This document sets out the PRIVACY and COOKIES Policies (the “Policy”) of BABY LIBERDADE – COMÉRCIO DE VESTUÁRIO LDA,, a Company incorporated and existing in Portugal with Company’s Identification number 509565891 its successors and permitted assigns (“BABY LIBERDADE”) applying when an user (“USER”) provides to BABY LIBERDADE any personal data of your own or any other identified or identifiable individuals (“Data”) including when USER uploads Data into the Registration Form available for filling at http://www.babyliberdade.com website (“Website”).
To the far extent that USER is a legal representative of another organization or company this Policy applies to Data uploaded or disclosed to BABY LIBERDADE and may include the name, email indicated in the Contacts Registration Form along with their association to requests of information sent by BABY LIBERDADE.
If USER has any reservations, doubts or objections to this Policy, USER should resume and exit from the Website refraining from uploading any Data into the Website including the upload of Data – whether totally or in part - onto any online Form.
BABY LIBERDADE reserves the right to change this Policy at any time without prior notice. Any amended Policy will be integrated herein from time to time. Completion of the Registration Process with BABY LIBERDADE and continued use of the Website implies that USER is aware, acknowledges and accepts this Policy as amended and in force from time to time.
Last revised and applicable as from May 21st 2018.
What and how Data is collected?
All products and services provided by BABY LIBERDADE are reserved to professional or consumer use depending upon the properties and characteristics announced per each of the services or goods in question.
Registration and enrolling of an USER is automatically processed online and further verified and validated offline by the administrative supporting team of BABY LIBERDADE, notably to the effects of invoicing, sending of electronic messaging selected by USER or inclusion of USER in a client database, depending on whichever’s the case.
For further information on the applicable online terms and conditions of sale at the Website (“Terms”) please check out here.
BABY LIBERDADE WILL ONLY COLLECT DATA THAT IS VOLUNTARILY DISCLOSED AND SUBMITTED BY USER AND THAT USER AUTHORISES COMPANY TO COLLECT AND PROCESS PURSUANT TO THE LAWS IN FORCE FROM TIME TO TIME AND THIS POLICY. USER IS FREE NOT TO CONSENT DATA PROCESSING ACTIONS BY THE COMPANY OR BY ANY OTHER ENTITY AND MAY WITHDRAW A PREVIOUSLY GRANTED CONSENT AT ANY TIME AT HIS/HER SOLE AND FAIR JUDGEMENT AND CRITERIA.
A refusal to grant consent or the withdrawal of a previously granted consent may only prevent BABY LIBERDADE from completing the enrollment and registration of the USER at the Website or prevent BABY LIBERDADE from keeping the USER enrolled or duly registered at the Website. In case of a previously registered USER such will imply that USER is deleted from the Website’s Registered Users database, thereby preventing him/her from online subscribing a BABY LIBERDADE’ service or purchasing BABY LIBERDADE’s products through/at the Website’s online shop. Access to and visualization by USER of the Website will not be impacted and the purchasing of products or service subscription will continue available at alternate sales channels, namely BABY LIBERDADE’s shop, at Avenida da Liberdade, 144 to 156 R/C, Loja C, 1250-146 Lisboa.
BABY LIBERDADE may also collect and process company’s data, which may not be covered by the stipulations of this Policy as it applies to Data (“Corporate Data”).
Corporate Clients registering at the Website expressly grant to BABY LIBERDADE a fully paid, royalty free, non-exclusive, sub-licensable, perpetual, worldwide license for BABY LIBERDADE to collect and process Corporate Data of the Corporate Client in question for the intended business purposes of BABY LIBERDADE including those relating to its activity for commercial purposes, marketing and promotional activities of the BABY LIBERDADE or its partners.
What are and how do cookies work? Cookies Policy
Cookies are alphanumeric identifiers that COMPANY may transfer to into the Corporate client’s computer's hard drive or Website’s visitor to enable COMPANY’ systems to recognize Corporate Client’s browser and tell COMPANY how and when Website is visited and by how many people also permitting to enhance Corporate client’s user experience (UX) (“Cookies”). Cookies may keep track of Corporate Client’s movements within the Website, help Corporate Client to navigate or advise navigation, remember Corporate Client’s navigation history, theme selection, preferences and other customization functions (if/as available).
The Website uses the following Cookies:
- Google Tag Manager®
- Google Analytics
- Google AdWords
- Facebook Custom Audience®
- Facebook Connect®
NO DATA SHALL BE COLLECTED, STORED AND/OR PROCESSED THROUGH COOKIES.
