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Privacy and Personal Data Protection Policy

The protection of privacy and personal data is a fundamental commitment of ifthenpay

Privacy and Personal Data Protection Policy.

Preliminary Note

Ensuring the confidentiality of the personal data of our clients, partners, and suppliers is important to us and a cornerstone of our relationship with all. As such, ifthenpay, Lda. (hereinafter ifthenpay), as the entity responsible for the processing of personal data provided, in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, commonly referred to as the General Data Protection Regulation (GDPR) and other applicable national and community legislation, has adopted the Personal Data Privacy Protection Policy disclosed in this document, which establishes how Personal Data is collected, stored, and processed, ensuring its confidentiality and security.

PURPOSE

This Personal Data Privacy Policy applies to all personal information collected, processed, and stored by ifthenpay through various channels.

The individual user of the goods and services (hereinafter referred to as the Holder) that ifthenpay offers through its website, applications, and other digital or physical platforms (such as, but not limited to, forms and membership contracts) should be aware of this Personal Data Privacy Policy and the Terms and Conditions of use and provision of ifthenpay's goods and services whenever accessing areas requiring the provision of personal data, referred to as "Personal Data."

Prior to the submission and processing of Users' personal data, ifthenpay requests the express, informed, and unequivocal consent of the User regarding this Policy. The purpose of ifthenpay's Privacy Policy is to provide transparency regarding how personal data will be processed and to protect the information and data that any User of our services may enter on websites, applications, or digital platforms operated by ifthenpay.

For the purposes of Article 8, no. 1 of the GDPR, that is, regarding the direct offer of services by the so-called information society, ifthenpay ensures that no personal data is requested from minors under the age of 16, unless express prior consent has been obtained from their representatives, whether they be parents, guardians, or legal custodians, who should have been informed of this Personal Data Privacy Policy.

DATA PROTECTION AND PRIVACY PRINCIPLES

Processing operations conducted by ifthenpay comply with fundamental data protection and privacy principles, which guarantee the proper functioning of processes, the trust of customers, suppliers, and partners, as well as a positive public image: lawfulness, fairness, and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity, confidentiality, and transmission.

DATA PROTECTION AND PRIVACY PRINCIPLES

Ifthenpay ensures that all personal data is processed lawfully, that is, in strict compliance with the lawfulness principles imposed by the GDPR. This lawful basis exists when:

The Data Subject has given consent for one or more purposes that require it;
It is necessary for the performance of a contract to which the Data Subject is a party; or
For pre-contractual measures requested by the Data Subject;
To fulfill a legal obligation to which the data controller is subject;
To protect the vital interests of the Data Subject;
For the performance of a task carried out in the public interest or the exercise of official authority;
To further the legitimate interests of the data controller.

WHAT PERSONAL DATA IS COLLECTED AND HOW

Identification data: e.g., name, identification document numbers, date of birth;
Contact data: e.g., address, email, phone, mobile;
Tax information: tax identification number, tax status;
Family status: e.g., marital status, number of dependents;
Banking, financial, and transaction data: e.g., IBAN, bank account identification;
Analytical data: With access to our site, specific files are automatically collected and automatically deleted after a certain period. The collection of this data has purely technical objectives, such as connection configuration, system security, technical network management, and optimization of our website. The data we refer to includes: a set of computer data that is temporarily recorded in:
1. IP address of the requesting processor;
2. Date and time of access;
3. Name and URL of the transferred file;
4. Data volume transmitted;
5. Browser software and operating system identification;
6. Indication of successful transfer;
7. Internet service provider name.
8. Website from which you accessed our webpage.

This data is collected online through the completion of forms, applications, and digital platforms.

HOW ARE YOUR DATA PROTECTED?

Ifthenpay has invested in adopting administrative, technical, physical, and organizational measures that guarantee the security, integrity, and privacy of the Personal Data collected, suitable to the risk of each processing and consistent with practices established in the European Union. They aim to protect Personal Data against accidental or intentional manipulation, disclosure, loss or destruction, unauthorized access, misuse, alteration, as well as any other form of unlawful processing.

Partners and subcontractors who have access to Personal Data are required to adopt the necessary security, organizational, and technical measures to protect these data.

The Holder guarantees that the Personal Data provided is true and accurate and undertakes to notify any changes. Any damage caused to ifthenpay or any third party by providing erroneous, inaccurate, or incomplete information on registration forms shall be solely the responsibility of the provider of such information.

Our security measures are constantly being improved, following technological progress. However, we disclaim any liability when such acts result from criminal or unlawful conduct, in which case responsibility shall be attributed to the respective agents.

HOW LONG ARE YOUR DATA RETAINED?

We will retain your Data for the maximum period required to meet applicable legal, regulatory, and contractual obligations, and they will be deleted as legally required upon the Holder's request.

Data collected under contract (e.g., but not limited to, payment service provision) will be retained for the period required by law, particularly for tax/accounting purposes and for the safeguarding of guarantees and contractual responsibilities.

