Data Controller and contact information

The personal data that we obtain will be processed by:

Corporate Name: Flow – Holmes Place Coworking

Address: Praceta Professor Alfredo de Sousa 8A Algés 1495-241 Lisboa

Email: marketing@flow.holmesplace.pt

For any questions regarding our use of your personal data, you can also contact our Data Protection Officer at EPD@holmesplace.pt

Personal Data Collection

“Personal data” referes to specific data about personal or factual characteristics relating to a subject who can be identified from that data. This includes information such as name, address, telephone number and date of birth.

Information that does not allow you to be identified or that cannot be directly linked to your identity is not considered personal data.

We collect your personal data when you register in the customer area, when you book a tour to our premises, when you subscribe to our newsletter and our marketing campaigns, when you communicate with us through the different channels available on our website, when you exercise any of your rights, when you provide us with your data in the context of a contractual/pre-contractual relationship, when you physically access our premises, as well as through browsing data (cookies).

Purposes and legal basis

Recipients of your personal data

We may share your personal data with the following recipients:

·       Other Group companies, in order to guarantee centralised and secure information management.

·       Companies responsible for providing the following services: web and website devolopment, potencial clients management, eletronic communication, database management, among others. Nevertheless, we ensure that these service providers undertake to fulfil their obligations under the GDPR and, specifically, to process personal data only for the agreed purposes and in accordance with our instructions.

·       Public Authorities and Bodies, including courts, if required.

·       Other third parties, if the data subjects give their prior consent, or if the processing requires their intervention.

Transfers of personal data to third countries or international organisations

Within the scope of data sharing and if necessary, we’ll only transfer your personal data to third countries – which do not belong to the European Economic Area – for which the European Commission has not issued an adequacy decision regarding the level of protection of personal data, if the necessary and appropriate measures are in place under the applicable law to ensure the protection of the data subject to such a transfer. This measures can include standard contractual clauses approved by the European Commission or another mechanism.

Data storage

The personal data will be kept:

·       For no longer than is necessary for the purposes for which they are processed;

·       Until the data subjects withdraw their consent to the processing, unless there is another legal basis for the processing;

·       During the legally prescribed period, if there is a legal obligation to fulfil in this regard.

Data subject rights

The data subjects may exercise the following rights:

·       Access to their personal data;

·       Rectification and updating of their personal data;

·       Erasure – The data subjects may request the deletion of their personal data if it is no longer necessary for the purposes for which they were collected;

·       Restriction of processing;

·       Objection – The data subjects shall have the right to object, on grounds relating to their particular situation, at any time to the processing of their personal data which is based on our legitimate interests;

·       Data Portability;

·       Reject automated individual decisions;

·       Withdraw consent – Your consent can be withdrawn at any time; however, this withdrawn does not affect the lawfulness of the processing carried out prior to the withdrawal.

If you wish to submit a complaint or exercise the right to complain about any aspect related to the processing of your personal data, or about this Policy, you should contact EPD@holmesplace.pt.

Should you be dissatisfied with our processing of your personal data, or with our response after exercising any of the rights provided for in this Policy and in the General Data Protection Regulation, you also have the right to file a complaint with the National Data Protection Commission.

Information Security

We apply the appropriate technical and organizational measures to ensure a level of security appropriate to the risk. These measures are periodically reviewed and are designed to guarantee the security and protection of your personal data in terms of its availability, authenticity, integrity and confidentiality, as well as to prevent its loss, misuse, alteration, unauthorized processing or access, or any other form of illicit or abusive processing.