PRIVACY POLICY

Effective Date: March 06, 2025

This Privacy Policy together with Term of Use[1] constitutes a legally binding agreement between VOITA LDA, a Limited Liability Company incorporated and registered in Portugal under registration number 517185350, with its registered address at RUA ALFREDO VITORINO DA COSTA, 72, SÃO JOÃO DA TALHA, LISBOA. Zip:2695-772 (referred to as "we," "us", “Company” or "our"), and users of the website available at[2] voitalda.com (referred to as the "Website"). We serve as the controller of your personal data processed through the Website, meaning we determine the purposes and methods of processing your personal data.

This Privacy Policy explains how we collect, store, process, and use your personal data when you use our Website. By accessing or using the Website, you agree to the terms outlined in this Privacy Policy.

We encourage you to review this Privacy Policy regularly whenever you use the Website or otherwise interact with us by email, mail, phone, or other communication methods. If you do not agree with this Privacy Policy, please do not access or use the Website.

Categories of Information Processed

1.1. Information You Submit

We process certain personal information you provide when using the Website. This information is essential for fulfilling the contract between you and us, allowing us to provide the Website’s full functionality and the requested services.

This includes your name, email address, and any additional content in the email you send when contacting us at info@voitalda.com. We use this information to respond effectively to your inquiries, fulfill your requests, and send you requested communications.

1.2. Information Processed Automatically

When you use the Website, certain information about your device and user behavior is processed automatically. This information is generally non-personal and accessed only in aggregated form, meaning it does not directly identify you as an individual. We process this data based on our legitimate interest in enhancing the Website and delivering an optimal user experience. Without this information, some Website features may be limited.

We utilize third-party automatic data processing technologies to analyze information sent by your device through the Website (analytics tools). Some of these tools perform automated data processing, including profiling, to evaluate certain personal aspects such as preferences, interests, behavior, location, or movements (see data categories below). Data processing through these technologies begins automatically when you first access the Website.

Device Details: When you use a mobile device (tablet, phone, smartwatch) to access the Website, certain device information is reported, such as “device identifiers” — small data files or similar data structures uniquely identifying your device (not your personal identity). Device identifiers enable generalized or personalized reporting for third-party content and ads. The following types of data may be processed:

Device Information: Type, operating system and version, model, manufacturer, screen size, orientation, audio volume, battery level, and memory usage.

Internet Connection: Mobile carrier, network provider, network type, IP address, timestamp and session duration, speed, browser.

Cookies and Similar Technologies: The Website uses cookies and similar technologies (e.g., pixels, web beacons, scripts). A cookie is a text file downloaded to your device upon accessing the Website, then sent back to the server during your use. This enables us to operate the Website more effectively, such as understanding user access patterns and feature usage. We use aggregated data from cookies to optimize the Website, enhance our marketing efforts, and deliver content and features relevant to you.

Log File Information: Log file data is automatically reported each time you access the Website or install the Website on your device. Analytics tools log specific data, such as start and stop times, and interactions with the Website.

In-App Events: When you use our Website, analytics tools may log activity information (e.g., tutorial steps, levels achieved, payments, purchases, custom events, progression events, user data limitation methods).

Please note that information processed by analytics tools generally falls outside our control, and we are not responsible for such processing. Certain third-party services may perform data profiling, collecting data on your personality and/or device using their technologies.

Purposes and Legal Basis for Processing Information

2.1. Our goal is to continually enhance our Website and offer you new experiences. To support this goal, we process your information for the following purposes:

● To Provide Our Service: We use the information you submit and the data processed automatically to deliver all requested services to you.

● To Improve, Test, and Monitor Our Service: Automatically processed information helps us understand user behavior and trends, detect potential outages and technical issues, and operate, protect, improve, and optimize our Website.

● To Communicate With You: We use your information to communicate with you, including sending newsletters, marketing notifications, and requests for feedback about your experience with the Website. We also inform you about our policies and terms and respond to your inquiries when you contact us.

● To Prevent Fraud and Spam, and to Enforce Legal Compliance: We aim to keep the Website free of spam and fraudulent content, ensuring a secure environment for all users. We may use your information to prevent, detect, and investigate fraud, security breaches, and potentially illegal activities..

If new purposes for processing your personal data arise, we will inform you by updating this Privacy Policy to reflect those additional purposes.

2.2. We process your data under the following legal bases:

● Performance of Contract (the Agreement): 1) To provide you access to the Website and deliver the most relevant services available; 2) To communicate with you regarding your use of the Website, respond to your requests, and update you on services, information, and products; 3) To notify you of any important information or changes within the Website that may affect you.

● Our Legitimate Interests: 1) To send you marketing communications; 2) To analyze active user numbers, support users from different regions, ensure functionality across Website versions, and improve and optimize the Website; 3) To maintain the safety and security of the Website, enforce the Agreement, and prevent and address fraud; 4) To comply with our legal obligations.

2.3. For any data collected for marketing purposes, we will request your specific consent. You may withdraw this consent at any time, free of charge, by clicking the "Unsubscribe" link in our emails.

Sharing of Collected Data

3.1. Affiliated Entities: We may share your personal data with affiliated companies connected to Voita LDA. These affiliated entities will adhere to the principles outlined in this Privacy Policy.

3.2. Contractors: We do not sell or rent your personal data to external parties. However, we may share your information with business partners, suppliers, subcontractors, and other entities necessary to fulfill our contractual obligations or other agreements formed through our interactions with you. Additionally, we may share data with auditors, legal advisors, and other professional consultants.

