PRIVACY AND DATA PROTECTION POLICY

1 | Who we are

MBA has been in the advertising and marketing market since 1989, which has allowed it to improve techniques, invest in technological innovation and, above all, create and present the best solutions in printing, communication and promotion of products, services or events, adapted to needs of each customer. In 2011, knowing the demands and needs of the market with regard to mobility, we bet on the creation of the VOLTSTORE brand, where we made available kits for converting bicycles into electric, electric bicycles and electric motorbikes.

The privacy policy is intended to inform the form of collection, processing and protection of personal data provided online, which we collect and process in strict respect and compliance with national and European Union legislation applicable to the processing of data by all those who somehow relate to the MBA.

MBA is committed to ensuring respect for the rights of personal data subjects and wishes to make you aware of how it collects, uses and protects personal data, the information that the data subject makes available as well as the rights that can exercise. We work permanently to make sure your information is secure.

 

2 | Introduction

Through this Privacy Policy, MBA intends to inform data subjects about the establishment of rules for the use of this website, provide users and customers with information and sell and sell products and services provided by MBA and explain the terms of the processing of your personal data and how it protects them.

The rules in the statement below apply solely and exclusively to the websites and brands of MBA and regulate all information collected about its users and respective requests for contact or quotation. MBA reserves the right to modify at any time the information and commercial offer presented on this website, and may limit or not allow access to it.

Using this website grants the condition of user to whoever does so and implies acceptance of all the conditions included in this Privacy Policy. Some aspects of this website, due to their specialty, may be subject to specific conditions or rules that may replace, complete or modify this Privacy Policy, and therefore must also be accepted by the user who uses or accesses them. When browsing the website, using the present features and providing personal data to MBA, the data subject accepts the policies and terms and conditions present on this website, as well as consenting to the use of their data as defined below.

The user must carefully read this Privacy Policy, each time they use this website, as they are accessing one of our websites, the availability of their personal data implies knowledge and acceptance of the conditions contained herein. Thus, by providing your personal data, you are authorizing the collection, use and disclosure of them in accordance with the rules defined herein. MBA reserves the right to modify, at any time and without prior notice, the presentation and configuration of this website, as well as the General Conditions or the Privacy Policy.

 

3 | What does this Privacy Policy cover?

This document applies exclusively to the collection and processing of personal data carried out by MBA.

 

4 | Responsible for data processing

The entity responsible for the collection and processing of personal data that is collected during use and/or registration on this website is MBA - Marketing e Brindes, Lda., legal person number 502 640 421, headquartered at Rua Vilar of Mr. 493, 4455-213 Lavra, providing the service and that in the context decides which data is collected, the means of processing the data and for what purposes they are used, as it uses third parties to provide external services and adopts all security measures in data processing to ensure security, including protection against unauthorized or unlawful processing and against its loss, destruction, alteration, dissemination, unauthorized access or accidental damage.

MBA's obligations resulting from these terms and conditions, including the duty of confidentiality, are extended to all its employees and subcontractors, regardless of the nature of their relationship, which extends after the end of the contract or their functions. MBA does not provide or sell personal data of customers or users.

You may clarify any doubts or obtain additional information about this Privacy Policy and about the Processing of Personal Data, simply by sending your questions or complaints by registered letter to:

MBA - Marketing e Brindes, Lda.
A/C Responsible for Privacy
Rua Vilar do Senhor 493, 4455-213 Lavra
or to the email address: pd@nobrinde.com

 

5 | What is Personal Data?

Any information relating to an identified or identifiable natural person, whether through an identification number or other specific element that identifies them. An identifiable user is considered to be a user who can be identified directly or indirectly, for example through the name, identification number, location data, electronic identifier or other information that allows the identification of that natural person to be identified.

6 | Personal Data Holders

The holder of personal data is the customer or user, a natural person, to whom the data relates and who has benefited from MBA services or products. The user is the person who uses MBA services or products and the customer is the person who enters into the contract with MBA.

7 | Collection of Personal Data

When and how do we collect personal data?

