WHO ARE WE?
We are ESCRITASAPIENS, located on the island of Faial in the Azores. Our main activity is accounting, administrative management of human resources and taxation.

WHY THIS PRIVACY AND PERSONAL DATA PROTECTION POLICY?
This Policy is intended to inform “ESCRITASAPIENS” Customers/Users of the general rules on privacy and the processing of personal data, which are collected and processed in strict compliance with the provisions of the personal data protection legislation in force at all times, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“”GDPR””).
“ESCRITASAPIENS” respects best practices in the field of security and protection of personal data, and to this end has taken the necessary technical and organisational measures to comply with the GDPR and ensure that the processing of personal data is lawful, fair, transparent and limited to the authorised purposes.
“ESCRITASAPIENS” is committed to the protection and confidentiality of personal data and has adopted the measures it deems appropriate to ensure the accuracy, integrity and confidentiality of personal data, as well as all other rights of the respective data subjects.

WHAT DOES THIS POLICY COVER?
This Policy applies exclusively to the collection and processing of personal data for which “ESCRITASAPIENS” is responsible, within the scope of the services and products made available to its Customers/Users and in all situations in which personal data is processed.

WHAT IS PERSONAL DATA?
Personal data is any information of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable natural person.
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, location data, an electronic identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

WHAT DOES THE PROCESSING OF PERSONAL DATA CONSIST OF?
The processing of personal data consists of an operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, namely collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, restriction, erasure or destruction.

WHO IS THE DATA CONTROLLER?
The entity responsible for processing personal data is “ESCRITASAPIENS”, which determines the purposes and means of processing them.
To this end, if the owner of the personal data needs to contact the data controller, they can do so through the following means and contact details: geral@escritasapiens.pt

