Policy

Trade Game, S.A., makes known to you its Privacy Policy, through which it informs you of your rights and establishes how we collect and use your personal data.

At Trade Game, S.A. we undertake to use your data only for the clearly identified purposes and adopt various security, technical and organizational measures in order to protect the personal data that is made available to us against its disclosure, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of unlawful processing.

Responsible for the processing of personal data

Trade Game, S.A. is responsible for the processing of personal data transmitted to it:

  • Trade Game, S.A., with its headquarters at Rua do Viso, 116, 4470-220 Maia – Portugal

Personal data, holders, categories and how personal data is collected

What is personal data?

Personal data shall be considered, in the meaning of the General Data Protection Regulation adopted by Regulation EU 2016/679 of the European Parliament and the Council of 27 April (hereinafter GDPR) for any information relating to a natural person, identified or likely to be identified. A natural person who can be identified, directly or indirectly, in particular by reference to an identifier, shall be considered identifiable. An identifier may be, for example, the name, identification number, location data, electronic identifiers or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

Who are the personal data subjects?

The customer or potential customer, natural person or the representations of a legal person, to whom the personal data relate to and that use, or intends to use, the products or services provided by Trade Game, S.A..

 

What categories of personal data are processed in Trade Game, S.A.?

CIVIL IDENTIFICATION DATA ex. Name
TAX IDENTIFICATION DATA ex. Tax identification number
PERSONAL SITUATION DATA N/A
PERSONAL AND CONTACT INFORMATION Telephone contact, email address, among others.
DATA RELATING TO PURCHASE AND SERVICES History of purchased services.
CUSTOMER HISTORY Information and service purchase contract; proposals received.

 

How and when is your personal data collected?

Your personal data may be collected in the following circumstances:

  1. For the purpose of drafting a tender, awarding services, concluding and executing contracts, in particular when you purchase a service to be provided by Trade Game, S.A.

Foundation, purposes and duration of the processing of personal data

The grounds that legitimize the processing of your personal data by Trade Game, S.A. are as follows:

Consent: your personal data may be processed by expression of will, free, express, informed and explicit, under which you accept, by means of an unequivocal positive statement or act, that your personal data are processed for the purposes indicated.

Pre-contractual diligence and/or execution of a service contract:  your personal data may be necessary to clarify doubts, to present you with a proposal, for the conclusion, execution and management of the contracted services or to contract with the company Trade Game, S.A.

Compliance with legal obligation: your data may be necessary for the fulfillment of a legal obligation to which the controller, in this case the company Trade Game, S.A., is subject.

Legitimate interest of Trade Game, S.A.: your personal data may also be used to develop the available services of Trade Game, S.A. and to defend the legally protected rights and interests of Trade Game, S.A., which includes, the improvement and monitoring of the quality of the services provided, ex. analysis and processing of information on the quality and performance of the various means and processes of service provision, complaint management or compliance with a legal obligation that falls on Trade Game, S.A..

Thus, Trade Game, S.A. in Portugal will process your personal data in accordance with the following:

LEGAL BASIS FINALIDADES
CONSENT We process the personal data of customers and potential customers, with their express consent, for commercial purposes.
PRE-CONTRACTUAL STEPS AND/OR EXECUTION OF SERVICE CONTRACT We process personal data for the purpose of concluding, executing and managing the contract concluded between the client and Trade Game, S.A., in particular for the preparation of a proposal and contract; in the context of a complaint; for scheduling meetings; in the context of the provision of the service.
COMPLIANCE WITH LEGAL OBLIGATION When the processing is necessary to comply with legal obligations, your personal data will be transmitted to official entities for billing purposes, among others.
LEGITIMATE INTEREST We process personal data based on legitimate interest, namely for monitoring and business management; in connection with the customer’s contact request via telephone or e-mail; to respond to complaints made, to respond to requests/complaints made through the complaint portal or through direct contact with Trade Game, S.A. and also when we need to contact the representative of a legal person, in the context of the performance of a contract or pre-contractual diligence.

 

Trade Game, S.A., in case the customer is a legal person, in order to be able to fulfill its contractual obligations, needs to collect some personal data (name, email and telephone) of the representative or employee of that company, for the sole purpose of allowing the good performance of this contract.

In this case, the legal person client must ensure that the data collected from his representatives/collaborators are collected and transmitted to Trade Game, S.A. in a lawful manner (under one of the grounds of lawfulness provided for in the applicable legislation), and must confer on the holders of the personal data, their representatives or collaborators, the right to information on the processing of such data.