MBA applies the principle of lawfulness and respects the right to privacy of users of this website, does not collect any personal information without the prior consent of the data subject. In this way, the collection of personal data is limited to those strictly necessary for the purpose of the processing and is carried out with the consent of the user with the objective that the personal data that concern him are processed when he requests more information and/or quotes, acquire MBA products or services or subscribe to electronic communications. The user, by continuing to browse this website and by selecting a checkbox in an online consent process, confirms that he has read the terms and conditions of use and the privacy policy and accepts the binding agreement entered into between the user and MBA . The collection can be done orally, in writing or through one of the MBA websites. Personal data will be processed exclusively for the purposes determining its collection and will only be processed for different purposes when legally permitted and upon provision of information to the respective data subject.

On the other hand, and due to the increasingly intensive interaction through our website, MBA collects information for statistics relating to the use and navigation of customers on our website and respective functionalities, such as device information (model hardware, operating system version, among others), registration and location (browser type, browser language, IP address - Internet Protocol, among others ), the pages visited on the website and cookies (see Cookie Policy).

MBA may collect personal data from private entities that keep relevant information about the credit of the holders of personal data, provided that these bases comply with the data protection rules in force.

MBA may also access, collect or confirm personal data on websites of the Public Administration and private entities, namely, to verify the veracity of the identification and contact data provided by the user.

The user can access, browse and use this website without having to provide any personal information. However, to start a conversation in real time, make contact requests, clarify doubts, obtain personalized quotes by submitting forms or even save products in the list of recommended products, the data subject will have to provide adequate, relevant and personal data not excessive.

In this way, personal data are requested and provided only when the user gives his consent and submits a form, contact us through the real-time chat system (chat), makes a request for a quote (quick or cart) or for more information (forms available on this website). Personal data will be processed for the time strictly necessary, and we apply the principle of proportionality and limitation of conservation.

Any personal data provided by users will be treated with the security and confidentiality guarantees required by the Data Protection Law.

MBA collects the following information from and about you at the indicated locations/functionalities:

Location/Functionality (if applicable) Requested and collected data
New Registration Information The user provides the email address, password and name.
Contact Form Submission It is necessary to provide the name, email address, mobile phone and location, it is optional to fill in the company field.
Request for Budget (cart) It is preceded by a process of collecting information about the user, the registration information, and it is necessary to provide the email address, password, name, country, tax number, address , postal code and telephone, it is optional to fill in the field corresponding to the company, location, mobile phone and fax.
Request for Budget (quick) It is mandatory to provide your name, email address and taxpayer number, address and telephone are optional fields.
Real-time chat (chat) It is mandatory to provide name and email address.
Electronic Marketing Communications Subscription (newsletter) It is necessary to provide the email address, type of customer (company or individual) and select the electronic communication(s) you want to subscribe, filling in the name and company field is optional.


What categories of personal data do we handle?

Identification Data Examples
Identification and contacts Civil or fiscal identification number, company name, billing address, delivery address, telephone number and email address.
Service Product and/or services purchased.


What usage data do we handle?

Service usage data Examples
Location Geographic reference of the user or equipment at a given time
or while using services.
Usage profile Data resulting from browsing our website.

The information collected about you and your purchases will be used solely and exclusively by MBA. Which guarantees that this information will not be used or shared with third parties for promotional purposes via email or telephone.

 

| Purpose of collecting Personal Data

In general, the personal data collected are intended for the management of the contractual relationship, provision of services or products requested, answering the user's doubts and needs, information and marketing actions and the inclusion of the user in subscriber lists . You may, however, provide us with personal data for other purposes, such as for the purposes of sending complaints and suggestions, disseminating institutional information and/or making known campaigns, promotions, advertising and news about MBA products and/or services . When collecting the data, you will be provided with more detailed information about the use we will make of your data.

The collected data are essential to answering questions and requests for budgets, suggestions or complaints from the user, they can also be used for billing awarded products or services and for marketing actions by MBA and the brands that are part of MBA .

