Privacy Policy
Effective date: April 1, 2020
SCOPE OF THIS PRIVACY POLICY
We ask that you read this Privacy Policy (“Policy”) carefully to understand Sargento Martinho’s policies and practices regarding your Personal Data and the way in which they are treated.
This Policy explains how the Personal Data of Consumers is collected, used and disclosed by the entity to Sargento Martinho, as presented in the section on data controllers and contacts (Section 12) (“A Sargento Martinho”). It also includes information on how the Consumer can access and update their Personal Data and how to make certain choices about how their Personal Data is treated.
This policy covers 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. It should be noted that Sargento Martinho combines the Personal Data it collects through one method (for example, website) with the Personal Data it collects through another (such as Facebook and Instagram platforms).
If the Consumer does not provide the necessary Personal Data (Sargento Martinho will indicate when this is the case, for example, by making this information clear in the registration forms), Sargento Martinho may not be able to provide its goods and/or services. This Policy may change 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 HOW HE DOES IT
3. CHILDREN’S PERSONAL DATA
4. SIMILAR COOKIES/TECHNOLOGIES, LOG FILES AND WEB BEACONS
5. USE OF CONSUMER PERSONAL DATA
6. DISCLOSURE OF CONSUMER PERSONAL DATA
7. RETENTION OF CONSUMER PERSONAL DATA
8. STORAGE AND/OR TRANSFER OF CONSUMER PERSONAL DATA
9. ACCESS TO CONSUMER PERSONAL DATA
10. CONSUMER CHOICES ABOUT HOW SGT. MARTINHO USES AND DISCLOSES YOUR PERSONAL DATA
11. CHANGES TO SGT POLICY. MARTINHO
12. RESPONSIBLE FOR DATA PROCESSING AND CONTACT
1. SOURCES OF PERSONAL DATA
This Policy applies to all Personal Data that Sargento Martinho collects from and about the Consumer, through the methods described below (see Section 2), from the following sources:
Website Sargento Martinho. Consumer-oriented website operated by or for Sargento Martinho, including mini-sites that you use on third-party social networks, such as Facebook (“Websites”).
Email, text messages (SMS) and other electronic messages. Electronic communications between the Consumer and Sargento Martinho.
Data created by A Sargent Martinho. During the Consumer’s interactions with Sargento Martinho, we may create Personal Data about the Consumer (for example, records of purchases made on our website).
Data from other sources. Third party social networks (e.g. Facebook, Google) or market research (if feedback is not provided anonymously).
2. PERSONAL DATA THAT SGT. MARTINHO COLLECTS ABOUT THE CONSUMER AND HOW HE DOES IT
Depending on how the Consumer interacts with Sargento Martinho (online, offline, over the phone, etc.), 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 him, such as name, postal address, email address, social media details or telephone number.
Account access information. Any information required to access the Consumer’s account profile. This may include the login ID/email address, user name, password in unrecoverable form and/or the Consumer’s security question and answer.
Demographic information and interests. Any information that describes the Consumer’s demographic or behavioral characteristics. This may include the Consumer’s date of birth, age or age range, gender, geographic location (eg zip code), favorite products, hobbies, interests, and household and lifestyle information.
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 browser icon. If the Consumer accesses the website via a mobile device such as a smartphone, the information collected will also include, where permitted, the unique device ID, the identification of the advertising, geographic location and other similar mobile device data.
Information about the use of Websites/communications. When the Consumer navigates through Sargento Martinho’s Website or newsletters, interacting with them, 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 about their interactions, such as page response times, download errors and length of visits to certain pages. This information is collected 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 oppose 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 Sargento Martinho about their experience in using the products and services it offers.
Consumer Generated Content. Refers to any content that the Consumer creates and then shares with Sargento Martinho on third-party social networks or uploads to Sargento Martinho’s website, including the use of third-party social networking applications, such as Facebook. Examples may include photographs, videos, personal stories or other similar media and content. Where permitted, Sargento Martinho may collect and post Consumer-generated content relating to a variety of activities, including contests and other promotions, website attributes, Consumer engagement, and third-party social media.
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 their profile on a third-party social network (such as Facebook) and that the Consumer allows the third-party social network to share with Sargento Martinho . 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 third-party social network to share. Sargento Martinho receives information from the Consumer’s profile from the third-party social network (or parts thereof) whenever he downloads or interacts with a Sargento Martinho application on a third-party social network, such as Facebook, whenever he uses a social network integrated into the A Sargento Martinho website (such as Facebook) or whenever you interact with Sargento Martinho through a third-party social network. For more information on how Consumer information on a third-party social network is collected by Sargento Martinho or to opt out of sharing such information from social networks, please 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 your debit or credit card details (holder name, card number, expiration date, etc.) or other forms of payment ( if available). In any case, Sargento Martinho or its payment processing service providers handle payment and financial information in compliance with applicable laws, regulations and security standards, such as PCI DSS.
