Privacy Policy

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

What is personal data?

Personal Data is any information, of any nature and on any medium (e.g. sound or image), relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or indirectly, e.g. through their name, identification number, location data, an electronic identifier or other elements that allow the identification of that natural person.

Who are the data subjects of personal data?

The Customer or User, a natural person, to whom the data relates and who used the services or products of Piano B, Comércio e Manutenção de Pianos, Lda. The Customer is the person who enters into the contract with Piano B, Comércio e Manutenção de Pianos, Lda. and the User is the person who uses the services or products of Piano B, Comércio e Manutenção de Pianos, Lda., but who may not correspond to the Customer.

In this regard, Piano B, Comércio e Manutenção de Pianos, Lda. informs that it likewise protects personal data and respects the rights of customers and users.

What categories of personal data do we process?

The categories of data we process are as follows:

Identification, contacts and other identification data

Billing address, telephone contact, e-mail address and IP (if you registered on the internet)

2 – WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

The party responsible for the collection and processing of your personal data will be the company Piano B, Comércio e Manutenção de Pianos, Lda. which provides you with the service or product and which, in that context, decides what data is collected, the means of processing and the purposes for which the data is used.

3 – ON WHAT BASIS MAY WE PROCESS YOUR PERSONAL DATA?

These are the circumstances in which we process your personal data:

Consent

When we have your express consent – in writing, orally or through the validation of an option – and prior consent, and if that consent is free, informed, specific and unequivocal. Examples include your consent for Piano B, Comércio e Manutenção de Pianos, Lda. to analyze the use of services and products and make recommendations or send marketing messages, to use your identification or service usage data for sending marketing messages from Piano B, Comércio e Manutenção de Pianos, Lda., your consent for us to use service interaction information to improve the quality of our service; or

Performance of contract and pre-contractual steps

When the processing of personal data is necessary for the conclusion, performance and management of the contract entered into with Piano B, Comércio e Manutenção de Pianos, Lda., such as for the preparation of a proposal of products and/or services, for the management of contacts, information and requests, for the management of billing, collection and payments; or

Compliance with a legal obligation

When the processing of personal data is necessary to comply with a legal obligation to which Piano B, Comércio e Manutenção de Pianos, Lda. is subject, such as the communication of identification data to police, judicial, tax or regulatory authorities; or

Legitimate interest

When the processing of personal data corresponds to a legitimate interest of Piano B, Comércio e Manutenção de Pianos, Lda. or of third parties, such as the processing of data for service quality improvement, fraud detection and revenue protection, and when our reasons for its use should prevail over your data protection rights;

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

For how long do we process your Personal Data?

Your personal data is processed by Piano B, Comércio e Manutenção de Pianos, Lda. 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 consent. After the respective retention period has elapsed, Piano B, Comércio e Manutenção de Pianos, Lda. will delete or anonymize the data whenever it should not be retained for a distinct purpose that may subsist.

For what purposes do we process your Personal Data?

Marketing and Sales – Marketing or sale of new products or services – Analysis of consumption profiles – Adaptation and development of new products or services

Customer Management and Service Provision – Management of contacts, information or requests – Management of complaints; – Management of billing, collection and payments

Accounting, Tax and Administrative Management – Accounting, billing – Tax information, including sending information to the tax authority

Litigation Management – Judicial and extrajudicial collection – Management of other disputes

Fraud detection, revenue protection and audit – Detection of fraud and illicit practices – Protection and control of revenue

Credit risk management – Internal audit and investigation

Network and systems management – Support and improvement of the networks and applications that support the service. Monitoring, improvement and support of the service

Compliance with legal obligations – Location of calls for emergency services – Judicial requests – Investigation, detection and repression of serious crimes – Response to judicial, regulatory and supervisory authorities

Information security control – Access management, logs – Backup management – Security incident management

What are the periods for processing and retention of personal data?

Piano B, Comércio e Manutenção de Pianos, Lda. processes and retains your personal data in accordance with the purposes for which they are processed.