Purposes Examples of purposes (not exhaustive)
Client Management
and Service Provision

MBA is dedicated to the sale of promotional marketing products, products and services related to electric vehicles and printing services. It is necessary to process the data of the holders for the fulfillment of the purchase and sale contract or the provision of services to be concluded or for the carrying out of pre-contractual measures at the client's request, such as quotes or clarifications.

Management of contacts, information or requests;
Complaints management;
Billing, collection and payment management;
Consumption analysis.

Marketing and Sales

MBA may process the personal data collected in order to send the respective holder information about products and services marketed by it. The processing will be carried out with the express consent of the holder, provided in particular at the time of budget registration, submission of information requests or when subscribing to our electronic communications. The consent may be revoked at any time by the holder.

Marketing or selling new products or services;
Adaptation and development of new products or services.

Accounting Management,
Tax and Administrative
Accounting, invoicing;
Commission management;
Tax information, including submission of information to the tax authority.
Litigation Management Judicial and extrajudicial collection;
Management of other conflicts.
Fraud detection, protection
of revenue and auditing
Detection of fraud and illegal practices;
Revenue protection and control;
Credit risk management;
Internal audit and investigation.
Fulfillment of obligations
cool
Judicial requests for interception of communications;
Investigation, detection and prosecution of serious crimes;
Response to judicial, regulatory and supervisory entities.
Security Control
of information
Access management, logs;
Backup management;
Security incident management.
Recruitment

During the personnel selection and recruitment process, it collects and processes the personal data of the respective candidates.

Physical Security Control

MBA facilities have a video surveillance system, properly signposted. The image recordings obtained are preserved for a period of 30 days after the capture, after which they are destroyed (without prejudice to conservation for a longer period in case of legal proceedings).

Video surveillance on premises.

 

8 | Fundamentals of Personal Data Processing

A treatment is considered to be an operation or a set of operations carried out on personal data, through automated or non-automated means, such as collection, registration, conservation, alteration, recovery, consultation, use, disclosure , deletion or destruction.

On what basis can MBA treat your personal data?

Consent: MBA obtains your express consent to the processing of your personal data for one or more specific purposes - in writing, orally or via of validation of an option - and prior and this consent is free, informed and specific;

or

Execution of contract and pre-contractual steps: when the processing of personal data is necessary for pre-contractual steps or for the execution and execution of the contract concluded with the MBA. For example, for the preparation of a proposal for products, services or information on the delivery address, for the management of contacts, information and orders, for the management of invoicing, collection and payments;

or

Compliance with a legal obligation: when the processing of personal data is requested to comply with a legal obligation to which the MBA is subject, such as communication of identification or traffic data to judicial, police, tax or regulatory entities;

or

Legitimate interest: when the processing of personal data corresponds to a legitimate interest of MBA or third parties, such as the processing of data to improve the quality of service provided by MBA and fraud detection.

 

9 | What are the deadlines for the processing and retention of personal data?

MBA does not process or retain personal data for longer than necessary depending on the purpose for which they are processed.

In some cases, the law requires the processing and retention of data for a minimum period of time, namely: for one year, traffic and location data for the purpose of investigation, detection and prosecution of serious crimes by the competent authorities or for 10 years the data necessary for information to the Tax Authority for accounting or tax purposes. According to Law nº2/2014, art. 123 nº 4, “The books, accounting records and respective supporting documents must be kept in good order for a period of 12 years.”

As there is no specific legal obligation, the user's personal data are processed only for the period of time necessary to achieve the defined purpose that motivated its collection and preservation and always in accordance with the law or, whichever is the case. applicable, until you exercise your right to object, right to be forgotten or withdraw your consent. In this way, MBA will process and maintain the personal data of users during and after their business relationship, considering the period necessary to provide more information, provide products or services.

With regard to video surveillance (without sound) of its facilities, MBA keeps the recordings of images and respective personal data for a maximum period of 30 days.

