Privacy - Lazer Telecom

LAZER PRIVACY POLICY

Valid from: ___ December 2018
Last Updated: ___ December 2018

ABOUT US
LAZER TELECOMUNICAÇÕES, SA (hereinafter referred to as “LAZER”) is a commercial company, registered at the Loulé Commercial Registry Office under No. 501 949 372, which operates in the telecommunications market, with headquarters at Rua Cristóvão Pires Norte, Edifício North, R / C, Shop D, 8135-117 in Almancil (hereinafter referred to as “we”, “our”, “ours” or, just, “LAZER”).

LAZER provides electronic communication services and specific services (“Services”), which can be contracted in person and / or electronically on its website https://lazertelecom.com/

SCOPE OF THIS PRIVACY POLICY
LAZER we are strongly committed to promote transparency and we take very seriously the protection of your privacy and your personal data. This Privacy Policy explains what data we collect, what purposes we may use, how we treat them, when we may disclose them, how long we will keep them, and how you can manage your personal data and exercise your rights.
In order to guarantee the protection of your personal data, LAZER respects the best practices to ensure security and protection of personal data, having taken the necessary technical and organizational measures to comply with the provisions of the General Data Protection Regulation (hereinafter “GDPR”) and to ensure that the processing of personal data is lawful, transparent and restricted to the purposed to which they have been collected.
The rules foreseen in this Privacy Policy complement the provisions regarding the protection and processing of personal data, provided for in the agreements that our Customers made with LAZER, general conditions and other contractual documentation associated with the Services.
The term “Personal Data” as used in this Privacy Policy means that any information related to an identified or identifiable singular person (“personal data”, “data” or “information”), in accordance with the requirements of the General Data Protection Regulation – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR").
For the purposes established on nr 7 of the 4 th Article of the GDPR, LAZER is the “controller” of the personal data that you share with us. The present Privacy Policy does not apply to personal data you may provide to third parties. If you decide to visit or use services or products that are made available by third parties, please be aware that this Policy will not apply. We are not responsible for the privacy rules and practices followed by such third parties.
The present contains the following sections:
Information collected by Lazer;

  • How we use the personal information you share with us;
  • Legal source applied for processing your personal data;
  • To whom we may disclose your data;
  • How Lazer protects your personal data;
  • Transfer of your personal data;
  • How long we will retain your personal information;
  • Options available to you regarding the use of your personal data;
  • Services provided by third parties;
  • Changes to the present Privacy Policy;
  • LAZER contact information.

INFORMATION COLLECTED BY LAZER
LAZER will collect different types of information from you when you use or interact with our website or with our Services.

A. When and How do we collect your personal information?
LAZER collects your personal data, in particular through telephone, in writing, through its website, guaranteeing, as and when necessary, the prior consent of the holder of the personal data.
Some personal data can be necessary to ensure the correct execution of some of our website’s functions and may affect your browsing experience, however some personal information is indispensable for contracting LAZER Services and in case of lack or insufficiency, LAZER may be unable to provide its Services.
If the holder of the personal data is not a Customer of the LAZER website, their personal data will only be processed when they are made available, in particular, by the subscription of the newsletters by LAZER, in which case the rules of this Privacy Policy will apply.
The personal data collected may be processed in a computerized and automated or non-automated manner, ensuring that LAZER complies with the applicable personal data protection legislation, ensuring the security of the respective storage, as well as the use thereof strictly for the purposes for which have been collected or given the consent of the data subject.
LAZER may collect your personal information on the below mentioned situations:

  • When you manage your Account;
  • When using our website and/or when you use our Services or related functionalities;
  • When you subscribe to receive our newsletter or other information by email, text or instant messages;
  • When providing information for your user profile;
  • When you request customer service, support request or any other type of assistance;
  • When you contact us by e-mail or through another channel;

LAZER processes the personal data necessary to provide the Services and / or supply the products, and the types of information we collect directly from you which include: name, ID card and VAT card number, e-mail address, telephone number, address, information required for invoicing, data relating to direct debit authorization, and contact information.
Without prejudice to the fulfilment of the legal procedures related to preservation and transmission of data for the purposes of investigation, detection, prosecution of serious crimes, as well as other treatments to which it is legally bound, traffic data, geographical location, profile and/or consumption of the Customer will be treated by LAZER, to the extent that it is necessary for the respective provided Services. Information regarding location may also be recorded and transmitted to organizations legally competent to receive emergency calls for the purpose of responding to incoming calls.

