MHPB, as the entity responsible for the processing of personal data collected through the computer platforms you provide — namely, the website “https://mhpb.pt/” (hereinafter, “official site”) and any other applications available for use on computers, tablets, mobile phones, or other devices (hereinafter, “Platforms”) — adopts the necessary conduct and implements mechanisms to ensure strict compliance with the legislation related to personal data that is in force at any given time, notably Law No. 58/2019, of August 8, which ensures the implementation, within the national legal framework, of Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data.

For this purpose, MHPB approves and implements a Privacy Policy, which is an integral part of the Terms of Use (also available on this official site), providing the Platforms with the necessary functionalities to exercise the rights of the user, as the data subject, regardless of their nationality or place of residence, and also implements security mechanisms to protect said personal data from unlawful intrusions and unauthorized access.

This Privacy Policy establishes the rules governing the processing of personal data of the user of the Platforms, from its collection — notably, through the official site of MHPB —, retention, use, transmission, to its deletion, as well as the prior consents for such processing and its purposes.

Without prejudice to the provisions of the law, MHPB reserves the right to modify, replace, and/or revoke, in whole or in part, its Privacy Policy, and, unless otherwise indicated, modifications take effect after their publication on the Platforms.

The Privacy Policy may be supplemented with specific usage rules for each Platform, which are also binding.

Within the scope of the Privacy Policy, the following definitions apply:

1. a) “Personal Data”, information relating to the user (notably, full name, civil identification number, tax number, and, when associated with any of these, gender, location data, platform usage data), which is collected by MHPB or transmitted to it by any commercial partner;
2. b) “Processing”, operation or set of operations performed on Personal Data, whether automated or not, such as collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, restriction, erasure, or destruction;
3. c) “Profiling”, any form of automated processing of Personal Data that involves using that data to evaluate certain personal aspects of the user, notably to analyze or predict aspects related to personal preferences and interests;
4. d) “Supervisory Authority”, an independent public authority established by the State to supervise the application of legislation related to personal data protection, in order to defend the fundamental rights and freedoms of individuals with regard to processing and to facilitate the free movement of such data within the European Union.

MHPB is the entity responsible for processing the Personal Data collected through the user’s registration and/or activity on the Platforms or through personal contact, whether in person, by phone, email, or postal mail, and can be contacted by the user via postal mail (by sending a letter addressed to “MHPB – Data Protection” at the following address: Torre de Monsanto, Rua Afonso Praça, n.º 30, 7.º andar, 1495-061 Algés) or by email (by sending an email to the following address: geral@mhpb.pt).

MHPB does not collect Personal Data automatically but only when they are voluntarily provided by the user, such as when the user registers on the Platforms or fills out an online form or at MHPB’s offices.

The user can visit the official site of MHPB anonymously, although doing so will limit the use to resources available for such browsing.

Upon registering on the Platforms, the user may be asked to enter their full name, date of birth, email address, gender, municipality, country of residence, and other relevant information.

By providing Personal Data to MHPB as described in the Privacy Policy and granting the relevant consents, the user is giving MHPB their consent to use this information for the purposes outlined below.

Personal Data is processed in a lawful, fair, and transparent manner with respect to the user, being collected for specified, legitimate, and lawful purposes, and also adequate, relevant, and limited to what is necessary for the purposes for which it is processed, accurate and kept up to date where necessary.

MHPB takes all appropriate measures to ensure that inaccurate data, considering the purposes for which it is processed, is erased or corrected without delay.

Personal Data is stored in MHPB’s IT systems and kept for different periods depending on the purpose for which it is intended and considering legal criteria, necessity, and data retention minimization, with such storage being retained by default until the user exercises their right to have it deleted, provided the purposes of its processing remain valid.

Processing is carried out in a manner that ensures the security of Personal Data, including protection against unlawful access, appropriation, alteration and/or unauthorized disclosure, unlawful destruction, and the dissemination of malicious software (computer viruses), with MHPB adopting appropriate technical and organizational measures for this purpose.

In the event of loss, misuse, alteration, and unauthorized access or appropriation of personal data provided or transmitted to MHPB, data subjects will be notified within the legal timeframes.

