Privacy Policy

DATA CONTROLLER AND SCOPE OF APPLICATION

A) EMPATHY TALENT, LDA., Tax ID 513507728, headquartered at Edifício LACS, Rocha Conde de Óbidos, 1350–352 Lisbon (hereinafter referred to as “LACS”), is the entity responsible for collecting and processing the Personal Data of Website Users. This policy aims to inform Users in accordance with and for the purposes of the General Data Protection Regulation (the “GDPR”), as supplemented by Law No. 58/2019, dated August 8.

B) Users should carefully read this Privacy Policy and freely decide whether to provide their Personal Data to LACS prior to submitting such data.

PERSONAL DATA COLLECTED, PURPOSES, LEGAL BASIS, AND RETENTION PERIOD

Personal Data	Purpose	Legal Basis	Retention Period	Mandatory
Identification Data: First and last name Contact Data: Mobile number and email address	To respond to requests or inquiries made through the contact form available on the Website	Consent	1 year after form submission	Yes (without this data, contact requests cannot be processed)
Identification Data: Name Contact Data: Email	To send our Newsletter	Consent (for Users without a client relationship with LACS) or Legitimate Interest (for Users with such a relationship)	Until the User unsubscribes	Yes (without this data, the newsletter cannot be sent)

A) After the expiration of the above retention periods, LACS will delete or anonymize the Personal Data unless it is required to retain the User’s Personal Data to comply with legal or contractual obligations.

USER RIGHTS

A) Users have the right to request from LACS, under applicable personal data protection laws, the following:

Access to Personal Data relating to them;
Rectification of inaccurate or incomplete data;
Erasure of data, unless processing is necessary to comply with legal obligations or other lawful grounds;
Restriction of processing in legally specified cases;
Objection to processing, where applicable;
Data portability in accordance with applicable laws. Requests should be sent to the following email address: info@lacs.pt. Users also have the right to lodge a complaint with the competent supervisory authority, which in Portugal is the National Data Protection Commission (https://www.cnpd.pt/).

B) LACS reserves the right to deny requests that are manifestly unfounded or excessive, particularly due to their repetitive nature, as permitted by applicable laws. In such cases, Users will be informed of the reasons for the denial and the possibility of lodging a complaint with the supervisory authority.do pela legislação aplicável. Nestes casos, o Utilizador será informado das razões da recusa e da possibilidade de apresentar reclamação à Autoridade de Controlo.

C) Users may withdraw their consent to the processing of their Personal Data at any time without affecting the lawfulness of processing carried out prior to withdrawal. However, withdrawing consent may impact the availability of certain LACS functionalities.

D) To exercise their rights, Users must submit a request accompanied by a copy of a valid identification document, avoiding the use of a national ID card whenever possible.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

A) LACS may engage third parties to provide specific services, which may involve, in certain circumstances, access to Users’ Personal Data by these entities.

B) In contracting third parties, LACS undertakes to implement the necessary technical and organizational measures to ensure that these entities offer high levels of assurance in processing Users’ Personal Data. These assurances will be contractually stipulated in accordance with the GDPR provisions.

C) As a rule, LACS will not transfer Users’ Personal Data outside the European Economic Area (EEA). However, whenever such transfers occur, LACS will ensure that:

The destination country is covered by an adequacy decision by the European Commission; and/or
The transfer is carried out using appropriate safeguards, such as standard contractual clauses, binding corporate rules, or other legally recognized mechanisms that ensure privacy, integrity, and security compliance under GDPR.

SECURITY

A) LACS declares that it has implemented and will continue to implement appropriate technical and organizational security measures to ensure the protection of the Personal Data provided by Users, preventing its alteration, loss, processing or unauthorized access. These measures will be continually adjusted according to the current state of technology, the nature of the data processed and the associated risks.

B) LACS undertakes to implement and maintain strict technical and organizational security measures to ensure the confidentiality, integrity and availability of the data contained on the Website.

C) Users’ Personal Data will always be processed in accordance with the legally required level of protection, in order to prevent its alteration, loss, processing or unauthorized access, taking into account the state of the art and best practices in the sector.

D) In the event of a breach of Personal Data that may result in a risk to the rights and freedoms of Users, LACS undertakes to report the situation to the National Data Protection Commission (CNPD) within the legally required timeframe and, where applicable, to inform the affected data subjects promptly and clearly.

COOKIES

A) Cookies are text files containing small amounts of information that are downloaded and stored on the User’s device via the browser when visiting a website.

B) Cookies can be classified according to their purpose. Some cookies are strictly necessary for the website’s functionality, while others collect statistical data to analyze website usage and performance. Additionally, cookies may provide additional functionalities or store navigation preferences for optimized future interactions. Certain cookies may also measure the success of applications or third-party advertising campaigns.

To access the list of cookies used on the website, simply click on the cookies notice button at the bottom of the screen.

C) The Website uses various categories of cookies, with durations depending on their purpose. Session cookies expire when the browser is closed, while persistent cookies remain on the User’s device for a pre-defined period.

D) It should be noted that some of the aforementioned cookies do not collect personal data or allow Users to be identified, and are therefore not considered personal data for legal purposes.

E) Users have the right to revoke the consent previously granted for the use of cookies or to change their preferences regarding the management of cookies, at any time, through the cookie settings page made available on the website. Alternatively, most browsers allow the User to control the cookies stored on the devices, as well as to delete them immediately if they choose not to authorize the local storage of cookies. Further information on cookies can be found on the websites www.aboutcookies.org or www.allaboutcookies.org.

F) Users can configure their devices and browsers to accept or reject all or some cookies, with the exception of those identified as “strictly necessary”. These cookies are essential for the proper functioning of the Website, and their deactivation may compromise browsing or the full functioning of the Website.

G) The use of cookies that are not strictly necessary for the functioning of the Website will depend on the User’s prior, free, specific, informed and unequivocal consent, in accordance with the provisions of the applicable legislation. No optional cookie will be installed on the User’s device without their express consent.

H) The Website may include third-party cookies, such as Google Analytics, which collect statistical or behavioral data from Users for analytical or advertising purposes. These cookies may involve the transfer of data to countries outside the European Economic Area. LACS will implement appropriate safeguards, such as standard contractual clauses, to ensure the protection of personal data in accordance with the GDPR.

CHANGES TO THE PRIVACY POLICY

LACS reserves the right to adjust or modify this Privacy Policy at any time. Any changes will be duly communicated and published on the Website to ensure accessibility and transparency for Users.

Last updated on: 8 January 2025