Privacy policy

It is important that you read this privacy policy carefully to understand how we take care of, handle, and process your personal data, and to be aware of your rights and how the law protects you.

What is included in this policy?

  1. Important information and who we are

  2. The personal data we collect and how we use it

  3. Who we share your personal data with

  4. International data transfers

  5. How we keep your personal data secure

  6. How long we retain your personal data

  7. How you can control your own personal information

  8. Changes to this privacy policy and our duty to inform you about them

1 - Important information and who we are

Purpose of this privacy policy The purpose of this privacy policy is to inform you about how we collect, handle, and process your personal data. It applies to your use of our websites, app, and when you contact us.

Responsable for the treatment of data

We are Dialogo Inédito Unipessoal LDA, located at Avenida Marquês de Tomar n.81 3.esquerdo, 1050-242 Lisbon, Portugal, VAT number 516 121 561 (referred to as EUFONIA below).

For the purposes of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, known as the General Data Protection Regulation (GDPR), and Law No. 58/2019 of August 8th which ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 of the Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (LPD), EUFONIA adopts the necessary measures to ensure the security, integrity, and confidentiality of the data in accordance with the GDPR and LPD.

Contact information 

If you have any questions or concerns about this policy, including any requests to exercise your rights, please contact us by mail at Avenida Marquês de Tomar n.81 3.esquerdo, 1050-242 Lisbon, Portugal, or by email at hello@eufonia.io.

Third-party links 

Our websites and app may include links to third-party websites, plugins, and applications. In some cases, we may have joint responsibility with these third parties. This means that we may be jointly responsible with this third party for determining the collection and/or use/processing of your personal information. Clicking on these links or activating these connections may allow third parties to collect or share data about you. You may find links on our websites or in the app to other services operated by our company and trusted third parties. Clicking on such links may allow third parties to collect or share personal data about you, so we encourage you to read the privacy policy on the websites and applications you visit.


2 - The personal data we collect and how we use it

We process the following categories of personal data:

To apply and participate in our Open Calls for our projects, we collect your full name, date of birth, and contact information to register you for the Open Call.

To provide you with services and products related to the application and participation in the Projects resulting from the Open Call, we use your full name, contact information, and postal address.

To provide customer support, we use your full name, contact information, and any other information you provide when contacting us through our website, app, social media accounts, email, or phone.

We do not intend to collect or process special categories of data. However, if you voluntarily provide us with this information, we will only process it to respond to your inquiry. Any special category data you provide will be deleted once your inquiry is resolved. Regarding health data, we process information related to our services and whether or not you have hearing impairment. The Implementation Law of the GDPR establishes, in Article 29(6), a specific regime regarding access to this type of data. Under the heading "Processing of health data and genetic data," the mentioned Article 29(6) states that "the data subject must be notified of any access to his or her personal data, and the data controller must ensure the provision of this traceability and notification mechanism." Thus, we will ensure: (i) a traceability mechanism for data access (recording the identity of the person accessing, the time of access, and the accessed data); and (ii) a notification mechanism to the data subject that will include the traced elements.

To personalize and enhance your experience when visiting our websites or app, we use information about how you interact with our websites, app, and services to target our advertisements to be more relevant to you. This includes the use of cookies, pixels, and device identifiers. To learn more about how you can control your data, please refer to the details included in our cookie policy.

To inform you about products and services that may interest you, if you give us your consent, we use your full name, email address, pixel tracking, cookie data, and preferences to send marketing communications related to Open Calls and our services and products. You can withdraw your consent at any time, with future effect.

To stay in touch with you, we use your full name, contact information, and postal address to send you service and product communications.

To ensure the proper functioning of our websites and app, we use technical information about your device (including but not limited to your IP address, browser type, and version) to ensure the website is secure and functions on your device. We also use this data for management information and reporting purposes.

To develop and improve our products and services, we use information about how you interact with our websites, app, services, and emails to understand where to direct our advertisements to be more relevant to you. We use your feedback through satisfaction surveys to improve our services and customer service quality.

For security and protection purposes, and to prevent and detect criminal activities, we use your account information and some technical information about your device to confirm your identity, detect fraudulent behaviors, and prevent criminal activities.

To comply with our legal obligations, we may use the data we collect about you to ensure compliance with any legal obligations imposed on us.

We use different methods to collect data, including:

Direct interactions - you may provide us with any of the above-mentioned information when using our website or app, or when contacting us by phone, mail, email, or in person. We may also collect data if you participate in any events we promote.

