Privacy policy

PERSONAL DATA AND PRIVACY PROTECTION IS A CONSERVATÓRIO REGIONAL DE PALMELA’S COMMITMENT

Personal data and privacy protection is a Conservatório Regional de Palmela’s fundamental commitment towards the personal data owner that uses this digital platforms and services.

With the implementation of the new General Data Protection Regulation (GDPR), as of May 25th 2018, APS states that it remains strongly committed to protect the user’s personal data and privacy protection and, to that extent, update its Privacy Policy in accordance with all the data protection principles and standards that underpin the GDPR.

In this document, we explain what personal data we use, how we can use them, how we treat them, with who we share them, for how long we keep them and how you can contact us to exercise your rights.

APS suggests and invites you to consult the dedicated pages to privacy and personal data protection.

GENERAL DATA PROTECTION REGULATION

The new GDPR establishes rules about how a person, a company or an organization processes the personal data from the people of the European Union (EU).

The GDPR protects the personal data regardless the technology used to process those data. The protection is neutral in the technological point of view and applies both to the automatic process and the manual process, as long as the data is organized according to pre-defined criteria (in alphabetical order, for example). The way the data is stored is also irrelevant. In all cases, personal data is always subject to the protection requirements established in the GDPR.

WHO IS RESPONSIBLE FOR THE DATA HANDLING?

The Conservatório Regional de Palmela, is the entity responsible for data handling .

PROTECTION OF DATA

The Conservatório Regional de Palmela, through its management, will ensure the protection of data of its associates and users and for this purpose will be the body that (i) provides information and advises the controller or the subcontractor about their obligations under privacy and data protection; (ii) controls the compliance of data processing with applicable standards; (iii) advises, when requested, on the impact assessment on data protection and controls its implementation; (iv) is a point of contact with the holder of personal data to clarify questions regarding the processing of their data by the Conservatório Regional de Palmela; and (v) is the contact point for the control authority (National Commission on Data Protection - CNPD) on treatment-related issues, cooperating with this entity.

The Direction of the Conservatório Regional de Palmela can be contacted through the e-mail info@fispalmela.com

TREATMENT OF PERSONAL DATA, SCOPE AND AMENDMENT OF PRIVACY POLICY

By making your personal data available to the Conservatório Regional de Palmela, the holder of personal data allows them to be treated in accordance with this Privacy Policy.

This Privacy Policy applies to data that have been directly provided by the respective holder or collected in accesses of the holder in the services of the Conservatório Regional de Palmela. Thus, it is advised that the digital platforms and services of the Conservatório Regional de Palmela have links to other digital platforms and refer to contents of third parties that are not covered by the Privacy Policy of the Conservatório Regional de Palmela. it is advisable that whenever the holder of personal data navigates on these platforms, he / she is informed of the contents of the respective privacy policies, as well as the applicable terms and conditions.

The Conservatório Regional de Palmela reserves the right to change its Privacy Policy, so we encourage you to consult this document regularly. If the Privacy Policy changes, we will post a notice on our website.

WHAT KIND OF INFORMATION DOES THE CONSERVATÓRIO REGIONAL DE PALMELA COLLECT?

The Conservatório Regional de Palmela collects two kinds of information: personal information and anonymous information. Anonymous information occurs while the holder of personal data visits the digital platforms and aims to improve the operation of the same, including the management and prioritization of content. Personal information is voluntarily provided by the holder of personal data at the time of the voluntary registration. All data collected is processed automatically, and the information collected from the holder of personal data is managed with advanced security.

The register serves the holder of personal data access to subscription services for newsletters, comments and other features provided by the Conservatório Regional de Palmela.

To provide certain services, the Conservatório Regional de Palmela may have to make personal and anonymous information available to third parties. This will only happen, however, in these specific circumstances:

  1. With the express consent of the holder of personal data;
  2. When in good faith we believe it is required by law;
  3. When in good faith we believe that it stems from contractual stipulation;
  4. When in good faith we believe it is necessary to protect our rights or property;

The consent of the holder of personal data shall not be required for disclosure in the situations referred to in points (b) to (d). In any event, we will attempt to notify you to the extent permitted by law.

