Whitesmith is compliant with high privacy standards, therefore assuring that the processing of any personal data will be strictly directed to the identified purposes and always in respect of the data protection rights and legislation, namely the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR)
Definitions and legal references
Personal Data (or Data)
Means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The natural person to whom the Personal Data refers.
Personal Data Processing
Personal Data Processing can be performed by Whitesmith through automated and/or analogical means, such as:
- Register and storage
- Search and use
- Dissemination, regardless of the disclosure means
- Comparison or interconnection
- Limitation, deletion or destruction
In particular, Personal Data Processing comprises the information collected automatically through Whitesmith’s Application (or third-party services employed in the same Application), which can include: the IP addresses or domain names of the computers utilized by the Data Subjects who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the Data Subject, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the Data Subject's IT environment.
The individual using any Whitesmith’s Application, which must coincide with or be duly authorized by the Data Subject, to whom the Personal Data refers.
Whitesmith, Lda., as the legal person entitled to process the Personal Data in compliance with this Policy, which take decisions regarding the purposes, means and methods of Personal Data processing, including the security measures concerning the operation and use of Whitesmith’s Applications.
Any means by which the Personal Data of the Data Subject is collected by Whitesmith, as Data Processor, including Whitesmith’s corporate website (www.whitesmith.co)
How to contact us:
Whitesmith, Lda - Instituto Pedro Nunes, Rua Pedro Nunes, 3030-119 Coimbra, Portugal
Personal Data collected for the following purposes and using the following services:
- Tool: Google Analytics
- Personal Data: Cookies and Usage Data
- Managing contacts and sending messages
- Tool: MailChimp
- Personal Data: email address and name
- User Database Management
- Tool: Pipedrive
- Personal Data: Name, Organization name, e-mail address and phone
Personal Data collection and processing
Whitesmith’s Application collects, directly or through third-party services employed in the same Application, the following Personal Data: Usage Data and Data Subject personal e-mail address.
Whitesmith requires to the Data Subject, in all cases, the freely given, specific, informed and unambiguous consent for the processing of his/her personal data, using formal templates designed case by case, considering the type, scope and extension of said personal data processing.
Conditions applicable to child´s consent
According to Article 8 of the GDPR, all personal data belonging to children can only be processed under an express consent observing the rules of Article 6, number 1, point a) of the GDPR related to information society services when said children complete 13 years old.
For children with less than 13 years old, such processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child, preferably through the use of electronic certification means, such as Citizen Card or Digital Authentication Key.
All Data requested by this Application is mandatory and failure to provide this Data (or the Data Subject denial of express consent) may turn impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Data Subjects are free not to communicate this Data without any consequences on the availability or the operation of the service.
Data Subjects are responsible for any third-party Personal Data obtained, published or shared through this Application and shall confirm that they have said third party's consent to provide the Data.
Mode and place of processing the Data
Methods of processing
Whitesmith, as Data Processor, processes the Data of Data Subjects in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Processor access to said data, in some cases, Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Subcontractors. The updated list of these parties may be requested to Whitesmith at any time.
The Data is processed at Whitesmith operating offices and in any other places where the parties involved with the processing are located. For further information, please contact Whitesmith, through the appointed email address.
The Data is kept for the time necessary to provide the service requested by the Data Subject, or stated by the purposes outlined in this document, and the Data Subject can always request to Whitesmith, as Data Processor, the removal of his/her Personal Data.
The use of the collected Data
The Data concerning the Data Subject is collected to allow the Whitesmith to provide its services, as well as for the following purposes:
- Analytics and
- Managing contacts and
- sending messages.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable Whitesmith to monitor and analyse web traffic and can be used to keep track of Data Subject´s behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Managing contacts and sending messages:
This type of service/tool makes it possible to Whitesmith to manage a database of email contacts to communicate with the Data Subject. This service may also collect data concerning the date and time when the message was viewed by the Data Subject, as well as when the Data Subject interacted with it, such as by clicking on links included in the message.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
Data Subject database management
This type of service allows Whitesmith to build Data Subject profiles by starting from an email address that the Data Subject provides to Whitesmith’s Application, as well as to track Data Subject activities through analytics features. This Personal Data may also be matched with publicly available information about the Data Subject (such as social networks' profiles) and used to build private profiles that Whitesmith can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the Data Subject, such as emails based on specific actions performed on Whitesmith’s Application.
Pipedrive is a Data Subject database management service provided by Pipedrive, Inc.
Personal Data collected: Name, Organization name, e-mail address and phone
Data subject rights
The Data Subject has the right, at all time, to require to Whitesmith, free of charge:
- The access to his/her personal data
- The rectification and correction of his/her personal data
- The erasure of his/her personal data (the “right to be forgotten”)
- The limitation of his/her data processing
- The opposition of his/her data processing
- The portability of his/her personal data to an appointed third entity, provided that said data are stored exclusively in electronic form.
In every case, if a legal rule or legal obligation is in force which supersedes these data subject rights, Whitesmith reserves the right of denial of the data subject request (and/or to determine restrictions to said request, if and when applicable), duly communicating to the Data Subject the respective grounds of said decision.
The Data Subject is entitled to file complaints to Comissão Nacional de Proteção de Dados (hereinafter, CNPD), the Portuguese Controller Authority, according to the definitions duly stated in numbers 21 and 22 of article 4 and article 51 of the GDPR.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.