Sensitive Personal Data. Sargento Martinho does not seek to collect or process sensitive personal data in the normal course of business. When it proves necessary to process sensitive personal data of the Consumer for any reason, Sargento Martinho only does so in cases where the Consumer has voluntarily provided prior express consent (for example, for marketing purposes). If 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) in compliance with applicable law (for example, to comply with Sargento Martinho’s diversity reports).
3. CHILDREN’S PERSONAL DATA
We do not solicit or voluntarily 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, Sargento Martinho may collect personal data about children under the age of 13 by parents or a legal guardian who expressly consents to such collection.
4. SIMILAR COOKIES/TECHNOLOGIES, LOG FILES AND WEB BEACONS
Cookies/similar technologies. Consult our Cookies Policy to find out how you can manage your cookie settings and for detailed information about the cookies that Sargento Martinho uses, as well as the purposes for which they are used.
Registry Files. 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 Sargento Martinho to solve errors, improve the performance and maintain the security of its website.
Web Beacons. Web beacons (also known as “web bugs”) are small sequences of code that provide a graphic image on a web page or in an email with the aim of transferring information back to Sargento Martinho. Information collected through web beacons will include information such as IP address and information about how the Consumer responds to an email campaign (for example, what time was the email opened, which links the Consumer clicked on in the email, etc.). Sargento Martinho will use web beacons on its websites or will include them in emails sent to the Consumer. Sargento Martinho uses information from web beacons for various purposes, including, but not limited to, reporting on website traffic, counting unique visitors, auditing and reporting on emails, advertising and personalization.
5. USE OF CONSUMER PERSONAL DATA
The following paragraphs describe the different purposes for which Sargento Martinho collects and uses the Consumer’s 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 to everyone.
· Fulfillment of contractual obligations;
· Compliance with legal obligations;
· Sergeant Martinho’s legitimate interests;
· Improve and develop products and services;
· Make Sargento Martinho more efficient;
· Protect Sargento Martinho’s assets and personnel;
6. DISCLOSURE OF CONSUMER PERSONAL DATA
In addition to Sargento Martinho’s entity or ad-hoc partners in the country (responsible for Sargento Martinho’s operations) mentioned in the data controllers and contacts section (see Section 12), Sargento Martinho shares Consumer Personal Data with following organizations:
Service providers. These are external companies that 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, support, promotions, website development, data analysis, SAC, etc.). Service providers and their selected team are only allowed to access and use the Consumer’s Personal Data in the name and on behalf of Sargento Martinho, for the specific tasks requested of them, based on the instructions given by Sargento Martinho, being obliged to keep Consumer Personal Data confidential and secure. When required by applicable law, the Consumer may obtain a list of suppliers that process their Personal Data (see Section 12 to contact Sargento Martinho).
Credit/collection reporting agencies. To the extent permitted by applicable law, credit reporting and collection agencies are external companies that Sargento Martinho uses for assistance in verifying the Consumer’s creditworthiness (in particular for orders with an invoice) or to collect outstanding invoices.
Third-party companies using Personal Data for their own marketing purposes. Sargento Martinho does not license or sell the Consumer’s Personal 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 when the Consumer’s authorization is requested.
Third party recipients using Personal Data for legal reasons or due to merger/acquisition. 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 CONSUMER PERSONAL DATA
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 the Consumer’s Personal Data are as follows:
a) Sargento Martinho will keep copies of the 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 newsletter sending list and has not stopped subscribing to it); ii. The period in which Personal Data is necessary in connection with the purposes set out in this Privacy Policy and Sargento Martinho has a legal basis to keep them;
Also adds,
b) The duration of: i) any applicable legal period (e.g. period legally foreseen for the Consumer to bring a lawsuit) and ii) an additional period of 2 months after the period described above (so that Sargento Martinho can identify any Personal Data of a consumer who may bring a lawsuit after the period provided for in i), and
c) Additionally, if any relevant legal actions are brought, Sargento Martinho may continue to process the Consumer’s Personal Data during the necessary period of the respective legal action.
During the situations described in sub-paragraphs b) i) and b) ii), Sargento Martinho will restrict data processing to storage and apply the respective security measures, except if such Personal Data needs to be reviewed or accessed following any complaint. or any legally foreseen obligation.
After the periods provided for in subparagraphs a), b) and c) are completed, Sargento Martinho will permanently delete or destroy the Consumer’s Personal Data or, alternatively, may anonymize them.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF CONSUMER PERSONAL DATA
Sargento Martinho uses several reasonable measures (described below) to keep Consumer Personal Data confidential and secure. It should be noted, however, that such protections do not apply to information that the Consumer chooses to share in public areas, such as third-party social networks.
Persons who may access Consumer Personal Data. The Consumer’s Personal Data will be processed by employees of Sargento Martinho or by authorized service providers, accessing only the strictly necessary data, depending on the specific purposes for which the Consumer’s Personal Data were collected (for example, the team responsible for matters of Consumer support will have access to the Consumer register).