MBA may possibly store personal data for periods longer than the duration of the business relationship, either based on the client's consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that underlie it, but always for the period necessary to carry out the respective purposes. For example, contact for marketing and sales purposes, data preservation within the scope of invoice claims, collection, exercise of warranty rights and after-sales service.

 

10 | Rights of the holder of personal data

Procedure for the Exercise of Rights by Data Subjects

The data subject has the right to request information about the personal data that MBA holds and processes. In this way, you can, at any time, access information about your data, limit its treatment, rectify it if it is not correct, delete it and/or request deletion of your data for marketing or telemarketing purposes.

The information must be provided in writing by sending a message to MBA via email to pd@ nobrinde.com or letter addressed to the MBA Responsible for Privacy, Rua Vilar do Senhor 493, 4455-213 Lavra, it is essential to identify the holder of the personal data and indicate the action you intend to take. The data subject can also exercise their rights orally, and MBA must verify their identity by means other than oral. MBA facilitates the exercise of the data subject's rights, unless it demonstrates that it is not in a position to identify the data subject.

If a data subject submits manifestly unfounded or excessive requests, namely due to their repetitive nature, MBA may demand payment of a reasonable fee taking into account the administrative costs of providing the information or may refuse to proceed with the request.

Access Right

The data subject has the right to obtain confirmation as to which personal data are or are not being processed and, if they are being processed, the right to access information about them, such as the purpose of the processing data, category of data in question, retention periods, among others. Right to view/hear or obtain a copy, for example of invoices and written agreements. The data subject must request access by letter or electronically and MBA will respond to the request no later than one month from the date of receipt of the request, and may explain its reasons if there is an intention to refuse the request . The deadline may be extended up to two months, when necessary and taking into account the complexity of the request and the number of requests. MBA informs the data subject in the event of any extension and the reasons for the delay within a period of one month after receiving the request. The data subject is entitled to lodge a complaint with a competent supervisory authority and with the competent courts of the Member States, in particular in the Member State of his habitual residence, his place of work or the place where the alleged infringement was committed, if the data subject considers that the processing of personal data concerning him violates the General Data Protection Regulation.

Right to Rectify or Change Data

The data subject, through a formal request, has the right to rectify or change their personal data that are inaccurate or request that incomplete personal data be completed, such as address, TIN, email, telephone contacts, among others.

Right to Forget or Erase Data

The data subject may request the right to be forgotten, it ceases to be processed if it is no longer necessary for the purpose for which it was collected or processed, without undue delay, provided that there are no valid grounds for the its conservation in the case of legal obligations.

Right to Limit Treatment

The data subject may request the limitation of the processing of their personal data, if one of the following situations applies:
- contest the accuracy of the personal data, for a period that allows the controller to verify its accuracy;
- the processing is unlawful and the data subject opposes the deletion of personal data and requests, in return, the limitation of its use;
- the data controller does not need the data for processing purposes, but these data are required by the data subject for the purposes of declaration, exercise or defense of a right in a legal proceeding;
- if the processing has been opposed until it is verified that the legitimate reasons of the data controller prevail over those of the data subject.

The data subject to whom the limitation of processing has been granted has the right to be informed by the controller before the limitation of said processing is canceled.

Right to Data Portability

The data subject has the right to receive, in a structured format, the personal data that concern him and that he has provided to a controller, just as he has the right to transmit these data to another controller. The data subject is entitled to have personal data transmitted directly between the data controllers, but in this case only if this is technically possible.

When a data subject exercises his right to data portability, he does so without prejudice to any other right, and may continue to use and benefit from the data controller's services and products even after data portability.

Right to Withdraw Consent or Right of Opposition

The data subject may oppose or withdraw his consent at any time to the processing of personal data concerning him, for example in the case of data processing for marketing purposes or when the processing is for different purposes from those for which the data was collected, provided that there are no compelling and legitimate reasons or for the purposes of declaration, exercise or defense of a right in a judicial process.

Obligation to Notification of Compliance with the Treater's Duties

The data controller must notify each recipient to whom the personal data has been transmitted of any rectification or deletion of personal data or limitation of processing, unless such communication proves impossible or involves a disproportionate effort.

