Data protection policy
Hivecity, Lda based on Júlio Dinis Avenue, nº 2, 2nd floor Left – 1050-131 Lisbon with the Fiscal and VAT number 513 653 619 (hereby “Hivecity”).

While executing its activities, Hivecity proceeds personal data treatment, meaning, all information regarding a identifiable person (henceforth “data owner(s)”) considering identifiable a singular person that may be identified, directly or indirectly, specially by reference to an identifier, like for example a name, an identification number, location data, electronic identifiers or one or more specific elements regarding physical, physiological, genetic, mental, economic, cultural or social identifiers of that singular person.
Hivecity, in the cases where the purpose and means of personal data treatment in the scope of its activities is determined, will be considered responsible for the data treatment , assuring the compliance of the Data Protection Legislation.

According to the referred legislation, Hivecity stands for the treatment of personal data according to all applicable principals known as: i) Legality, Loyalty and Transparency Principle; ii) Purpose Limitation Principle; iii) Data Minimization Principle; iv) Accuracy Principle; v) Conservation Principle and Integrity and Confidentiality Principle.

In total harmony with the referred principles, Hivecity integrally respects the protection rights of the data owners regarding their personal data. Data owners may contact Hivecity to obtain any information related to the treatment of personal data through the contact information provided.

Considering the above, it is established in the present Data Protection and Privacy Policy as per the Regulation (UE) 2016/679 of the European Parliament and the Council of the 27th of April of 2016 (henceforth “Data Protection Legislation”), that Hivecity compromises to conduct all operations regarding data treatment according to the disposed and in the terms of the following paragraphs:

Legality Fundamentals – What do they consist of?
Consent
Hivecity may treat Personal Data with the Data Owner’s consent for the respective treatment through a free, specific, informed and explicit will manifestation that accepts, via a declaration (by writing or verbally) or via a positive and unambiguous action (by filling in a option), that agrees that your Personal Data can be an object of treatment.

Pre-contractual diligences or contract execution
Hivecity may treat Personal Data if these are necessary, without limiting, in the execution of a contract for service provision and/or product supply in which Hivecity takes part as a Collaborator, Client and/or Supplier, or to perform requested pre-contractual diligences.

Compliance of a legal obligation
Hivecity may treat Personal Data to assure and guarantee the compliance of legal obligations to which Hivecity is liable before the legislation of a Member of the State and/or of the European Union
Defence of the data owner’s vital interests

Hivecity may treat Personal Data in order to assure the defence of Hivecity’s vital interests, if the same treatment is essential to Hivecity’s life.

Legitimate interests
Hivecity, others Responsible or Third Parties, may treat Personal Data under the circumstance that the same treatment will not prevail Hivecity’s interests or rights and fundamental liberties.

1.Legality Fundamentals and Data Treatment Purposes

Hivecity will treat the Data Owner’s personal data with the following legality fundamentals:
Regarding the previously mentioned, the collecting of personal data based on the exposed legality fundamentals will be essentially for Hivecity’s activity development related purposes, such as consultancy activities for business and management, studies, economic-financially viable projects, due-diligence compliance, human resource management, training, architectural and engineering studies and projects and other scientific, technical and similar non-specific consultancy activities. Other than the referred activities, the analysis and investment in real estate assets, as well as the purchase and sale of rustic, mixed and urban buildings, leasing or any other property related business and the management of owned or third-party property, are also integrated as such. Lastly,
In effect, from the legality fundamentals, those most frequently applied are Hivecity’s contract implementation and the compliance of legal obligations meaning that not collecting personal data would imply an impossibility in fulfilling the purposes for which the personal data are object of treatment.

2.Treatment methods
The treatment of user’s personal data will be processed automatically and manually by computing instruments, applying strictly purpose related logic and, in any case, assuring the safety and confidentiality of the personal data.

3. Personal Data Disclosure and Transmission
About the disclosure and transmission of personal data, Hivecity’s collaborators will proceed to treat the personal data meaning they will have access to the Data owner’s personal data. The mentioned Hivectiy’s collaborators will treat the Data Owner’s personal data exclusively for the purposes explicit on the present Policy and in strict compliance with the current or future Data Protection Legislation.
Third parties that may treat personal data under Hivecity’s responsibility may equally access the Data Owner’s personal data as subcontractors including, without limiting, the IT service providers necessary to the functioning of information systems, outsourcing service providers or cloud computing services, professionals and consultors.
The Data Owners have the right to obtain a complete and updated list of the subcontractors (if existent) appointed by Hivecity, by sending a specific request to Hivecity under the terms specified in the 7th paragraph of the present Policy.

