Privacy Policy

Disruptive Media Training

Disruptive media training respects all your personal data privacy and confidentiality. 

In this document you can find all information related to the way we treat your data respecting all RGPD (General data Protecting regulation ).

All data that you provide to Disruptive media training are treated and processed accordling with Data Protection Law nº 58/2019 that assure the execution in juridic nacional order, the regulation (UE) 2016/679 of parliament and council, of 27th April 2016.

We also inform that when you visit our website (www.disruptivemediatraining.com) doesn’t mean that we save your personal data. However, there are some computing data that are automatically saved in each access. 

In addition, there are some website areas that need some user personal information to provide the requested services. That data collection is done in a total clear way.

We reinforce that all collected information is only for Disruptive Media Training personal and exclusive use. 

We therefore undertake not to sell, exchange, rent or share to third parties without your consent, unless we are required to do so by a court order.

The following is a description of the type of data we collect, the processing to which they are subject and their usefulness for the services we provide. 

Entity Responsible for processing personal data

Disruptive Media Training Unipessoal LDA

Street

Agostinho Neto nº18J, 1750-006 Lisbon

Mobile

(+351) 913 401 376

general@disruptivemediatraining.com

https://disruptivemediatraining.com/

Purpose and data processing

Disruptive Media Training processes the following data:

1. Identification data (name, age, Tax ID number, email, mobile phone)

2. Issuing certificates sent by e-mail

3. Economic and transitional information (your payment details)

4. Connection, Geo-location and/or navigation data (IP address of the requesting processor, date and time of access; name and URL of the downloaded file; identification data of the browser software and operating system; website from which you accessed our site; name of the Internet service provider);

5. Commercial information (advertising of training offers through subscription to our newsletter).

6. Use of cookies, invisible pixels, google analytics, Facebook Pixel (includes information relating to Facebook and Instagram). This information is used for statistical purposes and to improve the user experience of the website.

 

In addition to this, the data collected is used solely for the following purposes:

1. Registration for training actions;

2. Issuing the appropriate accounting documents (invoices);

3. Sending certificates via email;

4. Providing supplementary information to trainees by email;

5. Providing, improving, testing and monitoring the effectiveness of our service;

For marketing purposes the purpose of processing your data is to:

6. Newsletter sending: we will process your data to manage your subscription, including sending you personalized information about our training and services via email;

7. Diagnosing technical problems and maintaining security: when you access our site a set of computer data is automatically collected. The collection of this data has purely technical purposes, such as connection configuration, system security, technical administration of the network and optimization of our services.

 

The personal data collected are processed electronically and in strict compliance with the legislation on personal data protection, and are stored in specific databases. 

We would also like to add that all data processed are protected via Internet network under secure SSL protocol, this type of communication is not inviolable but currently corresponds to the best market practices. 

Additionally, data is stored in databases managed by Disruptive Media Training in encrypted form.

Recipients:

The data collected is not transferred to third parties with the exception of data necessary to comply with legal obligations. For any other purpose not foreseen in this Privacy Policy, the data provided by you will not be publicly disclosed and may only be provided to third parties with your prior and express consent. 

Data Retention Term:

The personal data collected will be kept only for the period necessary to fulfil the purposes indicated above. 

1.  Specific Purposes with Term of Conservation:

Marketing: your data will be treated until you cancel your subscription to our newsletter;

Rights of the owners of personal data:

Under the terms of the law, the holders of personal data have the right to access, freely and without restriction, confirm, rectify, delete or block the data they have provided, and may exercise it in writing, via email, at any time and free of charge, under the terms of Law No. 58/2019 of 8 August 2019.

Right of Access (Art. 15 Data Protection Regulation)

“The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are subject to processing and, if so, the right to access his or her personal data and the following information:

1. The purposes of data processing;

2. The categories of personal data concerned;

3. The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or belonging to international organizations;

4.  When possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

5. The existence of the right to request from the controller rectification, erasure or restriction of processing of personal data concerning the data subject or the right to object to such processing;

6. The right to lodge a complaint with a supervisory authority;

7. If the data have not been collected from the data subject, the available information as to the origin of such data;

8. The existence of automated decisions, including profiling, as referred to in Article 22º, nº1 and nº4 and, at least in such cases, relevant information concerning the logic involved and the significance and expected consequences of the processing for the data subject. 

