Welcome to CeLLo. Incorporadora's Privacy Policy. We value our users' privacy and are committed to protecting the personal data you share with us. This policy describes how we collect, use, share and protect your personal information when you use our website and related services.

This Privacy Policy describes CeLLo. Incorporadora’s practices with respect to information collected from users who access our website at www.cello.pt or who otherwise share personal information with us. personally and/or collectively.

Fundamentals for data collection

The processing of your personal information, that is, all information that could potentially allow your identification with reasonable means, hereinafter referred to as "Personal Information", is necessary for the performance of our contractual obligations towards you, as well as to provide our services, to protect our legitimate interests and to comply with the legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to read the Privacy Policy and use it to make informed decisions.

Information Collected

We collect two types of data and information from Users:

The first type of information is non-identifiable, non-personally identifiable information relating to a User that may be made available or collected through your use of the Site (“Non-Personal Information”). We do not know the identity of a User from whom the Non-Personal Information was collected. Non-Personal Information that is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information about your activity on the Site (e.g., pages viewed, online navigation, clicks, actions, etc.).

The second type of information is Personal Information, which is individually identifiable information, that is, information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device information: We collect personal information from your device. Such information includes:

• Geolocation data;
• IP address;
• Unique identifiers (e.g. MAC address and UUID);
• and other information relating to your activity through the Site;
• Identifying information such as name, address, telephone number and email address;
• Navigation information such as IP address, browser type, operating system, internet service provider (ISP), pages visited, access time and other traffic information;
• Cookies and similar technologies are used to track and improve your experience on our website, personalize the content and ads displayed, as well as for analytical purposes.
• Information provided by third parties such as information about you from third party sources, social networks, business partners or analytics services.
• Registration Information When you register on our Site you will be asked to provide us with certain information, such as: full name; email or physical address; and other information.

Receiving information

We receive your Personal Information from various sources:

• When you voluntarily provide us with your personal data when registering on our Site;
• When you use or access our Site as part of your use of our services;
• From third-party providers, services, and public registries (e.g., traffic analysis providers).

We do not rent, sell, or share user information with third parties except as described in this Privacy Policy.

Use of Information

We use your personal information for the following purposes:

• Improve and Personalize the Site: We use the information collected to understand your preferences and provide relevant content.
• Communication: We may send you emails or other communications relating to our services and website updates.
• Marketing: We may use your data for marketing purposes, such as sending you promotional materials about our products and services.
• Analytics and Statistics: We use anonymous data for internal analytics and statistics about website usage.
• Legal Compliance: We may process your information to comply with legal or regulatory obligations.
• Communicate with you – sending you notices regarding our services, providing technical information and responding to any customer issues you may have;
• Communicate with you and keep you informed of our latest updates and services;
• Serve you advertisements when you use our Site (see more under "Advertising");
• Market our websites and products (see more in "Marketing");
• Statistical and analytical purposes to improve the Website.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliates and subcontractors.

In addition to the purposes mentioned in this Privacy Policy, we may share personal information with our trusted third-party providers, who may be located in different jurisdictions around the world, for any of the following purposes:

• Hosting and operation of our Website;
• Partners and Service Providers: We may share your information with business partners and service providers who assist us with business activities, such as website hosting, data analysis, and marketing campaigns.
• Business Transfer: In the event of a merger, acquisition, or sale of company assets, your information may be transferred to a third party as part of the transaction.
• Legal Compliance: We may share information to comply with legal obligations, legal process or governmental requests.
• Providing our services to you, including providing a personalized display of our Site;
• Storage and processing of such information;
• Serving you with advertisements and helping us measure the success of our advertising campaigns, as well as retargeting some of our users;
• Provide you with marketing offers and promotional materials relating to our Site and services;
• Conducting research, technical diagnostics or analytics;

We may also disclose information if we have a good faith belief that disclosing such information would be helpful or reasonably necessary to:

(i) comply with any applicable law, regulation, legal process or governmental request;

(ii) enforce our policies (including our Agreement), including investigations of potential violations thereof;

(iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;

(iv) to establish or exercise our rights to defend against legal claims;

(v) prevent harm to the rights, property or safety of us, our users, your own safety or that of third parties; or

(vi) for the purpose of collaborating with law enforcement authorities and/or if we deem it necessary to enforce intellectual property or other legal rights.

