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PRIVACY POLICY

INTRODUCTION

With this Privacy and Personal Data Protection Policy, ANYWHERE EVERYWHERE, LDA, a private limited company registered with the Commercial Registry under corporate identification number 513.690.450, with its registered office at Travessa da Gândara - Vale do Senhor, 3750–727 Recardães, union of parishes of Recardães and Espinhel, hereinafter referred to as “ANYWHERE EVERYWHERE”, intends to inform its Clients/Users about the policies and procedures regarding the collection, use, processing, and disclosure of any personal data provided directly by its Clients/Users or through third parties, through the use of its website – www.anywhere-everywhere.pt.

ANYWHERE EVERYWHERE respects the privacy of its Clients/Users and is committed to protecting the information it collects, as well as complying with all legal standards in force, as defined by the General Data Protection Regulation (GDPR).

Access to and use of the website implies agreement, acceptance, and binding of the users to this privacy and data protection policy.


1. WHO ARE WE?

ANYWHERE EVERYWHERE is a private limited company whose business purpose includes the marketing of professional audiovisual equipment and audiovisual content and software for such equipment; the sale and management of advertising spaces on panels; consultancy and training in marketing and communication; and the provision of institutional and promotional communication solutions.

ANYWHERE EVERYWHERE is committed to protecting the personal data of its Clients and Users of the products and services it provides, as well as the personal data of all respective data subjects, in any situation where personal data processing occurs.


2. NEED FOR THIS POLICY

Through this policy, ANYWHERE EVERYWHERE intends to inform its Clients and Users about the general rules governing the processing of personal data, which are collected and processed in strict compliance with the legislation in force at each moment, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”), as well as any other applicable legislation, particularly Law no. 58/2019 of 8 August.

ANYWHERE EVERYWHERE has adopted measures deemed appropriate to ensure the accuracy, integrity, and confidentiality of personal data, as well as to safeguard all other rights of the respective data subjects.

ANYWHERE EVERYWHERE follows best practices in the field of data security and protection and has implemented the necessary technical and organisational measures to ensure compliance with the GDPR, guaranteeing that the processing of personal data is lawful, fair, transparent, and limited to the authorised purposes under the GDPR and other applicable legislation.

This Privacy and Data Protection Policy complements the data protection provisions included in contracts entered into or to be entered into between Clients/Users and ANYWHERE EVERYWHERE, as well as the rules set out in the terms and conditions governing the various services offered and duly published on our website.


3. SECURITY MEASURES FOR PERSONAL DATA

ANYWHERE EVERYWHERE has implemented an internal security policy and rules concerning the processing of personal data.

These rules bind not only ANYWHERE EVERYWHERE but also all those who have access to the data, namely employees, collaborators, and service providers. Such technical and organisational measures aim to protect personal data against dissemination, loss, misuse, alteration, unauthorised access, or any other form of unlawful processing.

Third parties that process personal data on behalf of ANYWHERE EVERYWHERE (data processors) are also bound by written agreement to adopt adequate technical and security measures that meet GDPR requirements and protect the rights of data subjects.

Within ANYWHERE EVERYWHERE’s internal security policy, all online personal data collection methods are encrypted and securely stored, and physical and logical security measures have been implemented.

However, ANYWHERE EVERYWHERE’s efforts do not exempt Clients/Users from adopting their own online security measures (firewalls, antivirus, anti-spyware, website authenticity tools, etc.).


4. WHAT ARE PERSONAL DATA?

For the purposes of Article 4(1) of the GDPR, “personal data” means any information relating to an identified or identifiable natural person (“data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


5. WHAT IS PERSONAL DATA PROCESSING?

According to Article 4(2) of the GDPR, “processing” means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


6. WHO IS RESPONSIBLE FOR DATA PROCESSING?

ANYWHERE EVERYWHERE is the data controller, determining the purposes and means of processing personal data at all times.