Right of rectification (Art. 16 Data Protection Regulation)

“The data subject shall have the right to obtain, without undue delay, from the controller the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of an additional declaration.”

Right to erasure of data ("right to be forgotten") (Art. 17 Data Protection Regulation)

1. The data subject shall have the right to obtain from the controller the erasure of his/her personal data without undue delay, and the controller shall have the obligation to erase the personal data without undue delay when one of the following grounds applies:

2. The personal data are no longer necessary for the purpose for which they were collected or processed;

3. The data owner withdraws the consent on which the data processing is based pursuant to Article 6º, nº1,  or Article 9º, nº2, line a) and there is no other legal ground for the processing;

4. The data subject objects to the processing pursuant to Article 21º, nº1, and there are no overriding legitimate interests justifying the processing, or the data subject objects to the processing pursuant to Article 21º, nº 2;

5. Personal data has been unlawfully processed;

6. The personal data must be erased for compliance with a legal obligation arising from Union or Member State law to which the controller is subject;

7. The personal data have been collected in the context of the provision of information society services referred to in Article 8º, nº1;

8. Where the controller has made the personal data public and is obliged to erase them pursuant to paragraph 1, it shall take reasonable steps, including technical measures, taking into consideration available technology and the cost of implementation, to inform the actual controllers of the personal data that the data subject has requested them to erase links to, and copies or replications of, those personal data.

9. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

10. The exercise of expression freedom and information;

11. The compliance with a legal obligation requiring processing under Union or Member State law to which the controller is subject, the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

12. On grounds of public interest relating to public health under Article 9º, nº2, line h) and i), and under article 9º, nº3;

13. For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Article 89º, nº1, in so far as the right referred to in paragraph 1 is likely to make it impossible or seriously undermine the achievement of the purposes of such processing; or

14. For the establishment, exercise or defence of legal claims.”

Right to Limitation of Processing (Art. 16 Data Protection Regulation)

“The data subject has the right to obtain from the controller the limitation of processing if one of the following applies:

1. Contesting the accuracy of personal data, for a period enabling the controller to verify their accuracy;

2. The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

3. The controller no longer needs the personal data for the purpose of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

4. When client has objected to the processing pursuant to Article 21º, nº1, until it is established that the legitimate grounds of the controller override those of the data subject. 

5. When processing has been restricted pursuant to paragraph 1, personal data may, with the exception of storage, only be processed with the data subject’s consent, or for the establishment, exercise or defence of legal claims, for the rights protection of another natural or legal person, or for reasons of substantial public interest of the Union or of a Member State.”

6. The data subject who has obtained the limitation of processing pursuant to paragraph 1 shall be informed by the controller before the limitation to such processing is lifted.”

Right to Data Portability (Art. 20 Data Protection Regulation)

“1. The data subject shall have the right to receive personal data that  has provided to a controller, in a structured, commonly used and machine-readable format, and the right to transmit such data to another controller without the controller to whom the personal data have been provided being able to prevent this, if:

The processing is based on consent given pursuant to Article 6º, nº1, line a) or article 9º, nº2, line a) or a contract referred to in Article 6º, nº1, line b); and the processing is carried out by automated means.

2.When exercising your right to data portability under paragraph 1, the data subject shall have the right to have personal data transmitted directly between controllers, where technically feasible.

3.The exercise of the right referred to in paragraph 1 of this article shall apply without prejudice to article nº17. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4.The right referred to in paragraph 1 shall be without prejudice to others rights and freedoms.”

Right to object (Article 21 Data Protection Regulation)

1. The data subject shall have the right to object at any time, on grounds relating to the particular situation, to the processing of personal data concerning on the basis of Article 6º, nº1 line e) or f) or Article 6º, nº4), including profiling on the basis of those provisions. The controller shall cease processing the personal data, unless the controller demonstrates compelling legitimate grounds for such processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

2. When personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to direct marketing.

3. When the data subject objects to the processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication to the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and without prejudice to Directive 2002/58/EC, the data subject may exercise the right to object by automated means, using technical specifications.

