Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Idea Puzzle may process the following categories of personal data: a) identification data; b) data relating to education and work experience; c) professional data; d) professional activity data; e) invoicing and expenses data; and f) recorded image and sound data. Data subjects are the individuals to whom the data refers. The personal data categories listed above may belong to different categories of data subjects, such as clients, employees of institutional clients, applicants or alumni of Idea Puzzle. Idea Puzzle collects personal data in various ways and at different times, including when you send us an e-mail or reply to an invitation, when you give us your visiting card, when you sign up for our information or events, when you apply for a position with us or when you engage our services. In some cases, Idea Puzzle may collect personal data indirectly from public sources. When Idea Puzzle processes personal data that has been collected indirectly, it will provide all the information about the processing of that data to the relevant data subject at the earliest opportunity.
Idea Puzzle, Lda (“Idea Puzzle”) is firmly committed to the privacy and rights of data subjects and acts in accordance with the provisions of the General Data Protection Regulation (“GDPR”) and other applicable legislation, being registered at the Portuguese Data Protection Authority (https://cnpd.pt) with the number 578/09.
1. What data does Idea Puzzle process, who does it concern and how is it collected?
2. For what purposes and on what lawful basis does Idea Puzzle process personal data?
Idea Puzzle may process personal data for the following purposes: a) provision of technological and educational services; b) communications and sending of information, including the dissemination of technological and educational information; c) event management; d) protection of persons and goods; e) complying with statutory compliance obligations; f) invoicing and accounts management; g) submitting cases to scientific directories; h) judicial and non-judicial claims; and i) recruitment and selection. The respective lawful bases are the following: a) contractual performance; b) legitimate interest; c) legitimate interest and data subject’s prior consent where sound or image recordings are made or if photographs are taken; d) protection of Idea Puzzle’s premises and the persons on those premises; e) compliance with statutory obligation; f) contractual performance, legitimate interest, and compliance with statutory obligation; g) legitimate interest; h) legal interest in satisfying debt-claims and defending its rights; and i) pre-contractual audit at the request of the data subject and legitimate interest.
3. How long do we keep your personal data for?
Idea Puzzle will only keep your data for the period of time necessary to achieve the purposes established in this Policy or during the period required by the applicable legislation or regulations. Depending on the processing purpose, the personal data storage periods will be the following: a) provision of technological and educational services > for the duration of the client/firm relationship, plus 20 years; b) communications and sending of information > until the data subject objects; c) event management > 5 years from the contact date or attendance at the event (as the case may be) if there is no contact or attendance at another event by the data subject; d) protection of persons and goods > 30 days; e) complying with statutory compliance obligations > 7 years from the time Idea Puzzle’s identification is processed or, in the case of business relationships, after the end of the same; f) invoicing and accounts management > 10 years; g) submitting cases to scientific directories > for the duration of the case or brief; h) judicial and non-judicial collection and complaints > until payment of the amounts in debt or settlement of the dispute, whichever is applicable; and i) recruitment and selection > 3 years from the time the application or CV is received if the applicant is not selected; and for the duration of the professional relationship with Idea Puzzle in the remaining cases.
4. Who does Idea Puzzle transfer your personal data to?
Idea Puzzle does not transfer your personal data to third parties, except in cases where this proves to be necessary for the provision of the services you have engaged or for compliance with the obligations to which Idea Puzzle is subject. The transfer of data to third parties is carried out in accordance with the applicable data protection legislation and within the limits of the purposes and lawful bases established in this Policy. Idea Puzzle may share your personal data with the following entities: a) relevant parties for the technological and educational services we provide, for example, higher education institutions; b) public authorities, with regard to compliance with legal obligations; and c) service providers that supply services to Idea Puzzle for the purposes described above, such as IT providers, communications services, translation services and digital and physical archive services. In cases where the transfer of personal data to the above-mentioned entities involves an international transfer of personal data (i.e. outside of the European Union), Idea Puzzle: a) will carry out this transfer on the basis of a Commission adequacy decision, according to which the country or international organisation in question guarantees a level of personal data protection equivalent to that under European Union law; or b) if there is no Commission adequacy decision, it will ensure that such transfers are made in stringent compliance with the law and that appropriate guarantees are implemented to ensure the protection of your personal data. The existing adequacy decisions are available at www.eur-lex.europa.eu.