3.3. Public Authorities and Legal Obligations: To comply with legal mandates, court orders, or official requests, we may disclose personal data in response to legal processes or government inquiries.

3.4. Third-Party Service Providers: We may share your information with third-party providers that assist in improving website performance, search engine optimization, and other operational functions: (a) G-Suite Service (Storage): Your data may be stored on G-Suite, managed by entities like Google LLC (California, USA), Google Ireland Limited, and Google Asia Pacific Pte. Ltd. (Singapore). Refer to Google’s Privacy Policy for further details on their data processing practices; (b) Google Analytics (Analysis): Your data may be analyzed using Google Analytics to help us understand usage patterns. This service is provided by entities including Google LLC, Google Ireland Limited, and Google Asia Pacific Pte. Ltd. For more on Google’s data practices, see their Privacy Policy.

3.5. Collaborations with Third-Party Services: In some cases, we work with third-party services to support activities such as operational improvement, integration, customization, support, and marketing. These providers may include cloud storage vendors, data analytics services, marketing partners, payment processors, and communication service providers. They operate primarily as data processors and assist in achieving the purposes described in section 2 of this Policy.

3.6. Legal Defense and Rights Protection: We may disclose your data to uphold our Agreement and protect the rights, privacy, and property of ourselves, our affiliates, you, and others. This may include cooperating with courts, regulatory bodies, law enforcement, and government authorities as legally required.

International Data Transfer

4.1. Your personal data may be transferred to, stored, and processed in countries outside your own, including but not limited to the United States. These countries may have data protection laws that differ from those in your jurisdiction, potentially offering less protection.

4.2. When we transfer personal data internationally, we ensure that appropriate safeguards are in place to protect it as required by applicable data protection laws. These measures include:

- Standard Contractual Clauses: For transfers to countries not deemed to provide an adequate level of data protection, we may rely on standard contractual clauses approved by the relevant regulatory authorities, which commit the recipient to provide the same level of data protection as in the EU or your home jurisdiction.

- Privacy Shield Frameworks: Where applicable, we may transfer data to entities that comply with international data transfer frameworks, such as the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks, or equivalent mechanisms, to provide an additional level of assurance regarding data protection.

4.3. If you would like further information regarding the specific safeguards we apply to the international transfer of your data, please contact us at the details provided in this Privacy Policy.

Retention of Collected Data

5.1. We retain your data only as long as necessary to fulfill the purposes for which it was collected. Our retention period is determined by factors such as the volume, nature, and sensitivity of the data, the processing objectives, and whether these objectives can be achieved by other means. We also consider legal obligations, potential inquiries or complaints, and the need to protect our legal interests in case of potential claims. Once your personal data is no longer needed, we will securely delete or destroy it.

5.2. We will continue to retain information and documents, including electronic records containing personal data, in the following situations:

- To comply with legal or regulatory retention requirements.

- If the data is relevant to current or potential legal proceedings.

- To establish, exercise, or defend our legal rights, including sharing information to prevent fraud or manage credit risks.

Data Security

6.1. We implement a range of administrative, technical, and physical safeguards to protect your information. While we make every effort to secure the data you share with us, please be aware that no security system is entirely foolproof. Despite our best measures, no method of data transmission or storage is completely immune to interception or misuse.

6.2. Information shared online or through cloud services may be susceptible to unauthorized access or misuse. Although we are committed to protecting your information, we cannot guarantee absolute security. Please consider this when choosing to provide us with your data.

Data Subject Rights

7.1. Being a data subject, you have the following rights:

7.1.1. Right to Access: You have the right to obtain confirmation of whether we process your personal data and, if so, to request access to that data.

7.1.2. Right to Rectification: You can request the correction of inaccurate or incomplete personal data.

7.1.3. Right to Erasure: You have the right to request the deletion of your personal data from our systems, unless legal obligations require retention.

7.1.4. Right to Restrict Processing: You can request the restriction of processing your personal data under certain circumstances.

7.1.5. Right to Data Portability: You can receive the personal data you provided to us in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another controller.

7.1.6. Right to Object: You may object to the processing of your personal data based on specific grounds relating to your particular situation.

7.1.7. Right to Withdraw Consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

7.1.8. Right to Lodge a Complaint: If you believe that we have not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority.

7.2. To exercise any of these rights, please contact us using the details provided in the "Contact Us" section of this Privacy Policy.

7.3. We will respond to your request regarding your rights specified above and provide information on the action taken within one month from the receipt of the request at the longest. However, if we receive an overwhelming number of requests, the response time may be extended by an additional two months. In such cases, we will inform you of any extension within one month from the receipt of the request, along with the reasons for the delay.

Children's Privacy

We do not knowingly collect or seek personal information from children under the age of 18. If we learn that we have inadvertently collected personal data from a child under 18 without verified parental consent, we will take immediate steps to delete the information from our records. If you believe that we may have collected personal information from a child under 18, please contact us at info@voitalda.com.

Changes to this Privacy Policy

We may update this Privacy Policy periodically. When we make significant changes, we will notify you under certain circumstances, such as when required by applicable privacy laws or when the changes are material. If required by law, we will seek your consent for these changes. The "last updated" date at the bottom of this Privacy Policy will reflect the most recent revisions. We encourage you to review this page periodically for any updates.

If you have any questions, please contact us:

Voita LDA, address: RUA ALFREDO VITORINO DA COSTA, 72, SÃO JOÃO DA TALHA, LISBOA. Zip:2695-772

Email: info@voitalda.com

Last updated: March 03, 2025