B. Information that is automatically collected
When accessing to our website, some data will be automatically collected. Please find below the data we will collect:

  • Information regarding your computer, browser, mobile device or any other device that you may use to access to our website. This information may contain your IP address (Internet Protocol), geolocation, unique device identifiers, browser, language, operating system (OS) and other information related to transactions;
  • Additional “traffic data” and log files such as access time and date, software failure reports, session ID number, session duration, pages visited and exited.
    Other information related to your use of the website.

We treat this data as personal data if combined or associated with any of the above-mentioned identifiable information.

C. Information from third-parties
We may receive information about you from third parties or pages from other websites (ie: Facebook, Twitter, etc.), in agreement with their policies and terms. However, LAZER will not disclose any personal information to any third-party advertisers or any private entity without your express consent (whenever consent is the proper fundament of legitimacy of processing your personal data).

D. Cookies
LAZER uses cookies and other similar technologies (hereinafter, “Cookies”) to recognize your preferences and to make your experience of our website as optimized as possible. Cookies are small files that are stored on your computer or device. These can be used to determine if equipment has previously communicated with our pages. Only the Cookie installed on your device is identified. Personal data may only be stored in Cookies if you give your consent to the effect or if there is another legal basis that allows it.
When you visit our site, we explicitly request your consent to use Cookies. Most browsers automatically accept Cookies. You can avoid using Cookies on your device if you enable the “Do not accept cookies” option in your browser settings. You can also erase all Cookies installed on your device at any time. You should consult your browser’s instructions or the manufacturer of your device for this. Please note, however, that if you do not accept the use of Cookies, there may be restrictions on browsing our website.
We divide Cookies into the following categories:

  • Essential Cookies (Type 1): These cookies are essential for the correct functioning of web pages;
  • Feature Cookies (Type 2): These cookies allow you to increase the comfort and performance of web pages and perform various functions. For example, the choice of the language used may be stored in feature cookies;
  • Performance Cookies (Type 3): These Cookies collect information about using websites. These cookies, for example, help us identify which areas of our website are most popular. This allows us to optimize the contents of our web page to your needs and, by this way, to improve the service that we offer you. The information collected through these Cookies does not include personal data.

HOW DO WE USE YOUR PERSONAL DATA
We use the personal information that collect to manage the contractual relationship, to provide you with information or provide Services or other services you request, to inform you of other matters, events, promotions, products or services that we believe that may be of interest, in particular, content suggestions, to facilitate your use of the Services or our management and operation of those, and for the purpose for which the data was collected.

In addition, personal data may also be processed for the purpose of complying with legal obligations and for the purposes of investigation, detection and prosecution of serious crimes.
For example, we may use your personal data for the following:

  • To contact you in the context of the use of the Services or whenever you request it;
  • To allow your use of our website;
  • To upload your content, at your request;
  • To notify you about your account or transactions (including advertisements related to the Services) and to send you information about features or improvements to the Services;
  • To notify you of changes in our general conditions and policies;
  • To collect anonymous information or aggregate information that does not identify you or your equipment, which we may use for any purpose;
  • To optimize or improve our products, services and operations;
  • To detect, investigate and prevent activities that may violate our policies or be illegal;
  • To perform statistical, demographic or marketing analysis on users of the Services.

LEGAL ADVICE FOR THE TREATMENT OF YOUR PERSONAL DATA
The legal basis for the treatment of your personal data, in the terms defined in this Privacy Policy, is as following:

  • When you have given your consent, as defined in the applicable data protection law – Article 6 (1), al.
    a) of the GDPR;
  • When the use of your information is necessary to fulfil our obligations arising from the contract entered into with you (for example, our service agreement) – Article 6 (1), al. b) of the RGPD;
  • When the use of your information is necessary to comply with the law – Article 6. paragraph 1, al. c) of the RGPD;
  • When the use of your information is necessary under our legitimate interests or the legitimate interests of others (for example, to ensure the security of our web pages, our products, software, applications; to operate our business and our services, to ensure a safe environment for our employees and visitors, to make and receive payments, to comply with legal obligations and ensure our rights, to prevent fraud and to know the customer to whom we render the Services) – Article 6, paragraph 1, al. f) of the RGPD.

