73100 promotes the protection of the confidentiality and privacy of the information entrusted to it. As part of this fundamental obligation, 73100 also promotes the adequate protection and use of personal data (referred to as “personal data”, “personally identifiable information” or “PII”) that are collected through its websites.
As a rule, our intention is to collect only the personal data that is voluntarily made available by the visitors of our sites, in order to offer them information and / or services.
- Collection and use of personal information
- What information do we collect
- Legal basis for the use of personal information
- Automatic collection of personal information
- IP Addresses
- Google Analytics
- Web beacons
- Location based tools
- Social network widgets and apps
- Sharing and transfer of personal information
- Transfers to third parties
- Data security and integrity
- Links to other sites
- Changes to this policy
- Issues regarding this policy and its implementation
1. Collection and use of personal information
1.1 What information do we collect
In cases where you have registered to receive information from certain services, we may store your email address temporarily until we receive confirmation of the information you provided by email (eg when we send an email to an email address you provided as part of your registration to confirm a subscription request).
1.2 Legal basis for the use of personal information
As a rule, 73100 collects only the personal data necessary to respond to your request. When additional information is requested, on an optional basis, you will be notified at the time of collection.
The Portuguese legislation allows us to process personal information, as long as we have a legal basis to do so and it is our duty to inform you of these grounds. As a result, when we process your personal information, we will do so in accordance with one of the following processing conditions:
- Execution of a contract: when the processing of your personal information is necessary to perform our obligations under a contract or for pre-contractual arrangements at the request of the data subject
- Legal obligation: when we are required to process your personal information in order to fulfil a legal obligation, such as keeping records for tax purposes or providing information to a public authority or a judicial or supervisory authority;
- Legitimate interest: we may process your information, wherever in our legitimate interest, in order to promote our lawfully developed activities, provided that it does not compromise your interests; or
- Consent of the data subject: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to do so. You may withdraw your consent at any time by contacting 73100 at [email protected]
In some cases, 73100 and its service providers , web beacons and other technologies to automatically collect certain types of data when visiting our sites, as well as through e-mails that we can exchange.
The collection of this information will allow us to optimize your user experience and better understand and optimize the performance, handling and effectiveness of 73100 sites and to evaluate the effectiveness of our marketing activities.
1.3.1 IP Addresses
An IP address is a number assigned to your computer each time you access the Internet. It allows computers and servers mutual recognition and communication with each other. The IP addresses through which visitors’ access can be registered for IT security purposes and system diagnostics. This information can also be used in an aggregated way to check site trends and analyse performance.
Cookies can be installed on your computer or device whenever you enter our site and they serve to allow the site to remember your computer or device.
In some of our sites, a window will appear asking if you want to accept cookies. If you do not accept cookies, your computer or device will not be monitored for marketing purposes. A secondary type of cookie may also be requested, the “user-input” (user-fed cookies). These cookies can not be blocked through the initial window. Your choice is saved in a cookie, and is valid for a period of . To change this option, simply clear your browser’s cookies.
Although most browsers automatically accept cookies, you can choose to accept them via your browser settings (usually through Tools or Preferences). You can also delete cookies from your device at any time. However, please note that if you do not accept cookies, you may not be able to fully experience the features of our site.
You can find more information on how to manage cookies through your browser’s help file or through some websites, such as www.allaboutcookies.org.
Here is a list of the types of cookies used on our sites:
|Objective||Description||Type & Period|
|Performance (ex.: User’s browser)||Our sites are developed through common Internet platforms. These platforms have built-in cookies that help with compatibility issues (eg to identify the type of browser used) and improve performance (eg faster loading of content)||Session Deleted after closing the browser|
|Security cookies (ex.: Asp .NET)||If you log in to our sites to access a restricted area, our cookies ensure that your device stays logged in for the duration of your visit. You must use your username and password to access restricted areas||Session Deleted after closing the browser|
|Site preferences||Our cookies may also save your preferences (eg language) or try to improve your experience (eg customize a greeting or content). This applies to areas where a specific record has been created to access or create an account||Session Deleted after closing the browser|
|Analysis||We use a variety of third-party analytics tools that help us understand how visitors use our sites. This allows us to improve their quality and content for our visitors. The data includes items such as total visits or page views and references to our sites||Persistent, but are automatically deleted after two years without accessing the site|
|User feedback||We use a third-party search tool to invite a percentage of visitors to give their feedback. Cookies are used to prevent visitors from being asked to give their feedback more than once The first type of cookie (1) is stored if the visitor is not invited to participate in the study and is used to ensure that visitors are not invited to do so after their first viewing of the page. The second type of cookie (2) is stored if the visitor is invited to participate in the survey and is used to ensure that the visitor is not invited back to the study for a period of 90 days||(1) Session Deleted after closing the browser (2) Persistent Automatically cleared after the 90-day period or after sending the invitation to participate in the study|
|Social share||We use widgets or third-party social networking shortcuts to provide you with additional functionality for sharing content from our web pages to social networks and via e-mail. Using these widgets or shortcuts may result in the installation of a cookie on your device to make it easier to use the services of these features, ensure that your interaction appears on our web pages (eg, social share count cache is up to date) and record information about your activities on the Internet and at our sites. We recommend that you carefully read the Privacy Information of each of our service providers before using them||Persistent, but are automatically deleted after two years without accessing the site|
Our pages may also use third-party tools and widgets to provide additional functionality. Using these tools and widgets may result in the installation of a cookie on your device to make it easier to use the services of these features and ensure that your interaction appears properly on our web pages.
