This document is dated March 28, 2018.

Transparência e Integridade is a civic association, registered in Portugal with the number 509 569 242 (hereafter referred to as “TI-PT”). Its official address is Rua Leopoldo de Almeida, 9B, 1750-137 Lisboa, Portugal. TI takes a very serious approach to the privacy of users of its website https://transparencia.pt (hereafter referred to as “website”). This document (hereafter referred to as the “Privacy Policy”) defines the conditions under which TI-PT handles personal data collected on its website. It also provides information about the methods adopted to safeguard the data.

Should you not agree with the current Privacy Policy, please do not use the website. The website helps TI-PT carry out its work. For example, the website allows it to disseminate information about campaigns for the general public, send out press releases and mobilize its network of workers and volunteers.

Providing personal data on the website presupposes knowledge of the current Privacy Policy. Users younger than 18 years old, who have not been authorized to use the site by their parents or tutors, should not send personal data to the website.

TI-PT presumes that the user is authorized to supply data collected on the website and that this data is current, true and accurate.

Responsibility for handling the data

TI-PT is responsible for managing the website, for the content of the website and for handling the personal information of users gathered on the website. The domain is the property of Transparência e Integridade, Civic Association.

Where TI-PT uses the services of third parties (subcontractors) who act on behalf of TI-PT, our Privacy Policy requires these third parties to use the relevant technical, security and organizational methods whenever they handle personal data, according to Law n.º 67/98 of 26 October (hereafter referred to as the “Personal Data Protection Law”).

Data handling, use and motives for use

When users use the website, TI-PT is authorized to handle the following categories of data, for the motives indicated:

Data registered in the reserved area and other account management data

Data registered by the user allows them access to the reserved area where they can subscribe to TI-PT newsletters, receive information relating to the their interests, or browse previous TI-PT activity. This data simplifies the signature of petitions organized by TI-PT, as well as the dissemination of news and information about campaigns and activities. To access TI-PT’s reserved area, a user must create a registered account (hereafter referred to as “LOGIN”). To create a LOGIN, users must provide the following information: name, email, and choose a username and password. To access the reserved area, users must first identify themselves by providing their username and password.

Data collected from forms available on the website

Auto-fill user forms on the website (for example, forms to subscribe to campaigns, register as a volunteer or activist, request training sessions, programs or projects, or subscribe to TI-PT newsletters) necessitate the gathering of personal data, as well as the IP address (ID number of the electronic device accessing the internet). Registering the IP address helps avoid fraud, for example the non-authorized use of credit cards. However, TI-PT also allows users to provide data by phone, fax or email.

Subscribing to TI-PT newsletters and auto-filling certain forms implies that TI-PT will send information messages to the email account or telephone number supplied by the user. Occasionally these messages may request information that allows TI-PT to better understand the generic profile of its users. Users have the right to cancel TI-PT newsletters, or withdraw from campaigns or programs, at any time.

Data collected for the management of donations and legacies

Obligatory or optional personal data gathered in relation to donations to TI-PT, by MultiBanco, direct debit, bank transfer or credit card is used to manage the monetary contributions of each user, to establish further contact with the donor or the person providing the legacy, and to send regular information about TI-PT’s activities.

Data gathered via the purchase of products from the TI-PT online shop

TI-PT uses data collected from its website shop to buy and sell products, send articles by post and for the invoice for each purchase. TI-PT has the right to send promotional messages to its buyers; these messages include the possibility to unsubscribe.

Processing requests

TI-PT handles user personal data in order to process legal requests, including:

• Clarification of questions submitted by the user;
• Providing information or clarification in the ordinary course of registration or association (as per the applicable subscription / affiliation agreement);
• Technical support for some other operation on the website;
• Processing Personal Data update and rectification requests;
• Handling complaints and resolving disputes with users;
• Registering users’ requests or the organization to which they belong, their affiliation to other data collection groups or to organizations that provide services similar to TI-PT.

User statistics

TI-PT is authorized to use users’ personal data in aggregated and anonymised form for statistical purposes, and to monitor trends and website usage patterns, with a view to continuous improvement of its performance.

With whom is users’ personal data shared?

TI-PT sometimes needs to share user personal data with third parties and is authorized to do this. The user acknowledges and agrees that TI-PT may transmit personal data to:

• The Secretariat of Transparency International;
• Administrative or judicial authorities, especially when TI-PT is required to do this by law or by any judicial or administrative order, issued by the appropriate authorities;
• Third parties subcontracted by TI-PT, if TI-PT considers this reasonable, in order to investigate, prevent or take action regarding illegal or improper activities, suspected fraud, or potential threats to TI-PT, for users of the website, or violations or suspected violations of the Terms of Use.

Right of Access, Rectification and Updating of Data

Under the law, TI-PT guarantees the right of access, rectification, updating and deletion of personal data at all times. On the basis of a written request addressed to TI-PT (the controller) at the following address [email protected], TI-PT also guarantees the right to oppose the use of personal data for direct marketing purposes, in all cases.

Cookies

TI-PT uses cookies on this website. A cookie is a small text file that identifies your computer on the TI-PT server. Cookies do not identify the individual user, just the computer used. Cookies are not used to analyze users’ activities; instead they provide information that allows TI-PT to improve the website and store individual users’ preferences.

Users can use their website browser settings to exercise some control over cookies. Users can configure their computer to accept all cookies, to notify them when a cookie is issued or to decline to receive some or all cookies. How to do this depends on the browser (web browser) you use. For more information please see the “Help” function of your browser or visit www.allaboutcookies.org. If you accept cookies, they may remain on your computer for many years, unless you delete them. It should also be noted that deactivating cookies may involve the loss of opt-outs or preferences set on the website, and may make the website less efficient to use.

This website always seeks your prior consent to the use of cookies.

Security of personal data

Data collected is stored in an automated, confidential file. TI-PT uses technical and organizational procedures to prevent security breaches and unauthorized access to personal data, and employs other security measures required by the Data Protection Act.

Nevertheless, despite its best efforts, and given the insecurity inherent to the internet, TI-PT cannot ensure full and absolute inviolability of information received.

Alterations

TI-PT reserves the right to modify this Privacy Policy at any time and without prior notice. We advise you to consult it regularly.