5. Is your personal data safe?
Idea Puzzle has a very strict security policy, from a technical and organisational viewpoint, in order to protect your personal data from unauthorised destruction, loss, alteration, disclosure or access and against any other form of unlawful or abusive treatment. The technical and organisational security measures created and implemented by Idea Puzzle are also required of Idea Puzzle’s service providers that may process personal data on their own behalf. If you have any questions about this matter, or if you would like more details about our data security, or if you know of any inappropriate situation, please contact us through either of the channels in point 9 below.
6. What rights do you have as data subject?
As data subject, you have the following rights: a) Right of access - You may ask Idea Puzzle at any time for confirmation as to whether it processes your data, for access to your personal data and for information about that processing. You may also obtain a copy of the personal data that is processed. b) Right to rectification - If your personal data is incorrect or incomplete, you may ask for it to be rectified or completed. c) Right to erasure or to be forgotten - In certain situations, you have the right to request the erasure of your personal data. This right may be restricted in certain situations if the processing of the data is necessary for compliance with statutory obligations to which Idea Puzzle is subject or when the processing is necessary for the purposes of declaring, exercising or defending a right in legal proceedings. d) Right to restrict processing - In certain situations, you may ask Idea Puzzle to limit access to personal data or suspend processing activities. This will happen, for example, in cases where you dispute the accuracy of your personal data, for a period of time which enables Idea Puzzle to check its accuracy, or in cases where you have objected to the processing, until it is verified whether the legitimate interests of Idea Puzzle or of a third party prevail over yours. e) Right to data portability - In cases where the processing of data is based on a contract to which you are a party or on your consent, you may ask Idea Puzzle to hand over to you the data you supplied in a structured, current and automatic reading format. You may also ask Idea Puzzle to transfer this data to other data controllers, as long as this is technically possible. f) Right to object - When the data processing is based on Idea Puzzle’s legitimate interest or when it is carried out for purposes other than those for which the data was gathered, but which are compatible with the same, you have the right to object to the processing of your data for reasons related to your own personal situation. Idea Puzzle will cease to process your personal data in such cases unless it has legitimate reasons to carry out this processing and these reasons prevail over your interests. g) Right not to be subject to automated decision-making – Idea Puzzle makes no automated individual decisions, including profiling, which have an effect on your legal status or significantly affect it in a similar way. h) Right to withdraw consent - In cases where the processing of the data is based on your consent, you may withdraw your consent at any time. If you withdraw your consent, your personal data will no longer be processed, unless there is another lawful basis that permits processing. i) Right to lodge a complaint with the supervisory authority - You have the right to lodge a complaint with the relevant supervisory authority about matters related to the processing of your personal data. In Portugal, the supervisory authority is the Comissăo Nacional de Proteçăo de Dados (National Data Protection Commission). For more information, visit https://cnpd.pt. Please note that the exercise of the above-mentioned rights may be restricted by virtue of third-party rights and freedoms, statutory obligations or confidentiality obligations or the prevailing legitimate interests of Idea Puzzle or a third party.
7. How can you exercise your rights?
You may exercise your rights in either of the following ways: a) E-mail: to the e-mail address email@example.com; or b) Letter: addressed to Ricardo Morais, Idea Puzzle, Lda, Rua Duarte Barbosa, 37, 2B, 4150-285, Porto, Portugal. There is no charge for exercising your rights.
8. How can you contact us?
If you have any questions or need more information about the processing of your personal data or your rights as data subject, please contact us at the following addresses: a) E-mail: to the e-mail address firstname.lastname@example.org; or b) Letter: addressed to Ricardo Morais, Idea Puzzle, Lda, Rua Duarte Barbosa, 37, 2B, 4150-285, Porto, Portugal. There is no charge for exercising your rights.
9. How can you stay informed about the processing of your personal data?