Last updated: May 31St, 2023
1 - SCOPE
Our website and social media channels;
Innovation and Acceleration programs (each, a “Program”);
The Program websites and their related subdomains;
Applications for attendance at the Programs;
Online surveys relating to the ecosystem and our Programs;
The Program’s official social media channels;
Promotion of events.
2 - WHAT IS PERSONAL DATA?
Personal data is any information, of whatever nature and whatever its medium, including sound and image, concerning an identified or identifiable natural person (“data subject”).
An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to other factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity.
3 - INFORMATION WE COLLECT
When we provide the Services, we collect and receive information in several different ways. In many cases, you choose what information to provide, although some information is required for us to provide you the Services.
3.1 - DIRECTLY FROM YOU
We collect a variety of information from you when you provide it to us directly, such as:
Website contact form information: When you contact us through our website for inquiries or to register to our newsletter, you must provide us with basic information such as your name and email address. If you are a startup interested in our Services, you may also need to provide additional information about your business, such as the industry and country you operate in.
Program application information: When you want to join one of our Programs, we collect information from you regarding you and your business, including name, email address, company description, industry, and other information relevant to the Program.
Surveys: We may ask you to participate in surveys regarding your experience at the Program or the ecosystem in order to help us improve and for related commercial purposes.
3.2 - FROM YOUR BROWSER OR DEVICE
We automatically collect certain information from your browser or device when you use certain Services or read a message from us. For example, we collect:
Data regarding the device you are using, such as what devices you use to access the Service; logs will be recorded by our servers based on the information sent from your app or browser;
Information automatically as you navigate through the site using cookies and other tracking technologies;
Information collected automatically may include usage details, IP address and location, and information collected through cookies and other tracking technologies.
Information may be recorded by cookies and similar technologies when you use the Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
3.3 - FROM OTHERS
This is information we receive that you do not directly provide when you use the Services. We get it from other users of the Services, third-party services we use to provide the Services, from information we collect and from our partners and vendors. We collect this information through:
Your social media accounts: Such as the number of followers you have on your LinkedIn account.
Scouting efforts: We may collect information directly from you, use public record sources or create editorial content about your organization in order to identify opportunities for your organization. For example, we may engage with you verbally, by e-mail or use other sources to get this information.
Third party platforms: We get information about you from third-party partners including those carrying out market research, company research and lead generation services. For example, we may collect information about your professional
4 - PURPOSES AND LEGAL BASES
FOR PROCESSING YOUR INFORMATION
We use your information in order to provide, operate, improve, understand, customize, support, and market our Services.
As a Controller, Fábrica de Startups processes your data for the following purposes and on the following legal grounds:
1. when we have a legitimate interest. This is applicable when the interest is not overridden by your data protection interests;
Communicating with you: We use your personal information to contact you regarding your registration to a Program, to present new opportunities that might be relevant for you, to notify you of any changes to our policies and practices, for commercial, sales, or investment purposes, and to respond to any requests or inquiries you may submit to us.
Provide, develop and improve the Services: We process your information as necessary to pursue our legitimate interests in improving the Program and our other Services, such as our Program websites. For example, we may use your information to conduct data analysis across our Services.
Website management: We process your information in accordance with our legitimate interests of marketing the Services to you. For example, we use your information to market future Programs to you and to exhibit attending companies.
2. when necessary to provide you with the Services (performance of a contract);
Providing and improving the requested Services: We use your personal information as necessary to run our Services, such as to register program attendees, facilitate information sharing with partners with whom you have consented for us to share information, and provide you with relevant connections and content based on this information. In this context, we can also act as a Processor, acting on behalf of our Clients.
3. where you have consented to the processing, which you may withdraw at any time;
Marketing: If you opt-in to receiving marketing communications from us, we will use your personal information for outreach and marketing, such as to send you information about our future Programs. You can opt-out of these communications by using the unsubscribe links in our communications. We may also use your information in order to market the Program. For example, we sometimes use your image in our published list of Program attendees. If you want to object to this use, please contact us here at firstname.lastname@example.org.
4. where you have consented to the processing, which you may withdraw at any time;
We may also use your image in our marketing materials in order to highlight the attendees participating in the Program. We also use photos and audio-visual footage from past Programs which may contain your image or voice. If you want to exercise your right to object to any of these uses please email us at email@example.com necessary for us to comply with a legal obligation such as:
Management of tender procedures;
Compulsory insurance contracting;
Mandatory communications to public authorities;
Compliance with other legal or regulatory obligations.
5 - SHARING WITH THIRD PARTIES
Other attendees: Our Services, such as the Programs, are set up with the means of allowing attendees to connect with each other. For example, you may share personally identifiable information about you and your business when applying to a program. The application information that you choose to provide, will be accessible to the program partners. When you apply to a Program, you consent to the sharing of your contact information with these individuals and companies.
