Commitment to Data Protection and Privacy

QUITE A MIND, LDA / MAKEADREAM complies with all applicable community and national legal standards in the field of data protection, privacy and information security.

QUITE A MIND, LDA / MAKEADREAM is implementing a Personal Data Protection System and an Information Security System, in order to ensure regulatory compliance and the demonstration or disclosure of institutional responsibility in terms of protecting data and information security, implementing all the necessary technical and organizational measures, either to comply with the general legal regime of the Law Enforcement of the General Regulation on Data Protection (Law 58/2019, of 8 August), or to comply with the legal regime of the General Data Protection Regulation, EU Regulation 679/2016, of 27 April).

For any clarification or additional information or to exercise your rights in this area, please contact the Data Protection Officer of QUITE A MIND, LDA / MAKEADREAM via email dataprotection@makeadream.pt.

"Personal data" means information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier. Personal identifiers are, for example, a name, an identification number, location data, electronic identifiers or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means an operation or set of operations carried out on personal data or on sets of personal data, by automated or non-automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration , retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, erasure or destruction.

"Cookies" are small text files with information considered relevant that the devices used for access (computers, mobile phones or portable mobile devices) load, through the internet browser (browser), when an online site is visited by the Customer or User.

Quite a Mind, Lda / Makeadream, headquartered at Avenida Torre de Belém 17, 1400-342 Lisbon, Portugal, Legal Person with NIF 514560665, hereinafter referred to as QUITE A MIND, LDA / MAKEADREAM, is the entity responsible for the sites in line and computerized applications, hereinafter referred to as channels or applications, through which Users, Service Recipients or Customers have remote access to the services of QUITE A MIND, LDA / MAKEADREAM that are presented or provided, at any time, through them , the entity being considered responsible for the processing of personal data.

Quite a Mind, Lda / Makeadream, headquartered at Avenida Torre de Belém 17, 1400-342 Lisbon, Portugal, Legal Person with NIF 514560665, hereinafter referred to as QUITE A MIND, LDA / MAKEADREAM, is the entity responsible for the sites in line and computerized applications, hereinafter referred to as channels or applications, through which Users, Service Recipients or Customers have remote access to the services of QUITE A MIND, LDA / MAKEADREAM that are presented or provided, at any time, through them , the entity being considered responsible for the processing of personal data.

For the purposes of contacting the Data Protection Officer of QUITE A MIND, LDA / MAKEADREAM, please send an email to dataprotection@makeadream.pt or to each of the specific addresses identified on the online sites, describing the subject of the request. and indicating an email address, a telephone contact address or a mailing address.

For any other purpose, the following general contacts of QUITE A MIND, LDA / MAKEADREAM can be used:
– Postal Address: Avenida Torre de Belém 17, 1400-342 Lisbon, Portugal;
– General Electronic Mail: info@makeadream.pt;
– General Electronic Mail: info@makeadream.pt;

QUITE A MIND, LDA / MAKEADREAM processes the personal data strictly necessary for the provision of information and the functioning of its channels, according to the uses made by Users, Recipients of the Service or Customers, whether those provided for the purposes of registration of requests or obtaining information, either those that are provided for the purposes of joining those channels, or those that result from the use of the services provided by QUITE A MIND, LDA / MAKEADREAM through them, such as accesses, consultations, instructions, transactions and other records relating to your use.

In particular, the use or activation of certain features of the channels may imply the processing of various direct or indirect personal identifiers, such as name, home address, contacts, device addresses or geographic location, whenever there is for this the express consent of the User, Recipient of the Service or the Customer.

In all cases, Users, Service Recipients or Customers will always be informed of the need to access such data in order to use the features of the channels in question.

The personal data collected by QUITE A MIND, LDA / MAKEADREAM are processed by computer, in certain cases in an automated way, including the processing of files or the definition of profiles and within the scope of the management of the pre-contractual, contractual or post-contractual relationship with Users, Service Recipients or Customers, under the terms of national and community regulations in force.

The categories or types of personal data that are processed are generally the following:

– identification data;
– contact details;
– professional data;
– data billing;
– traffic data and access control.

In the different establishments of the Responsible for the Treatment, biometric data may also be processed, processed through the video surveillance systems that are installed.
A detailed listing of categories of personal data and categories of data subjects can be found in the Information Sheets on Data Processing.

All data processing operations comply with fundamental legal principles within the scope of data protection and privacy, namely with regard to their circulation, lawfulness, loyalty, transparency, purpose, minimization, conservation, accuracy, integrity and confidentiality, with QUITE A MIND, LDA / MAKEADREAM available to demonstrate its responsibility towards the data subject or any other third party that has a legitimate interest in this matter.

All data processing operations carried out by QUITE A MIND, LDA / MAKEADREAM have a basis of legitimacy, namely, due to the fact that the data subject has given his consent to the processing of his personal data for one or more specific purposes , either because the processing is considered necessary for the performance of a contract to which the data subject is a party or for pre-contractual steps at the request of the data subject, or because the processing is necessary for the fulfillment of a legal obligation to which the data controller is subject, either for public interest purposes or because the processing is considered necessary for the purpose of pursuing the legitimate interests pursued by QUITE A MIND, LDA / MAKEADREAM or by third parties.