Technologies or automated interactions - as you interact with our website, we will automatically collect some technical data about your equipment, actions, and browsing patterns. We collect this personal data using cookies, server logs, and other similar technologies. We may also receive this technical data about you if you visit other websites that use our cookies. Please read our Cookie Policy to understand how we use our cookies.

Third parties - we may receive information about you from third parties. When we receive information from other sources, we will inform you when we have collected that data, which may be shared internally and combined with the data already collected about you from your use of this website, so that you can immediately exercise your rights and, if applicable, withdraw your consent at any time, with future effect.

Legal basis for processing your personal data 

Depending on the processing activity, we rely on at least one of the following legal bases for processing your personal data under the GDPR:

Consent - whenever you have given us your consent, or explicit consent when appropriate (Compliance with contractual obligations (Art. 6(1)(a) of the GDPR). You can withdraw your consent at any time, with future effect.

Compliance with contractual obligations (Art. 6(1)(b) of the GDPR) - it is necessary for the performance of a contract or to take steps at your request before entering into a contract.

Legal obligation - it is necessary to comply with a legal obligation to which we are subject (Art. 6(1)(c) of the GDPR).

Legitimate interests - it is necessary for our legitimate interests (or those of third parties) except where your interests or fundamental rights and freedoms override those interests (Art. 6(1)(f) of the GDPR).

Vital interests - it is necessary for the protection of your vital interests or those of another natural person (Art. 6(1)(d) of the GDPR).

Public interest tasks - it is necessary for the performance of tasks carried out in the public interest or in the exercise of official authority vested in us.

If you do not provide your information 

If you do not provide certain information when requested, we may not be able to provide the services you intend to contract with us.


Marketing 

You can ask us to stop sending you marketing messages at any time by clicking "unsubscribe" in our emails. If you have given your consent, please read our Cookie Policy to learn how you can reject cookies and stop receiving online targeted advertising.

We may ask you to confirm or update your marketing preferences if you ask us to provide you with more products and services in the future or if there are changes in the law, regulations, or the structure of our business.

Change of Purpose 

We will only use your personal data for the purposes for which we collected it, and in accordance with the legal grounds for processing, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose and complies with applicable legislation, having legitimacy to do so. If you wish to receive an explanation of how processing for the new purpose is compatible with the original purpose, please contact us at hello@eufonia.io.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in accordance with the rules mentioned above, whenever it is required or permitted by applicable law.

3 - Who we share your personal data with 

We may share your personal data with third parties in order to provide the service you have requested from us. However, before sharing your data with any other entity, we will ensure that:

  • They provide sufficient guarantees regarding the confidentiality and security of your personal data.

  • We have a written contract with them that defines the terms of use of your data, how they can protect it, and what to do with it after the end of the contractual relationship.

  • We only share the data they need to fulfill the services requested by us.

4 -  International transfers 

Whenever we transfer your personal data outside the European Economic Area (EEA), we ensure an equivalent level of protection by implementing at least one of the following safeguards:

  • We will only transfer your personal data to countries that we consider offer an adequate level of personal data protection.

  • Whenever we use certain service providers, we ensure the existence of adequate safeguards and that we can use specific contracts approved for use in the European Economic Area (EEA), which provide personal data with the same protection it receives in the European Economic Area (EEA).

Please contact us at hello@eufonia.io if you would like more information about the specific mechanism we use when transferring your personal data outside the European Economic Area (EEA).

5 - How we keep your personal data secure 

We have taken appropriate security measures to prevent your information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. These measures include encryption and authentication tools to help protect and maintain the security, integrity, and availability of your personal data.

We limit access to your personal data to employees, agents, contractors, and other third parties who have a business need to know. Your personal data will only be processed according to our instructions and is subject to a duty of confidentiality. Health data will only be processed by or under the responsibility of professionals bound by confidentiality, to the extent necessary for the provision of Eufonia services.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulators of a breach when we are legally required to do so.

While data transmission over the internet or website cannot guarantee complete security against intrusion, we make every effort to implement and maintain physical, electronic, and procedural security measures to protect your personal data in accordance with applicable data protection requirements and prevent unauthorized access to your personal data.

If we have provided you with a password or if you have chosen one for accessing certain areas of our website or other portals, applications, or services operated by us, it is your responsibility to keep the password confidential and comply with any security procedures you have been informed of. We especially ask that you do not disclose your password.


