Privacy Policy
Introduction
This Privacy Policy explains what we do with your personal data when you show interest in subscribing our contact forms, newsletter, blog, rich materials or if you are visiting our website.
It describes how we collect, use and process your personal data and, in doing so, how we comply with our legal obligations towards you. Your privacy is important to us and we are committed to protecting and safeguarding the privacy rights of your data.
This Privacy Policy applies to the personal data of our website´s users, subscribers, customers, suppliers and other people we may contact in order to inform about our services or who they indicate as an emergency contact.
Concerning the applicable data protection legislation [including, but not limited to, the General Data Protection Regulation [Regulation (EU) 2016/679] (“GDPR”)], the company responsible for your personal data (“Link&Grow” or “we”) can be reached through the following email dpo@linkandgrow.pt.
Please note that we may change this Privacy Policy from time to time. If you want to stay up to date, please visit this page as all changes will be published here.
If you are not satisfied with any aspect of our Privacy Policy, you have legal rights which will be described whenever relevant.
Abbreviated section “Overview”
What kind of personal data do we collect?
SUBSCRIBER DATA: In order to provide you the best tailored content, we need to process certain information about you. We´ll only ask for information that will genuinely help us help you, such as your name, age, contact details, corporate information like the company´s name, your position, budget for digital marketing and interests regarding digital marketing.
When you access our website, we will also collect some other data from you.
CUSTOMER DATA: If you are our customer, we need to collect and use information about you or your company’s staff in matters that concern the service we provide, such as: the company’s tax number and address, IBAN for invoice issuance and its legal name.
When you access our website, we will also collect some other data from you.
SUPPLIER DATA: We need a small amount of information from our suppliers to ensure that everything works correctly. We need contact details of relevant people in your company so we can communicate with you. We also need other information, such as your bank details, so that we can pay you for the services you provide (if this is part of the contractual arrangements between us).
When you access our website, we will also collect some other data from you.
WEBSITE USERS: We collect a limited amount of data from users of our website, which we use to help us improve your experience when you use our website and to help us manage the services we provide. This includes information about how you use our website, how often you access it, and when it is most popular.
Our legal bases for the processing of your data.
How do we collect your personal data?
SUBSCRIBER DATA: There are two main ways we collect your personal data:
- Directly from you;
2. From third parties.
When you access our website or read or click an email from us, we may also collect certain data automatically or through you.
CUSTOMER DATA: There are two main ways we collect your personal data:
- Directly from you;
- From third parties and other limited sources (for example online and offline media).
When you access our website or read or click an email from us, we may also collect certain data automatically or through you.
SUPPLIER DATA: We collect your personal data during the course of our work with you.
When you access our website or read or click an email from us, we may also collect certain data automatically or through you.
WEBSITE USERS: We collect your data automatically through cookies when you visit our website, accordingly to your browser´s cookie settings. We will also collect your data when you contact us through the website, for example using the chat feature.
How do we use your personal data?
SUBSCRIBER DATA: The main reason for using your personal data is to help you find content and solutions in digital marketing that may be suitable for you or your business. The more information we have about you, your set of skills and your ambitions, the more personalized our service can become. Whenever appropriate and in accordance with local laws and requirements, we may also use your personal data for purposes such as marketing, profiling and diversity monitoring. We´ll seek for your consent to carry out some of these activities.
CUSTOMER DATA: The main reason for using customer´s information is to ensure that contractual arrangements between us can be properly enforced so that the relationship can proceed smoothly.
SUPPLIER DATA: The main reasons for using your personal data are to ensure that contractual arrangements between us can be properly enforced so that the relationship goes smoothly and to complies with legal obligations.
WEBSITE USERS: We use your data to help us improve the experience of using our website, for example by analyzing the criteria of your recent search to help us present solutions we believe are of your interest. If you are also a Link&Grow subscriber or customer, we may use data about your use of our websites to improve other aspects of our communications or services relating to you.
Please note that communications to and from Link&Grow staff, including emails, may be reviewed as part of internal or external investigations or litigation.
With whom do we share your data?
SUBSCRIBER DATA: Unless otherwise indicated by you, we may share your information with Link&Grow internal elements and associated third parties, such as our service providers when we consider that this will help us provide you with the best possible service.
CUSTOMER DATA: Unless otherwise indicated by you, we may share your information with Link&Grow internal elements and associated third parties, such as our service providers when we consider that this will help us achieve your goals.