When we need to comply with applicable laws and requests: When we believe that sharing your personally identifiable information with third-party is required to comply with an applicable law, regulation or request by a government entity, to protect ourselves, our users or others from harm or illegal actions, to respond to an emergency that threatens a person, to fulfill your support requirements and/or to generally protect the security and integrity of the Service.
Service Providers: We may share your personal information with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. These third parties provide us with services such as data hosting, e-mail delivery, testing, analytics, support infrastructure, and other areas. The use of these services requires the relevant third-party to access or use personally identifiable information about you. These third parties are contractually required to use it only to provide their service to us, and prohibited from using it for their own purposes.
Business reorganization: In instances where we are subject to a reorganization, such as a merger or acquisition of some or all of its assets, we may, in accordance with our legitimate interests, need to share information in the course of the transaction. In such circumstances, your information may be disclosed, where permitted by applicable law, in connection with such corporate restructuring, sale, or assignment of assets, merger, or other changes of control or financial status.
Aggregated information: We may also share aggregated or de-identified information, such as program attendee job titles with companies we do business with.
When Fábrica de Startups uses subcontractors in the situations described above, technical and organizational measures are adopted in order to ensure that these entities offer the highest guarantees, which are duly established and contractually provided for.
6 - DATA RETENTION
Your information will be stored until (A) you send us a written objection to us, (B) 10 (ten) years from the date of collection or more if a specific legal requirement is applicable, or (C) 2 (two) years from the date of collection when the data is collected under a human resources application through our Site.
Whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that motivated their collection or their subsequent processing, after which they will be deleted.
7 - DATA TRANSFERS
We collect information globally and primarily store that information in the United States on our own servers and that of our service providers as part of providing the Services. User data processing may involve disclosure to third parties or information storage in countries outside the territory of the European Union that may have different data privacy standards and protections than those which apply to your home country. We transfer your personal information in accordance with law, and take steps to ensure that your information is appropriately protected.
Data transfers outside the European Economic Area will be subject to appropriate safeguards in accordance with applicable law, with Fábrica de Startups committing itself to carry out only necessary transfers and to entities that guarantee the adoption of adequate technical and organizational measures.
8 - YOUR RIGHTS
Personal data subjects have the following rights:
Access: The data subject has the right to obtain from Fábrica de Startups confirmation as to whether or not their personal data are subject to processing, and if so, the right to access them and the following information: i) purposes of processing, ii) categories of data, iii) categories of recipients, iv) retention period, if applicable, v) the origin of data, vi) existence of automated decisions.
Rectification: The data subject has the right to obtain, without justified delay, the rectification of inaccurate personal data concerning him or her.
Erasure: The data subject has the right to obtain the erasure of his/her personal data when: i) the data is no longer necessary for the purpose for which it was collected, ii) the data subject has withdrawn his/her consent, iii) the data subject has objected to the processing, iv) the processing is unlawful.
Limitation: The data subject has the right to obtain the limitation of the processing of his or her data if: i) he or she contests their accuracy, during the period enabling Fábrica de Startups to verify their accuracy, ii) the processing is unlawful, iii) the data are no longer necessary for the purposes of the processing; iv) the data subject has exercised his or her right to object.
Opposition: The data subject has the right to object to the processing of data which is necessary for the performance of a task carried out in the public interest or for the purposes of the legitimate interests of Fábrica de Stratups. In such case, Fábrica de Startups may only continue to process the personal data in question if it provides compelling legitimate reasons overriding the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Withdraw consent: The data subject has the right to withdraw consent previously given, at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Portability: The data subject has the right to receive personal data in a structured, commonly used and machine-readable format, and the right to transmit such data to another entity when: i) the processing is based on consent or a contract, and ii) the processing is carried out by automated means.
Lodge a complaint: The right to lodge a complaint with a supervisory authority, which, in Portugal, is Comissão Nacional de Proteção de Dados (CNPD) (https://www.cnpd.pt/).
9 - SECURITY
The security of your personal information is important to us. Fábrica de Startups incorporates in its processes, in a logic of continuous improvement, administrative, technical, and physical safeguards to preserve the confidentiality, integrity, and availability of the personal data processed, guarantying that all appropriate technical and organisational measures to ensure a level of security appropriate to the risk were implemented.
Despite these measures, the Internet is not a fully secure environment and we cannot guarantee that your personal information won’t be intercepted or improperly accessed, in certain situations external to our control.
10 - HOW CAN YOU STOP THE USE OF PERSONAL DATA BELONGING TO YOU FOR DIRECT MARKETING?
You can stop direct marketing communications from by clicking the ‘unsubscribe’ link in any email communication that we send you, or by emailing us at: firstname.lastname@example.org. We will then stop any further emails. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
12 - CONTACT US