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Privacy Policy

We present the privacy policy of our website, accessible via the Internet at www.sterlingprimeconsulting.pt (hereinafter referred to as the "website").

We respect any concerns you may have regarding the confidentiality of information and personal data processed during your browsing of our website. This policy allows you to obtain additional information about the nature and use we make of the personal data you provide to us on the website, about the origin and use of browsing information processed during your visit to our website, and also about your rights.

By using our website, you are accepting the terms and conditions of this document.

We may amend this policy at any time, and such changes will take effect immediately.

1. Identity and contact details of the data controller

This website is operated by STERLING PRIME CONSULTING, UNIPESSOAL, LDA., with registered office at Edificio SartUp Alentejo, Av. 25 de Abril, S/N, 7080-134, Vendas Novas, under its unique registration and corporate tax identification number 518872661, in its capacity as data controller within the meaning of applicable personal data legislation, hereinafter referred to as STERLING.

2. Basis for the legitimacy of data processing

2.1 Through the website we may collect personal data (hereinafter your Data), transmitted via the contact form.

2.2 According to the GDPR, "personal data" means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifiers and/or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2.3 In addition to the data transmitted in the contact form, the Data concerning you collected and processed by our website also derives, depending on the services used, from your choices and the configuration of your device (especially with regard to cookies and other connection logs): your full name, email address, postal address and telephone number.

3. Purposes

3.1 Basis for the legitimacy of data processing

Therefore, your Data is collected for the purpose of:

  • We can answer your questions using the contact form;

  • To send you information about our offers, news and events (newsletters);

  • To evaluate geographic, demographic, and statistical data.

The personal data of STERLING's Clients and potential Clients may be collected and processed:

  1. When such collection and processing is necessary for the performance/fulfillment of a contract to which the data subject is a party or for the performance of pre-contractual steps requested by the data subject;

  2. When the collection and processing is necessary for compliance with a legal obligation to which STERLING, as the data controller, and/or the data subject, is/are subject;

  3. When the data subject has given their consent to the processing of their data for one or more specific purposes.

Your data will be used for commercial purposes, specifically marketing, in order to, among other things, communicate relevant informational campaigns and promotional activities carried out by STERLING.

STERLING may collect and process personal data when the Client or potential Client requests it as part of pre-contractual due diligence.

STERLING will collect the personal data of its Clients and potential Clients through the following methods: telephone contact; email.

The use of your Data can be retracted at any time by simply sending an email to (specify email).

Your data can also be deleted or corrected at any time; to do so, simply send a request to the email address (specify email).

4. Data retention period

The data concerning you, collected and processed through the contact form, will be kept for the duration of the processing of your request and for marketing and advertising purposes.

Your data will be kept for a period of 1 year from the date of collection.

At the end of this period, we may contact you again to confirm if you wish to continue receiving our communications about offers, news and events.

Your data will be destroyed within the timeframe established by law, starting from your request to unsubscribe.

Finally, connection logs collected with your consent, in the context of cookies and other connection logs set up on our website will be kept for a period not exceeding thirteen (13) months.

5. Data recipients

5.1 The personal information provided is intended exclusively for STERLING.

5.2 Exceptionally, your personal data may only be disclosed to third parties within the scope of legal requirements or in the exercise and fulfillment of court orders to that effect, including in the context of criminal prosecution, or otherwise for the purpose of preventing fraud against us (anti-fraud services).

6. Data security and confidentiality

We are committed to implementing all necessary precautions to preserve the confidentiality and security of the personal data processed and to prevent it from being distorted, damaged, destroyed, or accessed by unauthorized third parties.

At the time this version of its Privacy Policy was drafted, the aforementioned measures implemented consist of: (identify those that are actually applied in the Company - Examples):

- For password protection;

- In the use of digital certificates;

- In cases of physical access restrictions to locations where personal data storage servers are located;

- In the implementation of firewalls;

- In secure communication mechanisms, via the “https.” protocol.

Technical and organizational security measures were developed, especially with regard to information systems.

However, we do not control all risks associated with the use of the Internet and we draw visitors' attention to the existence of possible risks associated with its use and operation.

In the event that, for any reason, a security breach occurs that accidentally or unlawfully results in the destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, STERLING undertakes, in accordance with applicable law, to report the incident to the competent authorities without undue delay and, whenever possible, within 72 hours of becoming aware of it.

7. Your rights

According to current legislation, the User has the right to access and rectify their Data, as well as the right to request its deletion, object to its processing, and obtain its limitation or portability to the extent applicable.

You may also object to your Data being used for the purpose of creating your customer profile; in this case, you will not be able to benefit from personalized offers or services. These requests must be made by email sent to info@sterlingprimeconsulting.pt. Furthermore, you may, at any time, request to stop receiving our communications about offers, news and events, using the hypertext link provided for this purpose at the end of each email we send you.

Right to lodge a complaint

For any questions regarding the collection and processing of your Data by STERLING, you can contact us by email and customer support at info@sterlingprimeconsulting.pt .

The data subject may always submit any complaints they deem necessary to the competent authority for this purpose (presumably, in Portugal, this Authority will be the CNPD – National Data Protection Commission – www.cnpd.pt).

