Privacy Policy
Whitesmith is compliant with high privacy standards, therefore assuring that the processing of any personal data will be strictly directed to the identified purposes and always in respect of the data protection rights and legislation, namely the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR)
Accordingly, Whitesmith approves and publishes the following Privacy Policy.
Definitions and legal references
Personal Data (or Data)
Means any information relating to an identified or identifiable natural person (‘Data Subject’); 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.
Data Subject
The natural person to whom the Personal Data refers.
Personal Data Processing
Personal Data Processing can be performed by Whitesmith through automated and/or analogical means, such as
- Collection
- Register and storage
- Organization
- Customization
- Search and use
- Dissemination, regardless of the disclosure means
- Comparison or interconnection
- Limitation, deletion or destruction
In particular, Personal Data Processing comprises the information collected automatically through Whitesmith’s Application (or third-party services employed in the same Application), which can include: the IP addresses or domain names of the computers utilized by the Data Subjects who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the Data Subject, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the Data Subject's IT environment.
Data Subject
The individual using any Whitesmith’s Application, which must coincide with or be duly authorized by the Data Subject, to whom the Personal Data refers.
Consent
The freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing by Whitesmith (according to the below-mentioned rules and requisites) of Personal Data relating to him or her. In the specific case of the use of Cookies, the above-mentioned consent for its use is given through Whitesmith’s website, as well as the opt-out option for the rejection of the Cookies in use.
Data Processor
Whitesmith, Lda., as the legal person entitled to process the Personal Data in compliance with this Policy, which take decisions regarding the purposes, means and methods of Personal Data processing, including the security measures concerning the operation and use of Whitesmith’s Applications.
Whitesmith Applications
Any means by which the Personal Data of the Data Subject is collected by Whitesmith, as Data Processor, including Whitesmith’s corporate website (www.whitesmith.co)
Cookies
Small sets of data stored in the Data Subject's device. See “Whitesmith Cookie Policy” for specific measures related to Cookies.
Legal information
This Data Protection and Privacy Policy has been drafted and approved to fully comply with the obligations set under REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR).
How to contact us
Whitesmith, Lda - Instituto Pedro Nunes,
Rua Pedro Nunes,
3030-119 Coimbra,
Portugal
[email protected]
Personal Data collected for the following purposes and using the following services:
- Analytics
- Tool: Google Analytics
- Personal Data: Cookies and Usage Data
Personal Data collected for the following purposes and using the following services:
Whitesmith’s Application collects, directly or through third-party services employed in the same Application, the following Personal Data: Name, location and picture.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific information texts displayed prior to the Data collection and the consent declaration by the Data Subject. The Personal Data may be freely provided by the Data Subject, or, in case of Usage Data, collected automatically when using this Application, always upon previous Data Subject express consent.
Whitesmith requires to the Data Subject, in all cases, the freely given, specific, informed and unambiguous consent for the processing of his/her personal data, using formal templates designed case by case, considering the type, scope and extension of said personal data processing.
Conditions applicable to child´s consent
According to Article 8 of the GDPR, all personal data belonging to children can only be processed under an express consent observing the rules of Article 6, number 1, point a) of the GDPR related to information society services when said children complete 13 years old.
For children with less than 13 years old, such processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child, preferably through the use of electronic certification means, such as Citizen Card or Digital Authentication Key.
All Data requested by this Application is mandatory and failure to provide this Data (or the Data Subject denial of express consent) may turn impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Data Subjects are free not to communicate this Data without any consequences on the availability or the operation of the service.
Any use of Cookies – or of other tracking tools – by this Application (or by the owners of third-party services employed by this Application) serves the purpose of providing the service required by the Data Subject, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Data Subjects are responsible for any third-party Personal Data obtained, published or shared through this Application and shall confirm that they have said third party's consent to provide the Data.
Mode and place of processing the Data
Methods of processing
Whitesmith, as Data Processor, processes the Data of Data Subjects in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Processor access to said data, in some cases, Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Subcontractors. The updated list of these parties may be requested to Whitesmith at any time.
Place
The Data is processed at Whitesmith operating offices and in any other places where the parties involved with the processing are located. For further information, please contact Whitesmith, through the appointed email address.
Retention time
The Data is kept for the time necessary to provide the service requested by the Data Subject, or stated by the purposes outlined in this document, and the Data Subject can always request to Whitesmith, as Data Processor, the removal of his/her Personal Data.
Mode and place of processing the Data
The Data concerning the Data Subject is collected to allow the Whitesmith to provide its services, as well as for the following purposes:
The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable Whitesmith to monitor and analyse web traffic and can be used to keep track of Data Subject´s behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected:
Cookies and Usage Data.
Place of processing:
- Privacy Policy
- Opt Out
Data subject rights
The Data Subject has the right, at all time, to require to Whitesmith, free of charge:
- The access to his/her personal data
- The rectification and correction of his/her personal data
- The erasure of his/her personal data (the “right to be forgotten”)
- The limitation of his/her data processing
- The opposition of his/her data processing
- The portability of his/her personal data to an appointed third entity, provided that said data are stored exclusively in electronic form
In every case, if a legal rule or legal obligation is in force which supersedes these data subject rights, Whitesmith reserves the right of denial of the data subject request (and/or to determine restrictions to said request, if and when applicable), duly communicating to the Data Subject the respective grounds of said decision.
The Data Subject is entitled to file complaints to Comissão Nacional de Proteção de Dados (hereinafter, CNPD), the Portuguese Controller Authority, according to the definitions duly stated in numbers 21 and 22 of article 4 and article 51 of the GDPR.
In addition to the information contained in this privacy policy, Whitesmith Application may provide the Data Subject with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request. More details concerning the collection or processing of Personal Data may be requested from the Data Processor at any time, through the provided Whitesmith’s contacts.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Changes to this Privacy Policy
Whitesmith reserves the right to make changes to this Privacy Policy at any time by giving notice on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a Data Subject objects to any of the changes to the Policy, the Data Subject must cease using this Application and can request to Whitesmith the removal of his/her Personal Data. Unless stated otherwise, the then-current privacy policy shall continue to apply to all Personal Data already in the possession of Whitesmith.