Last updated on November 1, 2023 - this text was translated automatically

1 – WHAT ARE PERSONAL DATA AND WHAT CATEGORY OF DATA DO WE PROCESS?

What are personal data?

Personal Data is any information, of any nature and in any medium (e.g. sound or image), relating to an identified or identifiable natural person.

A person who can be identified directly or indirectly, for example through name, identification number, location data, electronic identifier or other elements that allow the identification of that natural person, is considered identifiable.

Who are the holders of personal data?

The Customer or User, a natural person, to whom the data relates and who has used VASCOKMT.COM's services or products. The Customer will be the person who enters into the contract with VASCOKMT.COM or one of the companies in the VASCOKMT.COM Group and the User is the person who uses the services or products of VASCOKMT.COM or the companies in the VASCOKMT.COM Group, but which may not correspond to the Customer. For example:

- In the business segment, the contract with VASCOKMT.COM is in the name of the company but the Users are the customers or employees of that company;

- In the private segment, a Customer can purchase several products and services.

In this regard, VASCOKMT.COM informs that it also protects personal data and respects the rights of customers and users.

What categories of personal data do we process?

The categories of data we process are as follows:

Identification, contacts and other identification data, civil or tax identification numbers, payment data, billing address, telephone contact and email address; date of birth, gender, your professional activity and IP (if you registered on the internet), products and services purchased or subscribed.

2 – WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The person responsible for collecting and processing your personal data will be the company that provides you with the service or product and that decides which data is collected, the means of processing and the purposes for which the data is used.

3 – ON WHAT BASIS CAN WE PROCESS YOUR PERSONAL DATA?

These are the circumstances in which we process your personal data:

Consent

When you have your consent – ​​in writing, orally or through subscribing to a service – and in advance and if this consent is free, informed, specific and unequivocal. Examples include your consent for VASCOKMT.COM to analyze the use of services and products and make recommendations or send marketing messages, to use your identification data or use of services to send marketing messages from the VASCOKMT.COM Group , your consent so that we can use the service information to improve our quality of service;

or

Contract execution and pre-contractual measures

When the processing of personal data is necessary for the conclusion, execution and management of the contract concluded with VASCOKMT.COM, such as for the preparation of a proposal for products and/or services for the management of contacts, information and requests, to billing, collection and payment management;

or

Compliance with legal obligation

When the processing of personal data is necessary to comply with a legal obligation to which VASCOKMT.COM is subject, such as the communication of identification data to police, judicial, tax or regulatory entities;

or

Legitimate interest

When the processing of personal data corresponds to a legitimate interest of VASCOKMT.COM or third parties, such as data processing to improve service quality, fraud detection and revenue protection and when our reasons for your use shall prevail over your data protection rights;

4 – FOR WHAT PURPOSES AND FOR HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

How long do we process your Personal Data?

Your personal data is processed by VASCOKMT.COM only for the period of time necessary to achieve the defined purpose or, depending on what is applicable, until you exercise your right to object, right to be forgotten or withdraw consent.

After the respective retention period has elapsed, VASCOKMT.COM will delete or anonymize the data whenever it should not be kept for a different purpose that may subsist.

For what purposes do we process your Personal Data?

Purposes

Examples of purposes (non-exhaustive)

Marketing and Sales

- Marketing or selling new products or services

- Analysis of consumption profiles

- Adaptation and development of new products or services

Customer Management and Service Provision

- Management of contacts, information or requests

- Complaints management;

- Management of invoicing, collection and payments

Accounting, Tax and Administrative Management

- Accounting, invoicing

- Tax information, including sending information to the tax authority

Litigation Management

- Judicial and extrajudicial collection

- Management of other conflicts

Fraud detection, revenue protection and auditing

- Detection of fraud and illicit practices

- Revenue protection and control

- Credit risk management

- Internal audit and investigation

Network and systems management

Support and improvement of networks and applications that support the service Monitoring, improvement and support of the service

Compliance with legal obligations

- Location of calls to emergency services

- Court requests

- Investigation, detection and repression of serious crimes

- Response to judicial, regulatory and supervisory entities

Information security control

- Access management, logs

- Backup management

- Security incident management

What are the processing and retention periods for personal data?

