of personal data communicated to them for this purpose, and may not use such data for any other purpose, for their own benefit or for the benefit of third parties, or correlate them with other data available to them.

14. PERSONAL DATA COLLECTED BY THE CUSTOMER AND REGISTERED ON ITS PLATFORMS

If Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda within the scope of the contracted services, carries out any of the operations that integrate the legal concept of “Processing of Personal Data” (as defined in the Data Protection Legislation) in the name and on behalf of the Client, the parties hereby determine that their intention is that the Client is the Controller and Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda. the mere Processor and that, in any event, each party shall comply with its respective obligations under the Data Protection Legislation in relation to any Personal Data that comes into the possession of the recipient. Without prejudice to the provisions of the preceding paragraph:

a) Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will process Customer Data comprising personal data (“Customer Personal Data”) only in accordance with the terms of the Contract and any lawful instructions reasonably given by the Customer;

b) Each party shall take appropriate technical and organizational measures against unauthorized or unlawful processing of Customer Personal Data or its accidental loss, destruction or damage;

c) Taking into account the nature of the Services, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will support the Client by means of appropriate technical and organizational measures, to the extent possible, to enable it to comply with its obligations related to the exercise of rights enshrined in the Law to the holders of Personal Data that it is up to the Client to control;

d) Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will not transfer the Customer’s Personal Data outside the European Economic Area without the Customer’s prior written approval;

e) The Customer must ensure that he/she has the right to transfer his/her Personal Data to Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda so that it can legally process them in accordance with the contract established between both parties;

f) Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda will keep a record of any processing of the Customer’s Personal Data carried out in the course of the services, together with records of compliance with its legal obligations regarding Personal Data Protection.

In cases where the contract results in Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda the obligations described above, it will provide the Customer with cooperation and appropriate assistance in relation to the Customer’s obligations in accordance with the Data Protection Legislation in relation to the Customer’s Personal Data, considering the nature of the Services and the information made available to Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda including:

a) Any request made by a data subject to have access to Customer Personal Data relating to that person;

b) The Customer’s obligations to report a security breach to regulators and data subjects and the Customer’s relations with Regulators;

c) Provide the Customer and regulators with all necessary information and assistance to demonstrate that the Services comply with Data Protection Legislation.

The cost of the above cooperation and assistance shall be borne by the Client, unless such cooperation and assistance relates directly to Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda‘s breach of its obligations under the Contract, in which case such cooperation and assistance shall be borne by Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda.

If Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda becomes aware of any unauthorized or unlawful processing of any Customer Personal Data or that such data is lost or destroyed or becomes damaged, corrupted or unusable, Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda shall, within a reasonable period after becoming aware of such facts notify the Customer.

Title to the Customer Data and all related Intellectual Property Rights are owned by the Customer.

15. CONTACTS

For more information on how Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda handles/processes the personal data of its Customers or to clarify any doubts, submit a complaint or leave comments on matters relating to Privacy and Protection of Personal Data, you should send your communications to:

Estrela Mestra – Ensino e Divulgação Cultural Unipessoal, Lda.
Square Afrânio Peixoto, 2 – 1º D
1000-009 Lisbon, Portugal
Email: clinicarsalvatore@gmail.com