Privacy Policy

Effective Date: April 1, 2020

SCOPE OF THIS PRIVACY POLICY

We ask you to read this Privacy Policy (“Policy”) carefully to understand A Sargento Martinho’s policies and practices regarding your Personal Data and how it is handled.

This Policy explains how the Personal Data of Consumers are collected, used and disclosed by the entity to A Sargento Martinho, as presented in the section responsible for data processing and contacts (Section 12) (“A Sargento Martinho”). It also includes information on how the Consumer will be able to access and update his Personal Data and how to make certain choices about the way his Personal Data is treated.

This policy covers A Sargento Martinho’s online and offline data collection activities, including Personal Data that it collects through various channels, such as websites, third-party social networks, Consumer support services, points of sale and events. Note that A Sargento Martinho combines the Personal Data it collects through one method (for example, website) with the Personal Data it collects through another method (such as Facebook and Instagram platforms).

If the Consumer does not provide the necessary Personal Data (A Sargento Martinho will indicate when applicable, for example, by making this information clear on the registration forms), A Sargento Martinho may not be able to supply his goods and / or services. This Policy may be changed from time to time (see Section 11).

This Policy provides important information in the following areas:

1. SOURCES OF PERSONAL DATA

2. PERSONAL DATA THAT SGT. MARTINHO COLLECTS ABOUT THE CONSUMER AND THE WAY IT DOES IT

3. PERSONAL DATA OF CHILDREN

4. COOKIES / SIMILAR TECHNOLOGIES, REGISTRATION FILES AND WEB BEACONS

5. USE OF PERSONAL CONSUMER DATA

6. DISCLOSURE OF PERSONAL CONSUMER DATA

7. RETENTION OF PERSONAL DATA FROM THE CONSUMER

8. STORAGE AND / OR TRANSFER OF CONSUMER’S PERSONAL DATA

9. ACCESS TO PERSONAL CONSUMER DATA

10. CONSUMER’S CHOICES ON HOW SGT. MARTINHO USES AND DISCLOSES HIS PERSONAL DATA

11. CHANGES TO THE SGT POLICY. MARTINHO

12. RESPONSIBLE FOR DATA AND CONTACT PROCESSING

1. SOURCES OF PERSONAL DATA

This Policy applies to all Personal Data that A Sargento Martinho collects from and about the Consumer, using the methods described below (see Section 2), from the following sources:

Website A Sargento Martinho. Consumer-oriented website operated by or for A Sargento Martinho, including mini-sites that it uses on third-party social networks, such as Facebook (“Websites”).

E-mail, text messages (SMS) and other electronic messages. Electronic communications between the Consumer and A Sargento Martinho.

Data created by A Sargento Martinho. In the course of the consumer’s interactions with A Sargento Martinho, we may create Personal Data about the same (for example, records of purchases made on our website).

Data from other sources. Third party social networks (for example, Facebook, Google) or market research (if feedback is not provided anonymously).

2. PERSONAL DATA THAT SGT. MARTINHO COLLECTS ABOUT THE CONSUMER AND THE WAY IT DOES IT

Depending on how the Consumer interacts with A Sargento Martinho (online, offline, on the phone, etc.), A Sargento Martinho collects various types of information, as described below.

Personal contact details. This includes any information provided by the Consumer, which allows A Sargento Martinho to contact you, such as name, postal address, e-mail address, social media details or telephone number.

Account access information. Any information required to access the Consumer account profile. This may include the login ID / email address, username, password in unrecoverable form and / or Consumer security question and answer.

Demographic information and interests. Any information that describes the consumer’s demographic or behavioral characteristics. This may include the date of birth, age or age group, gender, geographic location (for example, postal code), favorite products, hobbies, interests and household information and consumer lifestyle.

Technical information about the computer / mobile device. Any information about the computer system or other technological devices that the Consumer uses to access the Website, such as the Internet protocol (IP) address used to connect the Consumer’s computer or device to the Internet, type of operating system and type and version Internet browser. If the Consumer accesses the website through a mobile device, such as a smartphone, the information collected will also include, when allowed, the unique device ID, advertising identification, geographic location and other similar device data

mobile asset.

Information on the use of websites / communications. When the Consumer browses through the A Sargento Martinho website or newsletters, interacting with them, A Sargento Martinho uses automatic data collection technologies to collect certain information about the Consumer’s actions. This includes information such as the links the Consumer clicks on, the pages or content they view and for how long, and other similar information and statistics on their interactions, such as page response times, download errors and duration of visits to certain pages. This information is captured using automated technologies such as cookies (browser cookies, flash cookies) and web beacons; information also collected through the use of third party tracking. The Consumer has the right to object to the use of such technologies. For more details, see Section 4.

