This Privacy Policy is effective as of 16 May 2024 and may be periodically updated to reflect any changes in the way we handle your personal data or applicable laws.
This Privacy Policy governs the processing of personal data of data subjects (“Data Subject” or “Data Subjects”), collected in the context of their interactions with VanillaTribute, Unipessoal, Lda (“VanillaTribute”), as the data controller, under the General Data Protection Regulation, particularly through the use of the website www.vanillaproject.org (“Site”). By providing your personal data, the Data Subject acknowledges and agrees to the conditions of this Privacy Policy, which is complemented by the Terms of Use and Cookie Policies, both available in the website.
Collection and Processing of Personal Data
VanillaTribute will process your personal data only when necessary for specific purposes. Please refer to the table below to see (i) the list of purposes for which VanillaTribute uses your personal data and (ii) the legal basis for each purpose:
- Provision of the contracted service
Purposes | Basis | Personal Data Processed | ||
| Provision of Service | Opening files, registering, and managing clients | Legitimate interests of VanillaTribute in organizing its client portfolio | Identification data, contact information, and professional occupation data | |
| Analysis of new clients | Compliance of Legal obligations | Identification data, contact information, and professional occupation data | ||
| Provision of contrated services | Execution of service agreements | Identification data, communications data that may need analysis, among other data that may be necessary within the scope of the contracted service, to be communicated as appropriate. These data may include special categories of data (such as data regarding union membership or health data) or data related to criminal convictions and offenses. | ||
| Retention of information related to the service provided | VanillaTribute’s legitimate interests in keeping its documentation organized | Personal data processed in the scope of service provision | ||
| Aquisition of services | Seeking proposals for the provision of services needed by VanillaTribute | Pre-contratual diligences | Identification data, contact information, and service-related data that you provide | |
| Contracting and execution of services needed by VanillaTribute | Execution of service agreements | Identification data, contact information, and service-related data that you provide | ||
| Invoicing | Compliane with Legal obligations | Identification and contact information; details regarding the services provided and payment data used | ||
| Sending Communication | Envio de newsletter e outros updates | Consent of the data subject | Name and e-mail | |
| Responding to contact reqeust | Legitimate interest of VanillaTribute in ensuring a response to any inquiries from Site visitors | Identification data, contact information, the message you have sent us, and any data you have provided through it | ||
| Sending relevant communications | Legitimate interest of VanillaTribute in maintaining personalized contact with its former clients or collaborators | Identification and contact information | ||
| Organization and management of events | Management of participation and communication with event attendees | Legitimate interest of VanillaTribute in organizing and promoting its events | Identification data, contact information, data related to academic and professional background | |
| Internal and external dissemination of organized events | Consent of data subject | Identification data, data related to academic and professional background, and/or image and voice of participants | ||
| Protection of people and property at VanillaTribute’s physical facilities | Legitimate interest of VanillaTribute in ensuring the safety of visitors and the assets of its facilities | Image, identification data, and reason for visiting | ||
| Submission of recruitment applications | Pre-contractual measures at the request of the user | Identification data, data related to academic and professional background, contact information | ||
| Use of the website and interactions with VanillaTribute’s communications | Provision of the website and analysis of its usage and interaction | Legitimate interests of VanillaTribute or consent of the data subject, as applicable | Data related to your interaction with VanillaTribute’s website. For more information on this processing, please refer to our cookie policy, available in the website. | |
| Analysis of your interaction with VanillaTribute’s communications | Legitimate interests of VanillaTribute in understanding the reach of the communications sent | Data related to your interaction with the communications we send you, for example, whether you open the attachments to VanillaTribute newsletters | ||
Data Transmission
We may transfer personal data to our service providers, partners, public and governmental authorities, or third parties in the context of business relationships. These third parties may be located in other countries. Before making these transfers, we will take necessary steps to ensure that your personal data receives adequate protection as required by applicable data privacy laws and VanillaTribute’s internal policies.
VanillaTribute may transmit your personal data:
a) To other entities for the provision of certain services, as such service provision may involve these entities accessing your personal data. Any subcontractor of VanillaTribute will process your personal data on behalf of VanillaTribute, following our instructions and under the terms of the subcontracting agreement with the mentioned entities;
b) To third parties when such data communications are deemed necessary or appropriate (i) in light of applicable law, (ii) in compliance with legal obligations/court orders, (iii) in response to deliberations or decisions of regulatory authorities, or (iv) to respond to requests from public or governmental authorities.
In any of the above situations, VanillaTribute will take all appropriate measures to ensure the effective protection of personal data.
Additionally, the Site provides buttons for sharing content through the User’s social media networks. Using these buttons involves the transmission of User data to the social media providers where you are logged in with your user account. If you do not want any social network to have access to your information collected through the Site, you should ensure that you are not logged into your user accounts or log out of them. Alternatively, you can refuse the installation of third-party cookies used to enable this content sharing, as better described in the Cookie Policy, available in the website.
