Political Privacy and Data Protection Resolution

This document establishes the pre-contractual information related to distance contracts concluded through the address WWW.SOPRATAS.COM as referred to in Article 4 of Decree-Law No. 24/2014 of February 14, and all its subdomains, digital applications, or sub-websites.

SÓ PRATAS and its domain WWW.SOPRATAS.COM are owned by JULIO CRISTIANO PEREIRA DE OLIVEIRA RODRIGUES, located at RUA DO MONTE, 331 4405-812 GULPILHARES VILA NOVA DE GAIA, individual taxpayer number 206650450, hereinafter referred to as SÓ PRATAS.

SÓ PRATAS is responsible for the collection and processing of personal data obtained digitally, namely through the use of this website, committing to respect user privacy, ensuring the confidentiality and security of the data received, in strict compliance with current legislation.

This Personal Data Protection Policy describes our practices for the retention, processing, and access of personal information. By accepting, you authorize SÓ PRATAS to process your data, of which you confirm you are the holder, as well as the data related to your commercial and contractual relationship and its management, in accordance with this text. You also declare that you are aware and fully informed that the processing of your personal data previously transmitted by you includes all operations carried out by automated means or not.

Additionally, you acknowledge your rights to oppose, correct, and/or request the “Right to be Forgotten” regarding the processing of your Personal Data by sending a request to an email address, as well as the right to file a complaint with the competent authorities.

Please read the following terms carefully:

PREAMBLE

This Personal Data Protection Policy, hereinafter referred to as the “Protection Policy,” aims to inform you about the following points:

1.1 The commitments made by SÓ PRATAS regarding Personal Data Protection, under the General Data Protection Regulation, hereinafter referred to as “GDPR” (EU) 2016/679, concerning the protection of individuals regarding the processing of Personal Data and the free movement of such data; and

1.2 The manner in which SÓ PRATAS processes your Personal Data, particularly the Personal Data obtained digitally, namely through the website and/or digital applications.

DEFINITIONS

In the following framework, SÓ PRATAS provides definitions for the following terms:

Definition of “Personal Data”: refers to all information related to the Data Subject that allows for their identification.
Definition of “Data Subject”: an identified or identifiable individual to whom the Personal Data is associated. The user of the website is considered a Data Subject in relation to SÓ PRATAS. An individual may be identifiable or identified, directly or indirectly, through a name, identification number, location data, online identifiers (such as IP addresses and logs).
Definition of “Controller”: the internal entity that defines the purposes and means of Processing Personal Data.
Definition of “Processor”: an external entity to SÓ PRATAS that processes Personal Data on its behalf. The “Processor” has signed a confidentiality agreement with SÓ PRATAS, committing to keep confidential the information it processes.
Definition of “Processing”: any operation performed on Personal Data, by automated means or otherwise, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. Any other operation provided for under the GDPR is also considered Processing of Personal Data.

COMMITMENTS MADE

SÓ PRATAS guarantees the complete protection of Personal Data in accordance with the standards set forth in the GDPR concerning all procedures and obligations provided therein, particularly regarding the Processing of Personal Data of users of the websites and digital applications (e.g., visitors, customers, potential customers, job applicants, etc.).

SÓ PRATAS has implemented digital tools and procedures to ensure the effective protection of Personal Data.

In monitoring compliance with GDPR procedures, SÓ PRATAS has adopted and implemented various internal policies and procedures to raise awareness among its employees, suppliers, and partners about the protection of Personal Data.

3.1 PRINCIPLES OF PERSONAL DATA PROTECTION

Processing of Personal Data SÓ PRATAS commits to processing your Personal Data in accordance with the following principles:

Processing legally, fairly, and transparently, thus ensuring the principles of legality, fairness, and transparency;
Collection and processing for specific, explicit, and legitimate purposes. Compliance with the principle of purpose limitation, as they will not be processed in a manner incompatible with the purposes for which they were collected;
Collection and processing that is adequate, relevant, and limited to what is necessary, considering the purposes for which they are processed, thus respecting the principle of data minimization;
The Personal Data provided must be true, with the necessary rectification or updating whenever required or deemed appropriate.

Security of Processing SÓ PRATAS has defined technical measures and procedures to effectively implement the principles of Personal Data protection, in order to comply with the GDPR, thus protecting the rights, freedoms, and guarantees of Data Subjects from the outset of their collection and subsequent Processing. The same level of protection of Personal Data is imposed on all Processors (service providers, suppliers, partners, etc.).