6 - How long do we keep your personal data 

According to Article 17 of the GDPR, we will only store your data for the period strictly necessary for the respective processing purposes. If the data is processed for multiple purposes, it will be automatically erased or stored in a format that does not allow conclusions to be drawn about your identity as soon as the last specific purpose has expired.

Whenever there is no specific legal requirement, the data will be stored and retained only for the minimum period necessary for the purposes that prompted its collection or subsequent processing, after which it will be deleted. For application users, you can delete your account through the application. If you have any questions regarding the closure of your account and which data to retain, please contact hello@eufonia.io.

7 - How you can control your own personal information 

You can exercise the data protection rights recognized in the GDPR at any time. In summary, these include:

  • Being informed about how we use your personal data

  • Access to the personal data we have about you

  • Requesting the transfer of certain elements of your personal data to another service provider

  • Requiring us to correct any errors in the personal data we have about you

  • Requesting the deletion of your personal data in certain situations

  • Withdrawing your consent whenever the processing of your personal data is based on prior consent (e.g., unsubscribing from our direct marketing communications)

  • Objecting to or restricting or suspending us from processing your personal data in certain circumstances (e.g., if you want to restrict processing while we verify the accuracy of your personal data)

  • Requesting not to be subject to automated decisions that significantly affect you

  • Right to lodge a complaint with the National Data Protection Commission (CNPD), the regulatory authority for data protection in Portugal (www.cnpd.pt).

If you want to exercise your rights, please contact us at hello@eufonia.io. If you exercise any of these rights, we will review your request and respond within 1 (one) month.

8 - Changes to this privacy policy and our duty to inform you about them 

Our privacy policy is subject to regular review. This version was last updated on 2023-05-25. It is important that the personal data we have about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.


COOKIES POLICY

EUFONIA uses cookies to provide a better browsing experience that meets your needs, as well as to protect and improve the website and its services. Please read this Cookie Policy carefully to learn about EUFONIA's responsible use of cookies and the options you have to configure your browser and manage them.

What are cookies? 

Cookies are small data files generated on the user's computer that allow us to track their frequency of visits, the most selected content, and the security elements that may affect access control to restricted areas, as well as the display of advertising based on criteria predefined by EUFONIA and activated by cookies served by the said entity or third parties providing these services on behalf of EUFONIA.

Generally, there are the following types of cookies:

  • Based on their expiration:

    • Session: Expire at the end of the session.

    • Persistent: Do not expire at the end of the session.

  • Based on their origin:

    • First-party: Enabled by the website you are browsing.

    • Third-party: Originating from other websites.

  • Based on their purpose:

    • Technical: Enable navigation and use of different services.

    • Personalization: Allow access to the service with predefined characteristics.

    • Analytics: Enable tracking and analysis of user behavior.

    • Advertising: Enable the management of advertising spaces.

    • Behavioral advertising: Enable the management of advertising spaces and store information about user behavior.

What types of cookies do we use and for what purposes? 

In our services, we use the following types of cookies for the following purposes:

  1. Analytical cookies:

    • Used to collect user activity statistics, including the number of users visiting the site, the number of pages visited, and user activity and frequency of use on the site.

    • The collected information is always anonymous and cannot be linked to any specific individual.

  2. Authentication cookies:

    • Used to maintain user sessions during each visit, primarily in private areas of the site that require a username and password for access.

  3. Cookies used by social networks:

    • Allow users to share website content of interest with their contacts through a social network by using the corresponding button (plugin) embedded on the site.

    • The plugins store and access cookies on the user's device and enable the social network to identify its users when they interact with the plugins.

  4. Cookies used by external content plugins:

    • Necessary for providing specific types of services and stored by third parties.

    • This category includes, for example, cookies used by multimedia players (video) to store technical data for video or audio playback, such as image quality, loading parameters, etc.

  5. Third-party cookies for personalized advertising spaces:

    • Enable the management of advertising spaces that users see when accessing the site and are stored by third parties.

  6. Who has access to cookie information?

    • The information stored in cookies is used exclusively by EUFONIA.

  7. Can cookies be disabled?

  8. Changes and updates to the Cookie Policy:

    • EUFONIA may modify this Cookie Policy to comply with legislative or regulatory requirements or to adapt the policy to instructions and recommendations issued by regulators.

    • It is recommended to periodically review the Cookie Policy.

Last version: 25/05/2023