I. Cookies Policy

INTRODUCTION

FINDMORE uses cookies which are necessary for the proper functioning of its websites.
Subject to your preferences, FINDMORE may also use cookies to improve your experience, to secure and remember log-in details, for session management, to collect statistics, to optimize site functionality and to deliver content tailored to your interests. We honor the preferences you select, both here and in specific applications where further cookie preferences will specifically be solicited.
To provide a smooth navigation, your cookie preferences will be shared across the following FINDMORE web domains where the purpose and use of the cookies will remain the same:
Click “Agree and proceed with standard Settings” to accept cookies and go directly to the site or click “View cookie settings” for a detailed description of the types of cookies and/or to customize your cookie selection.

PERSONALIZATION COOKIES

These cookies are used to improve the overall experience of your visit to FINDMORE Websites and to tailor
content and advertising to your interests.

• Example functionality allowed
  Enable cookie consent collection and cookie blocking for privacy controls
  Provides secure log-in and transactions (i.e. authentication, single sign in, remember settings) across web pages
  Manage online services, load balancing and performance
  Maintain user’s input while filling out online forms for up to a few hours after the session
  Remember transaction progress for the duration of the session
  Store technical data for multimedia content players (e.g. play back video or audio content for the duration of a session)
  Remember your log-in details for automatic log-in across session
  Analyze site usage to provide better content experiences
  Conduct analytics to optimize site functionality
  Make sure the website looks and feels consistent
  Allow you to access email functionalities
  Allows personalization of FINDMORE page content and FINDMORE marketing relevant to your interests on FINDMORE and on third party publishers

FUNCTIONAL COOKIES

These cookies are used to improve the overall experience of your visit to FINDMORE Websites and to tailor
content and advertising to your interests.

• Example functionality allowed
  Enable cookie consent collection and cookie blocking for privacy controls
  Provides secure log-in and transactions (i.e. authentication, single sign in, remember settings) across web pages
  Manage online services, load balancing and performance
  Maintain user’s input while filling out online forms for up to a few hours after the session
  Remember transaction progress for the duration of the session
  Store technical data for multimedia content players (e.g. play back video or audio content for the duration of a session)
  Remember your log-in details for automatic log-in across session
  Analyze site usage to provide better content experiences
  Conduct analytics to optimize site functionality
  Make sure the website looks and feels consistent
  Allow you to access email functionalities
  Allows personalization of FINDMORE page content and FINDMORE marketing relevant to your interests on
  FINDMORE and on third party publishers

 

• Example functionality NOT allowed
  Allow you to share pages with social networks
  Allow you to access email functionalities
  Allows personalization of FINDMORE page content and FINDMORE marketing relevant to your interests on FINDMORE and on third party publishers

REQUIRED COOKIES

These cookies are needed to provide basic functionalities as you browse FINDMORE websites. These capabilitiesinclude cookie preferences, load balancing, session management, language selection and checkout processes

• Example functionality allowed
  Enable cookie consent collection and cookie blocking for privacy controls
  Provides secure log-in and transactions (i.e. authentication, single sign in, remember settings)
  across web pages
  Manage online services, load balancing and performance
  Maintain user’s input while filling out online forms for up to a few hours after the session
  Store technical data for multimedia content players (e.g. play back video or audio content for the
  duration of a session)
• Example functionality NOT allowed
  Remember your log-in details for automatic log-in across session
  Analyze site usage to provide better content experiences
  Conduct analytics to optimize site functionality
  Make sure the website looks and feels consistent
  Third party social plugin for sharing logged in state for members of a social network
  Allow you to share pages with social networks
  Allow you to post comments
  Allows personalization of FINDMORE page content and FINDMORE marketing relevant to your interests on
  FINDMORE and on third party publishers

II. Online Privacy Statement

This Statement is effective as of May 2018.
Your privacy is important to FINDMORE; maintaining your trust is paramount to us.
This Statement discloses the information practices for FINDMORE’s and our subsidiaries’ websites, what type of information about our websites’ users is gathered and tracked, and how the information is used, shared or otherwise processed offline.
It also describes how cookies, web beacons and other technologies may be used in our FINDMORE services and software products. References to FINDMORE websites, products and services in this Privacy Statement include apps, programs, and devices.