SUPPLIER DATA: Unless otherwise indicated by you, we may share your information with our service providers and companies to whom we provide services.
WEBSITE USERS: Unless otherwise indicated by you, we may share your information with providers of network analytics services, marketing automation platforms and social media services to ensure that the advertisements you receive are tailored for you.
How do we keep your personal data safe?
The protection of your information is important to us, which is why we apply appropriate measures designed to prevent unauthorized access and misuse of your personal data.
For how long do we keep your personal data?
If within a period of two years we haven´t had a relevant contact with you (or, if it applies, with the company with or for whom you are working), we will delete your personal data from our systems unless we in good faith consider that the law or other regulations oblige us to keep them (for example, due to our obligations to the tax authorities or related to an anticipated dispute).
How can you access, change or remove the personal data you have given us?
Even if we already have your personal data, you still have several rights regarding them. To get to know them, contact us. We will endeavour to deal with your request without undue delay and, in all cases, in accordance with the requirements of any applicable legislation. Please note that we may keep a record of your communications to help us resolve any issues you raise.
Right to object: If we are using your data because we believe it´s necessary for our legitimate interests and you don’t agree, you have the right to object. We will respond to your request within 30 days (although in certain cases we may be allowed to extend this period). As a general rule, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: If we have obtained your consent to process your personal data for certain activities (for example, to profile your suitability for certain functions) or consent for marketing purposes to you, you may withdraw your consent at any time.
Data Access Requests by the Subject: To be clear, you have the right to ask us at any time to confirm the information we have about you and you may ask us to change, update or delete this information. At this point, we will be able to comply with your request or, in addition, take one of the following actions:
- We may ask you to verify your identity or ask for more information about your request;
- If we can legally do so, we may refuse your request, but we will explain the reasons for doing so.
Right to erasure: In certain situations (for example, if we have unlawfully processed your data), you have the right to ask us to “erase” your personal data. We will respond to your request within 30 days (although in certain cases we may be allowed to extend this period) and will only disagree with you if certain limited conditions apply. If we agree to your request, we will delete your data, but we will generally assume that you would prefer us to keep a note of your name on our record of people who prefer not to be contacted. In this way, we will reduce the chances of being contacted in the future when your data is collected in unrelated circumstances. If you’d rather we didn’t, you may say so.
Right to data portability: If you so wish, you have the right to transfer your data from us to another controller. We will collaborate on this transfer – by directly transferring your data to you or by providing you with a copy in a commonly used automatic read format.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
If your interests or requirements change, you may unsubscribe from some or all of your marketing content (for example, emails about digital marketing or Link&Grow informational posts), by clicking on the unsubscribe link in the e-mail.
Who is responsible for processing of your personal data on the Link&Grow website?
Link&Grow controls the processing of your personal data on the website.
What are cookies and how do we use them?
A “cookie” is a small data file that is stored on your computer’s hard drive. They are used by almost all websites and do not harm your system. We use them to track your activity in order to help us ensure you get an experience with the smallest possible number of problems when you visit our website. We may use cookie information to ensure that we provide you with options tailored to your preferences on your next visit. We may also use cookies to analyse traffic and for advertising purposes.
If you want to check or change the type of cookies you accept, you can usually do so in your browser settings.
How to refuse cookies
If you don´t wish to receive cookies that aren´t strictly necessary to perform basic features of our website, you can opt-out by changing your browser settings.
Most browsers will accept cookies, but if you do not want us to collect data in this way you can choose to accept all or some of them or refuse cookies in your browser’s privacy settings. However, refusing all cookies means that you may not be able to fully enjoy the full functionality of our website. Each browser is different and therefore you should check the “Help” menu of your browser to learn how to change your cookie preferences.
For more general information about cookies, including how to disable them, see aboutcookies.org. You will also find information on how to delete cookies from your computer.
Detailed extensive versions of the sections
What kind of personal information do we collect?
Do you want to know with more detail the data we collect about you? The following is a more detailed analysis of the information we may collect. The information described below is of course additional to any personal data which we are required by law to process in a given situation.
