Customer Privacy Policy

1. Commitment of RCF Protecting Innovation, S.A.

The protection of privacy and personal data is a fundamental commitment of RCF Protecting Innovation, S.A. (hereinafter RCF) regarding the customers (“Customers”) of its products and services.

RCF recommends you to read this Privacy Policy as well as the respective updates.

2. Responsible for data processing

The responsibility of collecting and processing your personal data will be undertaken by RCF, which provides you with support services and internationalization of innovation, such as searches and registration of trademarks and patents, as well as management of arbitration and disputes, in addition to other related services and, thereby, it will decide which data are to be collected, which means of processing are to be used and for what purposes the data will be used.

3. Personal data, personal data owners and categories of personal data

What is personal data?

Personal Data is any information of any kind and in any media relating to an identified or identifiable individual. It shall be considered as identifiable any person who can be directly or indirectly identified, for example by the name, the identification number, a location data, an electronic identifier or by other elements that enable to identify that individual.

Who owns the personal data?

The Customer, that is to say the individual, to whom the data concerns, and who has used services or products provided by RCF PI. For example, a RCF Customer will be anyone who has entered into a contract to provide a service. A potential Customer will be anyone who is targeted by the RCF advertising campaigns, as well as anyone who requests information on the services commercialized by RCF.

With this regard, RCF informs that it also protects personal data and respects the Customers’ rights.

Which categories of personal data do we process?

Identification data:Identification and contacts

Examples: Company, contact name, address, e-mail, phone number

4. Grounds, Purposes and Duration of Personal Data Processing

On what grounds can RCF PI process your personal data?

Consent: when you have given your express consent – in writing, orally or through the validation of an option – and prior, and only when such consent is free, informed, specific and unequivocal. Examples of such consent is your consent to send direct marketing messages; profile definitions; recording of phone calls or

Contract enforcement and pre-contractual proceedings: when processing personal data is necessary to enter, enforce and manage a contract concluded with RCF PI, for example concerning requests for information, preparation of a proposal of services, provision of services, management of contacts/complaints, billing/collection/payments or

Compliance with legal obligation: when processing personal data is necessary to comply with a legal obligation to which RCF PI is subjected to, such as providing data to the Police, Judicial, Fiscal or Regulatory Authorities or

Legitimate interest: when processing personal data corresponds to a legitimate interest of RCF or of third parties, such as improvement of the quality of service or detection of fraud, and when the reasons for their use must prevail over the data owners’ rights.

For what purposes and for what lengths of time can RCF PI process your personal data?

Your personal data are processed by RCF PI only for the time period necessary to achieve the purpose established or, depending on the applicable law, until you exercise your right to object, your right to be forgotten or until you withdraw your consent. After the expiry of the storage period, RCF PI will eliminate or anonymize the data whenever they are not to be kept stored for any different purpose

What is the time limit for processing and storing your personal data?

RCF processes and stores your personal data according to the purposes for which they are processed. There are cases in which the law requires the processing and storage of data for a minimum period of time, namely for 10 years concerning the data necessary to provide information to the Tax Authorities, data for accounting or tax purposes, or data relating to commercial accountancy, and for 7 years for the purposes related to fighting money laundering and terrorism financing.

However, whenever there is not a specific legal obligation, in that case the data will be processed only for the time period necessary to fulfil the purposes that led to their collection and storage, and always in accordance with the law and with the guidelines and decisions of the CNPD Thus:

RCF will process and keep your personal data for the time period that it maintains a contractual relation with you.

With regard to the video surveillance of its premises, RCF will only keep the recordings of images and the respective personal data for a maximum of 30 days.

RCF may maintain other personal data for periods longer than the duration of the contractual relation, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that justify it, but always for the period of time strictly necessary for the fulfilment of the respective purposes, and in accordance with the guidelines and decisions of the CNPD.

Examples thereof are the contacts for marketing and sales purposes, data preservation in the context of invoice claim procedures, exercise of warranty rights, pending judicial litigation.

5. Methods and timing for collection of personal data

When and how do we collect your personal data?

We collect your personal data with your consent or when you acquire services provided by RCF.

The collection can be done orally, in writing or by e-mail.

However, your personal information may also be collected from sources available to the public or other sources, including on Internet sites.

6. Rights of the owner of the personal data

What are your rights?

Right of Access – right to obtain confirmation on which of your personal data are processed and information about them, for example, what are the purposes of processing those data, what is the time-limit to keep them, among other information. You have the right, for example, to see/hear or obtain a copy of, for instance, invoices or written agreements.

Right of Rectification – right to request rectification of your personal data that are inaccurate or request that incomplete personal data be completed, such as the address, Tax Identification Number, e-mail, telephone contacts, or others.

Right to erasure or “right to be forgotten” – right to have your personal data erased, provided that there are no valid grounds for their preservation, as in the cases in which RCF has to preserve the data to comply with a legal obligation or because there is an ongoing court case.

Right to Data Portability – right to receive the data you provided us in a commonly used digital and automatically readable format, or right to request the direct transmission of your data to another entity that has become the new responsible for your personal data, nevertheless, in this case only when it is technically possible.

Right to Withdraw your Consent or Right to Object – right to object or withdraw your consent to data processing, at any time, as for example in the case of data processing for marketing purposes, provided that no legitimate interests prevail over your interests, rights and freedoms, such as defending a right in a judicial process.

Right to Restriction of Processing – right to request a restriction in your personal data processing, in the form of: (i) suspension of the data processing or (ii) restriction of the processing scope to certain categories of data or processing purposes.

Right to lodge a complain – right to lodge a complain with the supervisory authority, the CNPD, as well as with the company.

How can you exercise your rights?

The exercise of rights is free of charge, except in the case of a clearly unfounded or excessive request, in which case a reasonable fee may be charged against costs.

The information shall be provided in writing. However, it may also be provided orally if requested. In this case, RCF must verify your identity by other than oral means. In this case, the RCF PI shall verify its identity by means other than oral means.

The response to requests shall be provided within a maximum of 30 days, unless when it is a particularly complex request.

Exercise your rights through the following address:

– privacydata@rcf.pt or

– Rua Tomás Ribeiro, 45 – 2º  1050-225 Lisboa, Portugal.

7. Transmission of Personal Data

Under what circumstances is your personal data communicated to other entities, subcontractors or third parties?

Your data may be transmitted to subcontractors to be processed in the name and on behalf of RCF, such as to industrial property agents or translators. In this case, RCF PI will take the necessary contractual measures to ensure that the subcontractors respect and protect Customer’s personal data.

Data may also be transmitted to third parties – entities other than RCF PI or subcontractors – in case the owner has given consent or entities to which the data must be communicated by law, such as the Tax Authorities.

Under what circumstances does RCF transfer your data to a third country?

RCF may have to transfer your personal data to a third country, outside the European Union, not included in the list of countries already considered by the EU as complying with adequate levels of personal data protection. In such cases, RCF will ensure that data transfers are carried out in strict compliance with applicable legal standards.