USER may also choose to refuse, delete or accept Cookies through selection of appropriate functions in the “options” or “preferences” sections of the web browser. USER should further navigate the “Help” menu of the web browser to properly understand and configure its Cookies preferences.
Refusal of Cookiesor their deletion may only cause the Website not to function as properly as usual or some of its features might be disabled.
By using the Website, USER consents to the processing of Data or Corporate Data by Google in the manner and for the purposes set out above. In case USER intends to disable tracking of navigation history in the internet please disable Google Analytics at http://www.google.com however please note that by doing this USER may not be able to use the full functionality of the Website.
In order to further understand what Cookies are all about, understand what Cookies were installed and how can they be managed and/or deleted by USER please visit www.allaboutcookies.org.
Anonymous Information. How does it work?
BABY LIBERDADE may share generic aggregated demographic information not linked to any personal identified information regarding visitors and users of the Website for the purposes outlined above.
Non-personal identification information may include the browser name, device name, type of computer and technical information about users, means of connection to the Website, such as the OS and/or the ISP utilized by user or other similar non-personal technical information.
When BABY LIBERDADE shares such information it shares it in a distinctive database so that information remains anonymous at all material times and cannot be reverted to be understood and processed as Data.
What are the purposes for which BABY LIBERDADE processes my Data?
BABY LIBERDADE may collect, store, process and manage Data for the following purposes:
- Technical and of Technical improvement - To enable BABY LIBERDADE and its partners and subcontractors in the operation and maintenance of the Website and to technically support BABY LIBERDADE, thereby improving the Website’s user experience by the USER; in providing and further improve the providing of its services to USER;
- Marketing and Commercial – To send alerts to USER on products, services, new products, improvements, scientific, technical bulletins, news, special promotions that may be interesting for the USER and for he/she has consented;
- Usability – In order to help USER to find the products or services that best adapt and respond to his/her needs from the navigation’s memory and the interaction collected through cookies, without access to Data;
- To make the Website more relevant and easier to navigate by USER and/or to help USER solve any navigation problems USER may find whilst using the Website;
- Newsletters and generic information - To send periodic emails If USER decides to register and/or join BABY LIBERDADE’s newsletters or non-solicited mailing (if/as available) and provided however that USER has so provided his/her consent.
If USER would like to unsubscribe from future emails, pushups or news from BABY LIBERDADE, he may
- Go to his/her preferences on the Profile Settings and follow the instructions therein for unsolicited messaging. However please note that despite such fact, as a registered USER, you may continue to receive e-mails from the System (v.g. referring to passwords) and all legal notices (v.g. updates, new versions or terms and conditions);
- Contact the Data Protection Officer:
How does BABY LIBERDADE protect my Data?
BABY LIBERDADE shall process Data only in accordance to this Policy and the European Laws in force – as amended from time to time- within the European Union.
BABY LIBERDADE adopted appropriate technical and organizational measures intended to protect Data against accidental loss, destruction, or alteration; unauthorized disclosure or access; or unlawful destruction.
Sensitive data exchange between the Website and USER is most unlikely to occur. However when/if such becomes the case BABY LIBERDADE shall use SSL secured communication channel with encryption and protected digital signatures so as to minimize a Data breach event.
NOTWITHSTANDING THE LATTER PLEASE BE ADVISED THAT BABY LIBERDADE CANNOT ENSURE FULL NETWORK SECURITY OVER THE WEB AND USE OF THE WEBSITE MAY EXPOSE USER AND DATA TO RISKS SUCH AS IDENTITY THEFT, FRAUD OR FRAUDULENT ACTION BY THIRD PARTIES OUT OF BABY LIBERDADE’S CONTROL THAT MAY CAUSE USER IRREPARABLE LOSS AND/OR DAMAGE OF UNQUANTIFIABLE IMPACT.
USER DISCRETION ON THE USE OF THE INTERNET, THE WEBSITE AND THE DISCLOSURE OF USERR DATA ALONG WITH ANY CONSENTS IN RESPECT THEREOF ARE STRONGLY ADVISED.
To whom may BABY LIBERDADE disclose my Data?
BABY LIBERDADE is not in the business of selling, trading, or renting Data and therefore exchange or sharing of Data with third parties is strictly limited and is only made in accordance to the applicable laws subject however to the following:
- BABY LIBERDADE may share Data within the group of affiliate and subsidiary group companies of BABY LIBERDADE for its activity’s intended purposes and for the integrated supply of goods and services that USER sources from BABY LIBERDADE.