All personal data processed within the scope of QUITE A MIND, LDA / MAKEADREAM channels are intended exclusively for the provision of information to Users, for the management of the personal information of the Service Recipients considered necessary for the purposes of relationship or communication management, as well as the provision of services to Customers and, in general, the management of the pre-contractual, contractual or post-contractual relationship with Users, with the Recipients of the Services or with the Customers.

The personal data collected may, even and eventually, be processed for statistical purposes, for information dissemination or promotional actions and for communication actions, namely to promote actions for the dissemination of new features or new services, through direct communication, either by correspondence, electronic mail, messages or telephone calls or any other electronic communications service.

Since prior information and the collection of express authorization for these last purposes are always assured, Users, Recipients of the Services or Customers may, at any time, exercise their right to withdraw consent or their right to oppose the use of their data. personal data for other purposes that go beyond the management of the relationship with the Data Controller, namely for the purpose of pursuing legitimate interests, for sending informative communications or for inclusion in lists or information services, and for this purpose, you must send a written request. addressed to the Data Protection Officer of QUITE A MIND, LDA / MAKEADREAM, in accordance with the procedures indicated below.

Pursuant to the principle of loyalty and transparency and to ensure compliance with the duty of information, QUITE A MIND, LDA / MAKEADREAM directly delivers or makes publicly available to all holders of personal data, depending on the way in which their personal data is collected, the information sheets on the data processing operations carried out, these sheets are accessible for consultation at any public service unit or at the Data Protection Officer.

Personal data will only be kept for the period necessary for the purposes that led to their collection or subsequent processing, ensuring compliance with all applicable legal rules in terms of archiving and the specific retention period being specified in each one. of the Information Sheets on Data Processing.

QUITE A MIND, LDA / MAKEADREAM may eventually use two major categories of "cookies": "cookies" within the scope of online sites and "cookies" within the scope of direct electronic communication channels, always being, in any of the categories, ensuring their deactivation by Users or Customers.

QUITE A MIND, LDA / MAKEADREAM uses "cookies" on its online sites in order to improve the performance and browsing experience of Users and Customers, increasing, on the one hand, the speed and efficiency of response and, on the other hand, another, eliminating the need to repeatedly enter the same information.

The use of "cookies" helps online sites to recognize the devices of Users and Customers the next time they visit them, and is also, in some cases, essential for their functioning.

The "cookies" used by QUITE A MIND, LDA / MAKEADREAM, in all its channels, do not collect personal information that allows the identification of Users or Customers, saving only generic information, namely the form or geographic location of access and the way in which use the channels, among others. The "cookies" only retain information related to the preferences of Users and Customers, and personal identifiers are not recorded.

Users, Service Recipients and Customers may, at any time, through the computer application they use to browse the internet ("browser"), make the decision to be notified of the receipt of "cookies", as well as to block the respective entry into your system.

In relation to the type of intended purposes, QUITE A MIND, LDA / MAKEADREAM may, whenever justified, use three different types of "cookies", according to the following specifications:

(i) Essential "cookies" - some "cookies" are essential to access specific areas of online channels, allowing navigation and use of their applications, such as accessing secure areas of the sites, through user registration - without these " cookies», services that require it cannot be provided;
(ii) Functionality "cookies" - Functionality "cookies" allow you to remember the user's preferences regarding navigation on online sites, thus not needing to reconfigure and personalize it each time you visit it;
(iii) Analytical "cookies" - these "cookies" are used to analyze how users use the online sites, allowing to highlight articles or services that may be of interest to users, monitoring the performance of the sites, as well as knowing which pages are the most popular, which method of linking between pages is most effective or to determine why some pages are receiving error messages - these "cookies" are used only for the purpose of creating and statistical analysis, without ever collecting personal information .

For these purposes, QUITE A MIND, LDA / MAKEADREAM can provide a high quality experience to Users, Service Recipients or Customers, personalizing information and offers and identifying or correcting any possible problems that may arise within the scope of their use. .

Regarding the type of validity, there are two types of "cookies":

(i) Permanent "cookies" - are "cookies" that are stored on the devices used to access the channels (computers, mobile phones, etc.), at the level of the computer application used to browse the internet ("browser"), being used whenever Users or Customers visit any channel again – in general, they are used to direct navigation according to the User's or Customer's interests, allowing QUITE A MIND, LDA / MAKEADREAM to provide a more personalized service;
(ii) Session «cookies» - are temporary «cookies», which are generated and are only available until the end of the session, since the next time the Customer/User accesses their internet browser ("browser") the "cookies" will no longer be stored – the information obtained allows you to manage sessions, identify problems and provide a better browsing experience

Users, Service Recipients or Customers can disable part or all of the "cookies" at any time - they must, for this purpose, follow the instructions available in each of the computer applications used to browse the internet ("browser"), being able to , however, with deactivation, you lose access to some features of the sites.