SUBSCRIBER DATA: Depending on the relevant circumstances and applicable local laws and requirements, we may collect all or part of the information listed below to enable us to offer you employment opportunities tailored to your circumstances and interests. In some jurisdictions, we have limitations on the processing of some of the data types described below. In these cases, we will not process the data in such jurisdictions:
- Name
- Age/date of birth;
- Marital status;
- Contact details;
- Data of the referenced person;
- Immigration status (in case you need a work permit);
- Nationality/citizenship/place of birth;
- Information about your interests and needs regarding digital marketing, collected directly and inferred, for example from articles read on our website;
- Supplementary information you choose to share with us;
- Supplementary information that your reference persons choose to share with us about you;
- IP address; dates, times and frequency with which you access our services.
Please note that the above list of categories of personal data that we may collect is not exhaustive.
When you access our website, we will also collect certain data from you.
CUSTOMER DATA: The data we collect about Customers is actually very limited. Normally, we just need to have your contact details or your company’s individual contact details (such as names, phone numbers and email addresses), to enable us to ensure that our relationship unfolds smoothly. We also have information related to your online involvement with Subscriber profiles and other material published by Link&Grow, which we use to ensure that our marketing communications addressed to you are relevant and timely. We may also have information that someone in your company has chosen to share with us. In certain circumstances, for example, when it relates to our financial teams. If for any reason we need any additional personal data, you will be informed.
When you access our website, we will also collect certain data from you.
SUPPLIER DATA: We don’t collect a lot of data about Suppliers – we just have to make sure our relationship goes smoothly. We will collect data for our contacts in your company, such as names, phone numbers and email addresses. We’ll also collect bank details so we can pay you back. We may also have information that someone in your company has chosen to share with us. In certain circumstances, for example, when it relates to our financial team.
When you access our website, we will also collect certain data from you.
SITE USERS: We collect a limited amount of data from the Users of our website, which we use to help us improve your experience when you use our website and to help us manage the services we provide. This includes information such as how you use our site, how often you access it, your browser type, the location from which you visit our site, the language you choose to view it and the times our site is most popular. If you contact us through the website using, for example, the chat feature, we will collect any information you provide to us, such as your name and contact details.
How do we collect your personal data?
SUBSCRIBER DATA: We collect SUBSCRIBER’s personal data in three main ways:
- Personal data that you, the subscriber, provide us with;
- Personal data we receive from other sources;
- Personal data we collect automatically.
Personal data you give us
Link&Grow needs to know certain information about you in order to provide a tailored service. This will allow us to offer you the best opportunities and should save you time by not having to go through information about jobs and services that aren´t relevant to you.
There are several ways to share your information with us. It all depends on what suits you. It may include:
- Enter your data on our website or through the blog, newsletter, contact request or landing pages content;
- Participate in a contest through a social network channel like Facebook or Twitter;
- Participate in a campaign through a social network channel like Facebook or Twitter;
- Participate in a campaign through search engines like Google Adwords or Bing Ads.
Personal data we receive from other sources
We also receive personal data about subscribers from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
Your reference persons may disclose personal information about you;
Our customers may share with us personal information about you;
If you “like” our Facebook page or “follow us” on Twitter, Linkedin, Pinterest or Instagram we will receive personal information from these sites; and
If you are referenced to us through a supplier, he may share personal information about you with us.
Personal data we collect automatically
When you access our website or read or click on an email from us, when appropriate and in accordance with local laws and requirements, we may also collect your data automatically or through you.
CUSTOMER DATA: We collect Customer’s personal data in three ways:
- Personal data we receive directly from you;
- Personal data we receive from other sources;
- Personal data we collect automatically.
Personal data we receive directly from you
We will receive data directly from you in two ways:
- If you contact us proactively, usually by phone or e-mail;
- If we contact you by phone or e-mail or, generally speaking, through the business activities of our consultants.
Personal data we receive from other sources
Where appropriate and in accordance with local laws and requirements, we may seek information about you or your colleagues from other sources, usually through due diligence or other market information, including:
- A third party market study and by analyzing online and offline media (we may do it ourselves or hire other companies to do it for us);
- From lists of participants at relevant events;
- From other limited sources and third parties (e.g., our Subscribers, if they provide us with your data to act as their reference).
Personal data we collect through our website
When you access our website or read or click on an email from us, when appropriate and in accordance with local laws and requirements, we may also collect your data automatically or through you.
WEBSITE USERS: When you visit our website there are certain information we may automatically collect, whether or not you choose to use our services. This includes your IP address, the date, time and frequency you access our site and how you browse its content. We will also collect your data when you contact us through the site using, for example, the chat feature.