User rights

You can request to:

• Receive confirmation as to whether or not non-personal information about you is being processed and access your stored personal information, together with supplementary information;
• Receive a copy of the personal information you voluntarily and directly provided to us in a structured, commonly used and machine-readable format;
• Request rectification of your personal information that is under our control;
• Request deletion of your personal information;
• Object to us processing your personal information;
• Request restriction of processing of your personal information by us;
• Make a complaint to a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the above rights or would like to receive further information, please contact our Data Protection Office (“DPO”) using the details provided below:

geral@cello.pt

351934650275

Information retention

We will retain your Personal Information for as long as necessary to provide our services and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purpose for which it was collected, taking into account the requirements applicable to the situation and the need to destroy outdated, unused information as soon as reasonably possible. Subject to applicable regulations, we will retain records containing customer personal data, account opening documents, communications, and anything else in accordance with applicable laws and regulations.

We may rectify, replenish or remove incomplete or incorrect information at any time and at our sole discretion.

Cookies and Behavioral Advertising Policy

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A cookie is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for a variety of different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

The Site uses the following types of cookies:

a. "session cookies" which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;

b. “persistent cookies”, which are read only by the Website, saved on your computer for a fixed period and are not deleted when you close your web browser. These cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next time you log in;

c. “third party cookies” which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not function properly and your online experience may be limited. By using the Site, you consent to our use of cookies as described in our Cookie Policy.

We use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit the sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third-party information collection

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party to which you choose to disclose information.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage, including third parties to whom we may disclose information as set forth in this Privacy Policy.

Information Security

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the security of the information we collect and retain, prevent unauthorized use of any information, and require any third parties to comply with similar security requirements in accordance with this Privacy Policy. Although we take reasonable steps to protect information, we cannot be responsible for the acts of those who gain unauthorized access to or misuse our Site, and we make no warranty, express or implied, that we will prevent such access.

You have the right to access, correct, update, or delete your personal information. To exercise these rights or for any questions about our Privacy Policy, please contact us using the information provided in the Contact section of the website. Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies. You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services.

Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to contact us.

User Commitment

The user undertakes to make appropriate use of the content and information that the Website offers on the website and, by way of example but not limited to:

• Not to engage in activities that are illegal or contrary to good faith and public order;
• Do not disseminate propaganda or content of a racist, xenophobic nature, gambling, any type of illegal pornography, in support of terrorism or against human rights;
• Do not cause damage to the physical (hardware) and logical (software) systems of its suppliers or third parties, to introduce or disseminate computer viruses or any other hardware or software systems that are capable of causing the aforementioned damage.

Transfer of data outside the European Economic Area (EEA)

Please note that some data recipients may be located outside the EEA. In such cases, your data will only be transferred to countries approved by the European Commission as ensuring an adequate level of data protection, or we will enter into legal agreements that ensure an adequate level of data protection.

Advertisements

We may use third-party advertising technology to serve ads when you visit the Site. This technology uses your information regarding your use of the Services to serve you advertisements (e.g., by placing third-party cookies on your web browser).

You can opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, as well as your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or using our third party subcontractors for the purpose of providing you with promotional materials relating to our services, which we believe may be of interest to you.

Out of respect for your right to privacy, we provide you within such marketing materials with means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists.

 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transactions

We may share information in the event of a corporate transaction (e.g., sale of a substantial portion of our business, merger, consolidation, or asset sale). In the above case, the transferee or acquiring company will assume rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children's privacy, especially in an online environment. The Site is not designed for or directed to children. Under no circumstances shall we allow minors to use our services without the prior consent or authorization of a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at geral@cello.pt

Updates or changes to this privacy policy

We reserve the right to periodically modify or revise the Privacy Policy; material changes will be effective immediately upon the posting of the revised Privacy Policy. The latest revision will be reflected in the “Last Modified” section. Your continued use of the Platform following the notification of such changes on our website constitutes your acknowledgment and consent to such changes to the Privacy Policy and your agreement to be bound by the terms of such changes.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, please contact us by email: geral@cello.pt

CeLLo. Incorporator

This policy is effective as of July 21, 2023.