This FINDMORE Online Privacy Statement supplements the FINDMORE Privacy Statement
This Statement applies to FINDMORE websites that link to this Statement but does not app ly to those FINDMORE websites that have their own Privacy Statement. Additionally, it does not apply to instances where we merely process information on behalf of clients for their benefit, such as when we act as a web
hosting service provider.
We may supplement this Statement with additional information relating to a particular interaction we have with you, such as a transaction document or a specific privacy statement when you order or use an online service.

FINDMORE’s privacy practices as it pertains to information collected through FINDMORE.EU, as described in this Privacy Statement, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.
If you have questions or complaints regarding our privacy policy or practices, please contact the FINDMORE DPO – Data Protection Officer. If you have an unresolved privacy or data use concerns that we have not addressed satisfactorily, please contact our Headquarter:

FINDMORE Consulting, SA
Av. D. João II, Edifício Mythos
Lote 1.06.2.1ª – 6º Piso, Escritório 2
1990-095 Lisboa
Portugal

COLLECTION OF PERSONAL INFORMATION

Introduction
You may choose to give us personal information directly in a variety of situations. For example, you may want to give us your name and contact information to communicate with you, to process an order, to register for a service, to provide you with a subscription, or to do business with us if you are a supplier or
a business partner.
If you tell us that you do not want us to use your information to make further contact with you beyond fulfilling your request, we will respect your wishes.

Registration
When you wish to receive information, download publications, enroll for a live or virtual event or request a trial, we may ask you to provide your name and business contact information, as well as other information in connection with your request. We use this information in connection with your request and to communicate with you.
This information may, in most cases, also identify you when you visit our websites. We will retain your information for potential future interactions with you.
We may also ask you to register an FINDMORE id, in which case you need to provide us with your name, email address, country location and other information if needed for the purpose for which you are asked to register. The FINDMORE id serves to uniquely identify you when you visit our websites, have a request
or order or use a product or service.
For ordering of most services, we require you to have registered an FINDMORE ID. Registration with FINDMORE ID may allow you to customize and control your privacy settings. Certain FINDMORE services may require unique registration, specifically for the purpose of providing these services.
In such cases, registration details provided by you for a service will only be used for the specific purpose of providing you with that service.

Website visits and FINDMORE services
We may also collect information relating to your use of our websites and FINDMORE services through the use of various technologies. For example, when you visit our websites or access our FINDMORE services, we may log certain information that your browser sends us, such as your IP address (including information deriving from your IP address such as your geographic location), browser type, version and language, access time, duration of access, and referring website addresses; we may also collect information about the pages you view within our sites, the time you spent on each site and other actions you take while visiting our website.
When you access our website without a FINDMORE id or signing in, we will still collect some of this personal information in order to enable the websites to function properly.

In addition, some of our sites include technologies that allow FINDMORE to collect certain information about the use of our services. We may also use such technologies to determine whether you’ve opened an e-mail or clicked on a link contained in an e-mail. For details regarding the technologies we employ,
see Cookies, Web Beacon and Other Technologies below.

Marketing information

Most information we collect about you comes from our direct interactions with you.
From time to time, we may also collect information that pertains to you indirectly through other sources, such as list vendors. When we do so, we ask the vendors to confirm that the information was legally acquired by the third party and that we have the right to obtain it from them and use it.
When you register for an event we may collect additional information (online or offline) in relation to the event organization, and during an event, such as participation in sessions and survey results. Events may be recorded and group photos taken.
We reserve the right to use photos for promotional use. When you provide us with your business contact information (such as by handing over a business card) we may use this to communicate with you.
The information that we collect, either directly or indirectly, may be combined to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you.