We collect your data automatically via cookies, in line with your browser’s cookie settings. If you are also a Link&Grow Subscriber or Customer, we may use data from your use of our websites to improve other aspects of our communications with you or the services we provide to you.
How do we use your personal data?
After obtaining the data about you, we use it in various ways.
SUBSCRIBER DATA: We usually use Subscriber data as follows:
Marketing activities
From time to time, we may send you information that we consider to be of interest to you. In particular, we may need to use your data for the purposes listed below, where appropriate and in accordance with local laws and requirements. Please note that this is a non-exhaustive list. To:
- Send you rich materials, digital marketing related content of your interest, report data, promotions, offers, events;
- Present promotional excerpts of your data on our websites as a successful story (only when we obtained your express consent to do so);
- Provide you with information about certain discounts and offers you are entitled to due to your relationship with Link&Grow.
We need your consent for some aspects of these activities that are not covered by our legitimate interests (in particular, the collection of data through cookies and the provision of direct marketing to you through digital channels) and, depending on the situation, we will ask you through an inclusion option or soft-opt-in.
Soft-opt-in consent is a specific type of consent that applies when you have previously engaged with us (for example, by sending a resume or other record available on a rich material or a free diagnosis to your company’s digital marketing). Under the soft-opt-in consent, we will consider that your consent has been given unless or until you opt-out.
If you do not agree with our marketing approach, you have the right to withdraw your consent at any time and you can learn more about how to do it below. No one is perfect, even if we try to be. We want you to know that even if you opt-out of our marketing communications through our preference centre, it is possible that your data can be retrieved through public sources in a non-market campaign. We’ll try to make sure that doesn’t happen, but if it does, we apologize in advance. We will only do so under the circumstances that you have again excluded yourself.
All of our marketing is based on what we think will best serve our Customers and Subscribers, but we are aware that we will not always get it right. We may use your data to serve you ads from Link&Grow and other content on other sites, such as Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (see our Cookie Policy). Even if you have turned off advertising cookies, you may still see a Link&Grow ad, but in this case, it was not directed to you personally, but to an anonymous audience.
Help us to declare, exercise or defend a right
In rare circumstances, we may use your personal data to help us declare, exercise or defend a right.
Profiling
While at present all of our digital marketing activities involve human decision-making during the process, we may in the future use fully automated technologies, such as specialized systems or machine learning to carry out an email sending process from start to finish, when appropriate and in accordance with local laws and requirements.
When appropriate, we will seek your consent to carry out some or all of these activities.
You have the right to withdraw that consent at any time.
CUSTOMER DATA: We use Customer information for:
- Marketing Activities;
- Help us to declare, exercise or defend a right
Here are a few more details on each of them:
Marketing activities
Subject to any local laws and requirements, we will not normally seek your consent when we send marketing materials such as our Global Competence Index to a corporate postal or email address.
If you do not agree with this, you have the right to opt-out of receiving marketing materials from us.
Please note that in certain jurisdictions in which we operate, we comply with additional local laws regarding marketing activities.
Help us to declare, exercise or defend a right
- In rare circumstances, we may use your personal data to assist us in declaring, exercising or defending a right.
SUPPLIER DATA: We understand that you are probably busy and do not want us to contact you about all sorts of things. To find the right balance, we will only use your information:
- To store (and update when necessary) your information in our database, so that we can contact you regarding our contracts;
- To offer you services or to obtain support and services from you;
- To fulfil certain legal obligations;
- To help us target appropriate marketing campaigns;
- In rare circumstances, to help us to declare, exercise or defend a right.
We may use your personal data for these purposes if we deem it necessary to do so for our legitimate interests.
We will not, as a rule, seek your consent when sending marketing messages to a corporate postal or email address.
If you do not agree, under certain circumstances you have the right to object.
Please note that in certain jurisdictions in which we operate, we comply with additional requirements of local law.
WEBSITE USERS: We use your data to help us improve the experience of using our site by analyzing, for example, your recent content search criteria, to help us present the best topics and subjects that we think are of interest to you.
Who do we share your personal data with?
Where appropriate and in accordance with local laws and requirements, we may share your personal data in various ways and for various reasons with the following categories of persons:
- Tax, audit or other authorities where we consider in good faith that legislation or other regulation requires us to share this data (for example, due to a request from a tax authority or in relation to an early dispute);
- Third party service providers that perform functions on our behalf (including external consultants, business partners and professional advisors such as lawyers, auditors and accountants, technical support functions and computer consultants who perform testing and development work on our company’s technology systems);
- Third party providers of IT services and storage of outsourced documents, where we have an appropriate processing contract (or similar protections);
- Marketing technology platforms and suppliers;
- In the event that Link&Grow is merged with or acquired by another company or company in the future (or if you are in significant talks for such a possibility), we may share your personal data with (potential) new owners of the company or company.
