Services Privacy Policy www.ashton.pt/
ASHTON INVESTMENTS Owner's contact e-mail: info@ashton.pt
Types of data collected
The Owner does not provide a list of the types of Personal Data collected. Full information on each type of Personal Data collected is provided in the respective sections of this privacy policy or through specific explanatory texts presented prior to the collection of Data. Personal Data may be provided free of charge by the User, or, in the case of Usage Data, collected automatically when using this service (this Application). Unless otherwise stated, all Data requested by this service (this Application) is mandatory and failure to provide it may make it impossible for this service (this Application) to provide its services. In the event that this service (this Application) specifically indicates that some Data is not mandatory, the User may choose not to communicate such Data without this affecting the availability or operation of the Service. If the User has any doubts about which Personal Data is mandatory, he/she may contact the Owner. Any use of Cookies - or other tracking tools - by this service (this Application) or by the owners of third-party services used by this service (this Application) is for the purpose of providing the Service requested by the User, in addition to any other purpose described herein. The User is responsible for any third party Personal Data obtained, published or shared through this service (this Application).
How and where data is processed
Treatment methods
The Owner will adopt appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data. Data processing is carried out using computers and/or IT tools enabled for this purpose, following organizational procedures and methods strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessible to certain types of responsible persons who are involved in the operation of this service (this Application) (administration, sales, marketing, legal department, system management) or to external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies), appointed as Subcontractors by the Owner, if necessary. The updated list of these parties may be requested from the Owner at any time.
Location
The Data is processed at the Owner's active offices and at any other locations where the parties involved in the processing are located. Depending on the User's location, data transfers may involve the transfer of User Data to a country other than their own. To find out more about the location of the processing of such transferred Data, the User can consult the section on information about the processing of Personal Data.
Conservation period
Unless otherwise stated in this document, Personal Data will be processed and stored for the time required by the purpose for which it was collected, and may be retained for longer due to applicable legal obligations or based on Users' consent.
Additional information for the user
Legal basis for treatment
The Owner may process Personal Data relating to the User if one of the following applies: The User has given his/her consent for one or more specific purposes. the provision of Data is necessary for the performance of a contract with the User and/or for any pre-contractual obligations of the same; the processing is necessary for compliance with a legal obligation to which the Owner is subject; the processing is related to a task carried out in the public interest or in the exercise of official powers granted to the Owner; the processing is necessary for the purposes of legitimate interests pursued by the Owner or by any third party. In any case, the Owner will collaborate in clarifying the specific legal basis that applies to the processing and, in particular, whether the provision of Personal Data consists of a legal or contractual requirement, or a requirement necessary to enter into a contract.
Additional information on shelf life
Unless otherwise stated in this document, Personal Data will be processed and stored for the time required by the purpose for which it was collected, and may be retained for longer due to applicable legal obligations or based on the consent of Users. Thus: Personal Data collected for purposes related to the fulfillment of a contract between the Owner and the User will be retained until such contract has been fully fulfilled. Personal Data collected for the purposes of the Owner's legitimate interests will be kept for the period necessary to fulfill those purposes. The User can find specific information regarding the legitimate interests pursued by the Owner in the respective sections of this document or by contacting the Owner. The Owner may retain Personal Data for a longer period if the User has given his/her consent to such processing, provided that such consent is not withdrawn. In addition, the Owner may be obliged to retain Personal Data for a longer period where it is required to do so in order to comply with a legal obligation or by order of an authority. Once the retention period has expired, the Personal Data will be deleted. Therefore, the rights of access, erasure, rectification and data portability cannot be exercised after the end of the retention period.