Market research and Consumer feedback. This includes information that the Consumer voluntarily shares with A Sargento Martinho about its experience in using the products and services it offers.

Consumer generated content. Refers to any content that the Consumer creates and then shares with A Sargento Martinho on third party social networks or sends to the A Sargento Martinho website, including the use of third party social media applications, such as Facebook. Examples may include photographs, videos, personal stories or other similar media and content. When permitted, A Sargento Martinho may collect and publish content generated by the Consumer relating to a variety of activities, including contests and other promotions, website attributes, Consumer involvement and third party social networks.

Third party social media information. Refers to any information that the Consumer publicly shares on a third party social network or information that forms part of its profile on a third party social network (such as Facebook) and that the Consumer allows the third party social network to share with Sgt. Martin. Examples include basic Consumer account information (eg name, email address, gender, date of birth, current city, profile picture, user ID, friends list, etc.) and any other additional information or activities that the Consumer allows the social network of third parties to share. A Sargento Martinho receives the Consumer profile information from the third-party social network (or parts of them) whenever it downloads or interacts with an A Sargento Martinho application on a third-party social network, such as Facebook, whenever it uses a social networking feature integrated on the A Sargento Martinho website (such as Facebook) or whenever it interacts with A Sargento Martinho through a third party social network. For more information on how Consumer information on a third party social network is obtained by A Sargento Martinho or to disable sharing of that information from social networks, visit the relevant third party social network website.

Payment and financial information. Any information necessary to complete an order or that the Consumer uses to make a purchase, such as debit or credit card details (name of the holder, card number, expiration date, etc.) or other forms of payment ( if available). In any case, A Sargento Martinho or its payment processing service providers handles payment and financial information in accordance with applicable laws, regulations and security standards, such as the PCI DSS.

Sensitive Personal Data. A Sargento Martinho does not seek to collect or process sensitive personal data in the normal course of activity. When it becomes necessary to process the consumer’s sensitive personal data for any reason, A Sargento Martinho only does so in cases where the Consumer voluntarily gave his prior express consent (for example, for marketing purposes). If A Sargento Martinho processes the consumer’s sensitive personal data for other purposes, it only does so based on the following grounds: (i) detection and prevention of illegal activities (including fraud prevention); and (ii) compliance with applicable law (for example, to comply with A Sargento Martinho’s diversity reports).

3. PERSONAL DATA OF CHILDREN

We do not voluntarily request or collect personal data from children under the age of 13. If we discover that we have inadvertently collected personal data from a child under the age of 13, we will immediately delete that child’s personal data from our records. However, A Sargento Martinho may collect personal data about children under the age of 13 by their parents or a legal guardian who expressly consents to such collection.

4. COOKIES / SIMILAR TECHNOLOGIES, REGISTRATION FILES AND WEB BEACONs

Cookies / similar technologies. See our Policy

of Cookies to find out how you can manage your cookie settings and for detailed information about the cookies that A Sargento Martinho uses, as well as the purposes of their use.

Log files. A Sargento Martinho may collect information in the form of log files that record activity on the website and collect statistics on the consumer’s browsing habits. These entries are automatically generated and help A Sargento Martinho to resolve errors, improve performance and maintain the security of his website.

Web Beacons. Web beacons (also known as “web bugs”) are small strings of code that provide a graphic image on a web page or in an email in order to transfer information back to A Sargento Martinho. Information collected through web beacons will include information such as the IP address and information about how the Consumer responds to an email campaign (for example, what time the email was open, what links the Consumer clicked on email, etc.). A Sargento Martinho will use web beacons on its websites or will include them in the emails it sends to the Consumer. A Sargento Martinho uses information from web beacons for various purposes, including, but not limited to, reports on website traffic, counting unique visitors, auditing and reporting on emails, advertising and personalization.

5. USE OF PERSONAL CONSUMER DATA

The following paragraphs describe the various purposes for which A Sargento Martinho collects and uses Consumer Personal Data, as well as the different types of Personal Data that are collected for each purpose. Note that not all uses below will be relevant for everyone.

· Compliance with contractual obligations;

· Compliance with legal obligations;

· A Sargento Martinho’s legitimate interests;

· Improve and develop products and services;

· Make A Sargento Martinho more efficient;

· Protect A Sargento Martinho’s assets and personnel;

6. DISCLOSURE OF PERSONAL CONSUMER DATA

In addition to the A Sargento Martinho entity or ad-hoc partners in the country (responsible for the operations of A Sargento Martinho) mentioned in the section responsible for data processing and contacts (see Section 12), A Sargento Martinho shares the Personal Data of the Consumer with the following organizations:

Service providers. These are external companies that A Sargento Martinho uses for assistance and support in its business (for example, order processing, payment processing, fraud detection and identity verification, website operation, market research companies, services support, promotions, website development, data analysis, SAC, etc.). Service providers and their selected team are only allowed to access and use Personal Consumer Data in the name and on behalf of A Sargento Martinho, for the specific tasks requested of them, based on the instructions given by A Sargento Martinho, being obliged to keep Consumer Personal Data confidential and secure. When required by applicable law, the Consumer will be able to obtain a list of the suppliers who handle his Personal Data (see Section 12 to contact A Sargento Martinho).