How do we safeguard your personal data?
We are committed to taking all reasonable and appropriate measures to protect the personal information we hold from misuse, loss or unauthorized access. We do this by creating a set of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect misuse, loss or unauthorized access to your personal information, please let us know immediately.
For how long do we keep your personal data?
We will delete your personal data from our systems if we haven´t had a relevant contact with you (or, when appropriate, the company you are working with or for) within a period of two years (or for a longer period if we in good faith consider that the relevant legislation or regulators oblige us to retain your data). After this period, it is likely that your data will no longer be relevant for the purposes for which they were collected.
For Subscribers whose services are provided through a third-party company or other entity, “relevant contact” with you means relevant contact with the company or entity providing its services. In cases where we are notified that such a company or entity no longer has such a relationship with you, we will not store your data for more than two years from that time or, if later, for a period of two years from the time we subsequently have relevant contact with you directly.
When we indicate “relevant contact”, we mean, for example, communication between us (verbal or written) or when you actively engage with our online services. If you are a Subscriber, we will consider sending your updated resume to our website or participating in one of our online training courses a relevant contact. We will also consider a relevant contact if you communicate with us about potential functions, either by verbal or written communication or if you click on any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as a relevant contact – this will only occur in cases where you click or reply directly.
How can you access, change or remove the personal data you have provided to us?
One of the main objectives of the GDPR is to protect and clarify the rights of EU citizens and people in the EU with regard to data privacy. This means that you have various rights to your data, even when they have been provided to us by you. They are described in more detail below.
To get to know these rights, contact us. We will attempt to deal with your request without undue delay and in any case within one month (subject to any extensions permitted by law). Please note that we may keep a record of your communications to help us resolve any issues you raise.
Right to object: this right allows you to object to our processing of your personal data when we do so for one of the following reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or to exercise official authority; (iii) to send direct marketing material; and (iv) scientific, historical, research or statistical purposes.
The categories “legitimate interests” and “direct marketing” above are the most likely to apply to our Subscribers, Customers and Suppliers. If your objection relates to our processing of your personal data as we consider it necessary for our legitimate interests, we shall act in accordance with your objection by terminating the activity in question unless:
- We can demonstrate that we have mandatory legitimate grounds for processing that override your interests;
- We are processing your data for the declaration, exercise or defense of a right.
If your objection relates to direct marketing, we must act upon your objection by terminating this activity.
Right to withdraw consent: If we have obtained your consent to process your personal data for certain activities (for example, for our marketing agreements or automatic profiling) you may withdraw this consent at any time and we will cease to perform the specific activity you previously consented to, unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
Access Requests by the Data Subject: You can ask us at any time to confirm the information we have about you and you can ask us to change, update or delete that information. We may ask you to verify your identity and more information about your request. If we grant you access to the information we hold about you, we will not charge you for such access unless your request is “manifestly unfounded or excessive”. If you ask us for additional copies of this information, we may charge you a reasonable administrative cost when legally permitted. In cases where we are legally permitted, we may decline your request. If we refuse your request, you will always be informed of the reasons for doing so.
Please note that in certain jurisdictions in which we operate, we comply with requirements of additional local legislation regarding the request for access by data subjects and may refuse your request in accordance with that legislation.
Right to erasure: In certain circumstances, you have the right to ask us to delete your personal data. The information shall normally meet one of the following criteria:
- The data are no longer required for the purpose for which we originally collected and/or processed them;
- After being previously given, consent to proceed with the processing of his data has been withdrew and there is no other valid reason for us to continue processing them;
- The data were unlawfully processed (i.e., in a way that does not comply with the GDPR);
- The data must be erased in order to comply with our legal obligations as the controller;
- If we process the data because we believe it is necessary to do so for our legitimate interests, it is opposed to the processing and we are not able to demonstrate compelling legitimate reasons for its continued processing.
Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements regarding the right of data subjects to erasure and we may refuse your request in accordance with that law.
