1. Privacy Policy: Purposes and field of application



The hereby Praivacy Policy is referred to the Services’ provision by the company under corporate name PORTUTEL, LDA, based at Portugal Avenida 5 de Outubro, 124-7.º Andar Lisboa with VAT 516091794which is registered with number 516091794 in relevant Chamber of Commerce (referred to as “the Company”).




The purpose of this Privacy Policy constitutes the description of all the the means which are used for the collection and processing of the personal data that the Company receives, via the internet or other ways, as also the Company’s privacy practices. 



The Company commits to take all necessary measurements for the protection and process of the personal data in a lawful manner, in full compliance to the General Data Protection Regulation (EU) 2016/679 (GDPR) and other related laws of its implementation. 




The provided Services by the Company are addressed to adults; personal data for any person, known by the Company to be aged under 18 years, are not collected, without the prior verifiable consent of the holder of parental responsibility over the child. In any case, the holder or the parental responsibility has the right, upon his/her request, to be informed regarding the information provided by the minor and/or to request its erasure. If the Company becomes aware that the person who is submitting his/her personal data is under 18 years old, the Company shall immediately erase said data. 




The present Privacy Policy is incorporated to the General Terms and Conditions, which are posted at the Company’s website, constituting a single text. The Company’s business activities are conducted via its website




2. Definitions

Personal data: any information relating to an identified or identifiable individual – natural person. The identifiable natural person means the person that his/her identity can be verified, directly or indirectly, mainly through the reference to an identifier, such as name, ID number, location data, one or more factors that characterize his/her physical, natural, psychological, financial, cultural or social identity.



Personal Data Subject: every natural person that his/her personal data are submitted to a process by or on behalf of the Company.


Data processing: any activity involving personal data, irrespective of the means and the procedure applied, e.g, collection, recording, use, revision, disclosure, organisation, projection and destruction of personal data


Processing restriction: the signaling of stored personal data in a purpose of their process in the future.


Profiling: any form of automated processing of personal data that is consisting of the personal’s data use for the evaluation of certain personal aspects of a natural person.  



Filing System: any structured personal data set, which is accessible in accordance to specific criteria, whether this personal data set is centralized, or decentralized or distributed over an functional or geographical basis.




Transmission: the access to personal data, for example by allowing access, broadcast or publication.



Data Controller: the natural person or the legal entity that determines the purpose, the way, the content and the procedure of the processing of personal data.  



Data Processor: the natural person or the legal entity, which processes personal data following the controller’s instructions. 



Personal Data Subject’s Consent: any indication of will, which is free, specific, explicit and in full aware of the personal data subject; with that way the personal subject data declares that agree with the fact of his/her personal data processing, via his/her statement or his/her clear positive act.



3. Processing Purpose of the Data


The processing of personal data is exclusively realized by the Company, in accordance to the purpose that is indicated upon the collection of personal data, in the context of Services’ provision by the Company, as also every legitimate purpose. 



The collected personal data by the Company aim to facilitate the creation or improvement, as also the personalization of the relationship between the Company and recipients of its Services.



The processing of the personal data is always conducted within the legal framework and the principles of good faith. For that reason, the personal data that are collected or are stored, are only the necessary, in order to fulfil the processing purpose. Moreover, the Company takes all the necessary measures for ensuring the legality of the said process which it should be, in any case, compliant with the purpose of data’s collection. 




The personal data processing for that purpose is lawful only if it is founded on the End User’s consent, as it is predicted to Article 6 paragraph 1a and Article 9 paragraph 2a General Data Protection Regulation (GDPR), as also the said processing is realized in the context of the contract’s performance where the End User is a contracting party, as a personal data subject. (Article 6 paragraph 1b GDPR)



4. Kind of the Personal Data that are collected



The kind of the personal data that are collected include the full name, email address, billing information or mobile telephone number and related data, as may be requested for time to time. In any case, the said collection and processing of your personal data needs necessarily your explicit consent to the Company.





5 Means of Collection of the Personal Data


The personal data collection is conducted either because you provides them to the Company on your own or via automated means. More specifically:



  • Provision of the Personal Data voluntarily by the Data’s Subjects


The Company collect personal data, when you submit personal information to the latter, on your own initiative. The said collection happens to the following cases:

- by your subscription to the Company’s website, in order to receive recreational content Services for mobile phones, for example notification sounds, games, pictures, news and others.,


- by using the download links, without your subscription, to the Company’s website, such as in cases of individual downloads or subscription via SMS by using your  mobile phone, 


-by submitting your opinions, suggestions, comments or complaints to the Company or through any communication between you and the Company.