USE OF PERSONAL INFORMATION

The following paragraphs describe in more detail how FINDMORE may use your personal information. Fulfilling your Transaction Request.
If you request something from FINDMORE, for example, a product or service, a callback, or specific marketing materials, we will use the personal information you provide to fulfill your request. To help us do this, we may share information with others, for instance, FINDMORE’s business partners, financial institutions, shipping companies, postal or government authorities, such as customs authorities, involved in fulfillment.

PERSONALIZING YOUR EXPERIENCE ON OUR WEBSITES

We may use the personal information we collect about you to provide you with a personalized experience on our websites and of our services, such as providing you with content you may be interested in and making navigation on our sites easier. We also may use this information to improve our websites.

PROVIDING SUPPORT

We may use your personal information to support products or services you have obtained from us, such as notifying you of a product update or fix. We may combine your information with information from other interactions with you to provide you with more valuable suggestions in relation to product support.
We will use personal information you provide in these sessions or in such forums in accordance with this Privacy Statement.
In the course of providing technical support to you, we may sometimes have incidental access to data that you have provided to us or data that is located on your system. This data may contain information about you, your organization’s employees, customers, partners, or suppliers. This Privacy Statement does not apply to our access to or handling of this personal information; the conditions regarding the handling and processing of this data is covered by the applicable Terms of Use or other agreements between you and FINDMORE, such as the Terms of Use for Exchanging Diagnostic Data.

FINDMORE SERVICES

We may use information collected on your use of the FINDMORE services to allow us to: establish statistics about the usage and effectiveness of our FINDMORE services; improve and personalize your use and experience of our services; tailor our interactions with you; inform our clients on overall use of their services, and improve and develop our services.

MARKETING

The personal information you provide to FINDMORE, as well as the personal information we have collected about you indirectly, may be used by FINDMORE for marketing purposes, i.e. to keep you informed about events, services that FINDMORE sells and which may complement an existing portfolio.
Before we do so, however, we will offer you the opportunity to choose whether or not to have your personal information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by contacting us directly (please refer to “Privacy Questions and Access” below).
Some of our offerings or events may be co-branded or sponsored by FINDMORE and third parties, such as business partners and solution providers, that use, resell or complement FINDMORE services.
Offerings and events that are co-branded clearly indicate when such partnership exists. If you sign up for these offerings or events, be aware that your information may also be collected by and shared with those third parties. We encourage you to familiarize yourself with those third-party privacy policies to gain an understanding of the manner in which they will handle information about you.
If you choose to “Email This Page” to a friend or colleague, we will ask for their name and e-mail address. We will automatically send a one-time e-mail sharing the page you indicated, but will not use that information for other purposes.

RECRUITMENT

In connection with a job application or inquiry, whether advertised on an FINDMORE website or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout FINDMORE in order to address your inquiry or consider you for employment purposes.

MONITORING OR RECORDING OF CALLS, AND OTHER INTERACTIONS

Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is FINDMORE’s general practice to monitor and, in some cases, record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.
Use of Information in the Social Computing Environment FINDMORE provides social computing tools on some of its websites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.
When downloading and using these applications or registering to use these social computing tools, you may be asked to provide certain personal information. Registration information will be subject to and protected in accordance with this Privacy Statement, except for the information that is automatically made available to other participants as part of your profile. These applications and tools may also include supplemental privacy statements with specific information about collection and handling practices. Read those supplemental statements to understand what the tools and applications may do.
Any other content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms or applications, is not subject to this Privacy Statement. Rather, such content is subject to the Terms of Use of those applications or platforms, and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools or get help to do so. Please refer to them to better understand yours, FINDMORE’s, and other parties’ rights and obligations with regard to such content. You should be aware that the content you post on any such social computing platforms may be made broadly available to others inside and outside FINDMORE.

PROTECT THE RIGHTS AND PROPERTY OF FINDMORE AND OTHERS

We may also use or share your personal information to protect the rights or property of FINDMORE, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your
personal information as required by law, and when we believe that disclosure is necessary to protect our rights, or the rights of others, to comply with a judicial proceeding, court order, or legal process served on our websites.