We may refuse to comply with your request only for one of the following reasons:
- To exercise the right to freedom of expression and information;
- To comply with legal obligations or to perform a task of public interest or the exercise of an official authority;
- For public health reasons in the interest of the public;
- For archiving, research or statistical purposes;
- For the exercise or defence of a right.
When fulfilling a valid request for data deletion, we will take all reasonable practical steps to erase the relevant data.
Right to restrict processing: In certain circumstances, you have the right to restrict our processing of your personal data. This means that we may only continue to store your data and may no longer carry out processing activities with it until: (i) one of the circumstances listed below is resolved; (ii) your consent; or (iii) additional treatment is necessary for the declaration, exercise or defence of a right, the protection of the rights of another person or reasons relating to the important public interest of the EU or a Member State.
The circumstances in which you have the right to request that the restriction of the processing of your personal data is:
- If you dispute the accuracy of the personal data we process about you. In this case, our processing of your personal data will be restricted by the period during which the accuracy of the data is verified;
- If you object to the processing of your personal data for our legitimate interests. In this situation, you may request that the data be restricted while we verify our basis for the processing of your personal data;
- If our processing of your data is unlawful, but you prefer to restrict our processing of your data rather than its deletion;
- If we no longer need to process your personal data, but need the data to declare, exercise or defend a right.
If we have shared your personal data with third parties, they will be notified of the restricted processing unless this is impossible or involves a disproportionate effort. We will, of course, notify you before lifting any restriction on the processing of your personal data.
Right to rectification: You also have the right to ask us to rectify any inaccurate or incomplete personal data that we hold about you. If we have shared such personal data with third parties, they will be notified of the rectification, unless this is impossible or involves a disproportionate effort. Where appropriate, we will also disclose to which third parties we have disclosed inaccurate or incomplete personal data. Where we consider it reasonable not to comply with your request, we will explain the reasons for the decision.
Right to data portability: If you wish so, you have the right to transfer your personal data between controllers. Indeed, this means that it can transfer the data to another online platform. To allow you to do so, we will provide you with your data in a password-protected, commonly used, auto-read format, so you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right to data portability applies to: (i) personal data that we automatically process (i.e., without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or to perform a contract.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
If you wish to exercise any of these rights or withdraw your consent to the processing of your personal data (if consent is our legal basis for processing your personal data). Please note that we may keep a record of your communications to help us resolve any issues you raise.
You can at any time ask to cancel your employment alert subscription.
It is important that the personal information we hold about you is accurate and current. Please let us know if there are any changes to your personal information during the period we retain your data.
Who is responsible for the processing of your personal data on the Link&grow website?
You can find out which Link&Grow entity is responsible for the processing of your personal data and where it is located.
How do we store and transfer your data internationally?
Do you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and accomplish the purposes described in this Privacy Policy, your data may be transferred:
- Between third parties (such as consultants or other suppliers of Link&Grow activity);
- To foreign customers or to customers in your country who may transfer your data internationally;
- To a cloud storage provider;
- To other third parties as referred to here.
We want to ensure that your data is stored and transferred in a secure manner. We will therefore only transfer data outside the European Economic Area or EEA (that is, the Member States of the European Union, together with Norway, Iceland and Liechtenstein) if it is in accordance with data protection law and it protects adequately your data, for example:
- By a data transfer agreement, which incorporates the contractual clauses-current type adopted by the European Commission for the transfer of personal data by data controllers in the EEA to controllers and processors in jurisdictions lacking adequate data protection laws;
- By joining the EU-US Privacy Shield framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement relating to other jurisdictions;
- By transferring your data to a country where the European Commission has noted an adequate level of protection with respect to that country’s data protection levels through its legislation;
- When necessary for the conclusion or performance of a contract between us and a third party and the transfer is in your interest for the purposes of that contract (for example, if we need to transfer data outside the EEA to comply with our obligations under that contract if you are our customer);
- If you have consented to the transfer of data.
Para assegurar que os seus dados pessoais recebem um nível adequado de proteção, aplicámos procedimentos apropriados com os terceiros com quem partilhamos os seus dados pessoais para garantir que a sua informação pessoal é tratada por parte desses terceiros de uma forma consistente e que respeita a lei da proteção de dados
To ensure that your personal data receive an adequate level of protection, we have applied appropriate procedures with the third party with whom we share your personal data to ensure that your personal information is handled by those third parties in a consistent manner and that it respects data protection law.
Cookies Policy
What is a cookie?
