The Luso-American Development Foundation (FLAD) has the priority of protecting the privacy of all users of its website and for that purpose has drawn up this privacy policy.

In particular, the processing of personal data carried out by FLAD is governed by the following principles: lawfulness, loyalty, and transparency in data processing; purpose limitation; data minimization; accuracy; storage limitation; integrity, confidentiality, and responsibility.

With the aim of ensuring its commitment towards the privacy of its users, FLAD has adopted the best practices for security and protection of personal data, in the best terms set out below.

Therefore, in order to ensure that all personal data is treated and protected in accordance with the General Data Protection Regulation, we ask that you read our privacy and data protection policy with the utmost attention.

It is essential that you read and give your express consent for the storage and processing of your personal data, in order to authorize the sending of communications in accordance with the rules defined herein.

Additionally, it is important to inform you that simply accessing FLAD’s website does not necessarily imply collecting personal data.  

 

Chapter One

Personal Data

I. Which data is processed and how is it collected?

FLAD only collects adequate, relevant data that are limited to what is strictly necessary for the proposes for which FLAD processes such data.

As regard applicants, suppliers, partners, employees and collaborators, FLAD shall only collect the following personal data: identification data, professional data, professional activity data, accountancy data, own personal data in the case of natural persons, or data of their representatives in case of legal persons, such as the name, nationality, contact details, citizen card details, position, duties, professional contacts and well as any other personal data whose treatment is strictly necessary for the performance of the contract or compliance with legal obligations.

With regard to contact requests, FLAD collects the following personal data: identification data such as name, email address, address, telephone or mobile phone number.

About the newsletter subscription, FLAD collects the following personal data: identification data such as an email address.

For applications, FLAD collects the following personal data: identification data such as name, email address and any data contained in the curriculum vitae.

Personal data is collected by various means, in particular, by filling out forms available on FLAD’s website, the sending of messages by email, telephone contact details, the handing over of a personal card, the call for applications, the sending of professional applications, and the hiring of services by or for FLAD.

FLAD may only process health data if duly appointed for that purpose and only with the consent of the data subjects.

 

II. Entity responsible for personal data processing 

The Luso-American Development Foundation, a charitable foundation established under private law, with the CITN (Corporate Identification Number) 501 526 307, whose head office is situated at Rua do Sacramento à Lapa nº 21, 1249-090 Lisbon, is the entity responsible for the collection and processing personal data for the purposes set out in this privacy policy.

If you deem that the information provided in this privacy policy is not clear enough, or for any other reason you regard it as relevant, please contact us by email fladport@flad.pt.

In order to contact the person responsible for matters relating to data protection at FLAD, send an email to dados@flad.pt.

 

III. What is the lawful basis and the purposes for processing personal data?

The legal basis for processing the personal data of applicants, suppliers, partners, employees, and collaborators, is the performance of a contract with a legal obligation, as provided for in Article 6 (1) (b) and (c) of the GDPR.

The processing of personal data of applicants, suppliers, partners, employees, and collaborators is intended for any purpose directly related to the performance of the contract concerned or compliance with legal obligations, namely, recruitment, hiring, contract management, accountancy, commercial activity, applicant management, communication, receiving proposals, and services provision.

The treatment of personal data for purposes other than those stated above, namely, personal data collected through FLAD’s website or through following the sending of email messages with contact requests, cannot be carried out without the consent of data subject as laid down in Article 6 (a) of GDPR.

Processing of personal data collected through FLAD’s website or email address is intended to provide a reply to contact requests, namely, sending proposals/budgets and other information on the promotion of scientific, technical, educational, commercial and business cooperation, to send marketing communications such as newsletters, event information, and other related activities, as well as recruitment.

 

IV. Personal data storage 

FLAD only retains personal data in a way that allows the identification of the data subjects for as long as it is strictly necessary for the purpose for which the data is processed, without prejudice to the need for storing the data for longer periods to meet legal compliance obligations.