INFORMATION FOR BUSINESS PARTNERS

If you represent an FINDMORE business partner, you may visit FINDMORE websites intended specifically for FINDMORE business partners. We may use information provided on that site to administer and develop our business relationship with you, the business partner you represent, and FINDMORE business partners generally.
For instance, this may involve using your information to send you details of FINDMORE business partner programs. It may also include sharing certain information with other business partners (subject to any confidentiality obligations that may exist), or FINDMORE clients or prospects. In connection with a particular transaction or program, we may also contact you as part of client satisfaction surveys or for market research purposes.

INFORMATION FOR SUPPLIERS

If you represent a FINDMORE supplier, you may visit FINDMORE websites intended specifically for use by FINDMORE suppliers. We may use the information provided on that site in connection with entering into or performing a transaction with you.

For example, this may include sharing information with other parts of FINDMORE, FINDMORE’s business partners, clients, shipping companies, financial institutions and postal or government authorities involved in fulfillment.
It may also be used to administer and develop our relationship with you, the supplier you represent, and other FINDMORE suppliers generally.

RETENTION

FINDMORE will retain your personal information for as long as is required to fulfill the purposes for which the information is processed or for other valid reasons to retain your personal information (for example to comply with our legal obligations, resolve disputes, or enforce our agreements).
Your registration information will be retained for as long as your account or FINDMORE id is active or as needed to provide you services.

If you wish to request that we no longer use your registration information to provide you services, contact us at DPOFindmore-GDPR@findmore.eu. In relation to FINDMORE services which you are the FINDMORE client contracting for that service with FINDMORE, your registration information may be retained to fulfill certain requirements of that FINDMORE client.

COOKIES, WEB BEACON AND OTHER TECHNOLOGIES

As mentioned above, we collect information from your visits to our websites and your use of our FINDMORE services and our software products to help us gather statistics about usage and effectiveness, personalize your experience, tailor our interactions with you, and improve our products and services. We
do so through the use of various technologies, including scripts, tags, Local Shared Objects (Flash cookies), Local Storage (HTML5) beacons, and “cookies”.

What are cookies and why are cookies used

A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer.
While cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to
personalize a known visitor’s experience of a website by being associated with profile information or user preferences.
Over time this information provides valuable insight to help improve the user experience.

Cookies are typically categorized as “session” cookies or “persistent” cookies. Session cookies help you navigate through the website efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current visit, or information needed to be able to complete a transaction. Session cookies are stored in temporary memory and erased when the web browser is closed.

Persistent cookies on the other hand, store user preferences for current and successive visits. They are written on your device’s hard disk, and are still valid when you restart your browser. We use persistent cookies, for example, to record your choice of language and country location.

How to express privacy preferences regarding the use of cookies

When visiting our websites or online services, you may have the possibility to set your preferences regarding cookies and other similar technologies by using the options and tools made available to you by either your web browser or FINDMORE. If a cookie manager has been implemented by FINDMORE, it will be displayed at your first visit to our website.

By clicking ‘cookie preferences’ at the footer of an FINDMORE website you can choose and change at any time which types of cookies you would like our websites and FINDMORE services to use. You can indicate your preference for required, required and functional or required, functional and personalization cookies.

Here you can also find more information on the types of cookies used. Using the cookie preferences does not result in deletion of cookies that are already on your device.
You can delete cookies already on your device via the settings of your web browser.

While FINDMORE websites, online and services at this time do not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser.

Look under the heading “Tools” (or similar heading) in your particular browser for information about controlling cookies. In most instances you can set your browser to notify you before you receive a cookie, giving you the option to decide whether to accept it or not. You can also generally set your browser to turn off cookies.

Cookies in our software products can be turned off in the product itself. Since cookies allow you to take advantage of some of our websites’ features or features of our services, we recommend that you leave them turned on. If you block, turn off or otherwise reject our cookies, some web pages may not display properly or you will not be able to, for instance, use any website or services that require you to sign in.

