Privacy
policy.

1. Data Control

The controller of the personal data processed through the Website is PLUGGABLE, S.A., NIPC 517 256 770, with registered office at Edifício GNRation, Praça Conde de Agrolongo, n.º 123, 4700-312 Braga, Portugal (‘Pluggable’).

2. Processing of Personal Data

Pluggable collects personal information from Users, both mandatory and optional, when they subscribe to the newsletter, book a meeting, contact Pluggable or send a job application, as well as data collected automatically when they browse the Website.

In accordance with the data protection legislation in force in the European Union (in particular, Regulation (EU) 2016/679, the General Data Protection Regulation), the processing of personal data is only permitted if at least one of the following conditions is met:

• When the data subject has given consent to the processing of their personal data (for this purpose, the User will be presented with a consent form for the use of their data, which may be withdrawn at a later date);
• When data processing is necessary for the conclusion of a contract with the data subject or for its performance;
• When data processing is necessary for compliance with legal obligations to which Pluggable is subject;
• When data processing is necessary to protect the vital interests of the data subject or another natural person;
• When data processing is necessary for the pursuit of a legitimate interest of Pluggable or a third party, provided that such interest prevails over the rights of the data subject requiring the protection of their personal data.

3. Data we collect

The types of data we may collect about you, depending on your use of the Website, include:

• Identification data (name);
• Contact details (email address, telephone number and LinkedIn profile);
• Curriculum vitae and other information included in job applications;
• Associated company data (name);
• Data related to meetings booked through the Website, such as the date, time and subject of the meeting;
• Browsing data, such as IP address, device and browser type, pages visited and interactions with the Website, collected through cookies and similar technologies, as described in section 10;
• Any other information you choose to provide when contacting us through the Website.

Some personal data is mandatory and is duly marked. The lack or insufficiency of such data may prevent or delay contact, application, newsletter subscription or meeting booking.

4. Purpose of Personal Data Collection

Pluggable uses Users' personal information for the following purposes, on the legal basis indicated for each:

• Respond to enquiries sent to Pluggable (legitimate interest);
• Contact Users after a job application and assess their application (steps taken at the candidate’s request prior to entering into a contract);
• Execute contracts entered into with Users for specific services (performance of a contract);
• Contact Users about existing or potential business relationships, including meetings booked through the Website (legitimate interest);
• Keep Users updated on Pluggable's services by sending the newsletter to Users who have subscribed to it (consent);
• Promote events in which Pluggable participates (legitimate interest);
• Analyse the use of the Website and improve its content, through analytics cookies, where the User has accepted them (consent); and
• Comply with legal obligations to which Pluggable is subject (legal obligation).

5. Your Rights

Unless otherwise indicated by the data subject, Pluggable assumes that the data collected has been entered by the User and that its entry has been authorised, and that it is true and accurate.

We ask Users to inform Pluggable of any subsequent changes to the data collected so that it can keep the information in its database correct and up to date and, consequently, fully comply with the purposes for which it is intended.

Users may request the restriction of the processing of their personal data whenever:

• They contest the accuracy of the personal data, for a period that allows Pluggable to verify its accuracy;
• The processing is unlawful (for example, if it does not occur for the purposes described in point 4 of this Privacy Policy);
• Pluggable no longer needs the personal data for processing purposes, but the data is necessary for the data subject for legal claims, defence or legal proceedings;
• They object to the processing of data.
• In the latter case, users may object to the processing of their personal data at any time, and it will be immediately ceased. However, the withdrawal of consent does not affect the lawfulness of previous processing based on consent or other legally required processing activities.

Users also have the right to request the deletion of their personal data from Pluggable's database (‘right to be forgotten’), which may occur at any time and without undue delay.

Users also have the right to access their personal data, to request its rectification and to receive the data they have provided in a structured, commonly used and machine-readable format (data portability). Where processing is based on consent, Users may withdraw it at any time, namely by unsubscribing from the newsletter through the link included in each email.

To exercise the above rights, Users should contact Pluggable via email at info@pluggableai.pt.

Users also have the right to lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at www.cnpd.pt.

6. Security Measures

Pluggable employs a variety of security measures, including encryption and authentication tools, to help protect and maintain the security, integrity, and availability of Users' personal data.

Although data transmission over the internet cannot guarantee complete protection against intrusion, Pluggable makes every effort to implement and maintain physical, electronic, and procedural security measures designed to safeguard Users' personal data on the Website in accordance with applicable data protection regulations.

Among other things, Pluggable has implemented the following security measures:

• Restricted personal access to Users' personal data based on the ‘need to know’ principle and only within the scope of the purposes outlined in section 4 of this Privacy Policy;
• Only authorised personnel, bound by confidentiality and secrecy obligations, may access personal data (all Pluggable employees and collaborators are required to keep personal data obtained in the course of their duties confidential);
• Storage of highly confidential data in encrypted form;
• Continuous monitoring of access to information systems to prevent, detect, and stop unauthorised use of Users' personal data;
• Retention of data only for the period strictly necessary for processing purposes or as required by legal or regulatory provisions.

Pluggable strives to apply the best organisational and security measures to protect Users' personal information on its Website, preventing its loss, misuse, alteration or destruction, thus ensuring its integrity, availability and confidentiality.

7. Sharing Personal Data

As a rule, Pluggable does not transfer or share the personal data of Users with third parties, unless required by law or as described in this section.

Pluggable may subcontract service providers when necessary, such as website hosting, newsletter and email services, meeting booking and website analytics, which may involve sharing personal data. In such cases, Pluggable will take all necessary measures to ensure that service providers offer all guarantees for the protection, security, and confidentiality of shared personal data. These service providers process personal data under the terms of service and data processing terms applicable to their services, which include obligations to protect that data.

Where service providers are located outside the European Economic Area, the transfer is covered by appropriate safeguards, such as an adequacy decision or the standard contractual clauses approved by the European Commission.

The Website includes links to and content from third parties, such as social networks and maps, which have their own privacy policies.

Users' personal data may also be transmitted to judicial, administrative, supervisory or regulatory authorities, as well as to entities that legally collect data or prevent and combat fraud.

8. Data Retention Period

Pluggable retains personal data only for the period necessary to fulfil the specific purposes for which it was collected, as outlined in section 4 of this Privacy Policy.

In general, newsletter data is kept until the User unsubscribes; data from contacts and meetings is kept for as long as the business relationship lasts; and spontaneous job applications are kept for future opportunities for as long as they remain relevant, are reviewed periodically, and are deleted when they are no longer relevant or when the candidate so requests.

Once the data is no longer needed, personal data will be irreversibly anonymised (with anonymised data possibly being retained) or securely destroyed.

However, Pluggable may be required to retain some personal data for a longer period, taking into account factors such as:

• Legal obligations under applicable laws requiring the retention of personal data for a specific period;
• Statute of limitations/limitation period under applicable laws;
• Litigation;
• Guidelines issued by competent data protection authorities.

During the period of personal data processing, Pluggable ensures that the data is treated in accordance with this Privacy Policy.

9. Changes to this Privacy Policy

Pluggable may modify this Privacy Policy whenever it deems necessary or whenever required by law. Whenever such changes occur, the new version will be published on the Website and will take effect immediately, so we advise you to check it regularly.

In the event of a conflict between this Privacy Policy and subsequent versions published after modifications, the most recent version shall prevail.

10. Cookies

The Website uses cookies and similar technologies. Analytics cookies are only used if the User accepts them in the cookie banner, and the User can change this choice at any time. More information is available in the Cookie Policy, at www.fanofthematch.ai/cookie-policy.