Privacy Policy

Last update on May 17, 2020
 

 

 

 

1 – WHAT IS PERSONAL DATA AND WHAT CATEGORY OF DATA DO WE HANDLE?

 What is personal data?

Personal Data is any information, of any nature and in any medium (eg sound or image), relating to an identified or identifiable natural person. An identifiable person is considered to be a person who can be identified directly or indirectly, eg through the name, identification number, location data, an electronic identifier or other elements that allow for the identification of that natural person.
 
Who are the holders of personal data?

The Client or User, a natural person, to whom the data relates and who has enjoyed the services or products of FRED'S ADVENTURES. The Client will be the person who enters into the contract with FRED'S ADVENTURES and the User is the person who uses the services or products of Fred's Adventures, but which may not correspond to the Client. For example: - In the business segment, the contract with Fred's Adventures is in the name of the company but the Users are the customers or employees of that company; - In the private segment, a Customer may purchase several products and services.
 
In this regard, Fred's Adventures informs that it also protects personal data and respects the rights of customers and users.
 
 
What categories of personal data do we handle?

The categories of data we handle are as follows:

 
 

Base data

Examples

Identification and contacts and 

oother identification data 

Números de identificação civil ou fiscal, dados para pagamento, a morada de faturação, o contacto telefónico e endereço de correio eletrónico; data de nascimento, género, sua actividade profissional e IP (se efectuou um registo na internet) 

Service

Products and services purchased or subscribed

Image

Image capture in activities and events

 

2 – WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Fred's Adventures will be responsible for the collection and processing of your personal data and, depending on the service provided, decides which data is collected, the means of treatment and purposes for which the data is used.

 

3 – ON WHAT BASIS CAN WE TREAT YOUR PERSONAL DATA?

These are the circumstances in which we handle your personal data:
 
Consent

When you have your express consent – ​​in writing, orally or by validating an option – and in advance and if this consent is free, informed, specific and unambiguous. Examples are your consent for Fred's Adventures to review your use of the services, make recommendations or send marketing messages, your consent for us to use the service information to improve our quality of service; 
 
or 
 
Contract execution and pre-contractual diligence

When the processing of personal data is necessary for the execution, execution and management of the contract entered into with Fred's Adventures, such as for the preparation of a proposal of products and/or services for the management of contacts, information and requests, for the billing, collection and payment management;  
 
or 
 
Compliance with legal obligation

When the processing of personal data is necessary to comply with a legal obligation to which Fred's Adventures is subject, such as the communication of identification data to police, judicial, tax or regulatory entities;  
 
or 
 
Legitimate interest

When the processing of personal data corresponds to a legitimate interest of Fred's Adventures or third parties, such as the processing of data for, improvement of service quality, fraud detection and revenue protection and when our reasons for its use prevail over their data protection rights; 

 

4 – FOR WHAT PURPOSES AND FOR HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

How long do we treat your Personal Data?

Your personal data is treated by Fred's Adventures only for the period of time necessary to achieve the defined purpose or, as applicable, until you exercise your right to object, right to be forgotten or withdraw your consent. After the respective conservation period has elapsed, Fred's Adventures will delete or anonymize the data whenever they should not be kept for a different purpose that may subsist.  
 
 
For what purposes do we process your Personal Data? 

Purposes

Examples of purposes (not exhaustive) 

Marketing and Sales

- Marketing or selling new products or services 
- Analysis of consumption profiles
- Adaptation and development of new products or services 

- Use of images for posts on social media and promotional materials 

Customer Management and Service Delivery

- Management of contacts, information or requests 
- Complaints management; 
- Invoicing, collection and payment management 

Accounting, Tax and Administrative Management

- Accounting, invoicing 
- Tax information, including sending information to the tax authority 

Litigation Management

- Judicial and extrajudicial collection 
- Management of other conflicts 

Fraud Detection, Revenue Protection and Auditing 

- Detection of fraud and illegal practices 
- Protection and control of revenue 
- Credit risk management 
- Internal audit and investigation 

Compliance with legal obligations 

- Call location for emergency services 
- Court orders 
- Investigation, detection and prosecution of serious crimes  
- Response to judicial, regulatory and supervisory entities 

Information security control

- Access management, logs  
- Backup management 
- Security incident management 

 
What are the deadlines for processing and retaining personal data? 
 
Fred's Adventures processes and maintains your personal data according to the purposes for which they are processed.  
 