TO WHOM WE CAN DISCLOSE THE DATA
In the scope of its activity and the provision of the Services, LAZER may use and disclose your personal data to third parties. LAZER takes appropriate measures, ensuring, in particular, contractually, that third parties who have access to your personal data are reputed and offer the highest guarantees in this area, adopting necessary technical and organizational measures to protect personal data against the destruction, accidental, unlawful, accidental loss, alteration, dissemination or unauthorized access and any other form of illicit treatment.

LAZER may disclose your data in the following circumstances and for the following purposes:
Third Consignee:
Computer service providers
Agents / Service Providers
Sponsors
Regulatory entities and police forces
Parent company, subsidiaries and related entities

Purpose of Disclosure:
Support for our IT systems and infrastructures
Provision of services (eg hosting, billing, payment processing, warehousing, content management tools, fraud protection, etc.)
Provision of services associated with the Services contracted (namely, installation and activation of the service)
Sponsorship management
Ensure law enforcement or emergency situations
Marketing
We may also disclose personal information to third parties as a result of, or in connection with, reorganization, re-incorporation, acquisition, debt financing, merger, sale of relevant assets or LAZER’s business or similar transaction, as well as in case of insolvency, bankruptcy, or liquidation in which personal data are transferred to one or more third parties as one of the assets of the company.
If we are involved in a lawsuit, we may disclose information about you that is relevant to the claim against third parties as a result of, or in connection with the associated legal proceedings.
If you authorize us, we may transfer your personal data to third-party providers of directory information services and publicly available lists.
Finally, we may periodically share anonymous or aggregated information for a variety of purposes, including reviewing the use of the Services or interests and behaviours. The sharing of this data is unlimited.

HOW LAZER PROTECTS YOUR PERSONAL DATA
LAZER has implemented reasonable and adequate technical and organizational measures to ensure a level of security appropriate to the risk, especially for the purpose of protecting your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
Therefore, the personal data collected through the forms on our website requires encrypted sessions of the Browser and all personal data transferred are stored securely in LAZER systems that are covered by all physical security measures and indispensable for the protection of personal data.
However, no Internet transmission method and no storage method (electronic or physical) is completely secure. While we do our best to protect your personal data, we cannot guarantee the absolute security and integrity of the transmission of your data to our systems. We therefore urge you to take additional security measures when browsing the Internet, including ensuring that you use up-to-date equipment and a Browser properly configured with security patches, active firewall, anti-virus and antispyware and that you ensure the authenticity of the web pages you visit. Any transmission occurs at your own risk.

TRANSFER OF YOUR PERSONAL DATA
The storage and processing of your personal data, as described above, may result in your personal data being transferred and/or stored in a country other than the country of your residence. We may also transfer your data to countries located outside the European Economic Area (EEA), where it may include countries that have very different levels of protection of personal data than those in the EEA. If this happens, special measures are provided to ensure that your data is safe to use. These measures include the conclusion of a contract incorporating the standard contractual clauses for the international transfer of data adopted by the Commission (“standard contractual clauses”) or the adoption of any of the other
mechanisms provided for in the GDPR (ie: the existence of a decision appropriateness by the Commission).

DURING HOW LONG WE RECEIVE YOUR DATA
LAZER will keep your data for no longer than reasonably necessary or required by law. The period of retention of the data will depend very much on the purposes for which we collect and use them and/or as necessary to comply with the applicable legislation.
The criteria we use to determine the periods of retention of your personal data include:

  • When you entered into a service agreement with us;
  • Whether there are contractual or legal obligations that require us to keep your personal data for a specific period of time;
  • If there is any ongoing legal action related to the contract you have entered into with us or that is otherwise related to your relationship with us;
  • What is the expectation of data retention at the time we collect your data;
  • What is the reasonable period of time for data retention if there are no other limitations on retention.

There are cases where the law determines a minimum period of 1 year conservation period for the treatment and conservation of traffic and location data for the purpose of investigation, detection and prosecution of serious crimes, data, or 10 years of data necessary for to the Tax Authority for accounting or tax purposes. Regarding the traffic data required for billing, namely, the destination and origin numbers of the calls made, the date/time of the communication, the duration of the communication and the IP address, the data relating to the communication will be kept for the maximum period of time 12 months from the date of completion of the call.
Regarding the recording of calls, and under the terms of the normative authorization, LAZER will keep the recordings to proof the commercial transaction and communications within the scope of the contractual relationship for the duration of the agreed contract plus 6 months.

