PRIVACY POLICY

Eyecon - Software, Lda. (“Eyecon”), a company with its head office at Rua Maria Angelina Turlu, 11, 9700-575 São Mateus da Calheta, Portugal, and registered under the corporate number 514 572 426, provides the website www.habtrail.com (the "Website"). All processing activities of personal data collected through this Website are governed by this Privacy Policy (“Policy” or “Privacy Policy”), which reflects Eyecon’s commitment and respect for the privacy and protection of personal data.

This Policy governs the processing of personal data, within the scope of the use of the Website by its visitors (“Users”).

Who we are – the data controller

Eyecon determines the purposes and means of the data processing, under the terms described herein, being considered for this purpose as the entity that is responsible for the processing of the User's personal data – the data controller – pursuant to the General Data Protection Regulation ("GDPR") and other applicable data protection legislation.

Eyecon can be contacted at the following email: info@eyecon-group.com

How do we process your personal data?

The access to and use of the Website does not necessarily imply the provision of your personal data. However, the use of the features available in the Website may involve the collection and processing of personal data.

We will only process personal data under a legal provision that allows it. In particular, we will process your personal data under article 6 of the GDPR. Below, you will find details about the personal data that we process, together with the purposes that allow its collection, and the legal basis that enables us to carry out these processing activities.

Consent: based on your free, unambiguous and specific consent, we will process the personal data you provide us through the forms available on the Website, including your first name, surname, employer/sponsor, e-mail address and profession/job position. We ask for your consent for the processing of personal data relating to the “Free Tour” and “Download” functionalities that you will find on the Website.

Pre-contractual steps and performance of the contract: we may also process personal data, within the scope of the execution of a licensing agreement for the software we provide. However, we process such data only as is necessary for the provision of the services, such as the profilename, email and other data requested for creating, accessing and managing a personal account.

We also process your personal data, including your first name, surname, employer/sponsor, email and profession/job position if you sent us a spontaneous job application or if you contact us to become our partner. The “Partner” functionality that you may find on the Website is included here.

Compliance with legal obligations: Eyecon is subject to legal and regulatory obligations, the fulfillment of which may involve the processing of personal data, namely tax and regulatory obligations.

Legitimate interests: we may process personal data to safeguard Eyecon's legitimate interests, in case your interests do not prevail given your specific circumstances. At this time, Eyecon does not pursue any legitimate interests with the processing of User data.

Your rights

Pursuant to the applicable legislation and the GDPR, the User, as a data subject, may request, at any time, access to the personal data concerning him/her, as well as exercise its rights of rectification, deletion, opposition, limitation of the processing and data portability – subject to the foreseen legal conditions – upon a written request addressed to Eyecon.

The User can also obtain confirmation about what personal data concerning him/her is being processed, and a copy of such data will be made available, if requested.

The User also has the right to withdraw its consent to the processing of data regarding the purposes based on it, not invalidating, however, the processing carried out up to that date based on the previously given consent.

The User can exercise the above rights by requesting it to the following e-mail address info@eyecon-group.com.

Personal data retention

The personal data will only be kept during the period necessary for the purposes for which they were collected, as identified above, unless another retention period results from the applicable law. In any case, Eyecon informs you of some of the retention periods applicable to its processing activities, namely:

  • Personal data collected based on your consent will be kept until your consent is withdrawn or until 3 years have passed without any further processing.
  • Personal data collected based on the performance of a contract will be kept until the end of the contractual relationship or for 2 years, counting from the date of termination such contractual relationship.
  • Personal data collected in the scope of a spontaneous job applications (including the “Partner” form) will be kept for 5 years.

When do we share data with other entities?

Eyecon may share your personal data with third parties:

  1. For the provision of certain services, such as information technology services, recruitment, marketing, legal and financial support, accounting, asset valuation, among others, since the provision of these services may imply access, by these entities, to your personal data.
  2. When it is deemed to be necessary or appropriate (i) in light of the applicable law, (ii) for the compliance with legal obligations/court orders, (iii) by deliberations or decisions of supervisory authorities, or (iv) to answer to requests from public or governmental authorities.
  3. For the purpose of carrying out legal audits and corporate acquisition, merger or demerger operations, as well as any financing operations of Eyecon, by national or foreign entities.

In any of the situations mentioned above, Eyecon will take all appropriate measures to ensure the effective protection of the personal data.

Eyecon transfers data internationally outside the European Economic Area.

Security measures

Eyecon makes its best efforts to protect the Users' personal data against unauthorized access and against loss of data integrity and confidentiality. To this end, it has adopted technical and organizational security measures, such as pseudonymization and data encryption (as appropriate), and implemented security systems, rules, and other procedures, in order to ensure the protection of personal data, as well as to prevent unauthorized access to data, its misuse, disclosure, loss or destruction.

Complaints

Without prejudice to any other administrative or judicial means of recourse, the User is entitled to file a complaint to a supervisory authority (in Portugal, to the Portuguese Data Protection Commission) under the terms of the applicable law or the GDPR, if he/she understands that the processing of its data by Eyecon infringes the legal provisions in force.

Changes to the Privacy Policy

Eyecon reserves the right to, at any time, change this Privacy Policy. These changes will be properly publicized on the Website.