There are cases in which the law requires the processing and conservation of data for a minimum period of time, for example, 10 years, the data required for information to the Tax Authority for accounting or tax purposes.  
 
But, whenever there is no specific legal obligation, then the data will only be processed for the period necessary to fulfill the purposes that motivated its collection and preservation and always in accordance with the law, the guidelines and decisions of the CNPD.  
 
Thus, Fred's Adventures will process and maintain your personal data for the period in which it maintains a contractual relationship with you. 
 
Fred's Adventures may keep other personal data for periods longer than the duration of the contractual relationship, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that underlie it, but always for the strictly period necessary for the achievement of the respective purposes and in accordance with the guidelines and decisions of the CNPD.  
 
Examples are contacting for marketing and sales purposes, preserving data within the scope of invoice claims, exercising warranty rights or offerings that are in the interest of the customer or prospect. 

 

5 – HOW DO WE COLLECT YOUR PERSONAL DATA?

How do we collect your personal data?  
We collect personal data with your consent when you purchase Fred's Adventures products or services, when you download or use Fred's Adventures e-books, quizzes, sessions, offers, products, services and applications or when you participate in market studies. Collection can be done orally, in writing or via the Fred's Adventures website.

But your personal information may also be collected from publicly accessible or other sources.  
 
 
How is your personal data collected indirectly?

In order for you to better understand this indirect collection, we indicate the following cases: 
 
Other relevant information about credit risk or about identification and contact details, for collection management, fraud detection and revenue protection.

Fred's Adventures may collect personal data from private entities that maintain relevant information about the credit of the holders of personal data, provided that these bases respect the applicable data protection rules. KAMAE may also access, collect or confirm personal data on websites of the Public Administration and private entities, namely, to confirm the accuracy of your identification and contact details. 

 

6 – DATA ANALYSIS 

Cookies Policy

Information about our use of cookies.

Our website uses cookies to differentiate you from other users of our website. This helps us to provide a good experience when browsing our website and also allows us to improve our website. 

A cookie is a small file of letters and numbers that we store in your browser or on your computer's hard drive, if you agree. Cookies contain information that is transferred to your computer's hard drive. 

The cookies we use are “analytical” cookies. They allow us to recognize and count visitor numbers and see how visitors move around our site when they use it. This helps us to improve the way our site works, for example by ensuring that users find what they are looking for with ease. You can find more information about the individual cookies we use and the purposes for which we use them below: 

Analytics 

The services contained in this section allow the owner to monitor and analyze web traffic and can be used to track user behavior. 

Google Analytics (Google Inc.) 

Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the collected data to track and examine the use of this website, prepare reports on its activities and share them with other Google services. 

  • Google may use the data collected to contextualize and customize ads from its own ad network. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy - Decline

Facebook Ads Conversion Tracking (Facebook, Inc.) 

Facebook Ads Conversion Tracking is an analytics service provided by Facebook, Inc. that connects Facebook ad network data with actions taken on this site. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy

Commented Content

Content comment services allow users to make and post their comments on the content of this website. 

Depending on the settings chosen by the owner, users can also leave anonymous comments. If there is an email address among the Personal Data provided by the user, it may be used to send notifications of comments about the same content. Users are responsible for the content of their own comments. 

If a third-party-provided content commenting service is installed, it may still collect web traffic data for pages on which the commenting service is installed, even when Users do not use the content commenting service. 

Facebook Comments (Facebook, Inc.) 

Facebook Comments is a content commenting service provided by Facebook, Inc., allowing the user to leave comments and share them on the Facebook platform. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy

Email marketing

We collect your name and email address when you register for a webinar or event, request a free resource, or join a waiting list via Systeme (Privacy Policy). 

We use this data to send you emails about useful advice and industry news and to notify you of services and products you may be interested in. You can unsubscribe from our list at any time. 

In addition, we collect your last name and postal address when you purchase a product or course, as part of our payment provider's card verification and sales tax collection process. 

Remarketing and behavioral targeting

This type of service allows this website and its partners to inform, optimize and serve advertising based on the user's past use of this website. 

This activity is carried out by tracking Usage Data and Cookies, information that is transferred to the partners who manage the remarketing and behavioral targeting activity. 

In addition to any opt-outs offered by any of the services below, you may opt-out of the use of cookies by a third-party service by visiting the Network Advertising Initiative opt-out page. 

