Privacy and Cookie Policy

PRIVACY AND COOKIE POLICY OF ARTURAI ACCORDING TO ARTICLE 13 OF REGULATION (EU) 2016/679 (“GDPR”)

Arturai, therefore makes the commitment to assure the protection of all personal data made available to it, by adopting various technical and organizational security measures in order to protect personal data against any form of illegal treatment.

Arturai is also committed to continuously improve the set of procedures and techniques implemented for the protection of personal data, including accepting, for this purpose, all suggestions that the users of this site send us.

Arturai Tecnologias de Informacao, Lda (hereinafter “Arturai”) is the data controller of the personal data collected through the use of the website.

1. PURPOSE AND LEGAL BASIS

The personal data is gathered exclusively for the following purposes:

• Contact request response. The legal basis for this purpose is the necessary performance of your request.
• Commercial management. The legal basis for this purpose is the performance of the contract with you.
• Recruitment processes. The legal basis for this activity is the performance of the contract with you.

2. PERSONAL DATA COLLECTED

After you browse the site, Arturai will process certain personal data, which may consist of an identifier such as a name, identification number, on-line identifier or one or more characteristic elements of your physical, physiological, economic, cultural or social identity, for example in your CV, able to identify you as the data subject (hereinafter, simply the “Personal Data”). The Personal Data we process is as follows:

a. Browsing Personal

Data In normal operation, the computer systems and software procedures used to operate the site acquire certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information not collected for association with identified data subjects, but information which, by its very nature could, through processing and association with data held by third parties, permit the identification of users. This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. This data is used in the form of server side “logs” for the sole purpose of obtaining information on the use of the site and to check its correct operation, to permit - given the architecture of the systems used - the correct provision of services, security and to ascertain liability in the event of possible cyber-crime against the site or third parties; this data is processed in accordance with the GDPR and kept for the time strictly necessary to achieve the aforementioned purpose.

b. Data provided voluntarily by the user

The site allows users to provide personal information voluntarily, for example, through registration on contact forms, requests for services or information, and the facultative, explicit and voluntary transmission of e- mail to the addresses indicated on the site, etc. The privacy policy therefore applies to the processing of any Personal Data provided voluntarily through the site. When you using our websites, please don’t provide any Personal Data falling within the special categories of personal data as defined in art. 9 of the Regulation, quoted verbatim as “[...] data suitable for revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as processing genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person”.

c. Third-party data provided by the site user

When using certain services of the site, Arturai may also process some third-party Personal Data that you have provided. In such cases, you, as a user of the site who provides the Personal Data of a third party (your friend, acquaintance, relative, etc.), act as an independent data controller, and therefore assume all relevant legal obligations and responsibilities. As such, you will be required to fully indemnify Arturai against any complaint, claim or demand for compensation for damages caused to any third party whose Personal Data has been processed through your use of the site in violation of the applicable data protection regulations. In the case described, in the e-mail recommending one of our products to the third party, Arturai will provide the third party with your name and e-mail address, this being Personal Data you have provided to Arturai, in order to adequately inform the third party of the reason for the e-mail and the source that provided their Personal Data.

e. Cookies

Definitions, characteristics and application of the legislation
Cookies are small text files that sites you visit send and record on your computer or mobile device, which are re-transmitted to the same sites on your next visit. Through the use of cookies, sites remember your actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) to avoid having to enter them again when you return to the site or browse its pages. Cookies are used for mainly for authentication purposes, session monitoring and to save information on the activities of users visiting the site and may also contain a unique identification code able to track of the activities of users browsing the site itself, for statistical or advertising purposes. While browsing a site, you may also receive cookies from sites or web servers different to the one you are currently at (known as “third-party” cookies). Some operations would be
impossible without the use of cookies, which in certain cases are technically necessary for the site to operate.
There are various types of cookies with different characteristics and functions, which can remain on your computer for different periods of time: session cookies, for example, are automatically deleted when the browser is closed; persistent cookies, on the other hand, remain on your device for a predetermined length of time.
According to current legislation, the use of cookies does not always require your consent. In particular, “technical cookies”, cookies used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user (for example, for authentication, language preferences), do not require this consent. In short, these cookies are either essential for the operation of the site, or necessary for the activities requested by the user.
The technical cookies do not require express consent.
On the other hand, “profiling cookies”, those aimed at creating user profiles and used to send advertising messages corresponding to the preferences expressed by the users while browsing the net, require the user’s prior consent.
Types of cookies used and optional enable/disable

Except for third party cookies, for which you should refer directly to the corresponding disable/enable procedures indicated in the links, the site uses the following cookies, which can be disabled:

• Technical browsing or session cookies strictly necessary for the operation of the Site or to permit use of the requested content and services.
• Technical analytics cookies, for the analysis of site usage by users. These cookies do not collect information on the user's identity or any personal data. The information is processed in aggregate and anonymous form.
• Functionality cookies, i.e. used to enable specific functions of the Site and a series of selected criteria (for example, the language) to improve the service provided.