There are cases in which the law requires the processing and retention of data for a minimum period of time, for example, 10 years for the data necessary for information to the Tax Authority for accounting or tax purposes.

But, whenever there is no specific legal obligation, the data will be processed only for the period necessary for the fulfilment of the purposes that motivated its collection and preservation, and always in accordance with the law, the guidelines and decisions of the CNPD.

Thus, Piano B, Comércio e Manutenção de Pianos, Lda. will process and retain your personal data for the period during which it maintains a contractual relationship with you.

Piano B, Comércio e Manutenção de Pianos, Lda. may retain other personal data for periods longer than the duration of the contractual relationship, whether on the basis of your consent, to ensure rights or duties related to the contract, or because it has legitimate interests that justify it, but always for the period strictly necessary for the realization of the respective purposes and in accordance with the guidelines and decisions of the CNPD.

Examples include contact for marketing and sales purposes, the preservation of data within complaint processes, invoices, the exercise of warranty rights or offers that are of interest to 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 acquire Piano B, Comércio e Manutenção de Pianos, Lda. products or services, when you download or use e-books, quizzes, sessions, offers, products, services and applications of Piano B, Comércio e Manutenção de Pianos, Lda. or when you participate in market studies. The collection may be done orally, in writing or through the Piano B, Comércio e Manutenção de Pianos, Lda. website. But your personal information may also be collected from publicly accessible sources or other sources.

How is the indirect collection of your personal data carried out?

So that you can better understand this indirect collection, we indicate the following cases: Other relevant information about credit risk or about identification and contact data, for the management of collections, fraud detection and revenue protection. Piano B, Comércio e Manutenção de Pianos, Lda. may collect personal data from private entities that hold relevant information about the credit of personal data subjects, provided that those databases comply with the applicable data protection rules. Piano B, Comércio e Manutenção de Pianos, Lda. may also access, collect or confirm personal data on Public Administration and private entity websites, in particular to confirm the accuracy of your

6 - DATA ANALYSIS

Cookie Policy

Information about our use of cookies. Our site uses cookies to distinguish you from other users of our site. This helps us to provide a good experience when you browse our site and also allows us to improve our site. A cookie is a small file of letters and numbers that we store in your browser or on the hard drive of your computer, 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 the number of visitors and to 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 easily. You can find more information about the individual cookies we use and the purposes for which we use them below:

Analytical

The services contained in this section allow the owner to monitor and analyze web traffic and may be used to track user behavior. Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the data collected to track and examine the use of this site, prepare reports on its activities and share them with other Google services. – Google may use the data collected to contextualize and personalize the ads of its own advertising network. – Personal Data collected: Cookies and Usage Data. – Place of processing: United States – Privacy Policy – Opt out.

Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analysis service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this site. – Personal Data collected: Cookies and Usage Data. – Place of processing: United States – Privacy Policy.

Commented Content

Content commenting services allow users to make and publish their comments on the content of this site. Depending on the settings chosen by the owner, users may also leave anonymous comments. If there is an e-mail 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 content commenting service provided by third parties is installed, it may still collect web traffic data for the 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. – Place of processing: United States – Privacy Policy.

E-mail marketing

We collect your name and e-mail address when you register for a webinar or event, request a free resource or participate in a waiting list, via Infusionsoft (Privacy Policy). We use this data to send you e-mails about useful advice and industry news and to notify you about services and products you may be interested in. You can unsubscribe from our list at any time. In addition, we collect your surname and postal address when you buy a product or course, as part of the card verification process of our payment and sales tax collection provider.

Remarketing and behavioral targeting

This type of service allows this site and its partners to inform, optimize and serve advertising based on the user’s past use of this site. This activity is carried out by tracking Usage Data and Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt-out offered by any of the services below, the user can 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 the activity of this site to the Facebook advertising network. – Personal Data collected: Cookies and Usage Data. – Place of processing: United States – Privacy Policy – Opt out.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that links the activity of this site to the Facebook advertising network. – Personal Data collected: Cookies and e-mail address. – Place of processing: United States – Privacy Policy – Opt out.

