We, the Vloom Marketing and Advertising Agency, believe that protecting the security and privacy of your personal data is important. This privacy notice explains how we collect, store, use, disclose, and transfer (hereinafter "process") your personal data. The personal data we collect about you depends on the context of your interactions with us, the products, services, and resources you use, your location, and applicable laws.

processing of personal data obtained through user use of our websites, applications, and online platforms.

Categories of personal data processed, purpose of processing and legal basis

By accessing our websites or using our online services or applications, we process information that you have actively and voluntarily provided about yourself, including the following categories of personal data:

- Your contact information, including name, e-mail address, phone number;
- Other personal data you have provided by filling out forms;
- Information submitted as part of a support request, survey or comment, or forum post;
- Information about your interaction, including your device and user identifier, information about your operating system, sites and services used during your visit, the date and time of each visitor request.

We process your personal data for the following purposes:

- To provide the services and functions, which includes creating and administering your online account, updating, securing and troubleshooting, providing support, and improving and developing our services;
- To verify your identity;
- To respond to and fulfill your specific requests;
- To process your request or provide access to specific information or offers;
- To send you marketing information or contact you in the context of customer satisfaction surveys as explained in more detail in Section 3;
- To the extent reasonably necessary to enforce applicable terms of use, establish or safeguard the right or legal defense to prevent fraud or other illegal activities, including attacks on Vloom's information systems.

Online offers provided by your organization

Our online offers and/or contests may be provided to you for use by the organization to which you belong, such as our clients. If your organization provides access to an online offer, our processing of personal data provided by or collected from you or your organization in connection with the content of the online offer is conducted under the direction of your organization and is subject to a data processing agreement between us and your organization. In such case, your organization is responsible for any personal data contained in such content and you should direct any questions about how personal data contained in such content is used to your organization.

Links to other sites

This privacy notice applies only to online offers linked to this privacy notice and not to other websites or applications of our affiliates that have their own privacy notice or that are operated by third parties. This privacy notice also does not apply in situations where we process information solely on behalf of our business partners, for example, when we act as a web or cloud hosting provider. We may provide links to other websites and applications that we believe may be of interest to you. We are not responsible for the privacy practices of other websites or applications.

- Processing of personal data resulting from your business relationship with Vloom

Categories of personal data processed, purpose of processing and legal basis

In the context of the business relationship with Vloom, Vloom may process the following categories of personal data of consumers and contact persons with potential customers, suppliers, manufacturers and partners (all referred to as "Business Partner"):

- Contact information such as full name, work address, work phone number, work mobile phone number, work fax number, and work email address;
- Payment data, such as data necessary for payment processing and fraud prevention, including credit/debit card numbers, security code numbers, and other related billing information;
- additional information required to be processed as a function of a project or business relationship with Vloom or voluntarily provided by the Business Partner such as personal data relating to orders placed, payments made, orders, and major milestones of projects;
- Personal data obtained from publicly available resources, credit rating/control databases and credit institutions;
- If legally required for compliance checks of Business Partners: date of birth, identification numbers, identity cards, and information about relevant and significant litigation or other ongoing legal proceedings against Business Partners.
Vloom may process your personal data for the purposes of:
- communicating with Business Partners about Vloom or Business Partners' products, services and projects, responding, e.g, responding to inquiries or requests or providing technical information about products purchased;
- planning, executing and managing the (contractual) relationship with Business Partners; performing, e.g, transactions and ordering products or services, processing payments, performing accounting, auditing, invoicing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
- Administering and conducting customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events;
- Conducting customer satisfaction surveys and direct marketing activities, as explained in more detail in Section 3;
- Maintaining and protecting the security of our products, services and websites by preventing and detecting security threats, fraud or other criminal or malicious activity;
- Ensuring compliance with legal obligations (such as record-keeping obligations), customs and export control, obligations to verify the legal compliance of Business Partners (in order to prevent economic or money laundering crimes) and Vloom policies or industry standards;
- Resolving disputes, enforcing our contracts and filing, exercising or defending a lawsuit.

Processing of personal data for customer satisfaction surveys and marketing

Where permitted by applicable law, Vloom may process your contact information for direct marketing purposes (e.g., invitations to trade shows, newsletters) and to conduct customer satisfaction surveys, in each case by email. You may at any time object to the processing of your contact information for such purposes by writing to tiagoseverino@vloom.pt or by using the opt-out option provided in the relevant communication received.