Facebook Remarketing (Facebook, Inc.) 

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that links activity on this website to Facebook's advertising network. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy - Decline

Personalized Facebook Audience (Facebook, Inc.) 

Facebook Personalized Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that links activity on this website to the Facebook advertising network. 

  • Personal Data Collected: Cookies and email address. 

  • Processing location: United States - Privacy Policy - Decline

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly on the pages of this website. 

The interaction and information obtained through this website is always subject to the user's privacy settings for each social network. 

This type of service can still collect traffic data for the pages on which the service is installed, even when Users do not use it. 

Twitter Tweet button and social widgets (Twitter, Inc.) 

The Twitter Tweet button and social widgets are services that allow you to interact with the Twitter social network provided by Twitter, Inc. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy

Facebook Like Button and Social Widgets (Facebook, Inc.) 

The Facebook Like Button and Social Widgets are services that allow you to interact with the Facebook social network provided by Facebook, Inc. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy

LinkedIn Button and Social Widgets (LinkedIn Corporation) 

The LinkedIn Button and Social Widgets are services that allow you to interact with the LinkedIn social network provided by LinkedIn Corporation. 

  • Personal Data Collected: Cookies and Usage Data. 

  • Processing location: United States - Privacy Policy

How to provide or withdraw consent for the installation of cookies

In addition to what is specified in this document, the user can manage cookie preferences directly in their own browser and prevent - for example - third parties from installing cookies. 

Through browser preferences, it is also possible to delete cookies installed in the past, including cookies that may have saved the initial consent for the installation of cookies by this website. 

Users can, for example, find information on how to manage cookies in the most used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari e Microsoft Internet Explorer

With respect to Cookies installed by third parties, Users may manage their preferences and withdraw their consent by clicking on the related deactivation link (if provided), using the means provided in the third party's privacy policy or by contacting the third party. 

Notwithstanding the foregoing, Owner informs that Users may follow the instructions provided in the initiatives subsequently linked by the EDAA (EU), by the Network Advertising Initiative (EUA) and by the Digital Advertising Alliance (EUA), DAAC (Canadá), DDAI (Japão) oor other similar services. These initiatives allow users to select their tracking preferences for most advertising tools.

The Owner, therefore, recommends that Users make use of these features in addition to the information provided in this document. 

System logs and maintenance

For operation and maintenance purposes, this website and any third party services may collect files that record the interaction with this website (system logs) using other personal data (such as IP address) for this purpose. 

Changes to this privacy policy

The owner reserves the right to make changes to this privacy policy at any time by notifying users on this page and possibly within this website and/or - as far technically and legally possible - sending a notice to users via any information of contact. 

If the changes affect the processing activities carried out based on the user's consent, the owner must obtain new consent from the user, when necessary. 

Owner and Data Controller 

Fred’s Adventures, Rua Vasco da Gama, 104 Serra dos Mangues 

2460-697 Alcobaça 

Owner's contact email: fred@fredsadventures.pt  

As the installation of third party cookies and other tracking systems through the services used on this website cannot be technically controlled by the owner, any specific references to cookies and tracking systems installed by third parties should be considered indicative. For complete information, we ask the User to consult the privacy policy of the respective third party services listed in this document. 

Given the objective complexity surrounding the identification of Cookie-based technologies, Users are encouraged to contact the Owner if they wish to receive more information about the use of Cookies by this Site. 

 

7 – WHAT ARE YOUR DATA PROTECTION RIGHTS AND HOW TO EXERCISE THEM?

What are your rights?  

See below for your rights and the details of what is safeguarded in each one

Right of access

Right to obtain confirmation of what your personal data are being processed and information about them, such as the purposes of the processing, the retention periods, among others. Right to view or obtain a copy of, for example, your invoices, written agreements or support requests you have made. 

  

Right of correction

Right to request correction of your personal data that are inaccurate or request that incomplete personal data be completed, such as address, VAT number, email, telephone contacts, or others. 

  

Right to data deletion or "right to be forgotten” 

Right to have your personal data erased, as long as there are no valid grounds for its preservation, such as in cases where Fred's Adventures has to keep the data in order to comply with a legal obligation to preserve it for investigation, detection and prosecution crimes or because a court case is in progress. 

  

Right to portability

Right to receive the data you have provided us in digital format for current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new person responsible for your personal data, such as receiving your invoices or transmit your contact details to the new person responsible, but in this case only if technically possible. 