Automated Individual Decisions, Including Profile Definition

MBA adopts adequate measures to safeguard the rights and freedoms and legitimate interests of the data subject, and informs the user that he can trace his profile based on his preferences and interests, through Google Analytics and Facebook Pixelin order to understand your interests so that we can provide services, increase the quality of products and services, always after informing and obtaining the holder's consent or if this treatment is essential for the execution of the contract between MBA.

The data subject has the right not to be subject to any decision taken solely on the basis of automated processing, including the definition of a profile, which has effects in its legal sphere or which significantly affects it in a similar way. If you do not wish MBA to do so, you may opt-out. To do so, please consult the information on behavioral advertising and online privacy at the following links NAI (English version), Aboutads (English version), English) and for European Union users Your Online Choices.

Right to Claim

The data subject has the right to complain to MBA through their contacts, available in this document and to the supervisory authority.

 

11 | Liability of Data Subjects

Data Subjects are responsible for providing reliable information to MBA.

 

12 | Transmission of Personal Data

The data of the holders can be transmitted to subcontractors, natural or legal person, public authority or other body that processes the data of the holders on behalf of the MBA, which will take the legally provided measures to ensure that the subcontractors offer guarantees that the personal data of the holder are respected and protected.

As part of its activity, MBA uses third parties to provide the following services:
- electronic communications, which implies access by this subcontractor to the information provided by subscribers and subscribers;
- payment processing through paypal, where name and email are requested;
- processing of payments through Meo Wallet, where the name and email of the data subject will be made available so that he/she can pay for your order through ATM reference, VISA or MasterCard or Balance Meo Wallet, in the latter case it is necessary the creation of an account where it is mandatory to fill in, in addition to the aforementioned data, the date of birth, type, number and expiry date of the identification document and birth date;
- transport and delivery of orders and related documents;
- internet storage (data center) and technical services;
- provision of the technological structure of the website, IT support and maintenance of systems and applications.

 

13 | Breach of Personal Data

In the event of a breach of personal data that is likely to pose a risk to the rights and freedoms of individuals, MBA will notify the competent supervisory authority in the shortest possible time, which may never exceed the within 72 (seventy-two) hours after obtaining knowledge of it. If the breach entails a high risk to the rights and freedoms of individuals, MBA will communicate the breach of personal data to the respective data subject, without undue delay.

 

14 | Personal Data Exposure

The user must be prudent in exposing his personal data, as well as in the circulation of this data on the internet, for this he must adopt security measures, maintain equipment and programs updated and configured with firewalls and antivirus. Your username and password identify your Login and give you access to your personal registration information, Budget History, Favorites and other MBA features.

It is advisable to choose a hard-to-find password, preferably alphanumeric in composition and with more than 10 characters. Avoid disclosing your website identification data at all.

Signing Out is just as important as Signing In. Ensure that you log out to prevent another user from viewing and purchasing products with improper identification. It is recommended that you avoid forgetting to go out especially when:

› Finalize a quote;

› Consult your data;

› Moving away from the computer, among other situations.

 

15 | Responsibility for MBA and Third Party Websites and Services

We advise you to read the terms and conditions of use as well as the cookies policy on this website.

This website includes hyperlinks to other websites or third party services, and these websites do not operate under this privacy policy. Therefore, MBA recommends that the user consult the conditions and policies of the website he browses, as well as those of third parties (Google, Facebook, YouTube, Issuu and Meo Wallet), in order to understand their procedures regarding the processing of defined personal data.

See the third-party privacy policy:

Facebook

Google

Issuu (English version)

Tawk (English version)

PayPal

Meo Wallet

 

16 | Analysis of the website and its users

On our website we use:

› Google Analytics, a website analytics service from Google (Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States) that uses cookies which are stored on the user's equipment to help analyze how this website is used. This information is transmitted and stored to a Google server located in the USA. Google will not associate your IP address with any other data held by Google. The user can at any time modify the browser settings so that the storage of cookies is permanently disabled.

