Privacy | Famility

Preamble

We take the protection of personal data very seriously. We would like to explain how we protect your data when you use our personalized services and what this means for you. Of course, we comply with all legal requirements regarding data protection to ensure the maximum protection of your privacy. We comply with the provisions of the General Data Protection Regulation (GDPR), and following the adaptation to data protection legislation in accordance with Regulation (EU) 2016/679, we comply with the implementation of Directive (EU) 2016/680 (Law EU Data Protection Adaptation and Implementation - DSAnpUG -UE ).

This data protection declaration applies to Famility site, which can be found in the website https://www.famility.pt , and its multiple subdomains and the all the App’s Famility, (hereinafter referred to as "Famility platform").

Last updated: March 1st, 2020

1. Name and address of the controller

The responsible for the treatment of your personal data is Famility Lda (hereinafter referred to as "Famility").

2. Data Protection Officer

You can contact our Data Protection Officer at any time, regarding any matter related to data protection. The best way to contact us is to send an email to: contato@famility.pt

3. General information on data processing

We only collect and use the personal data that is necessary to provide a functional service through our platform and for the content of our services.

3.1 Personal data

Personal data is information that can be associated with you as an individual. Examples of such data are your name, address, telephone number and e-mail address. Non-personal data is information such as the number of users of a website or service.

3.2 Processing of personal data

Treatment means any operation or series of operations carried out, with or without the aid of automated processes, on personal data, such as the collection, compilation, organization, classification, storage, adaptation or alteration, reading, retrieval, use, dissemination by transmission, dissemination or any other form of availability, comparison or interconnection, restriction, elimination or destruction.

Personal data is collected through this platform if they are catered gone on their own initiative and the consent, for example, when you register, in filling out forms, sending emails or use d and the Famility application. We use this data for the purposes indicated in each case or that result from the instructions, such as, for example, the application to join schools, child transport operators, among others. The transfer to third parties will only occur if this is expressly permitted by law or if you have given your express consent for the transfer within the scope of your registration or in the course of an active commercial relationship.

3.3 Legal basis for the processing of personal data

The collection and use of your personal data occur regularly only with your express consent. If we obtain your consent for the processing of your personal data, Art. 6th, no. 1, al. a) the GDPR as the legal basis for this treatment.

Exceptions are cases in which it was not possible to obtain prior consent for real reasons, and the processing of data is allowed in accordance with the legislation in force. For the processing of personal data that are necessary for the performance of a contract, of which Art. 6th, no. 1, al. b) the GDPR is the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

To the extent that the processing of personal data is necessary to comply with a legal obligation to which we are subject, Art. 6th, no. 1, al. c) the GDPR is the legal basis.

If treatment is necessary to safeguard a legitimate interest in our company or a third party and if your fundamental interests, rights and freedoms do not exceed this first interest, Art. 6th, no. 1, al. f) GDPR is the legal basis for treatment.

3.4 Elimination of data and retention time

Your main data is kept for the duration of the contract. After the resolution of the commercial relationship has started, your data will be kept for a maximum period of 4 years from your last transaction. If we initiate the resolution of the business relationship for security reasons or due to bankruptcy, we will keep your data for a maximum period of 5 years after your last transaction.

3.5 Security, TLS technology

We have adopted technical and organizational measures to protect your personal data, namely against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. These security measures are continuously updated in line with technological developments. The transmission of personal data between your computer or mobile device and our server is always encrypted (TLS protocol, Transport Layer Security).

4. Registration

Next, we describe the treatment of your data collected when you registered.

4.1 Registration process

On our platform, you can register providing your personal and children's data that you care about. Your data is inserted in a mask layer, then transmitted and saved.

Step1 - Membership in the FAMILITY platform, email validation:

The personal data collected during the e-mail registration process are as follows:

- E-mail, password of your choice.

Your data is not transferred to third parties. You will receive an email to validate your email account.

Step 2 - Completing the registration. The personal data collected during the registration completion process are as follows:

- name, identification card number, tax identification number, number telephone number, payment information (optional) and picture (optional).

