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Privacy policy

Framework

This policy aims to present the rules followed by 99x Tech when collecting, managing and processing personal data. This policy applies exclusively to personal data collected and processed by 99x Tech.

99x Tech is strongly committed to the protection of your personal data, ensuring that their collection and processing is done in close compliance with the legislation in force, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, commonly referred to as GDPR.

What is personal data?

Personal data is any information of any nature and regardless of its support, including sound and image, concerning an identified or identifiable person.

An identifiable person is defined as a natural person which may, directly or indirectly, be identified by reference to a name, identification number, location data, electronic identifiers, or to one or more specific elements of his / her physical, physiological, genetic, mental, economic, cultural or social identity.

Who is the owner of personal data?

Any natural person to whom the data relate, inter alia in a client, prospect, collaborator, candidate, partner, contact or visitor role.

What is the processing of personal data?

The processing of personal data consists of an operation or set of operations carried out upon personal data or personal data bundles, through automated or non-automated means, including, but not limited to collection, registration, organization, conservation, alteration, retrieval, consultation, use, disclosure, limitation, elimination, and/or destruction.

Who is responsible for processing your data?

The entity responsible for processing your personal data is 99x Tech, which you may contact at any time through one of the channels below:

  • Phone: +351 214 124 600
  • E-mail: pdm.europe@99x.io
  • Written communication: Alameda Fernão Lopes, 16- 13º, 1495-190 Lisbon, Portugal

What is our commitment to your data?

99x Tech strives to ensure the protection and confidentiality of your personal data and has taken measures deemed appropriate to guarantee the accuracy, integrity, and confidentiality of such data, as well as your rights as a data subject. For this purpose, we commend ourselves to: 

  • Requesting your consent to collect personal data.
  • Processing your personal data lawfully, collecting only the required information according to its intended purpose, without using the data collected for a purpose other than that of the intended collection.
  • Maintaining your personal data accurate and updated, and providing you, as the data subject, access to such data and the possibility of rectifying them.
  • Guaranteeing the right to delete your data in accordance with the legislation in force.
  • Respecting the professional secrecy regarding the data processed.
  • Limiting personal data interconnections to the minimum necessary.
  • Implementing appropriate protection and security measures to prevent any unauthorized persons from consulting, altering, destroying or adding your data.

For which purpose and on what ground do we collect your data?

In general, the personal data we collect may be used within the management of a contractual relationship, the provision of contracted services, the adequacy of our services to the needs and interests of our customers/users, the dissemination of relevant content, the disclosure/registration in events, communication and marketing, the dissemination/application to job opportunities.

Under the law in force, the processing of personal data is admissible only when at least one of the following conditions is verified:

  • Consent– when the data subject gives his / her express and prior written consent, orally or through the validation of an option, and if such consent is free, informed, specific, and unambiguous for the processing of his / her personal data to one or more specific purposes.
  • Contractual obligations and pre-contractual arrangements– where the processing of personal data is necessary for the fulfillment of contractual obligations in which the data subject is a party, or to pursue pre-contractual procedures at the request of the data subject, for example, the preparation of a proposal for a provision of services.
  • Legal obligations– where the processing of personal data is required to fulfill a legal obligation to which 99x Tech is subject, such as the communication of identification data to police, judicial, tax or regulatory entities.
  • Legitimate interest– where the processing of personal data corresponds to a legitimate interest of 99x Tech, in particular for the purpose of direct marketing, to prevent fraud or to ensure the security of the network and information in our computer systems, provided that your rights and freedoms are not seriously harmed.
  • The exercise of functions of public interest– when the data processing is necessary for the performance of public functions, or the exercise of the official authority vested in the data controller.
  • Defense of vital interest of the data subject or another natural person: in case the data subject is physically or legally incapable of giving his / her consent.

Which kind of personal data do we collect?

In the scope of the activity carried out by 99x Tech, we may collect and process personal data through various channels, namely by phone, in writing, and/or through online channels. Personal information may include:

  • Name, address (es), e-mail address (es) and telephone number (s).
  • Professional data such as your role, the name, size, and location of your company.
  • Behavioral or demographic attributes, when linked to personal identifiers.
  • Past transactional behavior on the channels.
  • Personal information available from public access sources.
  • Other information that, as the data subject, you opt-in an informed way to provide us, including, but not limited to contact details, professional data, demographic data, technological preferences, methodologies, technologies and software applications that you use in your organization, information regarding the use of services provided by 99x Tech.

How long do we keep your personal data?

Whenever there is no specific legal requirement, your data shall be stored and kept only for the minimum period necessary for the purpose (s) which led to their collection or subsequent processing.

What are your rights as a personal data subject?

As a personal data subject, we safeguard your right to access data, as well as to its rectification, updating, limitation, deletion/oblivion. You may exercise your rights in this regard through an e-mail communication to:

pdm.europe@99x.io

Under the legislation in force, you may also, at any time, withdraw your consent and oppose the processing of your personal data. In the event of prior consent, it may be withdrawn at any time, without compromising the legality of any processing done under the previously given consent.

Which measures does 99x Tech take to protect your personal data?

99x Tech is committed to ensuring the security of your personal data and has implemented appropriate, necessary and sufficient security measures of a technical and organizational nature to protect them against dissemination, loss, misuse, alteration, unauthorized access, as well as against any other form of illicit processing.

Under what circumstances may we communicate your data to third parties?

In the scope of our activity, 99x Tech may need to resort to third parties to provide certain services. When the provision of these services implies access by such entities to personal data, we take appropriate measures to ensure that these entities are reputed and offer data security guarantees, ensuring their legal processing under the law and following our privacy policy.

Third-Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below.

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”

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Changes to the Privacy and Personal Data Protection Policy 

99x Tech reserves the right to change the Privacy and Personal Data Protection Policy periodically. In the event of any changes to our policy and the way we collect and process your personal data, we will make available an updated version of this information on our website.