For matters relating to this policy or the GDPR, data subjects may contact ANYWHERE EVERYWHERE via email at dpo@anywhere-everywhere.pt or by written communication addressed to the company’s registered office:
Travessa da Gândara - Vale do Senhor, 3750–727 Recardães.


7. IS THERE A DATA PROTECTION OFFICER?

ANYWHERE EVERYWHERE has appointed a Data Protection Officer (DPO), in accordance with Articles 37 and following of the GDPR.

The DPO for ANYWHERE EVERYWHERE is Paulo Barrocas, who may be contacted via email at dpo@anywhere-everywhere.pt.


8. TYPES OF PERSONAL DATA THAT MAY BE PROCESSED

Considering the activities carried out by ANYWHERE EVERYWHERE, the company processes personal data necessary for service provision or for social responsibility activities, including name, address, telephone number, email, citizen card number, and tax identification number.

The amount of data collected will depend on the information provided by the Client/User.

Except where required to comply with legal obligations, all data will be processed exclusively by ANYWHERE EVERYWHERE, strictly to the extent necessary for its activity, allowing the Client/User to access, for example, specific service features, suggestions, and proximity information services.

Traffic, geographic location, profile and/or consumption data may also be processed for advertising or promotional purposes, provided that the data subject has given prior consent.

Consent may be withdrawn at any time, without affecting the lawfulness of processing based on previously given consent. To withdraw consent, users may contact dpo@anywhere-everywhere.pt.


9. PROCESSING BY SUBCONTRACTORS

In its activities, ANYWHERE EVERYWHERE may rely on third parties to provide certain services, which may require access to Clients’/Users’ personal data. When this occurs, ANYWHERE EVERYWHERE ensures that subcontractors comply with the GDPR and other applicable legislation, as well as with internal security standards.

Even when data are communicated to other entities, ANYWHERE EVERYWHERE remains responsible for those personal data.


10. USE OF PERSONAL DATA

Personal data are intended solely for ANYWHERE EVERYWHERE and may only be shared with third parties when required to comply with legal obligations.


11. COLLECTION OF PERSONAL DATA

ANYWHERE EVERYWHERE collects personal data via telephone, email, contractual engagement, and through its website, always ensuring the prior consent of data subjects.

Some personal data are essential for service execution, and failure to provide them may compromise the provision of services.

This policy applies to all data subjects, regardless of whether they are Clients/Users.

Personal data may be processed in automated or non-automated systems.

ANYWHERE EVERYWHERE ensures compliance with the GDPR and applicable legislation. Personal data are stored in secure databases and will never be used for purposes other than those for which they were collected or for which consent was granted.


12. PURPOSES OF DATA PROCESSING

In general, personal data collected are used to manage contractual relationships, provide contracted services, adapt services to Client/User needs, and for information and advertising actions.

Data may also be used — with the data subject’s consent — for social responsibility actions, handling complaints and suggestions, providing information about campaigns, promotions, products and services, or conducting market studies and satisfaction surveys.


13. RETENTION OF PERSONAL DATA

The retention of personal data is linked to the purpose for which they were collected and processed.

Except where a legal obligation requires otherwise, personal data will be retained only for the minimum period necessary for the purposes for which they were collected.


14. TRANSFER OF PERSONAL DATA

ANYWHERE EVERYWHERE undertakes not to transfer personal data, except where such transfer is made to subcontractors/partners under the terms of this policy and in full compliance with the GDPR and applicable legislation.

This does not prevent the data subject from exercising the right to data portability, if applicable.


15. YOUR RIGHTS AND HOW TO EXERCISE THEM

As a data subject, ANYWHERE EVERYWHERE guarantees you the right to access, rectify, update, restrict, and erase your personal data at any time (except for data essential for service provision during an ongoing contractual/commercial relationship).

You are also entitled to object to the use of your personal data for commercial purposes, to withdraw consent, and to exercise the right to data portability. ANYWHERE EVERYWHERE ensures the full exercise of all rights granted under the law to data subjects.

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