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 site. The interaction and information obtained through this website are always subject to the user’s privacy settings for each social network. This type of service may 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 interaction with the Twitter social network provided by Twitter, Inc. – Personal Data collected: Cookies and Usage Data. – Place of processing: United States – Privacy Policy.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services that allow interaction with the Facebook social network provided by Facebook, Inc. – Personal Data collected: Cookies and Usage Data. – Place of processing: United States – Privacy Policy.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services that allow interaction with the LinkedIn social network provided by LinkedIn Corporation. – Personal Data collected: Cookies and Usage Data. – Place of processing: 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 site. 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 and Microsoft Internet Explorer. With regard to Cookies installed by third parties, Users can manage their preferences and withdraw their consent by clicking on the related opt-out link (if provided), using the means provided in the third party’s privacy policy or by contacting the third party. Notwithstanding the above, the Owner informs that Users may follow the instructions provided in the initiatives subsequently linked by the EDAA (EU), the Network Advertising Initiative (USA) and the Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or 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 resources in addition to the information provided in this document.

Logs and system maintenance

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

Changes to this privacy policy

The owner reserves the right to make changes to this privacy policy at any time, notifying users on this page and possibly within this site and/or – to the extent technically and legally possible – by sending a notice to users through any contact information. If the changes affect the processing activities carried out on the basis of the user’s consent, the owner shall collect new consent from the user, where necessary.

Owner and Data Controller Piano B, Comércio e Manutenção de Pianos, Lda. – Av. Bombeiros Voluntários Nr. 1410 4º Esq. 4585-015 – BALTAR. PORTUGAL

Owner’s contact e-mail: Piano B, Comércio e Manutenção de Pianos, Lda. As the installation of third-party cookies and other tracking systems through the services used on this site 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 your rights and the detail of what is safeguarded in each one. Right of access: Right to obtain confirmation of which of your personal data are processed and information about them, such as the purposes of the processing, the retention periods, among others. Right to view or obtain a copy, for example of the invoices, written agreements or support requests you made.

Right of rectification

Right to request the rectification of your personal data that is inaccurate or to request that incomplete personal data be completed, such as the address, the NIF, the e-mail, the telephone contacts, or others.

Right to erasure of data or “right to be forgotten”

Right to obtain the erasure of your personal data, provided that there are no valid grounds for its retention, such as the cases in which Piano B, Comércio e Manutenção de Pianos, Lda. must retain the data to comply with a legal obligation of preservation for investigation, detection and repression of crimes, or because judicial proceedings are underway.

Right to portability

Right to receive the data you provided to us in a digital format of current use and machine-readable, or to request the direct transmission of your data to another entity that becomes the new controller of your personal data, such as receiving your invoices or transmitting your contacts to the new controller, but in this case only if it is technically possible.

Right to withdraw consent or right to object

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

Right of limitation

Right to request the limitation of the processing of your personal data, in the form of: 1- Suspension of processing 2- limitation of the scope of processing to certain categories of data or processing purposes.

Right to complain: Right to lodge 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, except if it is a manifestly unfounded or excessive request, in which case a reasonable fee may be charged taking into account the costs. The information must be provided in writing but, if you request it, it may be provided orally. In this case, Piano B, Comércio e Manutenção de Pianos, Lda. 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: Piano B, Comércio e Manutenção de Pianos, Lda. Mail: Av. Bombeiros Voluntários Nr. 1410 4º Esq. 4585-015 – BALTAR. PORTUGAL, e-mail: geral@netorochapianos.com.

8 – TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?

In what circumstances is there communication of your personal data to other entities, processors or third parties?

