Solmaior Privacy notice

Effective date: 26/06/2018

The careful reading of this privacy notice (“Notice”) is important to understand our policies and practices regarding your Personal Data and how we will treat it.

This Notice explains in detail how your Personal Data are collected, used, and disclosed by Solmaior entities as listed in the controllers & contact section (Section 11) (“Solmaior”). It also explains how you can access and update your Personal Data and make certain choices about how your Personal Data are used.

This Notice covers both Solmaior online and offline data collection activities, including Personal Data collected through various channels such as websites, apps, third party social networks, Customer Support Services (“CSS”) and events. It is important to notice that Solmaior combines Personal Data collected via one method (e.g. a Solmaior website) with Personal Data collected via another method (e.g. a Solmaior Customer Support Services). As part of this, Solmaior may combine Personal Data that were originally collected by different Solmaior entities. Please see Section 8 for further information.

It is equally important to notice the fact that if the client fails to provide the necessary Personal Data to Solmaior (the necessary information will be clearly identified on registration forms, Solmaior may not be able to provide goods and/or services. This Notice can change from time to time (Section 10).

 

The present Notice provides important information in the following areas:

  1. SOURCES OF PERSONAL DATA
  2. PERSONAL DATA COLLECT ABOUT THE CLIENT AND RELATED PROCEDURES
  3. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONSS
  4. USES MADE OF PERSONAL DATA
  5. DISCLOSURE OF PERSONAL DATA
  6. RETENTION OF PERSONAL DATA
  7. STORAGE AND/OR TRANSFER OF PERSONAL DATA
  8. ACCESS TO PERSONAL DATA
  9. CHOICES ABOUT PERSONAL DATA USES & DIVULGATION
  10. CHANGES TO NOTICE
  11. DATA CONTROLLERS & CONTACTS

 

1. SOURCES OF PERSONAL DATA

This Notice applies to Personal Data that Solmaior collects from or about their clients, through the methods described on Section 2), from the following sources:

Solmaior websites. Consumer-directed websites operated by or for Solmaior, including sites that Solmaior operates under own domains/URLs and mini-sites on third party social networks such as Facebook (“Websites”).

Solmaior mobile sites/apps. Consumer-directed mobile sites or applications operated by or for Solmaior, such as smartphone apps.

E-mail, text and other electronic messages. Electronic communications between the client and Solmaior.

Solmaior CRC. Calls to Solmaior Customer Support Services (“CSS”).

Data from other sources. Third party social networks (such as Facebook, Google) or market researches (if feedback not provided on an anonymous basis).

 

2. PERSONAL DATA COLLECT ABOUT THE CLIENT AND RELATED PROCEDURES

Depending on how the client interacts with Solmaior (online, offline, over the phone, etc.), Solmaior may collect various types of information, as described below.

Personal contact information. Includes any information provided by the client that would allow Solmaior to contact them such as: name, postal address, e-mail address, social network details, or phone number.

Account login information. Includes any information required to give access to the client’s specific account profile. It may include the login ID/email address, screen name, password in unrecoverable form, and/or security question and answer.

Demographic information & interests. Includes any information that describes the client’s demographic and/or behavioural characteristics. It may include date of birth, age or age range, gender, geographic location (e.g. postcode/zip code), favourite products, hobbies and interests, and household or lifestyle information.

Technical information about computer/mobile device. Includes any information about the computer system or other technological device used by the client to access one of Solmaior Websites or apps, such as the Internet protocol (IP) address used to connect the computer or device to the Internet, operating system type, and web browser type and version. In case the client accesses to a Solmaior website or app via a mobile device such as a smartphone, the collected information will also include, when permitted, the client phone’s unique device ID, advertising ID, geo-location, and other similar data.

Websites/communication usage information. Solmaior may resort to automatic data collection technologies as the client navigates through and interacts with our Websites or newsletters, to collect certain information about their actions. This point includes information such as which links the client clicks on, which pages or content has the client view and for how long, and similar information and statistics about interactions, such as webpages response times, download errors and length of visits. This information is captured using automated technologies such as cookies (browser cookies, flash cookies) and web beacons, and they can also be collected using third party tracking. The client may object to the use of such technologies, detailed on Section 3.

Market research & consumer feedback. Includes information that the client may voluntarily share with Solmaior, for example about their experience using Solmaior products’ and services’. The content is, therefore, created by the client, and it includes any content created and/or shared with Solmaior on third party social networks or apps of Solmaior, including the applications use on third party social networks. The information can be represented by photographs, videos, personal histories and other means and similar contents. When allowed, Solmaior may use the generated content by the client to collect and share, which includes contests, website features, consumer engagement, and third party social networking.