A “cookie” is an information file that is stored on your computer’s hard drive and records your browsing on a website so that when you visit that site again, it can present customized options based on the information stored about your last visit. We may also use cookies to analyse traffic and for advertising and marketing purposes.
They are used by almost all websites and do not harm your system. If you want to check or change the type of cookies you accept, you can usually do so in your browser settings. We also provide information on this aspect on our marketing preferences page on the Link&grow website.
How do we use cookies?
We use cookies to do two things:
- To track your use of our website. This allows us to understand how you use the site and track any patterns that arise individually or from larger groups, which will help us develop and improve our site and services in response to what our visitors want and need;
- To help us advertise jobs that we think are of your interest. Hopefully, that means you´ll spend less time scrolling through endless pages and that we can get you the job you want faster.
The cookies are as follows:
- Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but do not collect any information from your computer;
- Persistent cookies: A persistent cookie is stored as a file on your computer and is maintained when you close your web browser. The cookie can be read by the website that created it when you visit this site again. We use persistent cookies from Google Analytics and for personalization (see below).
Cookies can be categorized as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the site effectively, such as when you apply for a job and therefore cannot be disabled. Without these cookies, the services provided to you on the website cannot be provided. These cookies do not collect information about you that can be used for marketing or remembering where you have been on the Internet.
- Performance cookies: These cookies allow us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources, and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember the choices it makes (such as your username, language or region you are in) and provide enhanced functionality. For example, we may provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you made to the text size, font and other parts of the web pages you can customize. They may also be used to provide services you have requested, such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
- Personalization Cookies: These cookies help us advertise data about potential employment opportunities that we think are of interest to you. These cookies are persistent (while you are registered with us) and mean that when you log in or return to the site you may see job advertisements similar to the jobs you have previously navigated.
The table in Annex 2 lists the cookies we use in your jurisdiction, why we use them and what kind of cookies they are.
Legitimate interests
Our legal bases for the processing of your data
Legitimate interests
Article 6.1 f) of the GDPR is the relevant article in this case – it states that we can process your data if it is “necessary for the purpose of the legitimate interests pursued [by us] or by third parties, except where the interests or fundamental rights and freedoms of the data subject [you] which require the protection of personal data prevail.”
We do not consider any of the following activities to be detrimental in any way to people – in fact, they help us to offer you a more adapted and efficient service and therefore everyone wins! However, you effectively have the right to object to our processing of your personal data on this basis.
Please note that in certain jurisdictions in which we operate, in some cases a different legal basis may apply to the processing of data.
SUBSCRIBER DATA: We consider it reasonable to expect that if you are looking for digital marketing content or services on a related page or website, you do not mind us collecting and otherwise using your data to offer or provide you with our digital marketing services. We must do this so that we can function as a profitable company and to help you and other subscribers find the digital marketing content and services that best suit your needs.
We want to offer you tailored digital marketing content and relevant articles to read in order to help you learn more about digital marketing or choose the best service provider. We therefore consider it reasonable to process your data to ensure that we send you the most appropriate content.
We also consider it useful in your search for knowledge to participate in our specialized online training or in some of our most interactive services, if you have time. They are part of our service offering as a company and help differentiate us in a competitive market and therefore using your data for this reason is part of our legitimate interests.
We need to ensure that our business goes smoothly so that we can continue to provide services to subscribers. Therefore, we also need to use your data for our internal administrative activities, such as wage handling and billing, when relevant.
We have our own obligations under the law, the fulfilment of which is in our legitimate interest! If we consider in good faith that it is necessary, we may share your data for the purpose of detecting crime, collecting taxes or bringing forward litigation.
CUSTOMER DATA: In order to ensure that we provide you with the best possible service, we store your personal data and/or personal data of individual contacts in our company, as well as keep records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to answer a customer satisfaction survey. We think it is reasonable – we believe that these uses of your data are necessary for our legitimate interests as a company that provides you with various marketing services.
SUPPLIER DATA: We use and store personal data of individuals in your company to facilitate the receipt of services from you as one of our Suppliers. We also have your financial information so that we can pay for your services. We consider that all these activities are necessary in the context of our legitimate interests as a user of your services.
Consent
In certain circumstances, we are obliged to obtain your consent for the processing of your personal data in relation to certain activities. Depending on what exactly we are doing with your information, this consent will be an inclusion consent or a soft opt-in consent.