Cookies do not identify your e-mail address or personally identify you in any other way. We may obtain other means of identification through our analytical reports, namely IP addresses, but only to help us determine which areas of the site our visitors prefer and not to identify visitors individually.
BY BROWSING OUR SITES OR BY REGISTERING YOUR LOGIN INFORMATION TO ACCESS RESERVED AREAS TO REGISTERED USERS, YOU AGREE TO INSTALL COOKIES ON YOUR COMPUTER OR YOUR INTERNET DEVICE.
1.3.3 Google Analytics
73100 uses Google Analytics. For more information about how 73100 uses Google Analytics, see: http://www.google.com/analytics/learn/privacy.html
1.3.4 Web beacons
A web beacons is a small image on a web page that can be used to collect certain information from your computer, such as your IP address, the time the content was viewed, the type of browser, and the existence of cookies previously sent from the same server. 73100 only uses web beacons in accordance with applicable law.
73100 or its service providers may use web beacons to monitor the effectiveness of third party sites that provide recruitment or marketing services or to collect aggregate visitor statistics or manage cookies.
You can make some web beacons unusable by rejecting their associated cookies. The web beacons may still record an anonymous visit from your IP address, but the cookie information will not be recorded.
In some of our newsletters and other communications, we can confirm the email address of the recipient through links inserted in the messages. We collect this information to assess user interests and to improve future user experiences.
1.3.5 Location-based tools
73100 may collect and use the geographical location of your computer or device. This location data is collected to provide you with information regarding the services we believe may be of interest to you based on your geographic location and to improve our location-based products and services.
1.4 Social network widgets and apps
73100’s sites may include features to facilitate sharing through external social networking applications such as the Like button and the Twitter widget. These applications may collect and use information regarding your use of 73100 sites (see details on “Social Sharing” cookies in the table above). Any personal information you provide through these applications may be collected and used by other members of these social networks and such interactions are governed by the privacy policies of the companies providing the applications. We have no control over these companies or their use of your information and we are not responsible for such companies or their use of your information.
In addition, 73100 sites may host blogs, forums, crowdsourcing and other applications or services (collectively, “social media sources”). The purpose of social media sources is to facilitate the sharing of knowledge and content. Any personal information you provide in any of 73100’s social networking resources may be shared by other users of those respective resources (unless otherwise determined at time of collection), over which we have no control or restricted control.
73100 recognizes the importance of protecting children’s privacy, especially in the online interactive world. In particular, our sites are not designed or intended for children under the age of 13. It is not our policy to intentionally collect or hold information about anyone under the age of 13 except as part of a contract for the provision of professional services.
2. Sharing and transfer of personal information
2.1 Transfers to third parties
We do not share personal data with unaffiliated third parties, except as necessary for our legitimate business and professional needs, to respond to your requests and / or as required or permitted by law or by professional rules. This includes:
- Our service providers : 73100 works with partners, service providers and reputed representatives who can process your personal information on our behalf. 73100 will transmit your personal information to them only when these providers comply with our demanding data processing and security standards. We only share the personal information that allows them to provide their services
- In the event of restructuring or disposal to another entity: 73100 may disclose personal information related to the sale, assignment, or any other transfer of the business of the site on which the data was disclosed / transmitted
- Judicial or supervisory authorities: 73100 may disclose personal information to respond to requests from courts, government authorities or supervisory authorities, or where necessary or convenient to comply with applicable laws and regulations or judicial decisions
- Audits : disclosure of personal information may also be required for audits in the area of data protection or security and / or to investigate or respond to a complaint or threat of security.
In general, you are not required to provide any personal data when you visit our sites, but 73100 may request the provision of certain personal data so that you may receive additional information about our services and events. 73100 may also request your authorization for certain uses of your personal data and you may accept or refuse such uses. If you choose to subscribe to certain services or communications, such as an electronic newsletter, you may cancel at any time by following the instructions included in each communication. If you decide to cancel a service or communication, we will attempt to remove your data immediately, although we may request additional information before we can process your request.
As described above, if you want to prevent cookies from identifying you while browsing our sites, you can reset your browser to refuse all cookies or to inform you when a cookie is being sent. However, please note that some areas of our sites may not work correctly if you choose to decline cookies.
If you have transmitted personal data to 73100 you will in principle enjoy the following rights:
- Access and correction: appropriate access to such data to correct any inaccuracies, also called the “Request for Access”. If we are obliged to provide this personal data, we will do so without any kind of charge. Before providing personal information, you may be required to provide proof of identity and information about your interaction on our sites in order to more easily locate the data you have requested
- Opposition to processing: opposition to the processing of your personal data if we do not have the right to use them, request to delete your data or restrict its processing in certain circumstances.
5. Data security and integrity
73100 has security policies and security procedures adequate for the protection of personal data against loss, misuse, alteration or destruction. Despite 73100’s commitment, security against all threats can not be absolutely guaranteed. As far as we can assure you, access to your personal data is limited to those who need to know them. Those individuals who have access to the data are required to maintain the confidentiality of such data.
We also strive to maintain personal data only for as long as the information is required to respond to the request of a data subject or until such holder requests the deletion of the data and in any case never exceed the legally applicable term.
6. Links to other sites
7. Changes to this policy
8. Issues regarding this policy and its implementation
In any case, you always have the right to submit a complaint to the National Data Protection Commission in Portugal.