Third party social network information. Includes any information that publicly shared on a third party social network or information that is part of the client’s profile on a third party social network (such as Facebook) and that the client allowed the third party social network to share with Solmaior. Examples include basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that the client permitted the third party social network to share. Solmaior receives the client’s third party social network profile information (or parts of it) every time he downloads or interacts with a Solmaior web application on a third party social network such as Facebook, every time he uses a social networking feature that is integrated within a Solmaior site (such as Facebook Connect) or every time he interacts with Solmaior through a third party social network. For more information about how the data is obtained by Solmaior, or to opt-out of sharing such social network information, please visit the website of the relevant third party social network.

Calls to CSS. Communications with a CSS will be recorded or listened into, in accordance with applicable laws, for local operational needs (e.g. for quality or training purposes). When required by law, the client will be informed about such recording at the beginning of the call.

 

3. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS

Cookies/Similar Technologies. Cookies are important for a good website performance. To improve your experience, Solmaior uses cookies that remember the client’s login information, provide a safe connection, collect statistic data to optimize the website functionalities and present customized content adapted to the client’s interests. Please see Solmaior Cookie Notice for more detailed information on the cookies used and the purposes for which they are used to.

Log Files. Solmaior may collect information in the form of log files that record website activity and gather statistics about the client’s browsing habits. This process is automatically generated, and helps Solmaior to troubleshoot errors, improve performance and maintain the websites security.

Web Beacons. Solmaior may use web beacons on their websites or in emails. Web beacons (“web bugs”) are small code strings that deliver a graphic image for transferring data to Solmaior. The collected information via web beacons will include information such as IP Address and information about how the client respond to an email campaign. Solmaior may use this information for multiple purposes, including but not limited to, advertising, site traffic reporting, email auditing and reporting, unique visitor counts and personalisation.

 

4. USES MADE OF YOUR PERSONAL DATA

The following paragraphs describe the various purposes for which Solmaior collects and uses the client’s Personal Data, as well as the different Personal Data types collected for each purpose. It’s important to note that not all of the uses below will be relevant to every individual.

Customer service. Solmaior may use the client’s Personal Data for customer service purposes, including responding to the client’s questions and doubts. This process may require the use of personal contact information, as well as information regarding the reason for the client inquiry (it may be necessary, for example, the client’s location, technical questions, previous doubts and/or complains on a product and/or service, etc.).

Solmaior principles: Compliance with contractual and legal obligations, Solmaior legitim interests.

Solmaior legitim interests: Improve and develop new products and services, increase efficiency and delivery quality.

Contests, marketing and other promotions. Solmaior may use the client’s Personal Data with their consent (when required), to informe about goods or services (e.g. marketing communications, campaigns and promotions). The communication can happen via be done via email, ads, SMS, phone calls and postal mailings to the extent permitted by applicable laws. Some of Solmaior campaigns and promotions may be run on third party websites and/or social networks. This Personal Data use is voluntary, which means the client can oppose to the processing of their Personal Data for these purposes. For detailed information on how to modify your preferences about marketing communication, please see Sections 8 and 9 below.

Solmaior principles: Clients consent (when necessary), fulfilment of the contractual obligations and Solmaior legitim interests.

Solmaior legitim interests: Determine which of Solmaior products and services may interest to the client, define client types for new products and/or services.

Third party social networks: Solmaior may use the client´s Personal Data when there is an interaction with third party social networking features, such as “Like” functions, to serve and interact with the client trough advertisements on third party social networks. To analyse in greater detail these tools, the data obtained by Solmaior and how to deny consent, Solmaior recommends reviewing the privacy notices of the relevant third party social networks.

Solmaior principles: Clients consent (when necessary), fulfilment of the contractual obligations and Solmaior legitim interests.

Solmaior legitim interests: Determine which of Solmaior products and services may interest to the client, define client types for new products and/or services.

(Offline and online) personalisation. Solmaior may use the client’s Personal Data (when required) to: (i) analyse the client’s preferences and habits, (ii) anticipate their needs, (iii) improve and personalise the client experience on Solmaior Websites and apps; (iv) ensure the content on Solmaior Websites/apps optimization; (v) provide targeted advertising and content; (vi) allow to the client to participate in interactive features, whenever he chooses to do so. . This Personal Data use is voluntary, which means the client can oppose to the processing of their Personal Data for these purposes. For detailed information on how to modify your preferences see Section 8.