PROCESSING OF PERSONAL DATA

4.1 HOW PERSONAL DATA IS COLLECTED

SÓ PRATAS collects your Personal Data at the commercial establishment(s) it operates and through its website and/or digital applications, where the user explicitly provides and consents, specifying:

The commercial establishment(s) it operates;
Registration/account on our website and/or digital applications;
When browsing the websites or digital applications of SÓ PRATAS (i.e., technical information, such as IP addresses or logs, collected through cookies or similar technologies when authorized);
When purchasing items, products, or services online;
When subscribing to the newsletter provided by SÓ PRATAS;
When participating in a contest, marketing program, test, or survey;
When applying for a job at our commercial establishment or through the website;
When entering comments or images on the social media pages owned by SÓ PRATAS;
When, in any other way, you send us personal information and consent to its storage and processing;

4.2 WHY PERSONAL DATA COLLECTION IS NECESSARY

Management of Customer Relationships SÓ PRATAS collects Personal Data related to business relationships with customers and potential customers, particularly to:

Enable navigation on the website and digital applications of SÓ PRATAS, using your personal online account and related services;
Allow online ordering when purchasing items, products, and services on the website and/or digital applications;
Provide after-sales services related to your orders or the items, products, and services you have purchased;
Obtain your opinion on items, products, and services, particularly through surveys and tests;
Allow participation in contests, questionnaires, or other marketing programs;
Establish statistical analyses, financial, commercial studies, and for online traffic management (e.g., to obtain website usage levels, digital applications of SÓ PRATAS, as well as the relevance of the services offered as a way to improve their usability);
Send information, promotional communication, and/or advertising from SÓ PRATAS, particularly about products, services, news, campaigns, and events that may interest the customer, provided that (subject to your prior authorization, when necessary, and respecting your right to refuse, according to applicable legal requirements for direct marketing for commercial purposes). These notifications may be sent by email or through mobile services (telephone call, SMS, and MMS).

Fraud Prevention Your Personal Data will be processed in a manner to prevent fraud situations by third parties from arising. The Personal Data related to your order will be processed to ensure a high level of security during the transaction to prevent identity theft and payment fraud. To combat fraud, online payments may be subject to audits by SÓ PRATAS.

SÓ PRATAS may transfer your Personal Data to third parties, such as service providers or, when legally required, to public and/or judicial authorities. Under these conditions, SÓ PRATAS may refuse all commercial transactions until the situation is regularized. Upon verifying situations similar to those described above, the customer will be individually informed and will have the opportunity to express their opinion and prove their identity.

The information deemed mandatory is marked with an asterisk in the online forms available from SÓ PRATAS. Without the appropriate completion of these fields, the user’s request for information and/or orders cannot be processed. Providing the remaining information is optional.

Recruitment and Human Resources Management SÓ PRATAS collects your Personal Data through a form available at the commercial establishment(s) or on the respective page of the website, aimed at analyzing and responding to applications for specific jobs. In cases where no action is taken by SÓ PRATAS regarding the job application, the Personal Data will be retained according to the provisions set out in the section on “Retention Period of Personal Data.”

4.3 LEGAL BASIS FOR PROCESSING

The operations in the Processing of Personal Data of SÓ PRATAS customers are based on:

Your legitimate interest in achieving sales, protecting your activities, products, and services, as well as in better identifying customer preferences to personalize offers and highlight items, products, and/or services that best meet their needs;
The need to execute contracts entered into with your customers for the sale of items, products, and/or services;
When Processing is required by applicable law;
When explicit consent is obtained.

SÓ PRATAS has a legitimate interest in conducting recruitment operations to manage its activities in the best possible way, collecting all necessary data about interested candidates.

In all cases, it is emphasized that SÓ PRATAS only processes Personal Data if:

The Data Subject has given express consent for the Processing of their Personal Data for one or more specific purposes;
The Processing is necessary for the proper execution of a contract to which they are a party;
The Processing is necessary for the realization of SÓ PRATAS’s legitimate interests, unless these interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, especially if the Data Subject is a child.

4.4 STORAGE TIME OF PERSONAL DATA

SÓ PRATAS retains your Personal Data according to the retention periods imposed by applicable laws and regulations, considering its activities and storing them for the following periods:

When you contact us for information, we keep your personal data for as long as necessary to process and fulfill your request.
We retain your personal data used for direct marketing until you revoke the consent or request its deletion, in accordance with applicable legislation. In this case, SÓ PRATAS will only keep the information necessary to ensure your right to object in accordance with regulations and legal norms. Personal Data related to candidates is stored for one year after their last visit to the candidate’s space.

Cookies used by SÓ PRATAS are stored until the user removes them from their browser.