4.Data Owner’s Rights
In the terms of the current or future Data Protection Legislation, Hivecity informs Data Owners of their access, rectification, limitation, portability, and deletion rights and the right to oppose, in certain circumstances, to the Personal Data Treatment that can be exerted under the terms of the present chapter of the Data Protection and Privacy Policy.

Rights – What do they consist of?
Right to information provision Data Owners have the right to obtain clear, transparent and understandable information about how Hivecity uses their Personal Data and their rights. For that reason, Hivecity provides all this information in the present Data Protection and Privacy Policy.

Access right
The Data Owner has the right to obtain information about the Personal Data treated (if needed) by Hivecity and certain information (similar to those provided on the present Privacy Policy) about how the Data is treated. This right allows the Data Owner to acknowledge and confirm that we use their Data in conformity with the Data Protection Legislation.

Hivecity can refuse the supply of the required information in any situation that implies revealing Personal Data of another person or information that negatively impacts the rights of another person.

Rectification right
If the Data Owner’s Personal Data is incorrect or incomplete (for example, if their name or address are incorrect), a request may be conducted so that Hivecity takes the reasonable measures to correct said errors.

Data deletion right
This right, also known as “right to be forgotten” allows the Data Owner to require the deletion or elimination of their data as long as there is no longer existing fundamental purpose for Hivecity to pursue using them or for illicit use. Elimination does not consist a generic right for there are exceptions (for example, anytime the data is necessary in defence of rights in trial).

Treatment limitation right
The Data Owner has the right to “block” or prevent the future use of their Data whilst Hivecity evaluates a rectification request or as an alternative to deletion. In any circumstance where the Treatment is limited, Hivecity is still allowed to collect your data but unable to further use it. Hivecity keeps a list of the Data Owners who requested this “block” of future use of their data to assure that the limitation is respected.

Data portability right The Data Owner has the right to obtain and reuse certain Personal Data for their own purposes in various organizations. This right applies only to the Owners Data supplied to Hivecity and treated by Hivecity with consent as well as the data treated by automated means.

Opposition right
The Data Owner has the right to oppose to certain types of treatment for reasons related to their particular situation, at any time that treatment takes place for Hivecity’s or third-party legitimate interests. Hivecity may continue to treat said Data if proven for “prepondering legitimate reasons for treatment that surpass their interests, rights and liberties” or if the Data is necessary for the establishment, the exercise or in defence of rights in trial.

Complaint right The Data Owner has the right to file a complaint to the competent control authorities, the Nacional Data Protection Commission (Comissão Nacional de Protecção de Dados – CNPD) if the Treatment concerning Personal Data is considered to violate their rights and/or the Data Protection Legislation.

You may at any moment, by writing, exert the consecrated rights of the Data Protection Legislation and any applicable legislation via the methods described in the present Policy.

5.Safety and Confidentiality
To guarantee the safety and confidentiality of the personal data collected by Hivecity, the data bases used are protected with appropriate firewalls and passwords, according to the dispositions of the current or future Data Protection Legislation and further legal terms. The access to personal data is restricted to the justified use by authorized staff, according to the safety and confidentiality principles.
Violations against the Privacy Policy on behalf of Hivecity’s staff may lead to disciplinary action. Hivecity’s team is monitored and verified periodically as to assure the conformity with the rules and procedures.

6.How to contact Hivecity concerning Privacy and Data Protection
The Data Owners may exert their rights by contacting Hivecity via the following methods:
i)Registered post with notice of receipt to the address: Avenida Júlio Dinis, nº2, 2ºEsq. – 1050-131 Lisboa – Portugal
ii)Electronic mail to the inbox of hivecity@hivecity.pt
CONSUMPTION LITIGATIONS
In case of litigation, the consumer may appeal to a Consumption Litigation Resolving Entity
For more information:
www.centroarbitragemlisboa.pt