WHAT ARE PERSONAL DATA?

Personal data is information relating to an identified or identifiable person. Any person who can be identified directly or indirectly is considered identifiable. Also personal data is the set of distinct information that may lead to the identification of a particular person.

Examples of personal data:

  • Name and Nickname;
  • Address of a residence;
  • E-mail address;
  • Number of an identification card;
  • Location data (for example, the location data function in a mobile phone);
  • IP address (internet protocol);
  • Cookies;
  • Your phone's advertising identifier;
  • data held by a hospital or doctor that unequivocally identifies a person;
  • Sound or picture.

WHO IS THE PERSONAL DATA HOLDER?

The holder of personal data is the natural person to whom the data relate and who used the digital platforms and services of the Conservatório Regional de Palmela.

CATEGORIES OF PERSONAL DATA

Examples (not exhaustive):

TYPES

DATA

Main Identifiers

Name, Civil or fiscal identification number, Passport number, date of birth, marital status, address, telephone number, e-mail address, nationality, photos and files of the mobile device, household data, data related to kinship.

Additional Identifiers

IBAN, geo-location, educational level, gender, occupation, socio-economic data, personal ID, IP address, social network addresses, mobile device type, operating system, operating system version.

Special protection

Personal data of children under 16 years.

WHY PURPOSES CAN THE CONSERVATÓRIO REGIONAL DE PALMELA TREAT YOUR PERSONAL DATA?

Examples (not exhaustive):

PURPOSES

DATA PROCESSING

Training actions

Interactive participation, participation in competitions, analysis of navigation profiles, adaptation and development of new products, content creation or information services (notifications, newsletters, digital platforms of programs and content apps).

Provision of information services

Analysis of browsing profiles, adaptation and development of new products, content or information services (notifications, newsletters, digital platforms and informative dossiers and content apps).

Content Development

Analysis of navigation profiles, products, adaptation and development of new products, contents or services.

Engineering, Systems and Technology

Technical responses and complaints.

Control of physical security of premises

Control of access to facilities, security in buildings by specialized technicians, video surveillance. Control of access to facilities, security in buildings by specialized technicians, video surveillance.

Marketing and Communication

Users of the digital platforms and services of the Conservatório Regional de Palmela.

Museological Nucleus

Registration for identification of the interested parties, ease of contact and registration of activities.

Files

Registration for requesting copies and licensing of contents and data for billing.

Institutional Relations

Registration of guests and visitors, sending invitations.

We will request your express consent before using the information for purposes other than those expressly set forth in this Privacy Policy.

WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect personal data, such as when you participate in the contents of the Conservatório Regional de Palmela (programs, masterclasses, concerts, internships, etc.) or purchase products or services from the Conservatório Regional de Palmela when downloading or using products, services and applications from Conservatório Regional de Palmela. The collection can be done orally, in writing or through the digital platforms of the Conservatório Regional de Palmela.

WHAT IS THE BASIS FOR THE TREATMENT OF YOUR PERSONAL DATA?

CONSENT

Your consent must be expressed - in writing, orally or through the validation of an option - and prior, provided in a free, informed, specific and unambiguous manner.

As examples: your consent to the Conservatório Regional de Palmela to analyze the use of the services and consumption profile or so that we can use the recording of the calls you make for our services. or

Specific: consent by minors (16 years)

In the case of the processing of the personal data of minors, who may be subject to prior consent, the Conservatório Regional de Palmela will require consent from the holders of parental responsibilities, namely for participation in hobbies.