6.When personal data are processed for scientific or historical research purposes or statistical purposes as referred to in article 89º, nº1), the data subject shall have the right to object, on grounds relating to particular situation, to the processing of personal data concerning, unless the processing is necessary for the performance of a task carried out in the public interest.”

Right to Notification of Rectification or Erasure of Personal Data (Article 19 of the Data Protection Regulation)

“The controller shall notify each recipient to whom personal data have been transmitted of any rectification or erasure of personal data or restriction of processing carried out in accordance with article 16º, article 17º, nº1) and Article 18, unless such notification proves impossible or involves a disproportionate effort. If the data subject so requests, the controller shall provide the information on those recipients”.

Right to Withdraw Consent (Paragraph 3. art. 7 Data Protection Regulation)

“The data subject has the right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of the consent previously given. Before giving consent, the data subject shall be informed thereof. Consent shall be as easy to withdraw as it is to give…”

Automated individual decisions, including profiling. (Art. 22 Data Protection Regulation)

“1. The data subject shall have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2. Paragraph 1 shall not apply if the decision:

Is necessary for the conclusion or performance of a contract between the data subject and a controller;

Is authorized by Union or Member State law to which the controller is subject and which also provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject;

Is based on the explicit consent of the data subject.

3. In the cases referred to in paragraph 2º, line a) and c), the controller shall implement suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, in particular the right to at least obtain human intervention on the part of the controller, to express point of view and to challenge the decision.

4. The decisions referred to in paragraph 2 shall not be based on the special categories of personal data referred to in Article 9º, nº1), unless paragraph 2, line a) or g) of that article applies and appropriate measures are applied to safeguard the rights and freedoms and legitimate interests of the data subject.”

Right to lodge a complaint with a supervisory authority (Art. 77 Data Protection Regulation)

“1.Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of habitual residence, place of work or place of the alleged offence, if the data subject considers that the processing of personal data relating infringes this Regulation.

2.The supervisory authority with which a complaint has been lodged shall inform the complainant of the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 “.

3. We inform you that you may submit a complaint to the National Commission for Data Protection (CNPD), the competent authority for data protection in particular:

-CNPD: Avenue D. Carlos I, 134 – 1.º 1200-651 Lisbon

Tel: +351 213928400

Fax: +351 213976832

E-mail: geral@cnpd.pt

https://www.cnpd.pt/Duvidas/Duvida_participacao.aspx

In the terms of the Personal Data Protection Law, the data subject is guaranteed the mentioned rights, which can be exercised before the controller, namely through two mechanisms:

– Contacting Disruptive Media Training directly, by telephone, email (geral@disruptivemediatraining.com) or in person at our premises;

Alteration to Privacy and Cookie Policy

Disruptive Media Training may change the provisions set out in its Privacy and Cookie Policy when it deems appropriate, in line with the standards set out in EU and national legislation in force. We therefore suggest that you review our Privacy and Cookie Policy from time to time, as in the event of minor changes or significant improvements, you will find this information on our website.

Cookies Policy
Definition:

Cookies are small files, with alphanumeric information, stored on the hard drive of your personal computer, mobile phone or other device, containing information relating to your browsing on that website.

Our Cookie Policy

The use of cookies are to improve the users experience in our website, allowing the analysis of the use of the website, in order to optimize the functionalities therein. We inform you that we use the Analytics service provided by Google and Facebook Pixar to improve the quality/performance of the website, recording only generic information of the accesses received, using anonymous cookies for this purpose. If you wish to consult our website without using cookies, you must change the appropriate setting in your browser options, for this purpose you can consult the “Help” menu of your browser to find out the correct way to change or update cookies. However, if you set your browser to reject all cookies, this may limit the use of some features of our site.

External links

Our Privacy and Cookie Policy applies to our website only. However, this website contains links to partner websites. Linking to these sites always requires the user to click on the link. It is absolutely impossible for Disruptive Media Training to guarantee that the data protection practices of the respective entities comply with the law and our ethical requirements. Therefore, Disruptive Media Training cannot be held responsible for the content or privacy policy of external sites, and the owners of such sites are solely responsible for any damage or wrongdoing caused by visiting such sites.

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