8. Cookies or connection testimonials

8.1 What are ‘cookies’?

A ‘cookie’ is a text file that may be stored in a dedicated space on the hard drive of your device (i.e. computer, tablet, smartphone, etc.) via the web browser you use to view our Website, in accordance with your browser settings. This cookie file enables its issuer to identify the device on which it is stored for the duration of the cookie’s validity or registration period.

When you visit our website, information relating to your device’s browsing activity on our website may be stored in cookie files installed on your device.

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8.2 Cookies we set on our website

From the moment you access our Website, we may, subject to your preferences, set cookies on your Device, which enable us to recognise your Device’s web browser for the duration of the relevant cookie’s validity period.

 

The cookies we set enable us to

  • compile statistics and measure traffic volumes and usage of the various elements that make up our Website (pages and content visited, navigation paths), which enables us to improve the relevance and user-friendliness of our services;

  • count the total number of adverts published in our advertising spaces, identify these adverts and their respective number of impressions, the number of users who clicked on each advert and, where applicable, the subsequent actions taken by those users on the pages to which those adverts directed them, in order to calculate the amounts due to the parties in the advertising distribution chain (advertising agency, advertising network, website/media outlet) and compile statistics;

  • to adapt the presentation of our Website and our advertising spaces to the display preferences of your device (language used, screen resolution, operating system, etc.) when you visit our Website, in accordance with the viewing or playback hardware and software included on your device;

  • to tailor the advertising content on our Website and our offers in accordance with your browser, the purchases you may make and/or based on the location data (latitude and longitude) provided by your device (with your prior consent);

  • insofar as you have provided us with personal data, including your electronic contact details, at the time of your registration or when accessing any of our services, to link this data with browsing information in order to send you, for example, electronic surveys or to display on your Device, within the advertising spaces we provide, personalised adverts specifically targeted at you and which may be of interest to you;

  • tailor the advertising content displayed on your device via our advertising spaces, based on your device’s browsing activity on our Website or location data (latitude and longitude) transmitted by your device (with your prior consent);

  • to store information contained in a form you have completed on our Website (registration) or relating to products, services or information you have selected on our Website (subscribed service, etc.);

  • to implement security measures, for example, when you are asked to log in again to access content or a service after a certain period of time has elapsed.

 

8.3 Your cookie options

There are several options available for managing cookies. Any settings you choose may affect your internet browsing experience and your access to services that require the use of cookies. You may choose at any time to set and change your cookie preferences using the methods described below.

 

(a) Accepting cookies

The storage of cookies on a device is subject to the choice of the device user, who may indicate and change their preference at any time, free of charge, via the options provided by their web browser. If you have accepted the storage of cookies on your device via your web browser, the cookies included in the pages and content you have viewed may be temporarily stored in a dedicated area of your device, and can only be read by the issuer.

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(b) Rejecting cookies

If you reject the storage of cookies on your device, or if you delete those already stored, you will no longer be able to benefit from a number of features which are, however, necessary to navigate certain areas of our website. This would be the case if you attempt to access our content or services that require you to be identified. It is also the case when we – or our service providers – are unable, for technical compatibility reasons, to recognise the type of web browser used by your device, your language and display settings, or the country from which your device is connected to the internet.

 

In such cases, we accept no liability for any consequences arising from the malfunctioning of our services resulting from Netgocio’s inability to record or read the cookies necessary for their operation, which have been rejected or deleted by you.

 

(c) How can you manage your settings, depending on the web browser you use?

The settings for managing cookies and your preferences vary from one web browser to another. You can find instructions in your web browser’s help menu, which will explain how to change your cookie settings.

 

8.3.1 “Flash”© cookies from “Adobe Flash Player”™

“Adobe Flash Player”™ is a computer application that enables the rapid development of dynamic content using the “Flash” programming language. The Flash application (and similar applications) stores settings, preferences and usage data for this content using technology similar to cookies. However, “Adobe Flash Player”™ manages this information and your settings via an interface that is different from that provided by your web browser.

If your device is capable of viewing content developed using the Flash language, we encourage you to access your Flash cookie management tools directly via the website http://www.adobe.com/pt/.

9. Use of data

We undertake not to transfer or sell personal data to any third parties other than affiliates or partners, unless we have previously informed you in any communication, agreement or information available on the Site, or you have already given us your express consent, or the law so requires.

If we are legally or judicially required to disclose personal data concerning you, we undertake, to the extent possible, to notify you (unless STERLING reasonably considers that it is not authorized to do so in view of any legal or judicial obligations that may apply to it).

Given the state of technology, especially that generally applied to telecommunications networks, we cannot guarantee the confidentiality, integrity, or authentication of email messages sent by you to or received by STERLING.

10. Applicable law

In the event of any controversy or claim of any nature related to this website, Portuguese law shall apply, regardless of any conflict of applicable laws. All legal actions or proceedings arising out of or related to this Privacy, Security and Data Protection Policy, its validity, application, compliance or non-compliance, or the subject matter of this Privacy Policy, shall be subject to the jurisdiction of the Portuguese courts, and the user consents to and submits to the jurisdiction of these courts in the cases indicated.

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