Step 3- Registration of children on the platform. The personal data collected in the child registration process are as follows:

- Child's name, date of birth, tax identification number, and photo (optional).

In addition, the following personal data are collected:

- IP adress:

- Date and time of registration.

Your data, with the exception of your IP address, will be kept for the entire term of your membership, but for a maximum period of 4 or 5 years, depending on how our business relationship ended, as set out in Clause 3.4. After these deadlines, all your personal data will be irretrievably deleted, unless there are legal retention periods. During the retention period, the personal data required to comply with legal obligations will be completely blocked and will no longer be accessible for further treatment. We always delete your IP address after 6 months.

4.2 Legal basis

The legal basis for the treatment of this data, which is necessary for the execution of a contract or for the implementation of pre-contractual measures, is Art. 6th, no. 1, al. b) the GDPR.

5. PostIdent

Description of the treatment of your data under the “PostIdent” procedure.

5.1 Online identification

In our platform, you can validate the identity via email.

- E -mail address, password setting.

In the app, the user will undergo to an identity validation process via email confirmation. Upon completion, the results of this verification process will be sent to Famility.

5.2 Legal basis

The legal basis for the treatment of this data, which is necessary for the execution of a contract or for the implementation of pre-contractual measures, is Art . 6th, no. 1, al. b) the GDPR and its consent to the “PostIdent ” process , pursuant to Art . 6th, no. 1, al. a) the GDPR.

6. Google Maps

Next, we describe the processing of data in the context of using Google Maps.

6.1 Google Maps application

This platform, as well as the Famility application, uses the Google Maps API application. This allows us to show interactive maps directly on the website or in our application and allows you to use the map function conveniently. This application is essential for the functionality and the complete provision of our content and services. You can see the Google Terms of Service at: https://policies.google.com/terms?hl=en . Additional terms of service for Google Maps / Google Earth can be found at https://www.google.com/intl/en-US_US/help/terms_maps.html . You can consult Google's privacy policy at: https://policies.google.com/privacy?hl=en. We use Google Maps to determine the users' location and to calculate geographic proximity information with the estimated arrival time on top of real time traffic. With your approval, we will use Google Maps to, for example, send the “Aviso de Recolha” notifying the estimated time of arrival at the destination (school or otherwise). We do not share this information with Google. This data will only be transmitted to Google anonymously. It cannot be associated to you.

6.2 Legal basis

The legal basis for the treatment of this data, which is necessary for the execution of a contract or for the implementation of pre-contractual measures, is Art. 6th, no. 1, al. b) the GDPR.

7. Cookies

Next, we describe in detail the treatment procedures for the use of cookies.

7.1 Use of cookies

Cookies are small text files that are stored on your hard drive by a web server. Cookies contain information that can be read later by a web server in the domain that is associated with the cookie. Cookies cannot run programs or transmit viruses to your computer. There is a distinction between two different types of cookies. Session cookies are deleted as soon as the session ends. Temporary and permanent cookies are stored for a longer period or indefinitely.

7.2 Data in the context of the use of cookies

The cookies we use do not store any personal data. The cookies we use are also not associated with personal data. In this regard, these cookies cannot be assigned to a person. When a cookie is activated, it only receives an identification number. Personal data, such as name, IP address, etc. they are not associated with this identification number under any circumstances. When we use cookie technology, we only receive anonymous information, such as which pages on our platform were visited, etc.

7.3 Use of session cookies

Most of the cookies we use are called session cookies, which are necessary to keep your visit consistent, that is, to ensure that, for example, you are not asked to repeat your login and that your preferences or other information is already entered in the reservation request are saved during the session. In addition, we need session cookies to ensure that a specific offer you clicked is associated with your order (for example, promotional offers). These session cookies are automatically deleted when the session ends. In addition, we use cookies to visit the site later, to detect whether you are particularly interested in certain offers, to allow us to display those personalized offers on the site. This association is only made through abstract criteria (for example, " Swimming ") and not in a personalized way. These cookies have a shelf life of one year and are then automatically deleted.