› Facebook pixel (Facebook Ireland Ltd. 4 Grand Canal Square Grand Canal Harbor Dublin 2 Ireland) that allows measuring the effectiveness of MBA ads, by understanding the actions that users take on this website. You may disable the use of cookies in your internet browser settings/options.

 

17 | Personal Data of Minors

Our products are intended for adults (over 18 years old) or with express authorization from adults (over 13 years old).

 

18 | Procedural and Technical Security Measures

MBA respects the best practices in the field of security and protection of information and personal data, has implemented logical measures, with the use of firewalls and intrusion systems, organizational and security adequate, necessary and sufficient to protect the personal data of users against alteration, destruction, loss, dissemination or unauthorized access as well as any other form of accidental or unlawful processing.

 

19 | Payment Security

The security of payment for your orders is regulated by the payment service Meo Wallet and Paypal.

20 | Electronic Communications

User can receive information from MBA of 2 types:

- Information and response related to requests for information or quotes in one of the MBA brands. The user can receive clarifications to their doubts, sales proposal, order confirmation and update, order payment, order delivery, order acknowledgment and payment terms by email;

- Periodic information about the website, products and/or service, news, promotions and MBA campaigns, requiring the user to subscribe to all or one of the following categories:

› Promotional Marketing, Design and Print Services;

› Electric Vehicles and Electric Conversion Kits;

› Events: Products for Private and/or Business Events;

› Hotels: Hotel Equipment and Merchandising.

 

21 | Electronic Communications Subscription

MBA's electronic communications service is a free service available to any user of our website.

A natural person or legal person, by subscribing to any of MBA's electronic communications, acknowledges and accepts that MBA gets in touch via email to stay informed and updated about products, services, campaigns, promotions or news from MBA. You agree that you can cancel at any time and that the information provided through this website is stored and processed for the purpose of marketing communication as well as for market research purposes. Your personal data is treated confidentially, in accordance with current data protection law.

MBA reserves the exclusive right to unsubscribe from any user's electronic communication, at any time and without prior notice, if it suspects it is a false subscription.

MBA requires all subscribers to confirm subscription to electronic communications. The confirmation is made when the user clicks on the hyperlink sent to the email address provided at the time of subscription, thus there is a double confirmation of the express willingness to subscribe to one of the electronic communicationsfrom the MBA.

The user may change, withdraw and/or revoke his consent at any time through the unsubscribe link available at the end of all electronic communications or upon written request via the email address that he wishes to exercise his right of opposition, rectification, cancellation or deletion for the contacts indicated in this policy.

 

22 | Frequency of Electronic Communications

MBA electronic communications are sent periodically upon the need to communicate and inform subscribers. As a rule, electronic communications of a service or product are sent weekly or fortnightly, except for situations in which the MBA Marketing Department decides, in the interest of subscribers, to change the frequency. This will not exceed the sending of two electronic communications per week, nor will it be permanent.

 

23 | Limitation of Liability for Electronic Communications

MBA reserves, at any time, the right to modify or discontinue sending electronic communications, as well as the exclusive right to unsubscribe from electronic communications at any time and without prior notice.

 

24 | Unsubscribe from Electronic Communications

The electronic communications service is continuous, without an established term and can be canceled at any time by the user. To do so, the user must click on the unsubscribe link available at the end of all electronic communications that MBA sends. If you have problems with the unsubscribe feature, please send an email to pd@nobrinde.com requesting service cancellation.

 

25 | Privacy Policy Updates

This declaration is effective from the beginning of the MBA activity. Which reserves, at any time, the right to review and update its privacy policy, by means of an updated communication available on the website. The user may refer to the date at the end of this policy to verify the date of its last revision.

 

26 | Change Logs

Date Version Language Comments
05-25-2018 1.0 PT Initial version

 

27 | Contact us

In case of doubts or clarifications, consult the General Terms and Conditions of Use, you can also contact us by phone +351 229 982 500 or by email pd@nobrinde. com.

 

Last update date: This information has been updated on May 25, 2018.