1. Introduction

This Privacy Policy describes CONMA’s practices regarding information collected from users who access our site at www.conma.pt or who otherwise share personal information with us.

The processing of your personal information — that is, any information that may reasonably allow your identification (hereinafter “Personal Information”) — is necessary for the fulfilment of our contractual obligations, for the provision of our services, for the protection of our legitimate interests and for compliance with the legal, regulatory and financial obligations to which we are subject.

By using the Site, you agree to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy. We encourage our Users to read it and use it as a basis for informed decision-making.

2. What Information Do We Collect?

We collect two types of data and information from Users:

2.1 Non-Personal Information

Non-identified and non-identifiable information relating to a User, made available or collected through the use of the Site. We have no knowledge of the identity of the User from whom this information was collected. It may include:

• Aggregated usage information
• Technical information transmitted by your device (browser type, operating system, language preference, access time, etc.)
• Information about your activity on the Site (pages viewed, browsing, clicks, actions, etc.)

2.2 Personal Information

Individually identifiable information, that is, information that identifies an individual or can, with reasonable effort, identify them. This includes:

• Device information: geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) and other information related to your activity on the Site.
• Name, contact details and email address, so that we may subsequently get in touch with you.

3. How Do We Receive Your Information?

We receive your Personal Information from the following sources:

• When you voluntarily provide us with your personal data by registering on the Site;
• When you use or access the Site as part of using our services;
• From external providers, services and public records (e.g., traffic analytics providers).

4. How Do We Use Your Information?

We do not rent, sell or share user information with third parties, except as set out in this Privacy Policy. We may use the information for the following purposes:

• To communicate with you and keep you informed of our latest updates and services;
• To deliver advertisements to you when you use the Site;
• To market our sites and products;
• For statistical and analytical purposes aimed at improving the Site;
• To answer questions and clarify queries submitted through the “Contact” tab.

In addition to the purposes set out above, we may share personal information with our trusted third-party providers, who may be located in different jurisdictions around the world, for the following purposes:

• Hosting and operation of the Site;
• Provision of our services, including personalised presentation of the Site;
• Storage and processing of such information;
• Delivery of advertisements and assessment of the success of our advertising campaigns;
• Delivery of marketing offers and promotional materials relating to the Site and services;
• Conducting research, technical diagnostics or analytics.

We may also disclose information where we believe in good faith that such disclosure is necessary to:

• Comply with any applicable law, regulation, legal process or governmental request;
• Enforce our policies, including investigations of potential breaches thereof;
• Investigate, detect, prevent or take action regarding illegal activities, suspected fraud or security issues;
• Exercise our rights or defend against legal claims;
• Prevent harm to our rights, property or safety, or those of our users or third parties;
• Cooperate with law enforcement authorities or enforce intellectual property rights.

5. User Rights

You may request:

• Confirmation as to whether or not your personal information is being processed, as well as access to it;
• Receipt of a copy of your personal information in a machine-readable, structured and commonly used format;
• Rectification of your personal information under our control;
• Erasure of your personal information;
• Objection to the processing of your personal information by us;
• Restriction of the processing of your personal information;
• Lodging a complaint with a supervisory authority.

Please note that these rights are not absolute and may be subject to our legitimate interests and regulatory requirements. To exercise any of the rights above or to obtain further information, please contact our Data Protection Officer (“DPO”).

6. Data Retention

We will retain your Personal Information for as long as necessary to provide our services and to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purpose of collection, as well as applicable legal requirements.

We may rectify, replace or remove incomplete or inaccurate information at any time and at our discretion.

7. Minors

The Site is not designed for or directed at children. Under no circumstances will we allow the use of our services by minors without the prior consent or authorisation of a parent or legal guardian. We do not knowingly collect Personal Information from minors.

If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, they should contact us at info@conma.pt.

8. How Do We Protect Your Information?

We adopt industry-standard procedures and policies to ensure the security of the information we collect and retain, preventing its unauthorised use. We also require any third parties to comply with similar security requirements.

While we take reasonable steps to protect the information, we cannot be held responsible for unauthorised access or misuse of the Site by third parties.

9. Data Transfer Outside the EEA

Some data recipients may be located outside the European Economic Area (EEA). In such cases, your data will only be transferred to countries approved by the European Commission as ensuring an adequate level of data protection, or we will enter into legal agreements guaranteeing the same level of protection.

10. Marketing

We may use your Personal Information (such as name, email address, telephone number, etc.), either ourselves or through third-party subcontractors, to provide you with promotional materials relating to our services that we believe may be of interest to you.

Out of respect for your right to privacy, marketing materials will always include means to opt out of receiving future marketing communications. If you unsubscribe, we will remove your email address or telephone number from our distribution lists.

Please note that, even after unsubscribing from marketing messages, we may still send other important communications, such as customer service notices or communications of an administrative nature.

11. Business Transactions

We may share information in the context of a business transaction (e.g., sale of a substantial part of our business, merger, consolidation or sale of assets). In such cases, the assignee or acquiring company will assume the rights and obligations set out in this Privacy Policy.

12. Collection of Information by Third Parties

This Privacy Policy covers only the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties or websites on the Internet, different rules may apply. We encourage you to read the terms and conditions and privacy policy of each entity to which you choose to disclose information.

This Privacy Policy does not apply to the practices of companies we do not own or control, nor to individuals we do not employ or manage.

13. Updates to This Policy

We reserve the right to modify or revise this Privacy Policy from time to time. Material changes will take effect immediately upon publication of the revised Privacy Policy. The date of the last revision is shown in the corresponding section.

Continued use of the Platform following notice of such changes constitutes your confirmation and consent thereto.

14. How to Contact Us

For general questions about the Site or the information we collect, please contact us at info@conma.pt.