This Privacy and Personal Data Protection Policy aims to commit to respecting the rules of privacy and protection of personal data set forth in Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016 (GDPR), regarding the protection of individuals regarding the processing of personal data and the free movement of such data, as well as applicable national legislation. We take the necessary technical and organizational measures to comply with the GDPR and ensure that the processing of personal data is lawful, fair, transparent, and limited to authorized purposes.

SportyMentor has implemented security practices and adopted procedures with the aim of ensuring their implementation in the areas of SportyMentor’s intervention.

The protection of citizens regarding the processing of personal data is a fundamental right. Therefore, it is clarified which personal data SportyMentor collects and for what purpose they are used.

Commitment

SportyMentor ensures that the processing of personal data is carried out within the scope of the purpose(s) for which they were collected, or for purposes compatible with the initial purpose(s) for which they were collected.

SportyMentor commits to implementing a data minimization culture, where only the personal data strictly necessary for the development of its activities and the satisfaction of citizens’ interests are collected, used, and retained.

SportyMentor commits not to disclose or share personal data for commercial or advertising purposes.

Objective

SportyMentor aims to ensure a consistent and high level of protection for individuals, regardless of their nationality or place of residence, regarding the processing of their personal data.

The protection should apply to the processing of personal data by automated means, as well as to manual processing, if the personal data are contained or are intended to be part of a filing system.

The processing of personal data must be carried out lawfully and fairly.

Object

The principles of data protection should apply to any information concerning an identified or identifiable natural person. Personal data that have been pseudonymized, which could be attributed to a natural person by using additional information, should be considered information about an identifiable natural person.

Collection and Processing of Personal Data

SportyMentor collects and processes personal data that is voluntarily provided by the data subject (hereinafter referred to as the data subject) through the completion of various forms, whether in person, via the website, telephone, postal mail, or electronic mail.

Personal data may be provided through requests, communication, complaints, participation, and through the available customer service channels.

Any information provided by the data subject will only be used for the purpose described and in compliance with data protection legislation.

The period during which data is stored and retained depends on the purpose for which the information is processed and the existence of legal requirements that mandate their retention for a minimum period.

In the absence of specific legal requirements, data will be stored and retained only for the minimum period necessary for the purposes that prompted their collection or subsequent processing, after which they will be deleted.

Some data may be retained for purposes of public interest archiving, scientific or historical research, or for statistical purposes. In such cases, appropriate technical and organizational measures will be used to safeguard the rights and freedoms of the data subject.

Responsability

SportyMentor is responsible for the processing of the collected personal data, as well as for the development of this Privacy Policy.

The data subject accepts that, by not providing all the requested information, they may not achieve the correct operation of some features on the website and app, as well as jeopardize any computer processing, consultation, or contact. SportyMentor uses personal data to respond to citizens’ requests, including processing their cases, providing information on SportyMentor matters, and conducting studies.

SportyMentor ensures that these data will be limited in access to individuals within the SportyMentor community who have the need to know them.The personal data of minors will only be collected and processed with the consent of those holding parental responsibilities or legal guardianship. In certain situations, Personal Data may have a more sensitive nature. The General Data Protection Regulation classifies them as ‘special categories of data.

The processing associated with these special categories of data deserves enhanced protection under the GDPR and is subject to specific technical and organizational safeguards. Therefore, the collection of documentation that includes special categories of data should only be carried out when such data are included as instructive documents in the application models and forms provided and publicized.

Principles applicable to data processing

SportyMentor commits to ensuring that the data of the data subject processed by it are:

• subject to lawful, fair, and transparent processing in relation to the data
• collected for specific, explicit, and legitimate purposes, not processed subsequently in a manner incompatible with those
• adequate, relevant, and limited to what is necessary in relation to the purposes for which they are
• accurate and updated whenever
• stored in a way that allows the identification of data subjects only for the period necessary for the purposes for which they are
• processed in a way that ensures their security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, with appropriate technical or organizational measures

 

Data Subject Rights

1.  Right to Information

When data is collected from the data subject, they must be informed by SportyMentor about:

• the identity and contact details of the data
• the purposes of the processing for which the personal data are intended, as well as the legal basis for the processing, if
• if the processing of data is based on the legitimate interests of SportyMentor or a third party, the indication of such
• the recipients or categories of recipients of the personal data, if applicable.
• the retention period for the personal data.
• the right to request from SportyMentor access to personal data, their rectification, erasure, or
• the existence of a legal or contractual obligation to provide personal data or if it is a necessary requirement for the conclusion of a contract, as well as whether the data subject is obliged to provide personal data and the possible consequences of not providing such
• the existence of automated decisions, including profiling, and information about the underlying logic, as well as the significance and envisaged consequences of such processing for the data subject, if applicable.

