CWORDS, Lda PRIVACY AND PERSONAL DATA PROTECTION POLICY

CWORDS, Lda – Crossingwords (hereinafter " CWORDS, Lda "), is a private limited company that operates within the scope of providing translation and interpreting services, in all their aspects, and with particular emphasis on translations to and from the Portuguese language.

CWORDS, Lda is committed to protecting the personal data of this website users in all situations in which personal data are processed by CWORDS, Lda, having, in this context, prepared this Policy, which is based on its commitment to respect the applicable legislation on personal data protection.

Why this privacy and personal data protection policy?

This Policy is intended to make this website users aware of the general rules of privacy and processing of personal data, which are collected and processed in strict respect and compliance with the provisions of the personal data protection legislation in force in every moment, namely Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (hereinafter referred to as "GDPR").

CWORDS, Lda respects the best practices in the field of personal data security and protection, having for this purpose taken the necessary technical and organizational measures in order to comply with the GDPR and ensure that the personal data processing is lawful, transparent and limited to the authorized purposes.

CWORDS, Lda is committed to the personal data protection and confidentiality, having adopted the measures it deems appropriate to ensure the personal data accuracy, integrity and confidentiality, as well as all other rights of the respective data subjects.

The rules provided for in this Privacy and Data Protection Policy complement the provisions, in terms of personal data protection and processing, provided for in any forms or membership, enrolment or registration forms that this website associates and/or users may sign and/or transmit to CWORDS, Lda.

What does this privacy and data protection policy cover?

This Privacy and Data Protection Policy applies exclusively to the collection and processing of personal data whose processing CWORDS, Lda is responsible for within the scope of the services, actions and activities that it makes available to its associates and/or users of the CWORDS, Lda website and in all situations in which it processes personal data, namely through the processing, management and storage of data from the several forms/files available for this purpose on its website.

The CWORDS, Lda website may include hyperlinks to access other websites that are not related to CWORDS, Lda. These hyperlinks are made available in good faith, and CWORDS, Lda cannot be held responsible for the personal data collection and processing carried out through these websites nor does it take any responsibility with regard to such websites, namely their accuracy, credibility and functionalities made available in them.

What is personal data?

Personal data is any information, of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person.

An identifiable person is the natural person who can be identified, directly or indirectly, namely by reference to a name, identification number, location data, electronic identifiers or to one or more elements specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity.

What constitutes personal data processing?

Personal data processing consists of an operation or a set of operations carried out on personal data or sets of personal data using automated means, or not, namely the collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, limitation, erasure, or destruction.

Who is responsible for data processing?

CWORDS, Lda is the entity responsible for personal data processing (data controller) and determines the purposes and means for processing.

For this purpose, if the data subject needs to contact the data controller, they can do so through the means and contacts below:

• A contact form on the CWORDS, Lda website;
• Email sent to cwrequest@crossingwords.com;
• Written communication addressed to the Data Controller to the following address: Rua Dr Carlos Pires Felgueiras, 98 – 3ºC 4470-147 Maia ;

Who is the data protection officer?

The data protection officer plays a relevant role in the processing of personal data, ensuring, among other aspects, compliance of data processing with the legislation in force while confirming compliance with this Privacy and Data Protection Policy and defining clear rules for the personal data processing, ensuring that all those who entrust it with their personal data processing are aware of how CWORDS, Lda processes data and what rights they have with this regard.

Thus, the data subjects, if they so wish, may address a communication to the Data Protection Officer, regarding matters related to the personal data processing, using, for this purpose, the following email address: cwrequest@crossingwords.com

What are the types of personal data processed?

CWORDS, Lda, within the scope of the activities it carries out, processes the personal data necessary for the purposes indicated in the respective Statutes, processing data such as name, address, telephone number(s), email address(es), citizen card (ID card), NIF [Tax Identification Number], type of activity, start of activity, qualifications, working languages, specialization fields, services, according to more detailed information made available to the personal data subjects.

Notwithstanding the compliance with legal regulations regarding the retention and transmission of data for the purposes of investigation, detection, repression of serious crimes, as well as other processing to which it is legally obliged, the information of the associate and/or the website user will be processed by CWORDS, Lda to the extent necessary for the purposes indicated in its Statutes. In this way, based on the information, the associate and/or website user will have access, namely to informative and specific features of CWORDS, Lda websites.

Profile personal data are also processed for the purpose of marketing or disclosure of offers by CWORDS, provided the respective data subject has authorized it.

If there is prior consent from the associate and/or the website user, this consent can be withdrawn at any time, without compromising the lawfulness of the processing carried out based on the previously given consent.

When and how do we collect your personal data?

CWORDS, Lda collects your personal data, namely by telephone, in writing and through its forms on the website, guaranteeing, whenever necessary, the prior consent of the data subject.

Some personal data are indispensable for the performance of the contract and, in case of lack or insufficiency of personal data, CWORDS, Lda will not be able to provide the relevant product or service.

The personal data collected may be processed by computer and in an automated or non-automated manner, guaranteeing in all cases the strict compliance with the personal data protection legislation, being stored in specific databases, created for this purpose and, under no circumstances, the data collected will be used for a purpose other than that for which they were collected or the consent of the data subject was given.

Who are the recipients of personal data?

Notwithstanding the recipients indicated throughout this Privacy and Data Protection Policy, CWORDS, Lda may communicate the personal data of the associate and/or website user for the purpose of complying with legal obligations namely to police, judicial, tax and regulatory entities.

