TERMS OF USE AND PRIVACY POLICY

Effective Date: 1st of November 2019

1. INTRODUCTION

Eurofluxo, Lda. and its subsidiaries ("EUROFLUXO") want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about privacy, and we want to maintain your trust.

This Privacy Policy applies to information we collect from all sources, including in connection with our websites, mobile sites, applications ("apps"), widgets, and electronic newsletters or communications (collectively the "EUROFLUXO Services") that link to this Privacy Policy.

This Policy describes the types of Personal Data we collect, how we use it, and with whom we share it. It also describes generally EUROFLUXO's practices for handling Other Information (e.g., interests, demographics and services usage) collected through our EUROFLUXO Services or from a third party to the extent such information is associated with a particular device, user or user account. We also describe the measures we take to protect the information, your options for choice and access, and how you can contact us about privacy practices. As described more fully below, we share information with our subsidiaries, and affiliated companies ("EUROFLUXO Affiliates"), for the purposes described in this Privacy Policy. By using the EUROFLUXO Services, you acknowledge you have read and accept this Privacy Policy.

Your decision to use the EUROFLUXO Services and provide your Personal Data is voluntary. We indicate on our online, mobile, and other registration forms what types of Personal Data are requested. You may choose not to submit requested information online, or may choose to restrict the use of cookies (see Other Information below), but that may limit the services EUROFLUXO is able to provide to you.

The EUROFLUXO Services are not targeted to, and do not knowingly collect Personal Data from, minors under 16 years of age. We request that these individuals do not provide Personal Data through the EUROFLUXO Services.

2. WHAT WE COLLECT

EUROFLUXO and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent. EUROFLUXO and our service providers may collect the following information from and about you:

2.1 Personal Data

"Personal Data" for purposes of this Privacy Policy is the information that identifies you as an individual or relates to an identifiable person.

2.1.1 Personal Data You Submit

We collect Personal Data when you submit it to us, such as when you register for or subscribe to certain products or services; create a profile; visit our EUROFLUXO Services; use an interactive feature (such as chat or article sharing options); participate in a community forum; or contact customer service. The Personal Data you submit may include your name, postal address and email address.

2.1.2 Personal Data We Receive From Third Parties

To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, EUROFLUXO Affiliates, business partners, and, if applicable to you, the third party provider of your subscription. The Personal Data we receive from third parties may include your name, contact information, or relationships with various product and service providers, and your use of certain applications. When you access the EUROFLUXO Services, you are authorizing EUROFLUXO to collect, store, and use such information and content in accordance with this Privacy Policy.

2.2 Other Information

"Other Information" is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information. Our services use cookies and other tracking technologies to function effectively and deliver certain features.

3. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION

We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.

To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other EUROFLUXO products, services and websites.

This information can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations.

3.1 To Provide, Measure And Improve Our Products And Services

We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your subscription, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve services and features, to allow you to engage with us (e.g., to comment on content and participate in promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to provide you with customer support, including online chats, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data may be included in a directory that can be viewed and used by other users of these collaboration tools.

3.2 To Deliver Relevant Content And Recommendations

To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content on any of EUROFLUXO Services.

3.4 To Protect The Rights Of EUROFLUXO And Others

EUROFLUXO may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of EUROFLUXO, our Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.

4. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION

4.1 Our Disclosure of Personal Data and Other Information

EUROFLUXO and its subsidiaries may share your Personal Data with one another, as well as with EUROFLUXO Affiliates for the purposes described in this Privacy Policy, including for each company's marketing purposes if you have consented to such use. Users who visit EUROFLUXO Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy. EUROFLUXO is the party responsible for the management of the jointly-used Personal Data.

4.2 Information Made Public Through Use of Our Services and User Privacy Settings

Certain features on the EUROFLUXO Services give you an opportunity to interact with us and others. These may include the collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, and rating, tagging, and commenting on articles. When you use these features, you should be aware that any information you choose to submit, including your name, user name, location, email address, profile information, picture or image, likes, status, and comments, including any political or religious or other beliefs you express, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the EUROFLUXO Services. We are not responsible for any information you choose to submit and make public through these interactive features.

5. HOW WE PROTECT AND RETAIN PERSONAL DATA

EUROFLUXO uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting EUROFLUXO in accordance with the instructions below.

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

6. YOUR RIGHTS AND CHOICES

Where you have provided your consent for our use of your Personal Data, you have the right to withdraw your consent and we will apply your preferences going forward.

For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

7. OTHER IMPORTANT INFORMATION

7.1 Updates to Privacy Policy

EUROFLUXO may periodically update this Privacy Policy without prior notice to reflect changes in our practices. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the EUROFLUXO Services. We will notify you by posting a prominent notice on the EUROFLUXO Services indicating we have updated this Privacy Policy. Your use of the EUROFLUXO Services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Policy.

8. CONTACT US

If you have questions about this Privacy Policy or how we or our service providers handle your Personal Data, please contact our Data Protection Officer at dpo@eurofluxo.com.

Or you may write to:

Eurofluxo - Suporte a Novas Tecnologias, Lda.

Rua da Cavada Velha 13

4430-054 Vila Nova de Gaia

Portugal

We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, you can contact a supervisory authority. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.