Privacy Policy

ImpactLabs (hereinafter referred to as "impactLabs" and further identified below), owner and operator of the "impactMarket App" for mobile devices compatible with the iOS or Android system (hereinafter the "App") and the “impactMarket website” (hereinafter the "Website"), is determined to ensure to the users and potential users of the App, not only full compliance with all legal obligations but also the maximum privacy of your personal data and the security of the transactions performed through the App, in accordance with the best practices available in the market.

For due and legal purposes, you can find the full identification and contact details of the entity in charge of processing personal data below:

• Name: Marco Paulo da Silva Barbosa;

• Company's registration number: NIPC 516228293;

• Headquarters and postal address: Rua Irmãs Missionárias do Espírito Santo, n°37, 4715-213 Braga, Portugal Commercial Registry Office;

• Company's email address: [e-mail];

• Contact details of the Data Protection Officer: [e-mail].

The processing of personal data through the website will be carried out under the following terms:

1. Data controller

ImpactLabs is the entity Responsible for the Prossessing of the personal data provided by the App users, hereinafter referred to as “the Controller”.

2. Purposes and legal grounds of the personal data treatment

Depending on the App functionalities you use, your personal data may be processed for different purposes. These purposes and the applicable legal grounds are set out below:

• Marketing communications;

• Within the scope of the operation of our App, and in order to be able to provide you with our services, we will process the personal data that you decide to provide us with for the following purposes:

- Execution of the service provision contract concluded with the data subject;

- Creation of your user profile;

- Subscription upon reception of a donation. (...)

- In relation to the purposes mentioned herein, the legal basis applicable to the procesing of your personal data is the execution of a contract to which the data subject is party and the fulfilment of legal obligations to which we are bound, since the processing of such personal data is essential for the execution of the contract in question.

• For the purpose of responding to requests, enquiries or complaints, we process your personal data on the legal basis of our legitimate interest in providing you with a personalised, quality service, managing complaints and, where applicable, carrying out the necessary pre-contractual procedures at your request.

Our App uses Blockchain technology, and as such your personal data will be stored in interconnected blocks. For this reason, such data will necessarily continue to be processed even after the expiry of the legal basis applicable in each case, based on our legitimate interest in maintaining the integrity of the platform. However, we have no intention of accessing or using your personal data after the expiry of the legal basis that gave us the legitimacy to process it in the first place. We will not attempt to use your personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way. We will not intentionally give access to such data to any third party and we undertake to delete such data as soon as possible, provided that this does not compromise the integrity of the platform.

3. Time for which we store your personal data

The time for which we store your personal data may vary depending on the purpose for which it is processed. We will keep your personal data for the following periods:

• Sending marketing communications: until you exercise your right to object or revoke your consent, whichever is applicable.

• For purposes associated with the App:

- for as long as necessary to ensure full performance of the contract entered into with you;

- during the applicable legal time limits.

• For the provision of technical assistance and for the purpose of responding to requests, enquiries or complaints:

- for as long as necessary to ensure full performance of the contract concluded with you;

- during the applicable legal time limits.

Such data will necessarily continue to be processed, even though in a very restrictive manner, after the expiry of the legal basis applicable in each case, based on our legitimate interest in maintaining the integrity of the platform.

4. Transmission of personal data

We may communicate your personal data to third parties for the purpose of complying with the legal obligations applicable in each case or where necessary to provide the services to be contracted. Where the processing of personal data is carried out through external service providers, who act as processors, we follow strict criteria in the selection of service providers in order to comply with their data protection obligations and we undertake to sign a data processing agreement with them.

5. Rights of the data subject

As a data subject you have the following rights in relation to the processing of your personal data:

• Access: You may obtain information on whether we are processing your personal data, as well as consult your personal data included in files of this company.

• Rectification: You may change your personal data when it is incorrect as well as complete those that are incomplete.

• Erasure: You may request the erasure of your personal data when, among other reasons, the personal data is no longer necessary for the purposes for which it was collected.

• Objection: In certain situations you may request that your personal data is no longer processed. We will stop the processing of your personal data unless there are legitimate reasons or for the establishment, exercise or defense of rights in an administrative, judicial or extrajudicial procedure.

• Limitation of processing: You may request the limitation of the processing of your personal data in the following situations: (a) while contesting the accuracy of your personal data; (b) when the processing is unlawful and you have objected to it and requested the limitation of the use of your personal data; (c) when we no longer need to process your personal data, but you need it for the exercise or defense of rights in an administrative, judicial or extrajudicial procedure; (d) when you have objected to the processing of your personal data for compliance with an obligation of public interest or for the fulfilment of a legitimate interest, as long as these legitimate grounds for the processing are found to outweigh your grounds.

• Portability: In certain situations you will be entitled to receive, in a structured, commonly used and machine readable format, the personal data you have made available to us and those obtained from your relationship with us, as well as to transmit them to another entity.

If you have any questions or wish to exercise these rights, you may contact us at [e-mail]. To exercise your rights, if necessary, we may ask you to provide proof of identity. You should also indicate the right you wish to exercise. The exercise of your rights is free of charge, except in the case of a manifestly unfounded, excessive or repeated request.

Finally, we note that you may lodge a complaint with the competent supervisory authority (Comissão Nacional de Proteção de Dados) through the website www.cnpd.pt.