 Transfer and Disclosure of Personal Data

Vloom may transfer your personal data to:
- other companies within the Vloom Group or third parties - for example, sales partners or suppliers - as a result of your use of Vloom's Online Offers or our business relationship with you;
- third parties who provide IT services to Vloom and who process such data solely for the purposes of such services (e.g., hosting or IT maintenance and support services); and/or
- third parties for the purpose of complying with legal obligations or establishing, exercising, or defending rights or claims (e.g., litigation and arbitration, law enforcement and regulatory authorities, attorneys and counsel).

Personal Data Retention Periods

Unless otherwise stated at the time of collection of your personal data (e.g., in a form completed by you), we will delete your personal data if retention of such personal data is no longer necessary (i) for the purposes for which it was collected or otherwise processed, or (ii) to comply with legal obligations (such as retention obligations under tax or commercial laws).

Your rights

In accordance with applicable data protection legislation, you have the right to:
- Obtain from Vloom information as to whether or not your personal data is being processed, and if so, to have access to the personal data concerned;
- Obtain from Vloom the rectification of inaccurate personal data concerning your person;
- Obtain from Vloom the erasure of your personal data;
- to have Vloom restrict the processing of your personal data;
- to have data portability in respect of personal data about you that you have actively made available;
- to oppose, for reasons relating to your particular situation, the processing of personal data about you.

 Security

To protect your personal data against accidental or unlawful destruction, loss, use, or alteration, and against unauthorized disclosure or access, we use appropriate physical, technical, and organizational security measures.

Contact for Data Privacy Issues

Vloom's Data Privacy Organization provides support for any questions, comments, concerns or complaints regarding data privacy or where you wish to exercise any of your rights with respect to the privacy of your data. Vloom's Data Privacy Organization can be reached at: marketing@vloom.pt.
Vloom's Data Privacy Organization will always use its best efforts to respond to and resolve any requests or complaints submitted to it. In addition to contacting the Vloom Data Privacy Organization, you will always have the right to submit your request or complaint to the competent data protection authority.

Processing under the EU General Data Protection Regulation: data controller, legal basis for processing, and international transfers

This section applies and provides further information if your personal data is processed by one of our companies located in the European Economic Area.

Data controller

The specific company identified on this page as the operator of this site is the data controller within the meaning of the General Data Protection Regulation for the processing activities described in this Privacy Notice.
In the course of our business relationship with you, we may share Business Partner contact information with affiliated Vloom companies. We and these Vloom companies are jointly responsible for the adequate protection of your personal data (Art. 26 of the General Data Protection Regulation). To enable you to effectively exercise your rights as a data subject in the context of this joint controllership, we have entered into an agreement with these Vloom companies granting you the right to centrally exercise your rights as a data subject in accordance with section 6 of this Privacy Notice against Vloom Lisbon, Portugal.
To exercise your rights, you may contact: marketing@vloom.pt

Legal basis for processing

The General Data Protection Regulation requires us to provide you with information about the legal basis for processing your personal data.
The legal basis for our processing of data about you is that such processing is necessary for the purposes of:
- Exercising our rights and fulfilling our obligations under any contract we enter into with you (Article 6 (1) (b) General Data Protection Regulation) ("Contract Performance");
- Compliance with our legal obligations (Article 6 (1) (c) General Data Protection Regulation) ("Compliance with Legal Obligations"); and / or
- Legitimate interests pursued by us (Article 6 (1) (f) General Data Protection Regulation) ("Legitimate Interest"). Generally, the legitimate interest pursued by us in relation to the use of your personal data is the performance or efficient management of (i) your use of the Online Offers and / or (ii) our business relationship with you. Where the table below states that we rely on our legitimate interests for a particular purpose, we are of the opinion that your legitimate interests are not superseded by your interests and rights or freedoms, given (i) the regular reviews and related documentation of the processing activity described in this document, (ii) the protection of your personal data by our data privacy processes, including our binding corporate rules on the protection of personal data, (iii) the transparency we provide about processing activity, and (iv) the rights you have in relation to processing activity. If you would like more information about this approach and criteria, please contact our Data Privacy Organization at: marketing@vloom.pt.