Thus, it is important to clarify that personal data related to the recruitment and selection of applicants may be kept for as long as necessary for fulfilling its purposes (for example, should an applicant be involved in FLAD projects, their personal data will be processed in accordance with the human resource management purpose; otherwise, such data may be kept in reserve for future recruitment processes for a year, without prejudice to the data subject’s right to request the erasure of his data at any time).

When the requests are made through our contact form, the personal data is eliminated after the reply to the contact request, always six months after submission of the contact request.

When the personal data is collected through subscribing to the Newsletter, data is erased after 6 months, counting from the day the unsubscribing request is made.

However, for compliance with legal obligations regarding the storage of books, accounting records, and supporting documentation thereof, the personal data may be kept for archiving purposes during a 12-year period under the terms of Article 23 (4), of the Portuguese Corporate Income Tax Code.

 

V. Data subjects rights 

FLAD guarantees for every user, at any given time, the right of access to personal data, as well as their rectification, erasure, portability,  limitation and, or, the right to object to processing.

To that end, you may exercise any of these rights by writing to FLAD at the address of its head office or at the following email address dados@flad.pt.

Additionally, the user may lodge whatever complaints they may deem necessary with the competent authority for that purpose.

 

VI. Right to be forgotten

The data subject has the right to obtain, from the controller the erasure of his or her personal data, who, in turn, has the obligation to erasure such data whenever one of the following grounds apply:

(i) the data is no longer needed for their original collection or processing purpose;

(ii) the data subject has withdrawn his or her consent, when consent forms the legal basis or the data subject objects to the processing and there are no longer any overriding legitimate interests that justify their retention.

 

VII. Security personal data processing 

FLAD is committed to implementing all precautions necessary for preserving the confidentiality and security of the personal data collected and processed.  With this in mind, technical and organizational security measures have been developed, especially in regard to information systems.

FLAD would like to inform you that the said security measures shall be reviewed and updated according to the needs and demands of these matters.

In the event, for whatever reason, of a breach of security which either accidentally or unlawfully, causes unauthorized destruction, loss, modification, or disclosure of, or access to, personal data, FLAD shall undertake, under the provisions of applicable legislation, to communicate such breach to the National  Data Protection Authority, without any undue delay, whenever possible, but no later than 72 hours after becoming aware of the occurrence.  FLAD shall undertake further to communicate the breach of personal data to the data subject concerned, in compliance with the applicable legislation.

Additionally, notwithstanding the security measures adopted by FLAD, it is important to underline and be aware that users should also adopt additional security measures, namely, by ensuring that an active firewall is in place, as well as, updated antivirus and anti-spyware software.

 

VIII. Transmission and communication of personal data to third parties

FLAD shall only transmit personal data to third parties, in cases where this becomes necessary to promote scientific, technical, cultural, educational, commercial and business cooperation or for legal compliance obligations to which FLAD is subject, such third parties being chosen upon meeting high requirements and bound to comply with legal standards applicable in matters of personal data protection.

Such transmission, when required to fulfill its social purpose, or for compliance with legal obligations to FLAD is subject, or as a result of the data subject’s consent, is carried out while limiting the data transmitted to what is strictly necessary for the fulfillment of such obligations and by means of appropriate security measures. Personal data shall not be transmitted in any other case without the permission from the data subject.

In the course of its business, FLAD may make use of third parties in order to promote scientific, technical, cultural, educational, commercial and business cooperation (located, for example, in Portugal or in the United States of America), which might imply, in some situations, imply access by those third parties to personal data of users.

Thus, FLAD commits itself to adopt the necessary and appropriate measures, in order to ensure that the entities that have access to such personal data are reputed and offer high guarantees in this regard, which shall be duly provided for and safeguarded in writing in the agreement to be entered between FLAD and the third party/parties.

Consequently, any entity subcontracted by FLAD will process the date of users on its own behalf and for its own account, undertaking to take the necessary technical and organizational measures to protect the personal data against accidental or unlawful destruction, accidental loss; unauthorized alteration or disclosure of, or access to personal data and against any other form of unlawful processing.