Web beacons or other technologies

Some FINDMORE websites, services and software products may also use web beacons or other technologies to better tailor those sites to provide better customer service. These technologies may be in use on a number of pages across FINDMORE’s websites.

When a visitor accesses these pages, a non-identifiable notice of that visit is generated which may be processed by us or by our suppliers. These web beacons usually work in conjunction with cookies. If you don’t want your cookie information to be associated with your visits to these pages or use of these products, you can set your browser to turn off cookies or turn off cookies in the product itself, respectively. If you turn off cookies, web beacon and other technologies will still detect visits to these pages; however, they will not be associated with information otherwise stored in cookies.

For more information about the technologies employed by our services, including how to turn them off, please consult the user guide for the particular services you are using.
We use Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display FINDMORE advertising on others’ websites based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information.

We may also include web beacons in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links contained within clicked on.
Some of our business partners set web beacons and cookies on our site.

In addition, third-party social media buttons may log certain information such as your IP address, browser type and language, access time, and referring website addresses, and, if you are logged in to those social media sites, they may also link such collected information with your profile information on that site. We do not control these third party tracking technologies.

LINKS TO NON-FINDMORE WEBSITES AND THIRD-PARTY APPLICATIONS

To allow you to interact with other websites on which you may have accounts (such as Facebook and other social media sites) or join communities on such sites, we may provide links or embed third-party applications that allow you to login, post content or join communities from our websites. We may also provide you with general links to non-FINDMORE websites.
Your use of these links and applications is subject to the third parties’ privacy policies, and you should become familiar with the third-party sites’ privacy policies before using the links or applications.
FINDMORE is not responsible for the privacy practices or the content of those other websites.

CHANGES NOTIFICATION

If we make any material changes to this Privacy Statement, we will notify you via notification on our website, and as otherwise required by applicable law.

PRIVACY QUESTIONS AND ACCESS

If you have a question about this Privacy Statement or FINDMORE’s handling of your information, you can send an email to the FINDMORE DPO – Data Protection Officer. You can also contact us at:

FINDMORE Consulting, SA
Av. D. João II, Edifício Mythos
Lote 1.06.2.1ª – 6º Piso, Escritório 2
1990-095 Lisboa
Portugal

In certain cases, you may have the ability to view or edit your personal information online. In the event your information is not accessible online, and you wish to obtain a copy of particular information you provided to FINDMORE, or if you become aware the information is incorrect and you would like us to correct it, through this email address: DPOFindmore-GDPR@findmore.eu

If you no longer wish to receive marketing e-mails fro m FINDMORE, please send an e-mail to FINDMORE Marketing or follow the unsubscribe instructions included in each marketing email.

III. Findmore Privacy Statement

At FINDMORE, we recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with European General Data Protection Regulation (GDPR) and with applicable data protection laws in all countries in which FINDMORE operates.

This Privacy Statement describes FINDMORE’s general privacy practices that apply to personal information we collect, use and share about individuals within our clients, business partners, suppliers and other organizations with which FINDMORE has or contemplates a business relationship.

This Privacy Statement is supplemented by the FINDMORE Online Privacy Statement, which provides more information in the online context, including recruitment. We may provide additional or more specific information on the collection or use of personal information on websites or related to a specific product or service.

PERSONAL INFORMATION: COLLECT AND USE

We may collect your personal information as an individual for various purposes, such as the following:

• Access and use of websites or other online services
  When entering one of our websites, or using an online service, we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services.

 

• Responding to your request for information, order, or support
  When you contact us (online or offline) in connection with a request for information, to order a product or service, to provide you with support, or to participate in a forum or other social computing tool, we collect information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you.
  
  For instance, we collect your name and contact information, details about your request and your agreement with us and the fulfillment, delivery and invoicing of your order and we may include client satisfaction survey information.
  
  We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you.
  When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our websites. For ordering of most services and products we require you to have registered an FINDMORE id. Registration may also allow you to customize and control your privacy settings.
  