VASCOKMT.COM processes and stores your personal data according to the purposes for which they are processed.

There are cases in which the law requires the processing and conservation of data for a minimum period of time, for example, 10 years, the data necessary to inform the Tax Authority for accounting or tax purposes.

However, whenever there is no specific legal obligation, then the data will be processed only for the period necessary to fulfill the purposes that motivated its collection and preservation and always in accordance with the law, the guidelines and decisions of the CNPD.

Therefore, VASCOKMT.COM will process and maintain your personal data for the period in which it maintains a contractual relationship with you.

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

Examples include contact for marketing and sales purposes, the preservation of data in the context of invoice claim processes, the exercise of warranty rights or offers that are of interest to the customer or prospect.

5 – HOW DO WE COLLECT YOUR PERSONAL DATA?

How do we collect your personal data?

We collect personal data with your consent when you purchase VASCOKMT.COM products or services, when you download or use e-books, quizzes, sessions, offers, products, services and applications from VASCOKMT.COM or when you participate in market research.

Collection can be made orally, in writing or via the VASCOKMT.COM website.

But your personal information may also be collected from publicly accessible sources or other sources.

How is your personal data indirectly collected?

So that you can better understand this indirect collection, we recommend the following cases:

Other relevant information about credit risk or identification and contact data, for collections management, fraud detection and revenue protection.

VASCOKMT.COM may collect personal data from private entities that maintain relevant information about the credit of the holders of personal data, as long as these bases respect the applicable data protection rules. VASCOKMT.COM may also access, collect or confirm personal data on Public Administration and private entity websites, in particular, to confirm the accuracy of your identification and contact details.

6 - DATA ANALYSIS

Cookies policy

Information about our use of cookies.

Our website uses cookies to differentiate you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

A cookie is a small file of letters and numbers that we store on your browser or on your computer's hard drive, if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies we use are “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they use it. This helps us to improve the way our website works, for example by ensuring that users find what they are looking for easily. You can find more information about the individual cookies we use and the purposes for which we use them below:

Analytics

The services contained in this section allow the Owner to monitor and analyze web traffic and can be used to track user behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the collected data to track and examine the use of this website, prepare reports on its activities and share them with other Google services.

Google may use the data collected to contextualize and personalize ads from its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy - Refuse.

Facebook Ads Conversion Tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions taken on this website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy.

Commented Content

Content commenting services allow users to make and publish comments on the content of this website.

Depending on the settings chosen by the owner, users can also leave anonymous comments. If there is an email address among the Personal Data provided by the user, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.

If a content commenting service provided by a third party is installed, it may still collect web traffic data for pages where the commenting service is installed, even when Users do not use the content commenting service.

Facebook Comments (Facebook, Inc.)

Facebook Comments is a content commenting service provided by Facebook, Inc., allowing the user to leave comments and share them on the Facebook platform.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy.

Marketing de email

We collect your name and email address when you register for a webinar or event, request a free resource, or join a waiting list, via systeme.io(Privacy Policy).

We use this data to email you about helpful advice and industry news, and to notify you about services and products you may be interested in. You can unsubscribe from our list at any time.

Additionally, we collect your last name and postal address when you purchase a product or course as part of our payment provider's card verification process and sales tax collection stripe.com or paypal.com.

Remarketing and behavioral targeting

This type of service allows this website and its partners to inform, optimize and serve advertising based on the user's past use of this website.

This activity is carried out by tracking Usage Data and Cookies, information that is transferred to partners who manage remarketing and behavioral segmentation activity.

In addition to any opt-out offered by any of the services below, you may opt out of a third-party service's use of cookies by visiting the opt-out page. Network Advertising Initiative.

Remarketing do Facebook (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that links this website activity to the Facebook advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy - Refuse.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that links this website activity to the Facebook advertising network.

Personal Data collected: Cookies and email address.

Place of processing: United States - Privacy Policy - Refuse.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly on the pages of this website.

Interaction and information obtained through this website are always subject to the user's privacy settings for each social network.

This type of service can still collect traffic data for the pages where the service is installed, even when Users do not use it.

Twitter Tweet Button and Social Widgets (Twitter, Inc.)

The Twitter Tweet Button and Social Widgets are services that allow you to interact with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy.