What are the purposes of the personal data processing and their legal basis?

In general, the personal data collected is based on and intended for the management of CWORDS, Lda's relationship with its users, the adequacy of services to the needs and interests of website users and content suggestions, information and marketing actions. Additionally, personal data may also be processed for the purposes of complying with legal obligations and for the purposes of investigation, detection and repression of serious crimes.

Notwithstanding the additional information provided when collecting the data, CWORDS, Lda may also, provided that it is legally permissible, use the personal data provided by the personal data subject for other purposes, such as social intervention actions, sending complaints and suggestions, disseminating institutional information about CWORDS, Lda and/or to disclose campaigns, promotions, advertising and news about actions and promotions of CWORDS, Lda, as well as to carry out market studies or evaluation surveys.

For how long do we keep your personal data?

The period of time during which personal data is stored and kept varies according to the purpose for which the information is processed.

In fact, there are legal requirements that require data to be kept for a minimum period of time. Thus, and whenever there is no specific legal requirement, data will be stored and preserved only for the minimum period necessary for the pursuit of the purposes that motivated their collection or their further processing, under the terms established by law.

What are your rights as a data subject?

As personal data subjects, the website users are entitled, at any time, to the right to access, rectify, update, limit and erase their personal data (except for data that are essential to the provision by CWORDS, Lda. of the services duly identified on the Form as being mandatory or the compliance with legal obligations to which the data controller is subject), the right to oppose their use for marketing or advertising purposes by CWORDS, Lda and the withdrawal of consent, without this compromising the lawfulness of the processing carried out under that consent, as well as the right to data portability.

How can you access, rectify, update, limit, delete, oppose the processing of your personal data or remove consent?

Notwithstanding the GDPR provisions, the data subject may do so directly or upon written request addressed to the respective data controller through the contact information provided for the purpose in this document.

How can you opt out from receiving messages for marketing purposes?

CWORDS, Lda may promote, among its associates and/or website users, actions to disclose services, promotions and actions, namely via telephone, e-mail, SMS, MMS or any other electronic communications service, if the data subject has given consent. If the data subject do not intend to continue receiving these messages, they may at any time withdraw their consent to the use of their data for marketing and or advertising purposes.

How can you file a complaint?

Without prejudice to being able to file complaints directly with CWORDS, Lda through the contact information made available for this purpose, the associate and/or the website user can file a complaint directly with the Control Authority, which is the National Data Protection Commission (CNPD), using the contact information made available by this entity for this purpose.

What measures does CWORDS, Lda take to ensure your personal data security?

CWORDS, Lda undertakes to ensure the protection of the personal data security made available to it, having approved and implemented strict rules with this respect. Compliance with these rules is an obligation for all those who legally access the data.

Bearing in mind the concern and commitment shown by CWORDS, Lda in the defence of personal data, several security measures of a technical and organizational nature were adopted in order to protect the personal data made available to it against their dissemination, loss, misuse, unauthorized alteration, processing or access, as well as against any other form of unlawful processing.

Additionally, third parties that, within the scope of the provision of services, process the personal data of the associate and/or the website user in the name and on behalf of CWORDS, Lda, are required, in writing, to carry out appropriate technical and security measures that, at all times, comply with the requirements provided for in the legislation in force and ensure the defence of the data subject rights (namely, the protection of the privacy and personal data of the associates and/or the website users).

In this sense, the collection of personal data through email messages or data collection forms on the CWORDS, Lda website requires encrypted browser sessions and the use of the SSL (Security Sockets Layer) security protocol and all personal data transferred are safely stored and covered by all the physical and logical security measures that CWORDS, Lda deemed indispensable for the personal data protection.

Notwithstanding the security measures adopted by CWORDS, Lda, it is recommended that all Internet users adopt additional security measures on their computers, namely the use of updated browsers in terms of properly configured security "patches", with active firewall, antivirus and anti-spyware and that they certify the authenticity of the websites they visit on the internet, while avoiding websites whose reputation they do not trust.

Under which circumstances does data communication to other entities (third parties and subcontractors) take place?

CWORDS, Lda, within the scope of its activity, may use third parties to provide certain services. Sometimes, the provision of these services involves access, by those entities, to the personal data of the website users. When this takes place, CWORDS, Lda takes appropriate measures to ensure that the entities that have access to the data are reputed and offer the highest guarantees at this level, which is duly recorded and contractually safeguarded between CWORDS, Lda and those entities.

Thus, any entity subcontracted by CWORDS, Lda will process the personal data of the website users, in the name and on behalf of CWORDS, Lda, while taking the required technical and organizational measures in order to protect personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access and against any other form of unlawful processing.

Under which circumstances do we transfer your personal data?

The development of certain activities or actions and also the provision of certain services by CWORDS, Lda may involve transferring your data outside Portugal, including outside the European Union or to International Organizations.

In such a case, CWORDS, Lda will strictly comply with the applicable legal provisions, namely in what concerns the determination of the suitability of the destination country(ies) with regard to the personal data protection and the requirements applicable to such transfers, including, where applicable, the signing of appropriate contractual instruments that guarantee and respect the legal requirements in force.

How can you find out about any changes to the CWORDS, Lda privacy and personal data protection policy?

CWORDS, Lda reserves the right to, at any time, make adjustments or changes to this Privacy and Personal Data Protection Policy, which will be duly disclosed in the several communication channels of CWORDS, Lda.