Time limit for the retention of personal data

Trade Game, S.A. retains the personal data of the holders only for the period strictly necessary to achieve the purpose for which they were collected.  In certain cases, the law requires the retention of data for a specific period, in particular in the case of data necessary for information to the Tax Authority, which will be kept for 10 years, in accordance with current legislation.

We will also retain your data for as long as you maintain a contractual relationship with Trade Game, S.A. However, we may retain your personal data for longer periods longer than the duration of the service contracts established, on the basis of your consent, to ensure rights and duties related to situations in which trade game, S.A. has a legitimate interest, always respecting the period necessary to achieve the purpose for which they were collected.

In the event of no specific legal obligation, your data will be processed only for the period necessary to fulfill the purposes that motivated its collection, and as long as there are legitimate grounds that allow its retention by Trade Game, S.A. Once the maximum retention period has been reached, personal data will be irreversibly anonymized (anonymized data may be kept) or be destroyed securely.

Transmission of your personal data

Trade Game, S.A. transmits your personal data only when necessary for the purposes described above, namely for the provision of services requested by you.  Trade Game, S.A. suppliers and/or service providers are subject to the same terms and conditions of processing personal data as Trade Game, S.A. In this sense, they are expressly prohibited from using, processing, transferring, disclosing or recording the personal data of the holder for any purpose other than that for which they were specifically contracted, whether or not the express consent of the respective holder is applicable, depending on whether it is data whose processing is subject to the consent regime.

Trade Game, S.A., is obliged to comply with certain legal obligations that imply the processing of personal data without the consent of the respective holder. To this end, compliance with these legal obligations may imply the need to process personal data, such as:

i) compliance with legal, regulatory and/or administrative provisions;

ii) compliance with legal obligations relating to the reporting or responses to public authorities or agencies in charge of the development of public functions;

iii) compliance with obligations related to statistical purposes;

iv) preventing and combating fraud and/or money laundering and financial crime.

Link to other websites

We warn you that Trade Game, S.A. is not responsible for the privacy practices of third parties whose websites have a link on our website, and therefore cannot guarantee or be responsible, in any way, for the accuracy or authenticity of the information contained therein. We therefore advise you to read the privacy policies of any other website that is linked to the Trade Game, S.A. website.

Trade Game, S.A. does not guarantee the accuracy, completeness or authenticity of the information contained in any hyperlink or other Internet site. The personal data entered on other internet sites that are linked to the Trade Game, S.A. website shall be the sole responsibility of the data subject or the owner of the website concerned.

Rights of personal data subjects and response to requests from Data Subjects

Trade Game, S.A. guarantees the applicability and fulfillment of all the rights of the holder of the personal data provided for in the GDPR and legislation in force.

Right of access by the data subject

You have the right to obtain from Trade Game, S.A. confirmation that personal data concerning you are or are not processed and, if so, the right to access your personal data and information relating to such processing, for example, may require an exact copy of your compilation and request additional information about the processing we carry out.

Right to rectification

You also have the right to obtain, without justified delay, by Trade Game, S.A. the rectification of inaccurate personal data concerning you, including the right to correct or complete your personal data.

Right to erasure (“right to be forgotten”)

You may exercise the right to obtain the erasure of your personal data by Trade Game, S.A., and without undue delay, provided that: (i) personal data is no longer necessary for the purpose that motivated its processing; (ii) when you withdraw your consent and there are no other valid grounds for its retention; (iii) where it opposes the processing and there are no prevailing legitimate interests, to be assessed on a case-by-case basis justifying the processing; (iv) personal data must be erased under a legal obligation to which Trade Game, S.A. is obliged; (v) the personal data have been treated unlawfully, as well as in other legally provided for cases.

The right to the erasure does not apply where the processing of personal data is necessary to provide for the exercise of freedom of expression and information; compliance with a legal obligation requiring treatment; for reasons of public interest in the field of public health; for the purposes of archive of public interest, scientific research, historical or statistical purposes, where the exercise of the right to erasure is likely to seriously and irreversibly prejudice the attainment of the objectives of that treatment or, furthermore, for the purpose of declaration, exercise or defense of a right in the context of judicial proceedings.