In some cases, we may ask whether you agree to the relevant use of your personal data. In such cases, the legal basis for processing such data may (in addition to or instead of) your consent (Article 6 (1) (a) General Data Protection Regulation) ("Consent").

Processing of personal data in the context of Online Offers - Purpose and Legal Basis

To provide the services and functions of the Online Offering, which includes creating and administering your online account, updating, securing and troubleshooting, providing support, as well as improving and developing our Online Offerings

- Performance of the contract (Article 6 (1) (b) General Data Protection Regulation)
- Legitimate interest (Article 6 (1) (f) GDPR)

To charge for the use of the online offer

- Performance of the contract (Article 6 (1) (b) General Data Protection Regulation)
- Legitimate interest (Article 6 (1) (f) GDPR

To verify your identity

- Performance of the contract (Article 6 (1) (b) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)

To respond to and fulfill your requests or instructions

• Performance of contract (Article 6(1)(b) GDPR)

in order to process your request or provide access to specific information or offers.

- Performance of the contract (Article 6 (1) (b) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)

To send you marketing information or contact you in the context of customer satisfaction surveys, as explained in Section 3

- Consent, if provided voluntarily (Article 6 (1) (f) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)

As reasonably necessary to enforce the terms of the online offer, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on our information technology systems.

- Compliance with legal obligations (Article 6 (1) (c) GDPR
- Legitimate interest (Article 6 (1) (f) GDPR)

Processing of personal data related to your business relationship with us - Purpose and Legal Basis

Communicating with business partners about our products, services and projects, e.g. answering questions or requests or providing technical information about purchased products
- Performance of contract (Article 6 (1) (b) GDPR)~
- Legitimate interest (Article 6 (1) (f) GDPR)

Planning, executing and managing the (contractual) relationship with Business Partners; for example. performing transactions and ordering products or services, processing payments, performing accounting, auditing, invoicing and billing activities, arranging shipments and deliveries, facilitating repairs and providing support services;

- Performance of the contract (Article 6 (1) (b) GDPR)
- Compliance with Legitimate Interest (Article 6 (1) (c) GDPR)

Manage and conduct market analysis, sweepstakes, contests or other customer activities or events;

- Consent, if provided voluntarily (Article 6 (1) (f) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)

Conduct customer satisfaction surveys and direct marketing activities, as explained in more detail in Section 3;

- Consent, if provided voluntarily (Article 6 (1) (f) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)

Maintain and protect the security of our products, services and websites by preventing and detecting security threats, fraud or other criminal or malicious activity;

- Legitimate interest (Article 6 (1) (f) GDPR)

Ensuring compliance with legal obligations (such as record-keeping obligations), export and customs control, business partner compliance screening obligations (to prevent crimes such as money laundering), and our policies or industry standards;

- Compliance with legal obligations (Article 6 (1) (c) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)
Resolve disputes, enforce our contractual agreements and establish, exercise or defend legal claims.
- Compliance with legal obligations (Article 6 (1) (c) GDPR)
- Legitimate interest (Article 6 (1) (f) GDPR)

International Data Transfers

Where we transfer your personal data outside the European Economic Area, we ensure that your data is protected in a manner consistent with the General Data Protection Regulation. Therefore, and if required by applicable law, we take the following steps:
- We share your personal data with affiliated companies outside the European Economic Area only if they implement our Binding Corporate Rules ("BCR") for the protection of personal data. More information about the BCR can be found here.
- We transfer personal data to external recipients outside the European Economic Area only if the recipient (i) has entered into EU Standard Contractual Clauses with us or (ii) has implemented Binding Corporate Rules in its organization. You can request further information about the safeguards implemented in relation to specific transfers by contacting marketing@vloom.pt.

Your competent data protection authority

In case of doubts and requests related to data privacy, please contact our Data Privacy Organization at marketing@vloom.pt. In addition to contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.

More information for US residents

If you are a resident of the United States, please see the following:
Do Not Track
At this time, our Online Offers do not recognize or respond to browser "Do Not Track" signals. For more information about "Do Not Track", please visit your browser's support page.

Use by children

This online offer is not directed to children under the age of thirteen. We do not knowingly collect personal data from children under the age of thirteen without insisting that they seek prior parental consent, if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local laws and regulations, or to protect a child.