QUITE A MIND, LDA / MAKEADREAM, within the scope of direct electronic communication channels, may also use "cookies" in opening the different electronic communications sent, such as "newsletters" and e-mail, for statistical purposes - allowing you to know whether these communications are open and verify clicks through links or advertisements within those communications..

Also in this category of "cookies", Users, Recipients of the Service or Customers always have the possibility to disable the sending of electronic communications through the specific option in the footer of the same.

The provision of information or the provision of services by QUITE A MIND, LDA / MAKEADREAM to its Users, Service Recipients or Customers through the channels may eventually imply the use of services from subcontracted third parties, including entities based outside the European Union, for the provision of certain services, which may imply access by these entities to such personal data.

Except within the scope of compliance with legal obligations, execution of contracts or pursuit of legitimate interests, under no circumstances will there be communication of personal data of Users, Service Recipients or Customers to third parties that are not subcontracted entities or legitimate recipients, not being carried out, also, any other communication for purposes other than those mentioned above.

Any transfer of personal data to a third country or an international organization will only be carried out within the framework of compliance with legal obligations or guaranteed compliance with the Community and national legal rules applicable in this matter.

Taking into account the most advanced techniques, application costs and the nature, scope, context and purposes of the treatment, as well as the risks, of varying probability and severity, for Users, Service Recipients or Customers, QUITE MIND, LDA / MAKEADREAM and all entities that are its subcontractors apply the appropriate technical and organizational measures to ensure a level of security adequate to the risk.

For this purpose, several security measures are adopted in order to protect personal data against its dissemination, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of illicit treatment.

It is the exclusive responsibility of Users, Service Recipients or Customers to keep access codes secret, not sharing them with third parties, and in the particular case of computer applications used to access channels, maintain and keep the access devices in security conditions and follow the security practices recommended by manufacturers and/or operators, namely regarding the installation and updating of the necessary security applications, namely, among others, antivirus applications.

If there is a need to subcontract services to third parties that may have access to the personal data of Users, Service Recipients or Customers, the subcontractors of QUITE A MIND, LDA / MAKEADREAM will be obliged to adopt the security measures and protocols at the organizational level and the technical measures necessary to protect the confidentiality and security of personal data, as well as to prevent unauthorized access, loss or destruction of personal data.

Users, Service Recipients or Customers of QUITE A MIND, LDA / MAKEADREAM may, as holders of personal data, at any time, exercise their data protection and privacy rights, namely the rights of access, rectification, erasure, portability, limitation or opposition to treatment, under the terms and with the limitations provided for in the applicable rules.

Any request to exercise data protection and privacy rights must be addressed, in writing, by the respective holder, to the Data Protection Officer, in accordance with the procedure and contact details described below.

Users, Service Recipients or Customers have the right to file a complaint, either by registering the complaint in the Complaints Book, or by submitting a complaint to the regulatory authorities – in the latter case, they may file a petition or complaint directly with the National Commission. of Data Protection through the contacts available at www.cnpd.pt.

Users, Service Recipients or Customers may also make suggestions via email sent to the Data Protection Officer via email dataprotection@makeadream.pt.

QUITE A MIND, LDA / MAKEADREAM has implemented an incident management system within the scope of data protection, privacy and information security.

If any User, Service Recipient or Customer wishes to report the occurrence of any situation of violation of personal data, which causes, accidentally or illicitly, the destruction, loss, alteration, disclosure or unauthorized access, personal data transmitted, preserved or subjected to any other type of treatment, you can contact the Data Protection Officer or use the general contacts of QUITE A MIND, LDA / MAKEADREAM.

In order to guarantee the respective updating, development and continuous improvement, QUITE A MIND, LDA / MAKEADREAM may, at any time, make changes, which are considered appropriate or necessary, to this Data Protection Policy, ensuring their publication in the different channels to guarantee transparency and information to Users, Service Recipients and Customers.

The terms of the Data Protection and Privacy Policy are complementary to the terms and provisions, in terms of personal data, provided for in the General Conditions of Use of QUITE A MIND, LDA / MAKEADREAM channels.

The free, specific and informed availability of personal data by the respective holder implies knowledge and acceptance of the conditions contained in this Policy, considering that, by using the channels or by making their personal data available, Users, Recipients of the Service and Customers are expressly authorizing its treatment, in accordance with the rules defined in each of the applicable collection channels or instruments.

With a commitment to transparency and information and to ensure the adequacy of the Data Protection Policy to the different data processing operations carried out and, above all, to the different categories of data subjects, QUITE A MIND, LDA / MAKEADREAM can develop Policies Special Data Protection, such as, for example:

– the Data Protection Policy in the Work Context;
– the Data Protection Policy in Application Management and
– the Supplier Employee Data Protection Policy.

These special policies are made available directly to the respective categories of holders, being available for consultation by request to the Data Protection Officer.

For the exercise of any type of data protection and privacy rights or for any matter related to data protection, privacy and information security, Users, Service Recipients and Customers who interact with QUITE A MIND, LDA / MAKEADREAM can contact the Data Protection Officer via the email dataprotection@makeadream.pt, describing the subject of the request and indicating an email address, a telephone contact address or a mailing address for reply.

Policy Version: Version 1.0 - Date: 20200717