Data Transfer to Third Countries
Unless otherwise notified, any transfer of your personal data from the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or governed by standard contractual clauses (a copy of which can be obtained through the contact information provided below). Any other transfer of your personal data outside the EEA will take place in accordance with appropriate international data transfer mechanisms and standards.
Data Retention Periods
Our policy is to retain data only for the period necessary to fulfill the purposes for which it was collected. However, in certain cases, we may retain data for longer periods, particularly when required by law.
Please refer to the table below for more information on retention periods:
| Purpose | Storage period |
Opening of client files and client management | For as long as the contractual relationship for the provision of services continues |
Provision of the contracted services | For as long as the contractual relationship for the provision of services continues |
Storage of information relating to the services provided | 20 years from the termination of the relevant service agreement |
Procurement of offers to provide the services we need | For as long as required to contract the relevant service |
Hiring and performance of the services we need | For as long as required to perform the relevant agreement |
Billing | 10 years |
Sending of newsletters and other updates | For as long as your consent remains valid |
Reply to a contact request | For as long as required to reply to your request |
Sending of other relevant communications | One year from the last contact, without prejudice to your right to object to processing |
Management of registrations and communications sent to event participants | For as long as required to organize the event and send any subsequent relevant communications |
Internal and external promotion of organized events | For as long as required to promote the event, without prejudice to your right to withdraw your consent |
VanillaTribute’s participation in directories or applications for industry awards | For a period of one year or until consent is withdrawn |
Submission of recruitment applications | 5 years |
Website use | In accordance with our Cookie Policy, available in the website |
Data Subject Rights
At any time, you may:
1. Request access to the information we hold about you
As the Data Subject, you have the right to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to access your personal data and the information provided by law.
2. Request the rectification of information if it is inaccurate or incomplete
As the Data Subject, you have the right to have VanillaTribute rectify inaccurate or incomplete data concerning you without undue delay.
3. Request the erasure of your personal data
As the data subject, you have the right to request the erasure of your data by VanillaTribute without undue delay, and VanillaTribute is obliged to erase your personal data without undue delay when one of the following grounds applies:
a) The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
b) You withdraw your consent on which the processing is based (in cases where the processing is based on consent), and there is no other legal ground for the processing;
You object to the processing, and there are no overriding legitimate grounds for the processing.
4. Request the restriction of the processing of your personal data
As the Data Subject, you have the right to request VanillaTribute to restrict the processing of your data when one of the following applies:
a) You contest the accuracy of the personal data, for a period enabling VanillaTribute to verify the accuracy of the personal data;
b) The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead;
c) VanillaTribute no longer needs the personal data for processing, but the data is required by you for the establishment, exercise, or defense of legal claims;
d) You have objected to the processing, pending the verification whether the legitimate grounds of the controller override yours.
5. Object to the processing of your personal data
In cases where data processing is based on the legitimate interests pursued by VanillaTribute, or the processing is carried out for direct marketing purposes or profiling, you may object to the processing of your personal data at any time.
6. Withdraw consent if the processing is based on your consent
If consent is legally required for the processing of personal data, you have the right to withdraw consent at any time, although this right does not affect the lawfulness of processing based on consent before its withdrawal, nor does it affect the processing of the same data based on other legal grounds, such as compliance with a contract or legal obligation to which VanillaTribute is subject.
If you wish to exercise any of your rights, you should contact us in writing via email at [email protected].
Your requests will be handled with special care to ensure the effectiveness of your rights. You may be asked to provide proof of your identity to ensure that personal data is only shared with its rightful owner.
Please note that in certain cases (e.g., due to legal requirements), your request may not be immediately fulfilled.
You also have the right to file a complaint with the www.cnpd.pt.
Security and Confidentiality
We are committed to keeping your data secure and employ appropriate security measures to ensure the protection of your personal data and prevent unauthorized access. Our systems and security policies undergo periodic reviews to ensure that data is safe and protected. However, the transmission of information via the Internet is not completely secure, and we cannot guarantee absolute security of information transmitted to VanillaTribute’s Terms of Use, available in the website.
Users should protect the devices and equipment they use to access the Site against harmful software, viruses, and malware. Additionally, without appropriate security measures (e.g., using a secure browser, updated antivirus software, and firewall), there is a higher risk of unauthorized third parties accessing your personal data and passwords. Furthermore, if a User detects any issue, bug, or anomaly on the Site, they should immediately notify VanillaTribute and refrain from using such bugs or anomalies to access commercial information, other Users’ personal data, alter the Site, or use it unlawfully or differently from the way defined by VanillaTribute.
We also respect the confidentiality of your information. Therefore, we do not sell, disclose, or otherwise make your information available to third parties. VanillaTribute is committed to maintaining your information confidential in accordance with this Privacy Policy and applicable legislation.
Applicable Law
This Privacy Policy is subject to Portuguese law.