4.5 RECIPIENTS OF PERSONAL DATA

SÓ PRATAS employees responsible for customer support, sales, recruitment, and human resources can only access your Personal Data when strictly necessary.

SÓ PRATAS does not share your Personal Data with third parties, except for service providers, as specified in the section on “Security Measures and Subcontractors,” especially for purposes of fraud prevention, payment management, hosting, information technology administration, and customer support.

SÓ PRATAS may transfer Personal Data to third parties in response to requests from judicial authorities with legal authority to do so, in accordance with applicable legal standards.

SÓ PRATAS ensures the confidentiality and security of Personal Data during transfer to the aforementioned recipients.

5. ABOUT COOKIES

What are cookies? Websites, applications, and digital platforms may use cookies or similar technologies to enhance your browsing experience. Cookies are information stored on your personal device about the sites you visit. Sometimes, they are stored in a simple text file accessed by a server that reads and records the information. Websites can only read and write cookies that they own.

Our use of cookies When you browse our website, we use cookies to “recognize” your browser, either during your visit (“session cookie”) or across all your visits (“permanent cookie”). On our site, cookies are used for the following purposes:

For technical reasons (identifying sessions, maintaining settings or shopping carts, etc.) to adapt the presentation of the website, application, or digital platform to your device;
For statistical analysis and online traffic management, for example, to improve the usability of a website, application, and digital platform and the relevance of our services;
To redefine the target audience and provide marketing content on other websites;
For geo-location purposes when using specific functions, such as recommendations for store addresses and products available at the nearest point of sale.

Social networks To allow you to share content or comments about our products and/or services, our website may include components from social networks (buttons, plug-ins, etc.). These components are used by social networks to track your browsing habits and will only function if your browser is connected to the relevant social network (you do not have to have used the “share” button, for example). The social networks you use determine the terms governing your use of the information they obtain, and SÓ PRATAS has no control over how this information is used. We recommend that you review their respective privacy policies, which will specify how they use this data and the actions you can take to increase the confidentiality of your account.

Shared devices Since cookies are linked to the device and browser used, it is not possible to determine the identity of the user of the device. Therefore, some services and advertisements offered on this device may not correspond to your usage (the settings/browsing habits of other users of the device may influence the content offered). You can choose the level of confidentiality for your device by deciding who can use it (people authorized to access the device) and changing your settings (especially cookie settings).

Cookie settings You can change your cookie settings at any time, with various options available as described below. The settings you choose may affect your browsing experience and the operation of some services that require the use of cookies. In this regard, we reject any responsibility for the consequences of the limited operation of our services caused by disabling cookies on your device (inability to set or read a cookie).

6. SECURITY MEASURES AND SUBCONTRACTORS

SÓ PRATAS has implemented all appropriate technical and organizational measures to ensure an adequate level of security for Personal Data in relation to the risk, particularly to protect Personal Data against destruction, loss, alteration, unauthorized disclosure, or accidental or illegal access.

The same level of protection is imposed by SÓ PRATAS on its Subcontractors. Any SÓ PRATAS employee who may have access to your Personal Data during their work will keep it strictly confidential.

7. EXERCISING YOUR RIGHTS

You may, at any time, in accordance with applicable rules regarding Personal Data protection, exercise your rights of access, rectification, deletion, and transfer of your Personal Data.

You also have the right to object to the Processing of your Personal Data for direct marketing purposes and, therefore, request to stop receiving promotional communications from SÓ PRATAS at any time.

When the Processing is based on your express consent, you have the right to revoke your consent at any time.

To exercise your rights, particularly regarding the “Right to be Forgotten” or deletion of your Personal Data, you can contact us at the following address: PRACETA COLÉGIO DE GAIA, 358 VILA NOVA DE GAIA.

To allow us to respond to your request, you must provide us with the following identification data: name, surname, email or address, and any other information necessary to confirm your identity.

You also have the right to lodge a complaint with the Supervisory Authority in case of violation of the applicable rules on Personal Data protection, particularly the GDPR.

8. CHANGES TO OUR PROTECTION POLICY

The Personal Data Protection Policy may be changed by SÓ PRATAS at any time.

SÓ PRATAS may adjust the Protection Policy (e.g., if it is intended to use your Personal Data in a way other than stipulated in the Protection Policy in force at the time of data collection), which will be published without prior notice through an update on the Personal Data Protection Policy page. Communication to customers will only be made if the changes justify it.

For any questions or comments regarding our Protection Policy or how SÓ PRATAS collects and uses your Personal Data and to exercise your rights related to your collected Personal Data, please contact us at the following address: PRACETA COLÉGIO DE GAIA, 358 4400-090 VILA NOVA DE GAIA.