Credit / collection information agencies. To the extent permitted by applicable law, credit and collection information agencies are external companies that A Sargento Martinho uses to assist in verifying the consumer’s creditworthiness (in particular for orders with invoices) or to collect outstanding invoices.

Third party companies using Personal Data for their own marketing purposes. A Sargento Martinho does not license or sell Personal Consumer Data to third party companies for their own marketing purposes, except in situations where the Consumer has given consent. The identity of these third parties will be disclosed at the time the Consumer authorization is requested.

Third party recipients using Personal Data for legal reasons or due to merger / acquisition. A Sargento Martinho will disclose Consumer Personal Data to third parties for legal reasons or in the context of an acquisition or merger (see Section 5 for more details).

7. RETENTION OF PERSONAL DATA FROM THE CONSUMER

A Sargento Martinho will take reasonable measures to ensure that Personal Data will only be processed for the time necessary to satisfy the purposes set out in this Privacy Policy. The criteria for determining the retention period of Consumer Personal Data are as follows:

a) A Sargento Martinho will keep copies of Personal Data in a form that allows identification during: i. The duration of the relationship with the Consumer (eg, when the Consumer is included in a list of newsletters and has not stopped subscribing); ii. The period in which Personal Data

they are necessary in connection with the purposes set out in this Privacy Policy and A Sargento Martinho has a legal basis to maintain them;

In addition,

b) The duration of: i) any applicable legal period (ex .: period legally provided for the Consumer to bring a lawsuit) and ii) an additional period of 2 months after the period described above (so that Sgt Martinho can identify any Personal Data of a consumer who may take legal action after the period provided for in i), and

c) In addition, if any relevant lawsuits are brought, A Sargento Martinho may continue to process the Consumer Personal Data for the necessary period that the respective lawsuit lasts.

During the situations described in subparagraphs b) i) and b) ii), A Sargento Martinho will restrict the processing of data to storage and to apply the respective security measures, unless such Personal Data needs to be reviewed or accessed following any complaint or any legally required obligation.

After the periods foreseen in subparagraphs a), b) and c) are completed, A Sargento Martinho will permanently delete or destroy the Personal Data of the Consumer or, alternatively, it may also anonymize them.

8. DISCLOSURE, STORAGE AND / OR TRANSFER OF CONSUMER’S PERSONAL DATA

A Sargento Martinho uses several reasonable measures (described below) to keep Consumer Personal Data confidential and secure. Note, however, that such protections do not apply to information that the Consumer chooses to share in public areas, such as third party social networks.

People who can access Consumer Personal Data. Consumer Personal Data will be processed by employees of A Sargento Martinho or by authorized service providers, accessing only the data strictly necessary, depending on the specific purposes for which the Consumer Personal Data was collected (for example, the team responsible for matters Consumer support will have access to the Consumer register).

Measures applied in operational environments. A Sargento Martinho stores Consumer Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. A Sargento Martinho follows reasonable rules to protect Personal Data. The transmission of information over the Internet is unfortunately not completely secure and, although A Sargento Martinho makes every effort to protect Consumer Personal Data, it cannot guarantee the security of the data during transmission through Sgt’s websites or applications. Martin.

Measures that the Consumer must adopt. It is important that the Consumer also takes an active role in keeping their Personal Data safe and protected. When signing up for an online account, the Consumer must choose a password that is difficult for others to guess and never reveal their password to anyone. The Consumer is responsible for any use of his account and for keeping that password confidential. If the Consumer uses a shared or public computer, he should never select the option to remember his access data, email or password and make sure that he logs out each time he leaves the computer. The Consumer must also make use of any privacy settings or controls that A Sargento Martinho provides on its website or applications.

9. CONSUMER RIGHTS REGARDING YOUR PERSONAL DATA

Access to personal data. The Consumer has the right to access, review and request a physical or electronic copy of the information kept on it. The Consumer also has the right to request information about the origin of his Personal Data.

These rights can be exercised by sending us an email to [email protected] or to A Sargento Martinho, Rua Pinto Ferreira, 16 A Lj2, 1300-461 Lisboa, with proof of identification. If the order is submitted by a person other than the Consumer, without providing evidence that the order was legitimately placed on their behalf, it will be rejected.

Please note that any identifying information provided to A Sargento Martinho will only be treated in accordance with and to the extent permitted by applicable law.