Measures applied in operational environments. Sargento Martinho stores Consumer Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. Sargento Martinho follows reasonable rules to protect Personal Data. The transmission of information over the Internet is unfortunately not completely secure and, although Sargento Martinho makes every effort to protect the Consumer’s Personal Data, it cannot guarantee the security of data during transmission through Sargento Martinho’s websites or applications. .
Measures that the Consumer must adopt. It is important that the Consumer also takes an active role in keeping their Personal Data safe and secure. When registering for an online account, the Consumer must choose a password that is difficult for others to guess and never reveal his 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 must never select the option to remember his access data, e-mail or password and make sure he logs out whenever he leaves the computer. The Consumer must also make use of any privacy settings or controls that 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 held about him. The Consumer also has the right to request information about the origin of their Personal Data.
These rights can be exercised by sending us an email to info@sgtmartinho.com or to Sargento Martinho, Rua Pinto Ferreira, 16 A Lj2, 1300-461 Lisbon, 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 (eg modification, deletion of Personal Data). When provided for by law, the Consumer may (i) request the deletion, portability, correction or revision of their Personal Data; (ii) limit the use and disclosure of Personal Data; and (iv) revoke consent for any of Sargento Martinho’s data processing activities.
Under the terms of the applicable legislation, the Consumer also has the following rights regarding their Personal Data:
• The right to object, based on the Consumer’s particular situations, to the use of Personal Data by Sargento Martinho, or his representatives;
• The right to object to the processing of Personal Data by Sargento Martinho or its representatives for direct marketing purposes.
Note that, under certain circumstances, Sargento Martinho will not be able to delete the Consumer’s Personal Data without also deleting his user account. Sargento Martinho may be obliged to retain some of the Consumer’s Personal Data after the Consumer has requested its deletion, in order to satisfy its contractual or legal obligations. Sargento Martinho may also be authorized by applicable laws to retain some of the Consumer’s Personal Data to satisfy its business needs.
When available, the Sargento Martinho website has a dedicated tool through which the Consumer can review and edit the Personal Data that he/she has provided. Please note that Sargento Martinho requires its registered Consumers to confirm their identity (eg 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’s account.
Sargento Martinho hopes to be able to satisfy any question that the Consumer may have about how we handle their Personal Data. However, if the Consumer has unresolved doubts/questions, he also has the right to complain to the competent data protection authorities.
10. CONSUMER CHOICES ABOUT HOW SGT. MARTINHO USES AND DISCLOSES YOUR PERSONAL DATA
Sargento Martinho strives to give the Consumer options related to the Personal Data that he/she 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) 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 may consent to Sargento Martinho using his/her Personal Data to promote its products or services, which may be indicated through the respective relevant checkbox(es) located on the registration form or answering the questions presented by the commercial demonstrators, Collaborators of the SAC. If the Consumer decides that they no longer wish to receive such communications, they may unsubscribe from marketing-related communications at any time by 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 may deactivate them at any time by accessing the website/application or third-party social networks and adjusting their user preferences in the account profile, unchecking the relevant boxes or by calling Sargento Martinho’s SAC. Note that, even if the Consumer chooses not to receive marketing communications, he will still receive operational communications from Sargento Martinho, such as order confirmations or other transactions, notifications about account activities (for example, account confirmations, changes password, etc.) and other important non-marketing related announcements
Personalization (offline and online): Whenever required by law, if the Consumer wants their Personal Data to be used by Sargento Martinho to provide them with a personalized experience/advertising and targeted content, they can indicate this through the box(es)( s) of relevant verification(s) on the application form or by answering the question(s) presented by the commercial demonstrators or the SAC. If the Consumer decides that he no longer wishes to benefit from such a situation, he may cancel the receipt at any time by accessing the website/application and adjusting his user preferences in the account profile, unchecking the relevant boxes or calling Sargento Martinho’s SAC .
Interest-based advertising. Sargento Martinho partners with ad networks and other ad serving providers (“Advertising Providers”) that serve advertisements on behalf of Sargento Martinho and on behalf of other unaffiliated companies on the Internet. Some of these advertisements are tailored to the interests of the Consumer based on information collected on Sargento Martinho websites or on unaffiliated websites over time. The Consumer may also opt out of the collection of accurate location data from their mobile device through their mobile device’s location services settings.
11. CHANGES TO THE SGT POLICY. MARTINHO
Sargento Martinho will update this privacy policy if it changes the way it handles Consumer Personal Data. Sargento Martinho reserves the right to make changes to its practices and this Policy at any time; Please check back regularly for any updates or changes to the Sargent Martinho policy.
12. RESPONSIBLE FOR DATA PROCESSING AND CONTACT
To ask questions or comments about this policy and Sargento Martinho’s privacy practices or to file a complaint about Sargento Martinho’s compliance with applicable privacy laws, please contact Sargento Martinho at: info@sgtmartinho.com or postal letter to Sargento Martinho, Rua Pinto Ferreira, 16 A Lj2, 1300-461 Lisbon.
Sargento Martinho will confirm receipt and investigate any complaint about the way in which it processes Personal Data (including complaints alleging that Sargento Martinho has violated the Consumer’s rights under applicable privacy laws).