Your data may be transmitted to processors so that they process it on behalf and on account of Piano B, Comércio e Manutenção de Pianos, Lda.. In this case, Piano B, Comércio e Manutenção de Pianos, Lda. will take the necessary contractual measures to ensure that the processors respect and protect the personal data of the data subject. The data may also be transmitted to third parties – entities distinct from Piano B, Comércio e Manutenção de Pianos, Lda. or the processors – such as companies within the Piano B, Comércio e Manutenção de Pianos, Lda. group, companies with which Piano B, Comércio e Manutenção de Pianos, Lda. develops partnerships, in the case where the data subject has consented – or entities to whom the data must be communicated by force of law, such as the tax authority.

In what circumstances does Piano B, Comércio e Manutenção de Pianos, Lda. transfer your data to a third country?

Piano B, Comércio e Manutenção de Pianos, Lda. may have to transfer your personal data to a third country outside the European Union and that is not on the list of countries that the EU has already considered to meet adequate levels of personal data protection. In those cases, Piano B, Comércio e Manutenção de Pianos, Lda. will ensure that data transfers are carried out in strict compliance with the applicable legal rules.

9 – HOW DOES PIANO B, COMÉRCIO E MANUTENÇÃO DE PIANOS, LDA PROTECT YOUR PERSONAL DATA?

Piano B, Comércio e Manutenção de Pianos, Lda. 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 or unlawful processing.

Piano B, Comércio e Manutenção de Pianos, Lda. has implemented: – Logical security requirements and measures, such as the use of firewalls and intrusion detection systems in its systems, the existence of a rigorous policy on access to systems and information and the recording of actions performed by Piano B, Comércio e Manutenção de Pianos, Lda. employees on the personal data of customers or users (logging); – Physical security measures, among which a strict control of access to the physical facilities of Piano B, Comércio e Manutenção de Pianos, Lda. stands out and, on the part of employees, partners and visitors, as well as very restricted and permanently monitored access to the essential technological infrastructures of Piano B, Comércio e Manutenção de Pianos, Lda.; – Means of data protection by design (“privacy by design”) using technical means such as masking, encryption, pseudonymization and anonymization of personal data and, furthermore, a set of preventive measures favorable to privacy (“privacy by default”); – Mechanisms of scrutiny, audit and control to ensure compliance with security and privacy policies; – An information and training program for the employees and partners of Piano B, Comércio e Manutenção de Pianos, Lda.; – Access rules for Customers or Users to certain products or services, such as the introduction of a password, in order to reinforce control and security mechanisms.

10 – USEFUL ADVICE FOR THE PROTECTION OF YOUR DATA

Websites of Piano B, Comércio e Manutenção de Pianos, Lda. and third parties

Regarding the use and processing of personal data of Piano B, Comércio e Manutenção de Pianos, Lda. websites, do not fail to consult the rules on the use of cookies on the respective websites. The websites, products or applications of Piano B, Comércio e Manutenção de Pianos, Lda. may contain links to websites, products or services of third parties, which have no relationship with Piano B, Comércio e Manutenção de Pianos, Lda. or which are not covered by this Privacy Policy. The collection or processing of the personal data requested by those third parties is their sole responsibility, and Piano B, Comércio e Manutenção de Pianos, Lda. cannot be held responsible, in any circumstance, for the content, accuracy, veracity or legitimacy of those websites or for the misuse of the data collected or processed through them. We alert the Customers and Users of Piano B, Comércio e Manutenção de Pianos, Lda. to this fact and to the need, before using the websites, products or applications, to read and accept the rules relating to the processing of personal data defined by those third parties.

Other advice

Piano B, Comércio e Manutenção de Pianos, Lda. advises prudence in the exposure of your personal data and in the circulation of that data over the internet, acts that are the total responsibility of the customer, since that data is not fully protected against possible breaches; 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 (e.g. antivirus), not browsing on sites of dubious reputation or for which you do not have the due guarantees of authenticity, the physical protection of your equipment and avoiding entering access credentials on publicly accessible computers (e.g. cybercafés, hotels, etc.) and the use of strong and differentiated passwords for 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 refers only to this site, unless otherwise indicated in this document.

Information not contained in this policy

More details about the collection or processing of personal data may be requested from the Owner at any time.

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