- by your participation in the Company’s activities, such as competitions, games, surveys, fora, 


- by transferring your personal data by third parties which have a cooperation relationship with the Company and they are reliable. This data’s transfer is always conducted in the context of the fulfilment of the purpose for which you submit your personal data, giving your relevant consent,


-by transferring your personal data to the Company through public databases. 



  • Personal Information Collection via Automated Means (Cookies)-the Company’s Policy



Cookies are small text files, which are used for the storage of data that are related to you and your preferences. Every time that you visit specific websites, the cookies are placed automatically in a predetermined file in your computer by the server. The purpose of the cookies is to uniquely identify your computer to the server. In this way, it is allowed to the Company to collect information relating to the server, in order to facilitate your browse in the internet, as also to evaluate and test the function of the Company’s website. 





By using the cookies, the Company is able to identify your web browser, as also to determine whether you have downloaded the activation software, which is required in order to access specific material in the Company’s websites. Moreover, the Company may, through the cookies, determine the total number of visitors of its website and identify you when you visit again its website. Information pertaining to your activities in the Company’s website and other non-personal data may also be used, in order to be appeared only the online advertisements that the Company believes that correspond to your preferences.. 






Cookies have the ability of storing your access code in a website that you have previously used, in order to provide easy access to this, as also storing related data to your preferences, in order to redirect you to a website adjusted to said preferences.   




Information that can be used for your identification, it is not possible to be collected through the cookies of other related identifying means. The said collection can only happen in the case that you submit on your own such information, so the automated means are going to be used to deliver additional information regarding your use of the websites and/or the interactive emails, having as an exclusive purpose of increasing their usefulness for you. Such cases are indicatively and without limitation, your subscription request for the Company’s Services or the sending of an email.    






In the majority of the browsers, they are programmed to accept cookies. Although, there is the ability for you to adjust your browser’s settings so that the latter reject downloading the cookies or to notify you each time your browser receives a cookie. It is indicated that in this case, it is possible for some pages of the Company’s website may not function properly, and you may not have access to specific applications.





It is possible that the Company may use cookies and other similar means to associate your use of the Company’s website with personal data received by the Company or by a third party, reliable partner of the Company. 



The above mentioned case could indicatively happen if you have requested information regarding future products or promotional activities of the Company, cookies and/or your browsing history regarding your activities in the Company’s website, may allow the Company to limit the provided material to what the latter believe that you may find interesting, based on your previous online activities and preferences. In the above mentioned case that the Company intends to combine your personal data and cookies or information regarding your browsing history, the Company will necessarily request your previous express consent.      






At the Company’s website may appear third parties’ advertisements, which may also contain cookies. The said cookies are determined each time by the advertiser or the advertised entity and the Company has not the ability of controlling them. Therefore, you should refer to the advertiser’s or the advertised entity’s privacy policy, in order to ascertain if they use cookies and how.




Finally, the technical department or other departments of the Company or its associates may automatically collect information regarding the visitors of the Company’s website for purposes of maintenance, improvement, security and other legitimately acceptable reasons. Such information may include the IP address of visitors, the browser type, the date, time and duration of the visit and specific pages that the you have visited.




6. The Company’s Practices relating to the Personal Data collection and your notification



By providing your personal data each time, the Company ensures that you have been informed about who collects your personal information, the means of their collection, the kind of their use by the Company, as also about the purpose of thei collection.



For that reason, each time that you provide your personal data, the Company will take care of notifying you about your options regarding your personal data’s use, as also in any  case of a potential joint use of your data by the Company and third parties.   




In the event that your personal data are collected manually or by means not related to the internet (such as subscription form), the Company takes care of sending you a brief notice, whereby it describes how you may receive the Company’s entire Privacy Policy and other related information from it. In that way, your detailed notification, regarding to all related aspects of your personal data and their use by the Company, is ensured, so that you are able to give your express consent to the Company.




At the Company’s website, it is possible to appear links that redirect you to other companies’ websites. In some of the above cases, the third parties’ websites may contain the Company’s logo, even though the fact that the Company has not their operation or the responsibility about these websites’ content. 


At the Company’s website may also appeared advertisements from other companies, which may redirect you via a link to third parties’ websites. In that case the Company has no liability for the practices of third parties or for the privacy policies of third parties or local advertising companies on the internet. So, if you are redirected from the Company’s website via such link or by clicking on an advertisement, you should refer to the applicable privacy policy of the third party or the advertiser’s website, so that you have information about how they will handle any personal data collected from you. 