EXECUTION OF CONTRACT AND PRE-CONTRACTUAL DILIGENCES

When the processing of personal data is necessary for the execution, execution and management of a contract signed with the Conservatório Regional de Palmela, such as for the acquisition of archival contents; or

COMPLIANCE WITH LEGAL OBLIGATION

When the processing of personal data is necessary to fulfill a legal obligation to which the Conservatório Regional de Palmela is subject, such as the communication of identification or traffic data to police, judicial, fiscal or regulatory entities or data of location to ensure emergency services; or

LEGITIMATE INTEREST

The processing of personal data by the Conservatório Regional de Palmela may be justified on grounds of legitimate interest related to the performance of the tasks related to its activity as a business, such as data processing for quality of service improvement, fraud detection and revenue protection and when our reasons for using it should prevail over your data protection rights.

HOW LONG DOES THE CONSERVATÓRIO REGIONAL DE PALMELA TREAT AND KEEP YOUR PERSONAL DATA?

The Conservatório Regional de Palmela treats and preserves your personal data according to the purposes for which they are processed and only for the period of time necessary for the fulfillment of the purposes that motivated their collection and conservation, and always in accordance with the law, the guidelines and decisions of the CNPD, or, whichever is applicable, until you exercise your right of opposition, right to be forgotten or withdraw consent.

There are situations in which the law determines the retention of data for a minimum period of time, namely: for one year, traffic and location data for the purpose of investigation, detection and prosecution of serious crimes or for 10 years the data necessary for information to the Tax Authority.

After the respective period of conservation has elapsed, the Conservatório Regional de Palmela will eliminate or anonymize the data whenever they are not to be kept for a different purpose that can survive.

RIGHTS OF THE PERSONAL DATA HOLDER

The holder of personal data has rights to information, access and rectification or erasure of personal data and the right to portability of data, the right to limit or oppose the processing of their data, within the scope and under the terms of the RGPD and other applicable legislation .

The holder may withdraw, at any time, the consent that he has given for the processing of his personal data, within the framework of the RGPD. The revocation of consent shall not affect the lawfulness of the processing of personal data hitherto made, based on the consent you have previously provided.

You also have the right to complain about the processing of your data to the CNPD.

Exercise your rights through the following contacts:

Email
info@fispalmela.com

Letter
Conservatório Regional de Palmela - Av. Dr. Juiz José Celestino Ataz 27, 2950-253 Palmela

The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive or unjustifiably reiterated request, in which case a reasonable fee may be charged against costs.

The reply to the request shall be made without undue delay within one month of receipt of the request, unless it is a particularly complex request or occurs in exceptional circumstances. This period may be extended by up to two months, where necessary, taking into account the complexity of the request and the number of applications received.

In the context of your request, you may be asked to prove your identity so as to ensure that the sharing of personal data is only done with its owner.

TRANSMISSION OF PERSONAL DATA

Personal data may be transmitted to subcontractors for processing in the name and on behalf of the Conservatório Regional de Palmela. In this case, the Conservatório Regional de Palmela will take the necessary contractual measures to ensure that subcontractors respect and protect the personal data of the holder.

Data may also be transmitted to third parties - entities other than the Conservatório Regional de Palmela or subcontractors - such as companies with which the Conservatório Regional de Palmela develops partnerships, if the holder has consented - or entities to whom the data be communicated by law, such as the Tax Authority, judicial authorities, criminal police agencies, among others.

The Conservatório Regional de Palmela may occasionally have to transfer its personal data to a third country outside the EU and not included in the list of countries which the EU has already considered to meet adequate levels of protection of personal data. In such cases, the Conservatório Regional de Palmela will ensure that data transfers are carried out in strict compliance with applicable legal standards.

WHAT SECURITY PROCEDURES GUARANTEE THE PROTECTION OF YOUR DATA?

The Conservatório Regional de Palmela takes all necessary and legally required precautions to ensure the privacy of personal data processed and / or transmitted through its digital platforms. These precautions ensure online and offline security of this information.

DOUBTS?

If you have any questions about any of the topics covered in this document, please contact us to:

Email

info@fispalmela.com

Letter

Conservatório Regional de Palmela | Av. Dr. Juiz José Celestino Ataz 27, 2950-253 Palmela

FISP - Festival Internacional de Saxofone de Palmela