Privacy Policy

This Privacy Policy is part of the Terms and Conditions and aims to inform Users about how Pluggable processes personal data and ensures its privacy, security, and integrity in the development and execution of its activities.

  1. Data Control

The processing of personal data is the sole responsibility of Pluggable, as identified in point 1 of the General Terms and Conditions of Use.

2. Processing of Personal Data

The processing of personal data is the sole responsibility of Pluggable, as identified in point 1 of the General Terms and Conditions of Use.

Pluggable collects personal information from Users, both mandatory and optional, through subscription, application, and registration forms available on the Website.

In accordance with the data protection legislation in force in the European Union, 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personal data (for this purpose, the User will be presented with a consent form for the use of their data, which may be withdrawn at a later date);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;

  • Associated company data (name);

  • 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 and/or registration.

4. Purpose of Personal Data Collection

Pluggable uses Users' personal information, obtained through the completion of contact, application, or registration forms, to:

  • Respond to enquiries submitted through contact forms;

  • Contact Users after a job application;

  • Execute contracts entered into with Users for specific services;

  • Contact Users about existing or potential business relationships;

  • Keep Users updated on Pluggable's services; and

  • Promote events in which Pluggable participates.

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 5 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.

To exercise the above rights, Users should contact Pluggable via email at info@pluggableai.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 or website 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 5 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);

  • Encryption of data collected during transmission;

  • Storage of highly confidential data in encrypted form;

  • Protection of information technology systems using firewalls to prevent unauthorised access to Users' personal data;

  • 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 Website Users with third parties, unless required by law.

However, Pluggable may subcontract service providers when necessary, 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 act strictly in accordance with the instructions given by Pluggable, which implies a contractual agreement governing the relationship.

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

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 5 of this Privacy Policy.

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 addition, Website Users will be required to provide new consent regarding these modifications or updates. Refusal of consent may, depending on the specific case, result in restricted access to the Website.

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

Last updated: 25 November 2024