In any case, FLAD remains responsible for the processing of personal data.

Whenever necessary, and within the scope of hiring of third parties by FLAD, personal data may be transferred outside the European Union, under the terms and conditions permitted by applicable legislation.

 

IX. Access to third-party websites

Our privacy policy does not apply to third party websites. Therefore, whenever you visit another website from FLAD’s website, you should read the applicable privacy policy and verify that you agree with its terms before providing your personal data.

FLAD shall not be liable for any applicable privacy policy nor for the content made available on third party websites.

 

X. Changes to the privacy policy

FLAD reserves the right, at any time, to make changes to this privacy policy, being certain that such changes will be duly published on this website.

 

Chapter Two

Cookie Policy

I. Definition

Cookies must be understood as computer files that contain a sequence of numbers and letters which permits to uniquely identify the user’s Internet access device, although they may also contain other information such as the user’s browsing preferences on a given website. Cookies are downloaded through the browser to the user’s Internet access device (computer, mobile phone, tablet, etc.) when accessing certain websites.

The storage of cookies is performed by accessing equipment through the browser which only retains information related to preferences, not including personal data as such.

 

II. Cookie use 

This website uses cookies to improve its service. Some cookies are essential to ensure the functionalities made available, while others are designed to improve the performance and the experience of the users. Cookies serve to help determine the utility, interest, and how often the website is used, allowing faster and more efficient browsing, thus eliminating the need to repeatedly enter the same information.

This website uses cookies to differentiate between users. FLAD only collects standard web log information, including the user’s IP address, the browser type, and language, access times and the addresses of the reference websites. To ensure that our website is well managed and to facilitate browsing, FLAD, or its service providers, may also use cookies (small text files stored in the user’s browser) or web beacons (electronic images that allow our website to count visitors who access a website and certain cookies) to collect aggregated data.

You should not continue to access our website, after the cookie alert, if you do not agree with its use.

 

III. Types of cookies 

There are two sets of cookies that can be used:

Permanent cookies – cookies that remain stored in the browser of your access equipment (PC, mobile and tablet) and which are used whenever you make a new visit to one of FLAD’s websites. Generally, these cookies are used to direct navigation according to users’ interests, allowing a more personalized service.

Session cookies – temporary cookies that remain on the browser’s cookies archives until you leave the website. The information obtained by these cookies allows us to understand how users interact with our website and web traffic partners, to identify problems and provide the best navigating experience.

 

IV. Purposes of cookie use 

Strictly Necessary Cookies – It allows us to navigate the website and perform account related functions. Without these cookies, the required functions cannot be serviced.

Analytical Cookies – Used anonymously to create and analyze statistical information, with the aim of improving our website’s performance.

Functionality Cookies – Used to store the user’s preferences in using the website, so that it is not necessary to configure the site again each time you visit it.

Third-Party Cookies – Measures the success of the apps and the effectiveness of third-party advertisements. They may be used for personalized advertising with user data.

Advertisement Cookies – Target advertising in accordance with the interests of each user so as to target the advertising campaigns taking account of user tastes, while, at the same time, limiting how often the advert is viewed, thus helping to measure advertising effectiveness and the success of website organization.

 

V. Cookie management

Every browser allows the user to accept, refuse or delete cookies, and further inform the user whenever a cookie is received, namely, through the selection of appropriate settings in the respective browser. The user may configure cookies on his or her browser menu (e.g. “options” or “preferences”).

Disabling cookies may, however, prevent some web services from working properly, thus affecting, partially or completely, the navigation on the website.

 

VI. Updates to the cookie policy

FLAD reserves the right, at any time, to make changes to this cookie policy, and such changes shall be duly published on this website.

 

VII. Contact

If you want to ask questions or make complaints related to the Cookie Policy, you may do so through the email fladport@flad.pt.