I – Privacy and Protection of Personal Data
Privacy and protection of the personal data of all our members and users of services supplied by Creative You at all times are key aspects guiding how we act and how we organise ourselves. CREATIVE YOU strives to make sure all its members and users of its services are constantly up to date as regards the rules and principles concerning the protection and processing of personal data, making every effort to guarantee the security of the data in compliance with the legally defined rules and procedures, namely the Personal Data Protection Law.
Therefore, the company adopts the best technical and organisational practices to protect personal data against loss, accidental or illicit erasure and improper modification, as well as against breaches of integrity, access or non-authorised disclosure.
CREATIVE YOU also recommends that its members and users of its services adopt supplementary security measures, including the maintenance of equipment and duly updated and configured programs, the adoption of protection against malicious software and a firewall and the avoidance of websites that do not provide authenticity guarantees.
II – What is Personal Data?
Personal data is information of any nature, regardless their form, including sound and image, relative to a singular identified or identifiable person. Identifiable means the person may be directly or indirectly identified through an identification number or other specific details of his/her physical, physiological, psychic, economic, cultural or social identity.
III – Controller of the Collection and Processing of the Personal Data
CREATIVE YOU is the controller of the collection and processing of the personal data of its members and users of its services, and is in charge of deciding within the context of the service provision, which personal data are collected, the means of processing the data and the purposes for which they are used.
IV – Responsibility regarding data transmitted to Third Parties
CREATIVE YOU may, in exercising its activity and within the scope of the Services it provides, subcontract third parties to carry out the above-mentioned tasks and to manage its information systems, which may imply access by entities to the personal data of its members. When this is the case, CREATIVE YOU shall implement suitable measures to make sure that the entities that have access to the data provide the strongest guarantees in technical, organisational and human terms to guarantees this security.
As such, the Third Parties subcontracted by CREATIVE YOU, in addition to being bound to an agreement signed with CREATIVE YOU, are legally required to implement suitable technical and organisational measures to protect personal data against accidental or illicit destruction, dissemination, alteration, disclosure, non-authorised access or any other illicit processing, as well as being bound to special duties of professional secrecy and confidentiality.
Outside these cases, CREATIVE YOU will only transmit its members’ personal data to Third parties when:
a) compelled to do so by legal imposition and only insofar as its obligations, or
b) in cases expressly permitted by law, if members or users of the services expressly and specifically authorise this transmission and if they are duly informed, in writing, about who the recipients of the personal data are and the purposes for which the data is being transmitted.
In either case, CREATIVE YOU remains responsible for the personal data supplied by the members.
The provision of certain services by CREATIVE YOU may imply the transfer of your personal data outside Portugal. In this case, the company declares that it will scrupulously assess the suitability of the destination country as regards protection of personal data and the requirements applicable to such transfers, under the respective legal terms.
V – Conditions for the Personal Data Collection
CREATIVE YOU only collects and processes personal data from its members and users of its services upon obtaining express consent and/or as provided for in Law and in compliance with the legal regulations and the statutory obligations of CREATIVE YOU, for each of the specific processing purposes in question, under the terms of the Personal Data Protection Law.
However, some personal data are indispensable for CREATIVE YOU to provide its Services (mandatory data), and the members are duly informed in advance about this necessity and the consequences of not providing the aforementioned data.
If the personal data deemed indispensable are not supplied by the members or are insufficient, incorrect or out-of-date, CREATIVE YOU cannot provide the Services subscribed to and/or determined by Law. In this case the members shall accept full and sole responsibility for the insufficiency or inaccuracy of the data transmitted.
VI – Personal Data Storage Period
CREATIVE YOU shall only store the personal data of its members and users of its services for the period of time strictly necessary to enable:
a) the provision of the Service(s);
b) compliance with the legal requirements of CREATIVE YOU;
c) pursuance of the purposes for which the data is collected and/or processed;
d) exercising the rights of its members and users of its services and complying with the corresponding obligations.
VI – Rights of the members relative to their personal data
In accordance with the stipulations of the Personal Data Protection Law, the members and users of the CREATIVE YOU services, in their capacity of data subjects, and free of charge, have the right to access, correct, update and delete their personal data.
In any of the aforementioned cases, the members and users of the CREATIVE YOU services may exercise their legitimate rights by sending an e‑mail to email@example.com, addressed to the Personal Data Protection Officer.
VII – Unsolicited e-mails for direct marketing purposes
The contact data of members who are individuals may be used by CREATIVE YOU, upon obtaining consent, in direct marketing and promotional initiatives linked to the services it provides (e.g. commercial benefits), under the terms of the Law.
In any of the above cases, the members are entitled to withdraw their consent any time free of charge.
VIII – Cookies Data
Cookies are small text files stored in the computer by the internet browser, storing only information related to the user’s preferences (generic information), not including the user’s personal data.
The cookies used by CREATIVE YOU comply with the principles of anonymity and confidentiality and their sole purpose is to recognise the user. They are not used under any circumstances to collect information that identifies the user, or for direct marketing purposes. Cookies help the CREATIVE YOU website to recognise the user’s device the next time he/she visits the website.
Users can decide to be notified about the reception of cookies at any time through their internet browser and may block the cookies from entering their system.
What are cookies used for? Cookies help gauge the utility, interest and number of uses of the CREATIVE YOU website, enabling faster and more efficient navigation, eliminating the need to introduce the same information repeatedly.
IX – Personal Data Security Measures adopted
CREATIVE YOU employs a Data Protection Officer, who is responsible for implementing and complying with the legal rules and regulations on the processing of personal data, and who is responsible for designing and maintaining the Personal Data Security, Confidentiality and Protection Policy.
X – Contacts
For more information about how CREATIVE YOU processes the personal data of its members and the users of its services, or to clarify any doubt, lodge a complaint or leave comments about any subject related to the Privacy and Protection of Personal Data, please send your message to: firstname.lastname@example.org