7.4 Targeting on the website

The platform uses cookie technology to collect data that simplify to our platform. This tells us how the site is used and allows us to constantly optimize our offer. The data treated are as follows:

- Search terms used:
- Frequency of viewing pages;
- Use of website features.

These data are used exclusively for anonymous evaluation of the use of the website and are never associated with the personal data we hold. Using the information obtained through the analysis of the flow of clicks, we make our platform as attractive as possible to better respond to your needs.

7.5 Segmentation / Remarketing

We can use segmentation / remarketing to make offers on the Internet more relevant to all users. This technology allows us to show Famility advertising to Internet users who have already expressed interest in our platform, when they visit the websites of our partners. These advertising materials are displayed on the pages of our partners, based on cookies and an analysis of usage behavior on the website. The insertion of the advertisement is completely anonymous: personal data are not saved under any circumstances, nor are user profiles associated with personal data.

We can exchange information with trusted advertising partners, such as: technical identifiers, from your registration information on our platform or from our CRM system. This allows you to connect your devices and / or environments and have an integrated experience of use in the devices and environments you use.

7.6 Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses cookies, text files that are stored on your computer and that allow an analysis of your use of the website. The information generated by the cookie about your use of this website (including your IP address) will be transferred and stored on a Google server. However, if IP anonymization is enabled on this website, your IP address will first be abbreviated by Google in the Member States of the European Union or in other states that are part of the European Economic Area agreement. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there.

Google will use this information to evaluate your use of the site, to report on site activities for site operators and to provide other services related to the site and Internet usage, in particular features for Google Analytics reports performance, according to demographic characteristics and interests. Google Analytics Reports on Demographics and Interests allow us to use advertising data based on Google interests and / or third party data about our advertising audience (e.g., age, gender and interests) in conjunction with Google Analytics for activities, strategies and advertising content targeted and optimized on our platform.

Google may also transmit this information to third parties, as required by law or if those third parties process this data on behalf of Google. In any case, Google will not associate your IP address with other data stored by Google.

You can prevent these cookies from being saved by selecting the appropriate settings in your browser; however, we want to point out that, if you do, you will not be able to enjoy all the features of the website. You can also prevent data generated by cookies about your use of the website (including your IP address) from being transmitted to Google and the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https: // tools.google.com/dlpage/gaoptout?hl=en

Our site uses Google Analytics with the extension " anonymizeIp ". As a result, IP addresses are subsequently processed in an abbreviated form, so that a connection with a specific individual is not possible. If the data collected about the user is of a personal nature, they will be deleted immediately, and the personal data will be deleted immediately.

We use Google Analytics to regularly analyze and improve the use of our platform. We can improve our offer and make it more interesting for you as a user based on the statistics obtained. In exceptional cases where personal data is transmitted to the USA, Google submits itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework .

Third parties information: Google Dublin, Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, Fax: +353 (1) 436 1001. Terms of use: https://www.google.com /analytics/terms/gb.html, Data Protection Summary: https://support.google.com/analytics/answer/6004245?hl=en, as well as the privacy policy: https://policies.google. com / privacy? hl = en.

This site also uses Google Analytics to perform an analysis of visitor flows regardless of devices, which is performed using a user ID. You can disable cross-platform analysis of your usage on your Google Account, under the "Personal information and privacy", "Personal information" tab.

7. 7 Protection against the storage of cookies

It is possible to accept or reject cookies. Most web browsers accept cookies automatically. As a rule, you can specify in your browser settings that cookies should be rejected. If cookies are rejected, you may not be able to use some features of this website. If cookies are accepted, you can delete these cookies later. If you delete cookies, settings that are controlled by those cookies, including advertising settings, will be deleted and may no longer be recoverable.

7. 8 Legal bases

Our legitimate interest lies in the data processing processes mentioned above and the purposes pursued by them. For this purpose, the legal basis is found in Art. 6th, nº 1, al. f).

8 . Publicity

Next, we explain the processing of data for advertising purposes.

8 .1 Personalized advertising (newsletter)

You may have the option to subscribe to a free newsletter on our platform. This is done based on your consent. When you register for the newsletter, the data of the entry mask are transmitted to us. When sending the newsletter, we will provide information about the current products, services and offers that correspond to your personal interests.