- BABY LIBERDADE may share Data with business partners and other companies in the scope of existing partnerships in the scope of BABY LIBERDADE’s activity.
- Administrator data for purposes of Website security and/or fraud prevention.
- Data storage operations being contractually guaranteed before third party providers the compliance with the terms and conditions of the herein Policy.
- As far as the Website is concerned, BABY LIBERDADE may source from third party providers the tasks of Website’s administration and updating. Any Data shared with such third parties shall be STRICTLY AS NEEDED to the purposes of rightfull rendering of such support Website’s administration and updating services.
BABY LIBERDADE shall not disclose Data or confidential information of EU citizens into non-EU territories or into companies unrelated to BABY LIBERDADE or BABY LIBERDADE’s business activity, except (1) if USER so requires, consents or determines BABY LIBERDADE, which may result from the online activity of USER at the Website; or (2) as provided by Law; or (3) as imposed by a court or administrative order or another public determination by an entity or officer with jurisdiction over the BABY LIBERDADE outside the EU.
Unless as otherwise imposed by Law, whenever any of such entities contact the BABY LIBERDADE compelling it to disclose Data or Confidential Information of USER or Corporate Data (1) BABY LIBERDADE shall promptly communicate such compelled disclosure; (2) shall seek that the authorities in question contact directly the Data owner and to such effect shall only provide them with basic points of contact with him/her, as available to BABY LIBERDADE; (3) BABY LIBERDADE shall reasonably effort not to grant access to excessive information considering the one that was compelled from BABY LIBERDADE to be disclosed; (4) BABY LIBERDADE shall effort – to the far extent lawfully permitted and without additional costs – to prevent any entities to access directly to stored Data,
encryption keys used to secure or the confer the ability to break such encryption. COMPANY will not disclose Administrator Data outside BABY LIBERDADE or its controlled subsidiaries.
Where does BABY LIBERDADE process my Data?
Except as described elsewhere herein, Data may be processed only within the European Union only. Our systems are located at Bsolus and F3M (SAGE program).
BABY LIBERDADE abides by the European Union Data Privacy laws regarding the collection, storage, processing, management and retention of Data from European Union national or citizens which data is processed within the European Union.
Who is the Data Controller?
BABY LIBERDADE is the Data Controller and Bsolus and F3M are the third party providers for the operations of cloud management and storage. There are no other third parties engaged with Data processing operations from the Website.
Should USER intend to exert any of its rights he/she should please send a written message to:
BABYLIBERDADE – COMÉRCIO DE VESTUÁRIO LDA.
Address: Av. Da Liberdade, 144 to 156, R/C Loja C, 1250-146 Lisboa
Or by electronic message sent by using the Contact Form available at www.babyliberdade.com
What are my rights?
The USER has the right to access, modify and/or delete (total or in part) his data, the right to be informed about the treatment activities, the right of opposition or limitation about treatment operations, the right to portability (in some cases) and all the ones listed at the legislation.
USER has also the right to make any complaint directly to the supervised entity about the data protection in Portugal, which is Comissão Nacional de Dados and to get the contacts of it, if requested by the Responsible of the Treatment.
BABY LIBERDADE will answer all the requests in the terms and if they are defined by law and by this policy.
For how long is my Data stored and processed?
BABY LIBERDADE retains USER Data until the longest of:
- The term within which the USER is registered at the Website;
- The term necessary for the fulfillment of a contractual/ pre-contractual obligation of BABY LIBERDADE towards the USER, the fulfillment of a legal obligation or the legitimate pursue of a business interest of BABY LIBERDADE;
- For as long as a consent by the USER lasts for a specific purpose and whenever the consent is the legitimate cause for Data processing.
How is my Data deleted?
Data is deleted through safe deletion procedures described in internal codes and policies in force at BABY LIBERDADE.
Digital Data may be anonymized whenever the removal or deletion of such Data from our systems may not reconcile on a reasonable basis with the data quality of the database in which they are located; notably, whenever the deletion or removal may imply a considerable risk of data breach to other data stored on same systems or part of same database and the latter are to remain integrate and active (impacts on data integrity and/or on systemic data quality feasible or anticipated).
Data in physical media will be eliminated by irreversible destruction processes.
What Laws and Jurisdiction?
Data will be processed solely according to this Policy and the Laws in force. No further laws shall apply to Data.
Any disputes hereunder shall be submitted and resolved exclusive by the Portuguese Courts, which territorial and material jurisdiction will be determined according to the procedural laws in force.
Last Revised and in force as of 21st May 2018