WARNING: if you disable technical and/or functionality cookies, the website may not be available, or some services or functions of the website may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the site.

• Third-party cookies, i.e. cookies from websites or web servers other than the Arturai’s site, used for the purposes of said third parties, including profiling cookies. Note that these third parties, listed below with links to the relevant privacy policies, are usually independent data controllers of the data collected through the cookies they serve; you should therefore refer to their personal data processing policies, information and consent forms (cookie enable/disable options), as specified in the aforementioned provision. On its part, Arturai makes all possible efforts to track the use of cookies on its site. For the sake of transparency, in the table available at the link provided below we provide regular updates on the cookies used and their purposes. We also provide links to the privacy policies of any third parties sending cookies through our site. As previously mentioned, such third parties are responsible for providing adequate information and obtaining your consent to the use of cookies, as required by the provision. This responsibility refers not only to the cookies sent directly by third parties, but also to any further cookies sent through our site through the use of services used by the third parties themselves. Given that these cookies are in effect sent by service providers of the aforementioned third parties, Arturai has no direct control over their use and no knowledge of their characteristics or purpose.

The details of the cookies sent through the site are as follows:

How to manage cookies

You can enable, block or delete cookies (entirely or in part) using the specific functions of your browser: however, if you disable technical and/or functional cookies, the website may not be available, or some of its services or functions may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the site.

You can get more information on how to set your cookie preferences on your browser through the following links:

• Internet Explorer
• Firefox
• Chrome
• Safari

You can also use the AdChoice tool provided by the Digital Advertising Alliance or the YourOnlineChoice tool provided by European Interactive Digital Advertising Alliance.

4. RETAINING PERIOD

The Personal Data collected for performance of the services and recruiting will be kept for the time strictly necessary to achieve that purpose. In any case, given that such processing is conducted for the provision of services, the data controller will process and store your Personal Data for the period allowed by applicable law for the protection of its interests.

5. SHARING PERSONAL DATA

Your Personal Data may be shared with these recipients:

- Personal authorized of the Arturai, for example employees.
- Processors who provide to Arturai some services, es. Akamai.
- Legal authorities to which we are obliged to disclose your Personal Data.

The recipients above mentioned could be located outside the European Economic Area. Arturai ensures that the processing of your Personal Data by said recipients is conducted in compliance with the GDPR and other applicable laws. In effect, such transfers may be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis. You can get more information from Arturai.

6. RIGHTS OF THE HOLDERS

Pursuant to art. 15 et seq. of the GDPR, you can exercise the following rights:

• Access: You can request to access your Personal Data that we are processing. You can also request to receive a copy of your Personal Data we are processing and obtain information about such processing.
• Correction: You can request the correction or modification of your Personal Data that we process if it is inaccurate or incomplete.
• Erasure: You can request that we erase your Personal Data that we are processing, when you feel that the processing is unnecessary or unlawful.
• Object: You can object to us processing your Personal Data when you have relevant grounds to do so which you think should prevent us from processing data about you.
• Restriction: You can request the restriction of Personal Data processing concerning you when the Personal Data in our possession is inaccurate, unnecessary, has been processed unlawfully, or you have already objected to processing.
• Portability: You can request to receive a copy of the Personal Data you have provided to us. We will send the data to you in a structured, commonly used and machine-readable format. You can also request that your Personal Data are transmitted to another data controller.
• Update your preferences for processing based on your consent.

Requests must be made in writing to the following address: info@arturai.com

You can withdraw your consent to the use of cookies using your browser functions or by consulting the privacy policies of the third parties serving cookies through the site.

In all cases you can always lodge a complaint with the competent Data Protection Supervisory Authority, pursuant to art. 77 of the GDPR, if you consider the processing of your Personal Data to be in violation of the legislation in force.

7. LINKS TO PARTNER SITES

The Arturai website might contain links to third-parties / partners' websites. The referred sites are not under the control of Arturai, thus Arturai is not responsible for the content of any of these sites. Users of the Arturai website are advised, when accessing other sites, to look for the pages within those sites that refer to their privacy policies.

8. CHANGES IN THE TERMS AND CONDITIONS

These privacy policy may be subject to change or revision. Any significant changes to these terms will be duly communicated to users on the Group's website.