In compliance with data protection legislation and to ensure continuous adherence to such legislation, as well as to receive complaints, claims, and suggestions from users regarding this matter, MHPB can be contacted directly by postal mail (by sending a letter addressed to “MHPB – Data Protection” at the following address: Torre de Monsanto, Rua Afonso Praça, n.º 30, 7.º andar, 1495-061 Algés) or by email (by sending an email to the following address: geral@mhpb.pt).

The Platforms are primarily intended to provide up-to-date information on MHPB’s activities, as well as to provide services to its clients and the general public.

Personal Data may be processed for the following purposes: entering into contracts; processing online purchases; managing the relationship with MHPB’s clients; providing services; adapting services to the needs and interests of clients; information or marketing actions, particularly for sending communications for direct marketing purposes, using automated communication systems that do not rely on human intervention (automatic calling devices), fax machines, or email (e-mail), including SMS (short message services), EMS (enhanced message services), MMS (multimedia message services), application notifications, and other similar applications; interaction on platforms and social networks, using or reproducing publicly available content where the user has referenced or tagged “MHPB”, its brands, products, or services; sending complaints and suggestions; disclosing institutional information about MHPB; campaigns, promotions, advertisements, and news regarding MHPB’s products and/or services; conducting market studies and evaluation surveys; Profiling, notably for developing personalization mechanisms.

Personal Data will also be used for:

1. a) Compliance with court orders, administrative requests, or information requests from any public authority with delegated or inherent powers, in which case Personal Data may be transferred to these entities;
2. b) Compliance with the Terms of Use and applicable law or the exercise of a right of MHPB in relation to the user, notably for debt collection, either judicially (before ordinary or arbitration courts) or extrajudicially, in which case Personal Data may be transferred to MHPB’s representatives and advisors, such as lawyers, solicitors, and/or accountants;

To access certain Platforms and/or Content, it is mandatory to provide the requested data, as without it, it is not possible to provide the requested services.

Credit card data provided by the user during the purchase of products, services, and/or content made available by MHPB is only collected for that purpose, specifically for processing payment of the price, confirming the order, and issuing the respective receipt/invoice, and will not be used for any other purpose.

The Personal Data collected is intended to be processed by MHPB in accordance with the purposes disclosed above and may, however, be transferred to third parties who are institutional partners of MHPB in the supply of goods and services made available to MHPB’s clients and the general public.

In formalizing the partnership mentioned in the previous paragraph, MHPB will require the institutional partner to strictly comply with the legislation in force concerning the protection of Personal Data provided.

Personal Data may also be transferred to third parties in the event of a sale, merger, consolidation, liquidation, reorganization, or acquisition of MHPB.

MHPB guarantees privacy and security in the transmission and storage of Personal Data, using SSL (Secure Sockets Layer) encryption for all information provided by the user.

MHPB implements and maintains operational security measures and technical means to avoid unauthorized access and appropriation, loss, or misuse of Personal Data.

Regarding privacy and personal data protection, MHPB’s obligations towards the user, as the data subject, are obligations of means (and not results), which is why, by accessing the Platforms and Content, the user recognizes and accepts the risks inherent to such activity in the digital and electronic environment, namely, unauthorized access, appropriation, alteration, and/or unauthorized disclosure, unlawful elimination, and the spread of malicious software (computer viruses);

The user also recognizes and accepts that MHPB, its managers, and employees will not be held responsible for unlawful acts committed by third parties, including other users, even in cases where such acts cause damage, whether of a patrimonial or moral nature.

Any communication or message sent by the user by email, file transmission, data input, or any other form of unsolicited communication, unless otherwise stated, will be considered non-confidential and free from any restrictions on use.

The following rights are recognized to the user concerning their personal data:

1. a) Access to Personal Data, as well as its rectification or deletion, notably through the Platforms, in the account created by the user;
2. b) Limitation of Processing regarding everything that concerns them, including the right to object to the processing;
3. c) Withdrawal of consent at any time, without affecting the lawfulness of processing based on previously given consent;
4. d) Portability of Personal Data when they are processed in an automated manner;
5. e) Complaint, either to MHPB or to the Supervisory Authority.

The deletion of the user/client registration or account, as well as the withdrawal of consent(s) on a specific Platform, only takes effect on that Platform and does not apply to the registration or account created, nor to the consents given, on another Platform.