7. Data Subject’s Rights 



All data subjects have the following rights, pursuant to GDPR, which the Company respects and protects:


(a) the right to be informed, means that the subject has the right, upon his/her request, of receiving information about his/her personal data that are maintained by the Company and more particularly, the kind of the data under process, who natural persons or legal entities have the right of process, as also the reasons of that


(b) the right of access, means that the subject is entitled to submit request to the Company with content of having free access to his/her personal data that are maintained by the Company


(c) right to rectification and completion, means that the subject is entitled, upon his/her notice to the Company, to request the correction of any accuracies to his/her personal data, as also the completion of any incomplete data, under the condition that these data are necessary for the purposes of the process



(d) right to erasure, means that the subject is entitled to request from the Company the erasure of his/her personal data that are collected by the Company. Although, some of the collected personal data will be erased after a specified period of retention, especially in cases that the Company is obligated by the Law to maintain the personal data or the collected data are necessary for the performance of Company’s contractual obligations towards the subject



(e) right to restriction of processing, means that the subject has the right to request the restriction of processing his/her personal data and especially: 1) if there is doubt for their accuracy, 2) if the processing is illegal, 3) if the collected data are not necessary for the data controller, 4) if he/she has objections to automated process

(f) right to data portability, means that the subject has the right to request the transfer of his/her data to another data controller



(g) right to object, means that the subject may object, at any time in the future, to his/her personal data’s process by the Company, if the Company processes his/her data on the basis of the reasons that are provided in article 6 (1e or 1f) GDPR (EU) 2016/679. If the subject objects, the Company shall stop processing his/her data, under the condition that there are no legal reasons that justify their further process. The personal data’s process for advertising purposes is not a legal reason.





(h) rights relating to the automated decision-making and profiling means that the personal data subject has the right of not being subjected to decision that has been taken exclusively on the basis of an automated processing, including profiling, which produces legal effects that concern the subject or significantly affect him/her with a similar way. The above mentioned do not apply in the following cases: 1)if the decision is necessary for the conclusion or the performance of the contract between the Company and the subject, 2) if it is allowed by the Law of European Union or the Law of the member state in which is subject the data controller or 3) if there is the express consent of the personal data subject.



(i) right to withdraw consent means that the subject has the right to withdraw his/her consent for his/her personal data’s process, at any time in the future.  The legitimacy of the personal data’s process is not affected by the said act, until the time of the withdrawal of his/her consent.



(j) right to freeze the personal data means that in some cases that are provided by the Law, the Company will freeze the personal data of the subject, upon his/her request. Furthermore, the process of personal data is only realized to a limited extent.



If the subject request to the Company for the discontinuance of his/her personal data’s use, the Company shall satisfy this request and shall maintain only the information necessary to comply with the national legislation. 


The subject may contact with the Company, in order to exercise his/her rights, and the Company shall respond in a timely manner, not exceeding 30 days. 



8. The Use and The Process of Personal Data 



The Company is bound that will use the provided personal data, according to this Privacy Policy and exclusively for the purposes that the End User’s provided them for. 




The Company maintains the ability of using the personal data that provided to the Company upon your registration to the Company’s Services, in order to send you important information and notices regarding to your account and the services that you have requested.


In a case of personal data collection by the Company that concerns the data’s provision directly by the himself/herself End User, when the latter requested to receive files or services from the Company, the Company will proceed to procession of the request for assistance or service, including processing the completion of the order and the payment, if any. So, the Company will not share the data with third parties, except for those that the Company uses to conduct its business (for example, the completion of the order and the payment processing), required to conclude purchases that are made by the subject and subscriptions that it has requested via





9. Personal Data’s Transfer to third parties



The Company undertakes the commitment of not transferring the personal data that are collected to third parties that are not related or associated with it, unless you have provided your express consent about that. If the Company receives personal data from a third party-business partner, the use of these information by the Company will be governed by the hereby Privacy Policy.


This Privacy Policy describes the types of other companies that may wish to send you notifications about their products and services and, therefore, wish to share your personal data, under the condition that you have explicitly consented to the above.  





The Company’s website may also be linked to websites operated by the Company’s affiliates, for example companies that are members of the Company’s Group. Although members of the Company Group abide by the rules of the Group, the subjects of the personal data should refer to the separate privacy policies and practices, which may differ in certain aspects from this Privacy Policy.