User rights in accordance with the General Data Protection Regulation (GDPR)
The User may exercise certain rights in relation to their Data processed by the Owner. The User has the right to, in particular, to the extent permitted by law: Withdraw their consent at any time. The User has the right to withdraw consent if they have previously given their consent to the processing of their Personal Data. Object to the processing of their Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than that to which you have consented. Access your Data. The User has the right to know whether the Data is being processed by the Owner, to obtain information regarding certain aspects of the processing and to obtain a copy of the Data being processed. Verify and seek rectification of the Data. The User has the right to verify the accuracy of their Data and to request that it be updated or corrected. Restrict the processing of your Data. The User has the right to restrict the processing of their Data. In this case, the Owner will not process your Data for any purpose other than storage. Demand the erasure or deletion of your Personal Data. The User has the right to demand that the Owner erase their Data. Receive your Data and transfer it to another data controller. You have the right to receive your Data in a structured, commonly used format and in a format that allows it to be read electronically, and, where technically possible, to transmit it to another controller without hindrance. Submit a complaint. Users have the right to lodge a complaint with the relevant data protection authority. Users also have the right to learn about the legal basis for Data transfers abroad, including to any international organization governed by public international law or created by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Information on the right to object to processing When Personal Data is processed in the public interest, in the exercise of official powers conferred on the Owner or for the purposes of the legitimate interests pursued by the Owner, the User may object to such processing by providing a reason relating to their specific situation to justify the objection. However, the User is warned that if their Personal Data is processed for direct marketing purposes, they may object to such processing at any time, free of charge and without providing any justification. When the User objects to processing for direct marketing purposes, the Personal Data will not be processed for such purposes. To find out whether the Owner is processing Personal Data for direct marketing purposes, the User may consult the relevant sections of this document.
How to exercise these rights
Any request to exercise the User's rights may be addressed to the Owner using the contact details indicated in this document. Such requests are free of charge and will be answered by the Owner as soon as possible and always within one month, providing the User with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate effort. At the User's request, the Owner will inform the User of such recipients.
Additional information on data collection and processing
Lawsuits
The User's Personal Data may be used for legal purposes by the Owner, in Court or in the steps leading to a possible legal action arising from the misuse of this service (this Application) or related Services. The User declares to be aware that the Owner may be obliged to disclose personal data at the request of government authorities.
Additional information on User Personal Data
In addition to the information contained in this privacy policy, this Application may make available to the User, upon request, additional and contextual information about the specific Services or the collection and processing of Personal Data.
System reports and maintenance
For operation and maintenance purposes, this Application, as well as any third-party services, may collect files that record interaction with this Application (system reports) or use other Personal Data (such as IP address) for this purpose.
Information not included in this policy
At any time, the Owner may be asked for more information about the collection or processing of Personal Data. You can consult the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to change this privacy policy at any time by notifying its Users on this page and possibly on this service (this Application) and/or as far as technically and legally possible - by sending a notification to Users via any contact information available to the Owner. We strongly recommend that you check this page frequently, referring to the latest modification described at the bottom. In the event that the changes affect processing activities carried out on the basis of the User's consent, the Owner will obtain a new consent from the User where necessary.
Definitions and legal references
Personal Data (or Data)
Any information that, directly or indirectly, or in connection with other information - including any personal identification number - allows the identification or identifiability of a natural person.
Usage data
Information collected automatically through this service (this Application) (or third-party services used in this service (this Application), which may include: the IP addresses or domain names of the computers used by Users using this Application, the URI (Uniform Resource Identifier) addresses, the date and time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User and the various information about the path followed in the Application. ), the country of origin, the characteristics of the browser and operating system used by the User, the various time information per visit (for example, the time spent on each page in the Application) and information on the path followed in the Application, namely the sequence of pages visited and other parameters on the operating system of the User's device and/or computer environment.
User
The person using this Application who, unless otherwise indicated, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Subcontractor
The natural or legal person, authority, agency or other public body processing Personal Data on behalf of the Controller, as described in this privacy policy.
Treatment Manager (or Owner)
The natural or legal person, authority, agency or other public body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures relating to the operation and use of this service (this Application). Unless otherwise specified, the Controller is the Owner of this service (this Application).
This Application
The means by which the User's Personal Data is collected and processed.
Service
The service provided through this service (this Application) as described in its terms (if applicable) and on this website/application
European Union (or EU)
In this document, unless otherwise indicated, all references to the European Union include all current Member States of the European Union and the European Economic Area.
Legal information
This privacy policy relates only to this Application, unless otherwise stated in this document. Last updated: November 15, 2023