  

Right to withdraw consent or right to object 

Right to oppose or withdraw your consent at any time to data processing, for example in the case of data processing for marketing purposes, provided that there are no legitimate interests that prevail over your interests, rights and freedoms , such as defending a right in a judicial process. 

  

Limitation right

Right to request limitation of the processing of your personal data, in the form of: 
 

  1. Treatment suspension 

  2. Limiting the scope of processing to certain categories of data or processing purposes. 

Right to complain

Right to file a complaint with the supervisory authority, the CNPD, in addition to the company or the DPO. 

How can you exercise your rights? 

The exercise of rights is free of charge, unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged taking into account the costs. Information must be provided in writing but, if requested, may be provided orally. In this case, Fred's Adventures must verify your identity by means other than oral. 
The response to requests must be provided within a maximum period of 30 days, unless it is a particularly complex request.  

Exercise your rights through the following addresses:  

Fred’s Adventures 
Letter: 

Rua Vasco da Gama, 104 Serra dos Mangues 
2460-697 Alcobaça 

Email: fred@fredsadventures.pt 
Telephone: +351 916 311 220 

 

8 – TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?

Under what circumstances is your personal data communicated to other entities, subcontractors or third parties?

Your data may be passed on to subcontractors for them to process in the name and on behalf of Fred's Adventures. In this case, Fred's Adventures will take the necessary contractual measures to ensure that the subcontractors respect and protect the holder's personal data. Data may also be transmitted to third parties - entities other than Fred's Adventures or subcontractors - such as companies with which Fred's Adventures develops partnerships, if the owner has consented - or entities to which the data must be communicated by force of law, as the tax authority.  
 
9 – HOW DOES FRED'S ADVENTURES PROTECT YOUR PERSONAL DATA?

Fred's Adventures has implemented the appropriate, necessary and sufficient logical, physical, organizational and security measures to protect your personal data against destruction, loss, alteration, dissemination, unauthorized access or any other form of accidental processing or unlawful..  
 
Fred’s Adventures has implemented: 
 
 

  • Logical security requirements and measures, such as the existence of a strict policy on access to systems and information and the recording of actions taken by employees of Fred's Adventures on personal data of customers or users (logging); 

  • Physical security measures, including strict access control to the physical facilities of Fred's Adventures, by employees, partners and visitors; 

  • Scrutiny, audit and control mechanisms to ensure compliance with security and privacy policies; 

  • An information and training program for Fred's Adventures employees and partners; 

  • Rules of access for Customers or Users to certain products or services, such as the introduction of a password, to allow the reinforcement of control and security mechanisms. 

 

10 – USEFUL ADVICE FOR THE PROTECTION OF YOUR DATA

Fred's Adventures and Third Party Websites

Regarding the use and processing of personal data from Fred's Adventures websites, be sure to consult the rules on the use of cookies on the respective websites. 
 
Fred's Adventures websites, products or applications may contain links to third party websites, products or services that have no relationship with Fred's Adventures or are not covered by this Privacy Policy. 
 
The collection or processing of personal data requested by these third parties is your sole responsibility, and Fred's Adventures cannot be held responsible, under any circumstances, for the content, accuracy, veracity or legitimacy of these websites or for the misuse of the data collected or processed through them. 
 
We alert Fred's Adventures Customers and Users to this fact and to the need, before using the websites, products or applications, to read and accept the rules regarding the processing of personal data defined by these third parties.  
 
 
Other advices 

FRED'S ADVENTURES advises prudence in the exposure of your personal data and in the circulation of this data over the internet, acts that are the full responsibility of the customer, since this data is not fully protected against possible violations, the adoption of complementary security measures, including the maintenance of equipment (PCs, tablets or mobile phones) and programs duly updated and configured with firewalls and protection against malicious software (eg, antivirus), not browsing sites with dubious reputation or for which they do not have the proper guarantees of authenticity, the physical protection of your equipment and avoid placing access credentials on publicly accessible computers (eg, cybercafés, hotels, etc.) and the use of strong passwords that are differentiated according to each service or website. 

 
 

Legal information 

This privacy statement was prepared based on provisions of multiple legislations, including art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). 

This privacy policy applies only to this website, if not otherwise indicated in this document. 

 
 

Information not contained in this policy

Further details regarding the collection or processing of personal data may be requested from the Owner at any time