The above-mentioned information is provided in a concise, transparent, intelligible, and easily accessible manner, free of charge and without undue delay.

If SportyMentor intends to further process the data of the data subject for a purpose other than that for which the data were collected, prior to that processing, it will provide the data subject with information about that purpose and any other relevant information, in accordance with the above- mentioned terms.

2. Right of Access to Data

The data subject has the right to obtain confirmation as to whether personal data concerning them are being processed or not. If so, they have the right to access their personal data and the following information:

• The purposes of the processing of data;
• The categories of personal data concerned;
• The retention period for personal data;
• The procedure for requesting SportyMentor to rectify or limit the processing of personal data;
• Information available about the origin of the data, if not collected from the data subject;
• The existence of automated decisions, including profiling, and information about the underlying logic, as well as the significance and envisaged consequences of such processing for the data subject.

Upon request, SportyMentor will provide the data subject, free of charge, with a copy of their data undergoing processing. The provision of further copies requested by the data subject may incur administrative costs.

3. Right to Rectification of Personal Data

The data subject has the right to request, at any time, the rectification of their personal data and the right to complete them if they are incomplete.

In the event of rectification of the data, SportyMentor communicates the rectification to each recipient to whom the data have been transmitted, unless such communication proves impossible or involves a disproportionate effort.

If the data subject requests it, SportyMentor provides information about these recipients.

4. Right to Limitation of the Processing of Personal Data

O titular tem o direito de obter a limitação do tratamento dos seus dados, quando:

• dispute the accuracy of personal data, for a period that allows SportyMentor to verify its
• the processing is unlawful, and the data subject opposes the erasure of the data, instead requesting the limitation of their use.
• SportyMentor no longer needs the data of the data subject for processing purposes, but these data are required by the data subject for the establishment, exercise, or defense of legal

 

• the data subject has objected to processing, pending verification that SportyMentor’s legitimate grounds prevail over those of the data subject.

 

5. Right to Data Portability

The data subject has the right to receive the personal data concerning them, which they have provided to SportyMentor, when the following conditions are cumulatively met :

• The personal data requested are provided by the data subject and concern
• The processing is carried out by automated means, based on the data subject’s prior consent or the performance of a contract in which the data subject is a party
• The exercise of this right does not prejudice the rights and freedoms of third

The information should generally be provided free of charge and in a structured, commonly used, and machine-readable format.

When the data subject requests it and it is technically feasible, SportyMentor is obliged to transmit the data directly to another organization or entity.

6. Right to Object to Processing

The fact that the processing of personal data is lawful, based on the exercise of functions of public interest, public authority, or for the legitimate interests pursued by SportyMentor or third parties, does not prevent the data subject from having the right to object to the processing of personal data concerning their specific situation.

In this situation, SportyMentor will cease processing the data of the data subject, unless it can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims by SportyMentor in judicial proceedings.

Exercise of Rights by Data Subjet

The right of access, rectification, erasure, and portability, as well as the right to object, can be exercised by the data subject by contacting SportyMentor.

SportyMentor will respond to the data subject’s request within a maximum period of one month from the receipt of the request, except in cases of special complexity, where this period may be extended to two months.

If the requests made by the data subject are manifestly unfounded or excessive, especially due to their repetitive nature, SportyMentor reserves the right to charge administrative costs or refuse to proceed with the request.

When the processing of the data subject’s data is carried out by SportyMentor based on their consent, the data subject has the right to withdraw that consent at any time. However, the withdrawal of consent does not affect the lawfulness of the processing carried out by SportyMentor based on the previously given consent.

For the exercise of the rights of data subjects provided for in EU regulations and national legislation on the protection of personal data, SportyMentor has appointed a Data Protection Officer (DPO) who can be contacted through the website https://sportymentor.eu/.

Applicable Legislation

Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Law No. 58/2019, of August 8, ensuring the implementation, in the national legal order, of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals regarding the processing of personal data and on the free movement of such data.

Law No. 41/2004, of August 18, transposing into the national legal order Directive No. 2002/58/EC of the European Parliament and of the Council, of July 12, on the processing of personal data and the protection of privacy in the electronic communications sector.

Law No. 67/98, of October 26 (Personal Data Protection Law).

Changes to the Privacy Policy

Occasionally, SportyMentor may update this Privacy Policy, always providing the latest version on its website and app.