Solmaior principles: Clients consent (when necessary), fulfilment of the contractual obligations and Solmaior legitim interests.

Solmaior legitim interests: Determine which of Solmaior products and services may interest to the client, define client types for new products and/or services.

Other general purposes (e.g. internal or market research, analytics, security). Solmaior may use the client Personal Data to other general purposes in accordance with applicable laws, such as conducting internal or market research and measuring the effectiveness of advertising campaigns. Solmaior reserves itself the right, should the client have multiple client accounts, to reconcile those accounts into one single account. Solmaior also uses your Personal Data to ensure the client’s security.

Solmaior principles: Clients consent (when necessary), fulfilment of the contractual obligations and Solmaior legitim interests.

Solmaior legitim interests: Improve and develop new products and services, increase efficiency, protect the assets and personnel of Solmaior.

Legal reasons or merger/acquisition. In case Solmaior or its assets are acquired by, or merged with another company, including through bankruptcy, Solmaior may share the client’s Personal Data with any of the legal successors. Solmaior may also disclose the client’s Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect the company and/or the public rights, privacy, safety or property; (v) to enforce the terms of any agreement or the terms of Solmaior Website.

Solmaior principles: Fulfilment of contractual and legal obligations and Solmaior legitim interests.

Solmaior legitim interests: Improve and develop new products and services, increase efficiency, protect the assets and personnel of Solmaior.

 

5. DISCLOSURE OF YOUR PERSONAL DATA

In addition to Solmaior entities and/or partners (responsible for Solmaior operations) mentioned in the data controllers & contact section (Section 11), Solmaior shares the client’s Personal Data with the following types of third party organisations:

Service providers. External companies that Solmaior may use to assist the business execution (e.g. budgets and services fulfilment, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, website development, data analysis, etc.). The service providers, and their selected staff, are only allowed to access and use the client’s Personal Data on Solmaior behalf for the specific tasks that they have been requested to carry out and are required to keep the client’s Personal Data confidential and secure. When required by applicable law, the client can obtain a list of the providers processing their Personal Data (Section 11).

Credit reporting agencies/debt collectors. To the extent permitted by applicable law, credit reporting agencies and debt collectors are external companies that Solmaior may use to verify the client creditworthiness (in particular for orders with invoice) or to collect outstanding invoices.

Third party companies using Personal Data for their own marketing purposes. Solmaior does not license or sell the client’s Personal Data to third party companies for their own marketing purposes except in situations where the client had given consent. These third party companies identity will be disclosed at the time the client consent is sought.

Third party recipients using Personal Data for legal reasons or due to merger/acquisition. Solmaior may disclose the client Personal Data to third parties for legal reasons or in the context of an acquisition or a merger (Section 4).

 

6. RETENTION OF YOUR PERSONAL DATA

Solmaior may use the client Personal Data in accordance with applicable laws, for as long as necessary to satisfy the purposes for which the Personal Data were collected (as described in Section 4 ) or to comply with applicable legal requirements. Personal data used to provide a personalized experience (Section 4) may be kept for the permitted duration.

 

7. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA

Solmaior uses a variety of reasonable measures that are described below to keep the client’s Personal Data confidential and secure. However, it’s important to notice that these protections do not apply to information that the client chooses to share in public areas such as third party social networks.

People who can access your Personal Data. The client’s Personal Data will be processed by Solmaior authorised staff or agents, depending on the specific purposes for which the Personal Data have been collected.

Measures taken in operating environments. Solmaior stores the client’s Personal Data in operating environments that use reasonable security measures to prevent unauthorised access and follows reasonable standards to protect the Personal Data. However, the transmission of information on the Internet is, unfortunately, not completely secure and although Solmaior does efforts to protect the client’s Personal Data, it cannot guarantee the security of the data during transmission through their Websites/apps.

Measures Solmaior encourages the client to take. It is important that the client plays an active role in keeping their Personal Data safe and secure. When signing up for an online account, please choose an account password that it’s difficult to guess and never reveal it. The client is equally responsible for his account use and for keeping the password confidential. Solmaior advices, in case the client uses a shared or public computer, to never choose to have the login ID/email address or password remembered, and to make sure to log out of your account. The client should also make use of any privacy settings or controls Solmaior provides on the Website/app.