Facebook Like Button and Social Widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services that allow you to interact with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy.

LinkedIn Button and Social Widgets (LinkedIn Corporation)

The LinkedIn Button and Social Widgets are services that allow you to interact with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy.

How to provide or withdraw consent for the installation of cookies

In addition to what is specified in this document, the user can manage cookie preferences directly in their own browser and prevent - for example - third parties from installing cookies.

Through browser preferences, it is also possible to delete cookies installed in the past, including cookies that may have saved the initial consent to the installation of cookies by this website.

Users can, for example, find information on how to manage cookies in the most used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari It is Microsoft Internet Explorer.

With respect to Cookies installed by third parties, Users can manage their preferences and withdraw their consent by clicking on the related opt-out link (if provided), using the means provided in the third party's privacy policy or by contacting the third party.

Notwithstanding the foregoing, the Owner informs that Users can follow the instructions provided in the initiatives subsequently linked by YESTERDAY (EU), for Network Advertising Initiative (USA) and by Digital Advertising Alliance (USA), DAAC (Canada), YES (Japan) or other similar services. These initiatives allow users to select their tracking preferences for most advertising tools.

The Owner therefore recommends that Users make use of these resources in addition to the information provided in this document.

System logs and maintenance

For operation and maintenance purposes, this website and any third party services may collect files that record interaction with this website (system logs) using other personal data (such as IP address) for this purpose.

Changes to this privacy policy

The owner reserves the right to make changes to this privacy policy at any time by notifying users on this page and possibly within this website and/or - as far as technically and legally possible - sending a notice to users via any information contact.

If the changes affect the processing activities carried out based on the user's consent, the owner must collect new consent from the user when necessary.

Data Owner and Controller

VASCOKMT.COM

Owner contact email: info(at)vascomkt.com

As the installation of third-party cookies and other tracking systems through the services used on this website cannot be technically controlled by the owner, any specific references to cookies and tracking systems installed by third parties should be considered indicative. For complete information, we ask that the User consult the privacy policy of the respective third-party services listed in this document.

Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner if they wish to receive more information about the use of Cookies by this Site.

7 – WHAT ARE YOUR DATA PROTECTION RIGHTS AND HOW TO EXERCISE THEM?

What are your rights?

See below your rights and details of what is protected in each one

Right of access

Right to obtainconfirmation which personal data is processed andinformation about them, such as, for example, the purposes of the processing, the conservation periods, among others. Straight toview or obtain copy, for example invoices, written agreements or support requests you made.

Right to rectification

Right to requestrectification of your personal data that is inaccurate or request that incomplete personal data becomplete, such as address, NIF, email, telephone contacts, or others.

Right to erasure of data or “right to be forgotten”

Right to obtain the erasure of your personal data, as long as there are no valid grounds for its conservation, such as cases in which VASCOKMT.COM must retain the data to comply with a legal obligation to preserve it for research, detection and repression of crimes or because a judicial process is ongoing.

Right to portability

Right to receive the data you provided in a commonly used and machine-readable digital format or to request the direct transmission of your data to another entity that becomes the new responsible for your personal data, such as receiving your invoices or transmit your contact details to the new person responsible, but in this case only if technically possible.

Right to withdraw consent or right to object

Right to oppose or withdraw your consent at any time to data processing, such as in the case of data processing for marketing purposes, as long as there are no legitimate interests that prevail over your interests, rights and freedoms , such as defending a right in legal proceedings.

Right of limitation

Right to request the limitation of the processing of your personal data, in the form of:

Suspension of treatment

limiting the scope of processing to certain categories of data or processing purposes.

Right to complain

Right to lodge a complaint with the control authority, the CNPD, in addition to the company or the DPO.

How can you exercise your rights?

The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged taking into account the costs. The information must be provided in writing but, if requested, it can be provided orally. In this case, VASCOKMT.COM must verify your identity by means other than oral means.

Responses to requests must be provided within a maximum period of 30 days, unless it is a particularly complex request.

Exercise your rights through the following addresses:

VASCOKMT.COM

Mail: info(at)vascomkt.com

8 – TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?

Under what circumstances is your personal data communicated to other entities, subcontractors or third parties?