Article 4(11) of the GDPR states that consent is “a free, specific, informed and explicit expression of the will by which the data subject accepts, by means of an unequivocal declaration or positive act, that the personal data relating to him or her are processed”. In plain language, this means that:
- You must give us your consent freely, without any pressure from us;
- You must know what you are consenting to – therefore we will make sure that we provide you with sufficient information;
- You shall have control over which processing activities gives consent or not. We provide these more specific controls in our privacy preference centre;
- You must have an unambiguous positive act in the transmission of your consent – it is likely that we provide a grid to tick so that this requirement is made clearly and unambiguously.
We will keep records of the consents you give in this way:
- As we have already mentioned, in some cases it could be based on soft opt-in consent. We are permitted to market products or services that are related to the recruitment services we provide, provided that we do not actively opt-out of such communications.
- Please note that in certain jurisdictions in which we operate, we comply with additional local consent requirements to receive marketing materials.
- As stated above, you have the right to withdraw your consent to such activities. You can do it at any time and information on how to do it can be found here.
Declare, exercise or defend rights
We may sometimes need to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in relation to the exercise or defence of rights. Article 9, paragraph 2, point f of the GDPR allows this processing when it is “necessary for the declaration, exercise or defence of a right in a judicial proceeding or when the courts act in the exercise of their judicial function”.
This may happen, for example, where we need to obtain legal advice in relation to legal proceedings or where we are required by law to retain or disclose certain information as part of a legal process.
Attachment 1 – How to contact us
The Link&grow entity responsible for the processing of the personal data of the Users of the Website, Subscribers, Customers, Suppliers and Person of reference for the Subscribers will be the Link&Grow´s DPO.
How can you contact us:
- To request to access, change or remove the personal data you have provided us with;
- If you suspect misuse, loss or unauthorized access to your personal information;
- To withdraw your consent to the processing of your personal data (if consent is the legal basis under which we process your personal data);
- For any comments or suggestions regarding this Privacy Policy.
You can write to the following address:
Rua da Boavista 291 3º Andar 4050-102 Porto – Portugal
Telephone: +351937366484
Alternatively, you can email us to: dpo@linkandgrow.pt
How can you contact us to update your marketing preferences?
You can send us an email to: dpo@linkandgrow.pt or by clicking on the unsubscribe link in any marketing email we send you.
Attachment 2 – Cookies list
- AddThis
- DoubleClick
- Google Analytics
- GA Audience
- Google Tag Manager
- Facebook Connect
- Facebook Custom Audience
- Hotjar
- Facebook Pixel
- Tawk.to
- RD Station
Glossary
- Subscribers – includes all contacts subscribing to conversion forms present on the website or Landing pages developed by Link&Grow such as: blog subscription, newsletters, rich materials, diagnostics, etc.
- Customers – while the designation is sufficiently enlightening, this category covers customers and others to whom Link&Grow provides services in the course of its business.
- Erasing – although we will make every effort to permanently erase your personal data as soon as the retention period ends or when we receive a valid request from you to do so, some of your data may continue to exist in our systems such as, for example, if they are waiting to be replaced. In our case, this data has been put out of use, which means that although it still exists in our archive system, it cannot be immediately accessed by our operating systems, processes or Personnel.
- General Data Protection Regulation (GDPR) – a European Union legal instrument aimed at harmonising European data protection laws. It has an effective date of application on May 25, 2018 and any references to it must be interpreted accordingly to include any legislation implementing it.
- Personnel – includes employees and interns directly involved in the Link&grow activity (or who accepted an offer to get involved), as well as certain workers involved in the Link&Grow service activity (although they are not considered collaborators). For these purposes, we also include Link&Grow employees involved in work at Customers’ premises. Independent contractors and consultants performing services for Link&grow are covered by the definition of a “Provider” for the purposes of this Privacy Policy.
- Suppliers – refers to partnerships and companies (including individual traders) and atypical workers as independent contractors and self-employed, who provide services to Link&Grow. In some circumstances, Link&Grow will outsource the services it provides to Customers to third-party providers that perform the services on behalf of Link&Grow. In this context, suppliers who are individual contractors, self-employed workers or contributors to suppliers will be treated as suppliers for data protection purposes. Please note that in this context, Link&Grow requires Suppliers to communicate the relevant parts of this Privacy Policy (including sections addressed to Subscribers) to their employees.
- Users of the Site – anyone accessing any of the Link&Grow websites.