Transfer of your Personal Data. The storage, as well as the processing of the client’s Personal Data may require its transference/transition to, and/or stored at, a destination outside of your country of residence. Solmaior may also transfer your Personal Data to countries outside the European Economic Area (“EEA”) including to countries which have different data protection standards to those which apply in the EEA.

 

8. ACCESS TO YOUR PERSONAL DATA

Access to Personal Data. When provided by law, the client, their successors, representatives and/or proxies have the right to access, review and request a physical or electronic copy of information held about the client. The client also has the right to request information on the source of their Personal Data.

These rights can be exercised by contacting Solmaior to the email sol@solmaior.com  or writing to Solmaior Lda, Av. D. João II, Lt. 30, Edifício Meridiano, 2ºB, 1990-092 LISBOA. If the request is submitted by a person other than the client itself without providing evidence that the request is legitimately made on their behalf, the request will be rejected. It is important to notice that any identification provided to Solmaior will only be processed in accordance with, and to the extent permitted by applicable laws.

Additional rights (e.g. modification, deletion of Personal Data). When provided by law, the client, their successors, representatives and/or proxies can (i) request deletion, portability, correction or revision of Personal Data; (ii) oppose the data processing; (iii) limit the use and disclosure of Personal Data; (iv) revoke consent to any of the data processing activities.

It is important to notice that in certain circumstances, Solmaior may not be able to delete the client’s Personal Data without also deleting the associated user account. Solmaior may also be authorised by the applicable laws to retain some of the client’s Personal Data after a deletion requested was made to satisfy legal or contractual obligations. Solmaior may also be permitted by applicable laws to retain some of the client’s Personal Data to satisfy business needs.

When available, Solmaior websites have a dedicated feature through which it’s possible to review and edit the Personal Data. Please note that Solmaior requires to all registered clients to verify their identity (e.g. login ID/email address, password) before accessing or making changes on their account information.

Solmaior hopes to satisfy any questions or doubts you may have about the way the company processes their client’s Personal Data. However, if there are any unresolved concerns, the client has the right to complain to competent data protection authorities.

 

9. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA

By using mechanisms that provide to the client the control on regarding their Personal Data, Solmaior works daily to provide to the client different options about their Personal Data:

Advertising, marketing and promotions. If the client wishes to have their Personal Data used by Solmaior to promote its products or services, indication it’s possible through the relevant tickbox(es) on the registration form, or by answering the question(s) presented by Solmaior Customer Support Center. If the client decides that no longer wishes to receive such communications, can subsequently unsubscribe from receiving marketing-related communications at any time, by following the instructions in each communication. To stop receiving marketing communications sent by any medium, including third party social networks, the client can opt-out at any time by accessing into the Websites/apps or third party social networks and adjust user preferences in their account profile by unchecking the relevant boxes or by calling our CSS. It is important to notice that, even if the client chooses not to receive marketing communications, it will still receive administrative communications from Solmaior, such as services or other transaction confirmations, notifications about account activities (e.g. account confirmations, password changes, etc.), and other important non-marketing related announcements.

Personalization (offline and online): When required by law, if the client wishes to have their Personal Data used by Solmaior to provide a personalized experience, it’s possible to indicate so through the relevant tickbox(es) located on the registration form or by answering the question(s) presented by our Trade demonstrators, CSS. If the client decides that no longer wishes to benefit from this, it’s possible to opt out at any time by logging into the Websites/apps and adjusting the user preferences in the account profile by unchecking the relevant boxes or by calling our CSS.

 

10. CHANGES TO OUR NOTICE

Solmaior may update and change this Notice if changes in the way the company handle Personal Data are necessary.  Solmaior reserves the right to make changes to their own practices and to this Notice at any time; please check back frequently to see any updates or changes to Solmaior Notice.

 

11. DATA CONTROLLERS & CONTACT

To ask questions or make comments on this Notice and Solmaior privacy practices or to make a complaint about Solmaior compliance with applicable privacy laws, please contact Us through to email sol@solmaior.com  or writing to Solmaior Lda, Av. D. João II, Lt. 30, Edifício Meridiano, 2ºB, 1990-092 LISBOA.

Solmaior will acknowledge and investigate any complaint about the way the company manages Personal Data (including complaints that Solmaior has breached the client’s rights under applicable privacy laws).

Data controllers:

Solmaior Lda, Av. D. João II, Lt. 30, Edíficio Meridiano, 2ºB, 1990-092 LISBOA

All activities controllers:

Solmaior Lda, Av. D. João II, Lt. 30, Edíficio Meridiano, 2ºB, 1990-092 LISBOA