We collect your email address and mobile phone number for this purpose. The identification of the e-mail address and the mobile phone number is carried out through the double adhesion procedure.

To cancel your subscription, you can send us an email to contato@famility.pt or use the link at the bottom of the newsletter.

You can revoke your consent for the processing of other personal data collected during the registration process at any time.

No data related to the processing of your data for the sending of newsletters will be transmitted to third parties. Your data will be used exclusively for sending the newsletter.

8 .2 Legal bases

The legal bases for processing your data after subscribing to the newsletter is, with your consent, Art. 6th, no. 1, al. a) the GDPR.

8 .3 Non-personalized advertising (newsletter)

If you buy services or use our platform and provide us with your email address, we can use it later to send you a newsletter (not personalized). In that case, only direct emails will be sent about goods or services like ours.

We collect your email address and mobile phone number for this purpose. You will only receive advertising emails after clicking on the link displayed in the email. In addition, we keep your IP addresses and the time of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, clarify possible misuse of your personal data.

No data related to the processing of data for sending newsletters will be transmitted to third parties. Your data will be used exclusively for sending the newsletter.

The data will be deleted as soon as they are no longer needed to achieve this processing purpose. Your email address and mobile phone number will therefore be saved for that purpose as long as the newsletter subscription is active.

To cancel your subscription, you can send us an email to contato@famility.pt or use the link at the bottom of the newsletter.

You can revoke your consent for the collection of other personal data processed during the registration process at any time.

8 .4 Legal bases

The legal bases for sending the non-personalized newsletter following the provision of services is Art. 7, paragraph 3 of the UWG (Law on Unfair Competition).

9 . Market studies

Next, we describe the data processing procedures in the context of market research.

9 .1 Statistical purposes

We process your personal data for the purposes of market research and voting. Your data will be anonymous, used only for statistical purposes and cannot be associated with it at any time. You can oppose this data processing at any time and without giving reasons with effect for the future. For this purpose, you can use the features described in Clause 2 of this privacy policy.

9 .2 Legal bases

This data processing is based on Art. 6th, no. 1, al. f) and serves to improve our objectives already mentioned in the privacy policy, a more effective advertising organization, in relation to our offers and services. We respect the protection of our customers by conducting market research with anonymous data.

10. Your rights as an affected person

10.1 Right to information

You have the right to ask us, at any time, about the data stored about you, as well as its origin, recipients or categories of recipients to whom that data was transmitted and the purpose of storage.

10.2 Right of revocation

If you have given your consent to the use of your data, you can revoke it at any time, without giving reasons, with effects for the future, under the legislation in force.

10.3 Right of correction

If your data stored by us is incorrect, you can correct it at any time in your customer account or have it corrected by us through our service center.

10.4 Right of elimination and blocking

You have the right to block and delete your personal data held by us. As a general rule, your personal data will be deleted within a maximum period of 2 working days after asserting this right. If the disposal is contrary to legal, contractual, tax or commercial law storage obligations, or other reasons based on the law, your data can only be blocked, but not deleted. Once your data has been deleted, it is no longer possible to provide you with information.

10.5 Right of data transfer

If you request the personal data you have provided to us, we will deliver or transmit them to you or another legally responsible person, if you so wish, in a structured, current and capable of being read mechanically format, if the latter is technically possible.

10.6 Right of objection

You have the right to object to the processing of your data for direct marketing purposes, at any time and without giving reasons. In addition, it should be noted that the execution of the base contract, as well as the treatment of individual contracts, may be restricted or no longer possible due to opposition to all data processing operations.

10.7 Extended treatment rights for personalized assessment

In relation to the processing of your data for personalized assessment, in addition to the rights mentioned above, you also have the right of participation granted to an individual in the decision-making process, a right of appeal and a right to disclose our position.

10.8 Contact to exercise your rights

To enforce your rights, the means available in Clause 2 of the privacy policy are available.

10.9 Right of appeal through a supervisory authority

You have the right to file a complaint with the competent supervisory authority against the processing of your personal data if you believe that your rights under the GDPR have been violated.