Additional rights (for example, modification, deletion of Personal Data). When provided by law, the Consumer may (i) request the deletion, portability, correction or revision of his Personal Data; (ii) limit the use and disclosure of Personal Data; and (iv) revoke consent for any of A Sargento Martinho’s data processing activities.

Under the terms of the applicable legislation, the Consumer also has the following rights regarding his Personal Data:

• The right of opposition, based on the consumer’s particular situations, in the use of Personal Data by A Sargento Martinho, or its representatives;

• The right to opposition to the treatment of Personal Data by A Sargento Martinho or its representatives for the purposes of direct marketing.

Please note that, in certain circumstances, A Sargento Martinho will not be able to delete Consumer Personal Data without also deleting his user account. A Sargento Martinho may be required to retain some of the Consumer’s Personal Data after requesting the elimination, in order to satisfy its contractual or legal obligations. A Sargento Martinho may also be authorized by applicable laws to retain some of the Consumer Personal Data to satisfy its business needs.

When available, the A Sargento Martinho website has a dedicated tool through which the Consumer will be able to review and edit the Personal Data he has provided. Please note that A Sargento Martinho requires its registered Consumers to confirm their identity (for example, login ID / email address, password) before they can access or make changes to their account information. This helps to prevent unauthorized access to the Consumer account.

A Sargento Martinho expects to be able to satisfy any question that the Consumer has about the way we treat his Personal Data. However, if the Consumer has unresolved doubts / issues, it also has the right to complain to the competent data protection authorities.

10. CONSUMER’S CHOICES ON HOW SGT. MARTINHO USES AND DISCLOSES HIS PERSONAL DATA

A Sargento Martinho strives to give the consumer options related to the Personal Data that he provides. The following mechanisms provide the Consumer with the following control over their Personal Data:

Cookies / similar technologies. The Consumer manages his consent through (i) A Sargento Martinho’s consent management solution or (ii) his browser, to refuse all or some cookies / similar technologies, or to receive alerts when they are being used. See Section 4 above.

Advertising, marketing and promotions. The Consumer can consent to A Sargento Martinho using his Personal Data to promote his products or services, he may indicate this through the relevant checkbox (es) located on the form registration or answering the questions presented by the commercial demonstrators, Employees of the SAC. If the Consumer decides that it does not wish to continue receiving such communications, it may unsubscribe from marketing-related communications at any time, following the instructions provided in each communication. In order not to receive marketing communications sent by any means, including third party social networks, the Consumer can disable them at any time by accessing the third party website / application or social networks and adjusting their user preferences in the account profile, deselecting the relevant boxes or by calling A Sargento Martinho’s Customer Service. Please note that even if the Consumer chooses not to receive marketing communications, it will still receive operational communications from A Sargento Martinho, such as order confirmations or other transactions, notifications about account activities (e.g., account confirmations, password changes, etc.) and other important non-marketing ads

Personalization (offline and online): Whenever required by law, if the Consumer wants his Personal Data to be used by A Sargento Martinho to provide him with a personalized experience / advertising and targeted content, he can indicate it through the box (es) relevant verification (s) on the registration form or by answering the question (s) presented by the commercial demonstrators or SAC. If the Consumer decides that he does not want to benefit from this situation anymore, he can cancel the reception at any time, accessing the website / application and adjusting his user preferences in the account profile, clearing the relevant boxes or calling the Sgt SAC. Martin.

Interest-based advertising. A Sargento Martinho has partnerships with ad networks and other ad serving providers (“Advertising Suppliers”) that serve advertising on behalf of A Sargento Martinho and on behalf of other non-affiliated companies on the Internet. Some of these advertisements are adapted to the interests of the Consumer based on information collected on the websites of A Sargento Martinho or on websites not affiliated over time. The Consumer may also interrupt the collection of accurate location data from his mobile device through the location services settings of his mobile device.

11. CHANGES TO THE SGT MARTINHO POLICY.

A Sargento Martinho will update this privacy policy if it changes the way it treats Consumer Personal Data. A Sargento Martinho reserves the right to make changes to its practices and this Policy at any time; check regularly to consult any updates or changes to the A Sargento Martinho policy.

12. RESPONSIBLE FOR DATA PROCESSING AND CONTACT

To ask questions or comments about this policy and about A Sargento Martinho’s privacy practices or to submit a complaint about A Sargento Martinho’s compliance with applicable privacy laws, please contact A Sargento Martinho at: [email protected] or postal letter to A Sargento Martinho, Rua Pinto Ferreira, 16 A Lj2, 1300-461 Lisbon.

A Sargento Martinho will confirm receipt and investigate any complaints about how it processes Personal Data (including complaints alleging that A Sargento Martinho has violated Consumer rights under applicable privacy laws).