Right to data portability

Where the processing of personal data is based on the express consent of its holder or with a view to the performance of a contract or when it is carried out by automated means, the holder of the personal data has the right to receive the personal data concerning him and which he has provided to Trade Game, S.A.,  in a structured, commonly used and machine-readable format, as well as the right to transmit such data to another controller (if technically possible), and if the processing is based on consent or a contract and if the processing is carried out by automated means.

Right to withdraw consent

The holder of the personal data may, at any time, change his consent, limit it to certain types of processing or withdraw it, however, the withdrawal of consent does not compromise the lawfulness of the previous processing carried out on the basis of the consent previously given. Therefore, and in the event of withdrawal of consent, your personal data may no longer be processed by Trade Game, S.A. unless, under the law, there is another basis that may validly justify such processing.

Right to object to processing

You may also be owe the processing of personal data concerning you at any time, where there are no compelling and legitimate reasons for the processing that prevail over your interests, rights and freedoms, or for the purposes of the declaration, exercise or defense of a right in a judicial process.  It should also be added that you have the right to objects at any time to the processing of your personal data for direct marketing purposes, including the definition of profiles that is related to such direct marketing.” In this case, Trade Game, S.A. undertakes to cease the processing of the data for this purpose.

Right to restrict processing

In certain situations you have the right to obtain from Trade Game, S.A. the limitation of the processing of your data, in particular if (i) disputes the accuracy of personal data for a period that allows Trade Game, S.A. to verify its accuracy, (ii) in cases where personal data are no longer necessary for the purposes of the processing but are required by the holder for the purpose of declaration,  exercise or defense of a right in the event of a judicial process and even when it opposes the processing, until it is found that the grounds of legitimate interest of Trade Game, S.A. prevail over its own, as well as in other legally provided for cases.

Rights in relation to automated decision making and profiling

You have the right not to be subject to any decision taken solely on the basis of the automated processing of your personal data, including profiling that has effects in your legal sphere or affects you significantly in a similar way.

Exercise of your rights

You may exercise your rights free of charge, unless it is a manifestly unfounded or excessive request, in which case a reasonable fee may be charged taking into account the costs generated by your request.  We will respond to your requests within a maximum of 30 days, except in cases of more complex requests.  In fact, you may exercise your rights through the following addresses:

Trade Game, S.A.,

Still, if you are not satisfied with our response after the exercise of any of these rights, you have the right to lodge a complaint with the National Data Protection Commission (CNPD) regarding matters related to the processing of your data.

Procedural and technical security measures

Trade Game, S.A. makes use of physical, technological and organizational security measures appropriate to the protection of your personal data in order to protect the personal data that is made available to us against its disclosure, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of unlawful processing.

To this end, Trade Game, S.A. applies technical and organizational measures to ensure an adequate level of security to the risk by keeping personal data on file and during the transmission of personal data.

Trade Game, S.A. has a computer system capable of resisting, with a high level of trust, accidental events or malicious or illegal actions that compromise the availability, integrity and confidentiality of personal data stored or transmitted.

Cookies

Trade Game, S.A. uses cookie technology to enable you to locate the routes you follow to this site, to help Trade Game, S.A. record your activity on this site and to evaluate and improve the site in order to make it more useful to you. Using this technology, Trade Game, S.A. does not record information about individual users. Do not forget that you can preset your browser not to accept cookies or to warn you in case cookies are sent.

Use of the Trade Game, S.A. website

  • With regard to the use of the materials present on the Trade Game, S.A., information, text, figures or graphics website, they may only be used for your personal use, and never for commercial purposes, nor shall you reproduce, modify, transmit, authorize or publish such information, texts, figures or graphics, in whole or in part, for any purpose without the prior written permission of Trade Game, S.A..
  • Regarding the use and risk of its use, Trade Game, S.A. specifically disclaims any liability for direct, indirect, incidental, consequential or special damages arising out of or in any way associated with your access to or use of this website, affecting your computer equipment, or your reliability in the information obtained through the Trade Game website, S.A.
  • The data contained on the website should be seen purely as information. Despite the efforts of Trade Game, S.A. to keep the content up to date and reliable, it may contain inaccuracies, typography errors or be outdated, and may be changed at any time without Trade Game, S.A. having an obligation to notify you.

Privacy Policy Update

Trade Game, S.A. reserves the right to update this policy at any time, in accordance with the legal requirements and/or needs of the commercial activity. The user is therefore invited to visit this page to check our policy.

This Privacy Policy was last updated on May 11, 2022.