WITH WHOM ARE YOUR DATA SHARED?

Ifthenpay will not sell, buy, share, or distribute your Personal Data to or from third parties.

Data collected by ifthenpay will only be shared with third parties when essential for the fulfillment of legal and contractual obligations, such as subcontracting entities, for example, for accounting, mailing, IT services, archiving, judicial or official bodies, attorneys in case of any dispute or claim, and others, in our service.

In cases of international data transfers originating from the European Economic Area to a third country or international organization with a data protection level deemed adequate by the European Commission, your Personal Data may be transferred based on this criterion.

For international data transfers to third countries or international organizations not recognized by the European Commission as having an adequate level of protection, we will rely on a derogation applicable to the specific situation (e.g., if the transfer is necessary to perform the contract with you, as in an international payment) or will implement safeguards to ensure the protection of your personal data:

Standard contractual clauses approved by the European Commission;
Binding corporate rules.

LINKS TO EXTERNAL WEBSITES/HYPERLINKS

Our Privacy and Personal Data Protection Policy applies exclusively to our website, applications, and other digital platforms. However, these platforms may contain links to third-party websites, such as partners and suppliers. Accessing these websites requires a User click on the respective link and is never automatic.

It is absolutely impossible for ifthenpay to guarantee that our partners' and suppliers' data protection practices comply with the law and our ethical requirements. Thus, ifthenpay assumes no responsibility for the content or privacy policy of external websites, and any damage, loss, misconduct, or violation caused or presumably caused or related to the use of these external websites or resources is the sole responsibility of their owners.

Cookies

The ifthenpay websites, online services, interactive applications, email messages, and advertising campaigns may use "cookies" and other technologies, such as pixel tags and web beacons. These technologies help us better understand user behavior, contributing to an improved user experience when browsing our web pages. They also allow us to enhance our services and measure the effectiveness of advertising campaigns and internet searches. We treat the information collected by "cookies" and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by applicable law, we will also treat these identifiers as personal information.

Procedures in Case of a Data Breach

If you believe that ifthenpay has not respected any of your personal data protection rights, you may file a complaint with the supervisory authority responsible for data protection, specifically the National Data Protection Commission (Comissão Nacional de Proteção de Dados).

Contact Information

ifthenpay, Lda.
Rua São José, N.º 757
4535-404 Santa Maria de Lamas, Portugal
Phone: +351 227 660 871
Email: info@ifthenpay.com

How Can You Stay Informed About Changes to This Information?

In a constantly evolving technological landscape, this information may be updated regularly.

You can always view the latest version online at www.ifthenpay.com or request it by email. We will inform you of any relevant changes through our website or our usual communication channels. Additionally, if required by applicable law, we will seek your consent to any significant updates.

Consent for the Collection and Use of Personal Data

ifthenpay will only use personal data provided by the data subjects and solely for the purposes for which it was collected, always based on the free, specific, informed, and express consent of its data subjects at each point of interaction with ifthenpay.

Data provided to ifthenpay will only be shared with third parties when necessary to fulfill legal and contractual obligations, such as, but not limited to, sharing with accounting services.

ifthenpay may use your personal data to send you news, products, and promotions related to ifthenpay’s activities and partnerships. Within the limits of this purpose, it analyzes your usage history of products and services, promotions used, frequency of service usage, as well as your profile and personal interests, so that the promotions sent are personalized and tailored to your needs and preferences at any given time.

Users have the right to opt out of our communications at any time.

Additionally, users can request that we stop analyzing their profile at any time, even if this means they will no longer receive news, offers, and promotions. The profile created about you will be used solely to personalize our communications, except in cases of legal, regulatory, or security matters.

What Rights Do You Have Over Your Data?

According to applicable regulations, data subjects have the right to:

Information and Access: This allows you to obtain details about how your data is processed and to request a copy of your data.
Rectification: If you believe your personal data is inaccurate or incomplete, you can request it to be corrected accordingly.
Erasure: You may request the deletion of your personal data, as far as legally permissible.
Restriction: You may request restrictions on the processing of your personal data, as far as legally permissible.
Objection: You may object to the processing of your personal data, particularly if based on legitimate interests, for reasons related to your specific situation. You can also object at any time to data processing for direct marketing purposes, including profiling related to direct marketing.
Automated Decisions: If applicable, you have the right to request human intervention by the controller, express your viewpoint, and contest automated decisions, including profiling.
Withdraw Consent: If you have provided consent for the processing of personal data, you may withdraw it at any time, as far as legally permissible.
Data Portability: Where legally allowed, you have the right to retrieve your personal data that you have provided or, if technically possible, to request the transfer of that data to another third party responsible for processing.

In person at our headquarters;
By registered mail to Rua São José, N.º 757, Santa Maria de Lamas, 4535 – 404 Santa Maria da Feira;
Through a request on the website www.ifthenpay.com;
In the Backoffice of the website www.ifthenpay.com;
By email at info@ifthenpay.com;
By phone at +351 227 660 871.