  
• Your use of FINDMORE services
  We collect information about your use of FINDMORE services to enable product features to operate, improve your user experience, tailor our interactions with you, inform our clients on the overall use of the services, provide support and improve and develop our services.
  For details regarding the technologies we employ, the personal information we collect, as well as how to control or block tracking or to delete cookies, please refer to the FINDMORE Online Privacy Statement.
• Contacting employees of our clients, prospects, partners and suppliers
  In our relationship with clients or prospects, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of services, provision of support, invoicing and management of the services or the relationship.

 

• Visitor information
  We register individuals visiting our sites and locations (name, identification and business contact information) and use camera supervision for reasons of security and safety of persons and belongings, as well as for regulatory purposes.

 

• Marketing
  Most information we collect about you comes from our direct interactions with you. When you register for an event we may collect information (online or offline) in relation to the event organization, and during an event, such as participation in sessions and survey results.
  
  We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information by email, telephone or postal mail about our services, or sign-up for subscriptions. When visiting our websites or using our services we may provide you with personalized information.
  You can always opt-out from receiving personalized communication by sending an e-mail to DPOFindmore-GDPR@findmore.eu

 

More information can be found in the FINDMORE Online Privacy Statement.

Where we reference that we use your personal information in connection with a request, order, transaction or agreement (or preparing for the same), or to provide you with services that you requested (such as a website), we do this because it is necessary for the performance of an agreement with you.

Where we reference that we use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent.
When we collect and use your personal information subject to the EU Privacy Legislation (EU-GDPR) this may have consequences for Your Rights.

 

PERSONAL INFORMATION SHARING

As an organization offering a wide range of services, with business processes, management structures and technical systems that cross borders, FINDMORE has implemented global policies, along with standards and procedures, for consistent protection of personal information.

As a global IT company, we may share information about you with our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Privacy Statement.
Between FINDMORE partners, we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, FINDMORE uses suppliers located in various countries to collect, use, analyze, and otherwise process personal information on its behalf.

Where appropriate, FINDMORE may also share your personal information with selected partners to help us provide you, or the company you work for, services, or to fulfill your requests, or with your consent.
When selecting our suppliers and partners, we take into account their data handling processes.

If FINDMORE decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is FINDMORE practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of FINDMORE, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

 

INTERNATIONAL TRANSFERS

The international footprint of FINDMORE involves a large number of transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business.

Some countries have implemented transfer restrictions for personal information, in connection with which FINDMORE takes various measures, including:

• Where required, FINDMORE implements Standard Contractual Clauses approved by the EU
  Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers
  or other third parties.

INFORMATION SECURITY AND ACCURACY

We intend to protect your personal information and to maintain its accuracy. FINDMORE implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure.

For example, we encrypt certain sensitive personal information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.

RETENTION PERIOD

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.

Because the circumstances may vary depending on the context and the services; the information provided in FINDMORE Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms.

SUBJECT RIGHTS

You can request to access, update or correct your personal information.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation.
Under GDPR, you may also have the right to request to have your personal information deleted or restricted, and ask for portability of your personal information.

SUBJECT RIGHTS

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint:

• Directly with FINDMORE (DPOFindmore-GD PR@findmore.eu)
• With the competent data protection authority. The name and contact details of the Data
  Protection Authorities in the European Union can be found in EDP O site

HOW TO CONTACT US

If you have a question related to this Privacy Statement, please contact us. Your message will be forwarded to the appropriate member of FINDMORE’s Data Privacy Team, such as Data Protection Officer or members of the team.
For the purposes of the EU General Data Protection Regulation (GDPR), the controller of your personal information is the DPO, located at:

Findmore consulting, SA – Av. D. João II, Edifício Mythos Lote 1.06.2.1A 6º Piso, Escritório 2, 1990-095 Lisboa,
unless indicated otherwise.

FINDMORE PRIVACY STATEMENT CHANGES

From time to time, we may update this Privacy Statement, as well as any other specific privacy statement. When making changes to this Privacy Statement, we will add the date of the update, at the top of this Privacy Statement.