Your data may be transmitted to subcontractors so that they can process it in the name and on behalf of VASCOKMT.COM. In this case, VASCOKMT.COM will take the necessary contractual measures to ensure that subcontractors respect and protect the holder's personal data.

Data may also be transmitted to third parties - entities other than VASCOKMT.COM or subcontractors - such as companies within the VASCOKMT.COM group, companies with which VASCOKMT.COM develops partnerships, if the holder has consented - or entities to whom the data must be communicated by law, such as the tax authority.

Under what circumstances does VASCOKMT.COM transfer your data to a third country?

VASCOKMT.COM may have to transfer your personal data to a third country outside the European Union and which is not part of the list of countries that the EU has already considered to have adequate levels of protection for personal data. In these cases, VASCOKMT.COM will ensure that data transfers are carried out in strict compliance with applicable legal regulations.

9 – HOW DOES VASCOKMT.COM PROTECT YOUR PERSONAL DATA?

VASCOKMT.COM has implemented the appropriate, necessary and sufficient logical, physical, organizational and security measures to protect your personal data against destruction, loss, alteration, dissemination, unauthorized access or any other form of processing accidental or unlawful.

In the systems hosted by VASCOKMT.COM, it has implemented:

Logical security requirements and measures, such as the use of firewalls and intrusion detection systems in your systems, the existence of a strict policy on access to systems and information and the recording of actions carried out by VASCOKMT.COM employees on data personal information of customers or users (logging);

Physical security measures, including strict access control to VASCOKMT.COM's physical facilities, by employees, partners and visitors, as well as very restricted and permanently monitored access to VASCOKMT.COM's essential technological infrastructures;

Means of data protection from design (“privacy by design”) using technical means such as masking, encryption, pseudonymization and anonymization of personal data and also a set of preventive measures favorable to privacy (“privacy by default ”);

Scrutiny, audit and control mechanisms to ensure compliance with security and privacy policies;

An information and training program for VASCOKMT.COM employees and partners;

Access rules for Customers or Users to certain products or services, such as the introduction of a password, to reinforce control and security mechanisms.

10 – USEFUL ADVICE FOR PROTECTING YOUR DATA

VASCOKMT.COM and third-party websites

Regarding the use and processing of personal data on VASCOKMT.COM websites, be sure to consult the rules on the use of cookies on the respective websites.

VASCOKMT.COM websites, products or applications may contain links to third-party websites, products or services, which have no relationship with VASCOKMT.COM or which are not covered by this Privacy Policy.

The collection or processing of personal data requested by these third parties is their exclusive responsibility, and VASCOKMT.COM cannot be held responsible, under any circumstances, for the content, accuracy, veracity or legitimacy of these websites or for the misuse of the data collected or treated through them.

We alert VASCOKMT.COM Customers and Users to this fact and to the need, before using the websites, products or applications, to read and accept the rules regarding the processing of personal data defined by these third parties.

Other advice

VASCOKMT.COM advises caution when exposing your personal data and circulating this data over the internet, acts that are the sole responsibility of the customer, as this data is not fully protected against possible violations, the adoption of additional security measures, including maintaining equipment (PCs, tablets or mobile phones) and programs duly updated and configured with firewalls and protection against malicious software (e.g., antivirus), not browsing websites with a dubious reputation or for which you do not have the necessary guarantees of authenticity , the physical protection of your equipment and avoid placing access credentials on publicly accessible computers (e.g., internet cafes, hotels, etc.) and the use of strong and different passwords depending on each service or website.

Legal information

This privacy statement was prepared based on provisions of multiple legislations, including art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates only to this website, if not otherwise indicated in this document.

Information not contained in this policy

Further details regarding the collection or processing of personal data may be requested from the Owner at any time.

Statement of responsibility

The content sold by VASCOKMT.COM cannot be interpreted as a substitute for professional advice (financial or otherwise). They are not intended to invest in, diagnose, treat, cure or prevent any problem – nor to replace professional advice. Always consult a qualified professional on any matter related to your finances or otherwise. The author/s do not assume any responsibility for losses or damages (direct or indirect) that may result, including, but not limited to, economic or other losses.

All documents made available by VASCOKMT.COM to the user or client are the intellectual property of VASCOKMT.COM and cannot be copied, sold or distributed without prior written consent.