WHAT TYPES OF PERSONAL DATA ARE PROCESSED?
As part of its activities, “ESCRITASAPIENS” processes the personal data necessary to provide services, processing data such as name, address, telephone number and e-mail address in accordance with the information provided by the personal data subjects.
Personal data may also be processed for marketing purposes, the dissemination of offers of goods or services or requests for quotes from “ESCRITASAPIENS”, if the data subject has authorised this.
If the data subject has given their prior consent, this may be withdrawn at any time, without jeopardising the lawfulness of the processing carried out on the basis of the consent previously given.
WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?
ESCRITASAPIENS” collects your personal data, in particular by telephone, in writing and via its website, guaranteeing, where necessary, the prior consent of the holder of the personal data.
Some personal data is essential for the performance of the contract, without which
“ESCRITASAPIENS” will not be able to provide the product or service in question.
If the holder of the personal data is not a Customer/User of “ESCRITASAPIENS”, their personal data will only be processed when it is made available, in which case the rules of this Policy will apply.
The personal data collected may be processed by computer and in an automated or non-automated way, in all cases guaranteeing strict compliance with personal data protection legislation, being stored in specific databases created for this purpose and, under no circumstances, will the data collected be used for any purpose other than that for which it was collected or consent was given by the data subject.
WHO ARE THE RECIPIENTS OF PERSONAL DATA?
Without prejudice to the recipients indicated throughout this Policy, “ESCRITASAPIENS” may communicate the personal data of the Customer/User for the purpose of complying with legal obligations, namely to police, judicial, tax and regulatory entities.
WHAT ARE THE PURPOSES FOR PROCESSING PERSONAL DATA AND THE LEGAL GROUNDS FOR DOING SO?
In general, the personal data collected is based on and intended for the management of the contractual and commercial relationship, the provision of the contracted services, the adaptation of the services to the needs and interests of the Client/User, namely for the purposes of access to specific functionalities of the services, information and marketing actions.
In addition, personal data may also be processed for the purposes of complying with legal obligations.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
The length of time for which personal data is stored and retained varies according to the purpose for which the information is processed.
In fact, there are legal requirements that oblige data to be kept for a minimum period of time. Therefore, whenever there is no specific legal requirement, the data will only be stored and kept for the minimum period necessary to fulfil the purposes for which it was collected or subsequently processed, under the terms defined by law.
WHAT ARE YOUR RIGHTS AS A HOLDER?
As holders of personal data, Customers/Users are guaranteed, at any time, the right to access, rectify, update, limit and erase their personal data (except for data that is indispensable for the provision of services by “ESCRITASAPIENS” or for the fulfilment of legal obligations to which the controller is subject), the right to object to its use for commercial purposes by “ESCRITASAPIENS” and to withdraw 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, ERASE, OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA, OR WITHDRAW CONSENT?
Without prejudice to the provisions of the GDPR, the holder of personal data may do so, directly or by written request, addressed to the respective Data Controller, through the contacts provided for this purpose in this document, as well as other contacts provided by “ESCRITASAPIENS”.
HOW CAN YOU OBJECT TO RECEIVING CONTACTS FOR MARKETING PURPOSES?
“ESCRITASAPIENS” may promote actions to publicise new products or services to its Customers/Users, namely by telephone, e-mail, SMS or any other electronic communications service, if the holder of the personal data has given their consent.
If the data subject no longer wishes to receive these communications, they may withdraw their consent to the use of their data for marketing purposes at any time.
HOW CAN YOU COMPLAIN?
Without prejudice to being able to submit complaints directly to “ESCRITASAPIENS” through the contacts made available for this purpose, the Customer/User can complain directly to the Supervisory Authority, which is the National Data Protection Commission (CNPD), using the contacts made available by this entity for this purpose.
WHAT MEASURES DOES ESCRITASAPIENS TAKE TO ENSURE THE SECURITY OF YOUR PERSONAL DATA?
“ESCRITASAPIENS” is committed to guaranteeing the protection of the security of the personal data made available to it, and has approved and implemented strict rules in this regard. Compliance with these rules is an obligation of all those who legally access them.
Bearing in mind the concern and commitment that “ESCRITASAPIENS” shows in defending personal data, various technical and organisational security measures have been adopted to protect the personal data made available to it against its dissemination, loss, misuse, alteration, unauthorised processing or access, as well as against any other form of illicit processing.
In addition, third parties who, in the context of the provision of services, process the personal data of the Client/User in the name and on behalf of “ESCRITASAPIENS”, are obliged, in writing, to implement appropriate technical and security measures which, at all times, meet the requirements of current legislation and ensure the defence of the rights of the data subject (in particular, the protection of privacy and personal data).
UNDER WHAT CIRCUMSTANCES IS DATA COMMUNICATED TO OTHER ENTITIES (THIRD PARTIES AND SUBCONTRACTORS)?
As part of its activity, “ESCRITASAPIENS” may use third parties to provide certain services. Sometimes, the provision of these services implies access by these entities to the personal data of Customers/Users. When this is the case, “ESCRITASAPIENS” takes appropriate measures to ensure that the entities that have access to the data are reputable and offer the highest guarantees at this level, which is duly enshrined and contractually safeguarded between “ESCRITASAPIENS” and the third party(ies).
Thus, any entity subcontracted by “ESCRITASAPIENS” will process the personal data of our Customers/Users in the name and on behalf of “ESCRITASAPIENS” and will adopt the necessary technical and organisational measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access and against any other form of unlawful processing.
In any case, “ESCRITASAPIENS” remains responsible for the personal data made available to it. In
this case, “ESCRITASAPIENS” uses Mailchimp as a marketing platform. By agreeing to our policies, you recognise that your information will be transferred to Mailchimp. Find out more about Mailchimp’s privacy policies here https://mailchimp.com/legal/.
You can unsubscribe at any time by clicking on the link in the footer of our emails. For more information on our privacy policies, please visit our website.
UNDER WHAT CIRCUMSTANCES DO WE TRANSFER YOUR PERSONAL DATA?
The provision of certain services by “ESCRITASAPIENS” may involve the transfer of your data outside Portugal, including outside the European Union or to International Organisations.
In this case, “ESCRITASAPIENS” will strictly comply with the applicable legal provisions, in particular with regard to determining the suitability of the country or countries of destination with regard to the protection of personal data and the requirements applicable to such transfers, including, where applicable, the conclusion of appropriate contractual instruments that guarantee and respect the legal requirements in force.
HOW DO WE USE COOKIES?
“Cookies” are small software tags that are stored on the computer via the browser, retaining only information related to preferences and therefore not including personal data.
To find out more about cookies and how “ESCRITASAPIENS” uses them on its website, see the section below “ABOUT COOKIES”.
HOW CAN YOU FIND OUT ABOUT ANY CHANGES TO THE PERSONAL DATA PROTECTION POLICY?
ESCRITASAPIENS reserves the right to make adjustments or changes to this Personal Data Protection Policy at any time.