OPTIONS THAT ARE AVAILABLE TO YOU REGARDING THE USE OF YOUR PERSONAL DATA
In accordance with the valid data protection law, as data holder, you have certain rights regarding the treatment of your personal data by the person responsible for the treatment (LAZER):

  • Right of access (Article 15 of the GDPR): The data subject has the right to obtain from the controller the confirmation that the personal data concerning him/her are processed and, if applicable, the right to access your personal data and explanatory information on how their data are being used;
  • Right of rectification (Article 16 of the GDPR): The holder has the right to obtain from the controller without undue delay the correction of inaccurate personal data concerning him or her;
  • Right to delete data (Article 17 of the GDPR): The holder has the right to obtain from the controller the erasure of his/her personal data without undue delay, and the latter has the obligation to erase personal data without delay when one of the following grounds applies:
    a) personal data are no longer necessary for the purpose for which they were collected or processed;
    b) the data subject withdraws the consent on which the data treatment is based (in cases where its use is based on consent) and there is no other legal basis for such treatment;
    c) The holder opposes the processing of his personal data and there are no prevailing legitimate interests justifying the treatment.
  • Right to limitation of treatment (Article 18 of the GDPR): The data subject has the right to obtain
    from the controller the limitation of treatment if one of the following applies:a) the accuracy of the personal data is contested by the data subject for a period which allows the data controller to verify its accuracy;
    b) the processing of data is unlawful and the data subject opposes the deletion of personal data and, on the other hand, requests the limitation of its use;
    c) the data controller no longer requires personal data for the purpose of processing, but such data are required by the data subject for the purpose of reporting, exercising or defending a right in the course of legal proceedings;
    d) the data subject is opposed to processing until it is established that the data controller’s legitimate motives prevail over those of the data subject.
  • Data portability right (Article 19 of the GDPR): the data subject has the right to receive the personal data referred to him in a structured, current and automatic reading format and the right to transmit that data to another responsible for the treatment.
  • Right of opposition (Article 21 of the RGPD): in cases where (i) the processing of your personal data is based on the legitimate interests of the controller, or (ii) the data is processed for the purpose of direct marketing or definition of profiles, the data subject may at any time object to the processing of their personal data.

If you wish to express your preferences regarding the type of communication you receive from us, you can do so at any time by updating the communication preferences specified in your account profile, either by email or attending at one of our desks.
If the basis for processing your personal data is consent, the data subject has the right to withdraw the right at any time, although it is not legitimate, it is not possible to obtain data based on prior consent given and subsequent data obtained on the basis on other grounds of lawfulness, such as the performance of a contract or a legal obligation which is what is the case in question.
Your requests will be processed with special attention so as to ensure the effectiveness of your rights. We may request that you provide us with the necessary information to verify your identity before we respond to your request.
You should note that, in certain cases (ie: due to legal requirements), your request may not be dealt immediately. In any case, you will be notified of the measures taken within one month from the time the request was made.

LAZER as responsible company and attentive to the needs of its customers, as well as concerned with providing the best service to the best quality, has a Data Protection Officer, who will be the intermediary between data holders and LAZER in matters of protection of data, doubts and answers.
Please contact us as referred to in the section below “LAZER CONTACTS INFORMATION” if you wish to exercise any of your rights or in case you have any questions regarding the processing of your personal data.
You also have the right to submit a complaint to the National Data Protection Commission (CNPD)
https://www.cnpd.pt/.

CHANGES TO THIS PRIVACY POLICY
This Privacy Policy will be subject to revisions which can reflect on amendments from time to time in order to reflect changes in the law or on our data treatment policies, the submission of new guidance from the local data protection authority, or advances in technology. We will notify you of any changes to this Privacy Policy and will give you the opportunity to expressly agree to any change before becoming subject to this Privacy Policy.
You may know that the Privacy Policy has changed since you last reviewed it by checking the “Last Updated” date that is included at the beginning of this document.

We encourage you to periodically review this Privacy Policy in order to keep you informed of how we collect, use and disclose your personal information.

LAZER CONTACT INFORMATION
If you have any questions or comments or wish to exercise any of your rights under this Privacy Policy and / or legally recognized, please contact us to:
E-mail: privacy@lazerspeed.com
Address: Rua Cristóvão Pires Norte, North Building, R / C, Shop D, 8135-117 Almancil
Phone: (+351) 289 396 055