Privacy Policy

Your privacy is important to us!

This website is managed and administered by SCORPION CIRCLE, a continuous work to guarantee the protection of personal data provided by the user, treating the information under the terms provided for in Portuguese law 58/2019 and 59/2019 of 8 August 2019, in line with the directive ( EU) 2016/680 of April 27, 2016 and the Brazilian law LGPD (General Data Protection Law) No. 13.709 / 2018. As well as applying best cybersecurity and data protection practices, described in ISO / IEC 27001: 2013, ISO / IEC 27701: 2019, ENISA, NIST CSF, Cert RMM, among other good market practices.

This privacy policy describes:

• Who is responsible for my personal data?
  What personal data is processed by SCORPION CIRCLE?
• How long will my personal data be kept?
• How do I keep my personal data?
• What entities can my personal data be sent to?
• What are my rights?
• Usage of external Services
• How can I find out about any changes to this privacy policy?

1. Who is responsible for my personal data

Your data will be processed by SCORPION CIRCLE LTD, No. 514 129 395, with address in Estrada de Moscavide 60A, Lisbon, Portugal telephone number + (351) 300 509 569.

You can contact us and our responsible for the protection of your data through the email scorpion@scorpion.pt.

2. What personal data is processed by SCORPION CIRCLE?

Origin of collection Purpose Legal basis Personal data
Data retention period

• Website / E-mail / Social networks Commercial communication Consent Full name 12 months
• Website / E-mail / Social networks Commercial communication Consent E-mail 12 months
• Website / E-mail / Social networks Commercial communication Consent Telephone 12 months
• Website Access survey analysis Consent IP address 12 months
• E-mail / Internal system Execution of a project Legitimate interest Full name Duration of the project
• E-mail / Internal system Execution of a project
• Legitimate interest E-mail Duration of the project
• E-mail / Internal system Execution of a project
• Legitimate interest
• Telephone Duration of the project

3. How long will my personal data be kept?

The period of time during which your personal data is stored and maintained varies depending on the purpose for which the data was collected.

Thus, your personal data collected for the purpose of marketing / commercial will be kept for a maximum period of 12 months from the last contact made, and if, within this period, you have not withdrawn your consent.

The personal data collected for the billing of the projects carried out will keep your personal data for the entire term of our business relationship and after the end of the contract we have to store it for a period of 10 years.

The data collected for the execution of a project will be kept for the period necessary for the execution of the same, as defined in a commercial contract.

4. How do we keep your personal data?

Our obligation is to keep your data safe, and we apply appropriate security measures to ensure that the protection of your personal data and prevent access to unauthorized persons. We subject our security systems and policies to periodic reviews to ensure that the data is safe and protected.

SCORPION CIRCLE is committed to applying safe practices, based on ISO / IEC 27001: 2013, recommendations from CNCS, NIST CSF and Cert RMM.

5. What entities can my personal data be sent to?

We only send data to third parties without your consent when required by law or judicial authority.

However, the processing of your personal data may be carried out by service providers, who act on our behalf, namely marketing and digital and social media agencies, accounting management services, auditors and lawyers, external entities as suppliers SaaS platforms, hosting and maintenance services. Some of these providers have their headquarters located outside the EEA, which implies an international sharing of your data, however we always take the necessary safeguards to guarantee the safe treatment of your data, through contracts concluded containing contractual clauses and application of secure controls defined by best practices for digital privacy and cybersecurity, as defined in item 4.

6. What are my rights?

As the data owner, you can exercise the following rights, within the legally established limits:

• Right of access to your personal data to know what data is being processed and the processing operations of your personal data;
• Right to rectify any of your inaccurate or outdated personal data;
• Right to erase your personal data;
• Right to object, that is, to request that your personal data not be processed, for reasons related to your personal situation;
• Right to withdraw your consent at any time, when this was the legal basis for the processing of your data;
• Right to request to limit the processing of your personal data in the following cases: If you dispute the accuracy of your data, for a period that allows SCORPION CIRCLE to verify its accuracy.

The processing of certain data is illegal and you object to the deletion of the data, requesting, in return, the limitation of its use.

When SCORPION CIRCLE no longer needs to process your data, but you request it for the purposes of declaring, exercising or defending a right in a judicial process.

When you oppose the processing of your data by SCORPION CIRCLE based on a legitimate interest, while checking whether the legitimate interest invoked prevails over the reasons invoked by the owner.

Right to portability, that is, to receive the personal data you have provided in a structured format, in common use and mechanical reading, and to transmit them to another controller.

To exercise these rights, you can send a written request to the contact indicated in the section “Who is responsible for my personal data?”.

To exercise your rights, you must indicate in your request your name and the right you are exercising.

If you believe that there has been a violation of the data protection legislation in force with regard to the processing of your personal data, you also have the right to file a complaint with the National Data Protection Commission (CNPD) – https: / /www.cnpd.pt/.

7. Usage of external Services

This Privacy Policy covers usage of the following external Services; unless specified otherwise:

* WhatsApp;
* Teams;
* Zoom

8. How can I find out about any changes to this privacy policy?

SCORPIONCIRCLE reserves the right, at any time, to make changes or updates to this Privacy Policy, these changes being duly updated on the website https://scorpioncircle.com.

We suggest that you check them regularly to be aware of any changes.

Updated 07 August 2023