Any third party that undertakes the processing on behalf of the Company, as indicatively and without limitation a service provider, is required to contractually agree to the processing of the personal data in accordance with this Privacy Policy; for that reason, the terms of this Policy are included in the pertinent agreements.  


It is possible the revelation of personal data to third parties only if it is necessary or if the subject expressly consents to it. The personal data should be provided anonymously, if deemed appropriate.




Moreover, the Company may use all the personal data, in an anonymously, for research purposes.



Third companies that are associates of the Company may offer the subjects downloads of data and files, by collecting personal data on behalf of the Company, when the subjects register or log in for individual downloads of files and services via their mobile phone. Then, the Company’s associates can share with the Company the personal data required, in order to offer the requested information, file downloads and other services. The Company’s associates also provide to subject’s mobile phone operator the required information, in order to charge him/her for the information and file downloads and other services that have been purchased. 







The Company maintains the ability of sharing subject’s personal data with its associates companies or with companies that belong to its Group of Companies, always in order to fulfil the processing purpose.


For the achievement of all the above mentioned purposes, all of the Company’s employees receive the necessary training in personal data and data security issues. As also, for the legitimacy of employees’, officers’ and associates’ access to personal data, this access should be justified by a legitimate reason, as it is predicted by the Law. 


The Company has the right of sharing subject’s personal data with outsource associates or agents, who provide their assistance to the Company for managing its informational activities (for example completion of orders, statistical analyses). Although, in that case the above mentioned persons can only use the provided personal data, in order to provide to the Company a specific service and not for any other purpose. 



The Company may enter into agreements with third companies that own the technology, which allows the Company to adjust the advertising and marketing messages that the personal data’s subjects receive on the Company’s websites. Non-personal data and browsing history data about subjects’ activities on these websites may be shared with these companies, in order to achieve this adjustment. These companies will not share the said information with any third party nor use it for any other purpose. It is, nonetheless, possible for the browsing history and other demographic information to be used, anonymously, exclusively for advertising-statistical purposes by the Company or its business associates. 






10. Data Storage, Time of Retention and Security



The time of personal data storage is determined by the time that is needed for the fulfilment of the purpose of its collection as also by the Law. The information relating to the storage of the personal data and the period of their retention are determined in the Data Retention Policy of the Company. 



The Company takes all measures indicated by technology, organisational or no, for the purpose of safeguarding the personal data that the Company possesses against loss, theft and unauthorised use, disclosure or modification, so as ensuring their integrity, confidentiality and availability. The Company uses also reasonable methods to ensure that the personal data are accurate, updated and properly completed. 









11. Cases of the Personal Data Disclosure



The Company is entitled to disclose your personal data without needing your consent, in the following cases: a) in order to protect its legitimate rights or the rights of other companies that belong to its Group of Companies or the rights of its employees, officers or associates, b) to safeguard the security of its website visitors, c) to be protected against fraud or committed criminal acts or any case of a suspicion for such act, d) for reasons relating to danger management, e) public order and security, public interest, f) in order to comply with the law or the legal procedures. 





12. Conditions of cross-border disclosure of the Personal Data


The subjects’ personal data disclosure to a third country is possible, only if the legislation of said country provides a sufficient level of data’s protection. In a different case, the personal data may only be transferred to this country, if the subject has expressly consented to their transfer or if the data protection is provided for by a relevant agreement for data’s transfer, which provides all the necessary warranties about their protection  





13. Transfer of the Company


If the Company transfers, in whole or in part, its business or sells or transfers assets or, in general, engages in a merger or transfer of its business, it is allowed to transfer subjects’ personal data to a third party as part of this transaction. 




14. The Amendment of the Privacy Policy Provisions


The above provisions represent the entire agreement with the Company, which has the right to amend or update or remove all provisions herein, without any notice. The amendment or update will be effective upon relevant modification of this document. Therefore, the subject should regularly refer to this Policy, in order to be informed about the Company’s latest policies and practices. If the Company materially changes its practices in regard to the collection and use of subject’s personal data, said data will continue to be subject to the Policy that was applicable during their collection, unless the subject have been accordingly notified and did not object to said change. 





15. Solving Personal Data’s Issues-Communication



For the reason of exercising subject’s rights, for example resolving a privacy issue, for issues relating to the collection and processing of subject’s  personal data by the Company, in order to revise, rectify or erase subject’s personal data or to discontinue any future communication with the subject, the latter may contact the Company via the email address  [email protected] by calling the customer service at 2112348319  or by sending a letter to the Company’s head offices at Portugal Avenida 5 de Outubro, 124-7.º Andar Lisboa