PRIVACY AND DATA PROTECTION POLICY


This Privacy and Personal Data Protection Policy aims to commit to respecting the rules of privacy and protection of personal data set forth in Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016 (GDPR), regarding the protection of individuals regarding the processing of personal data and the free movement of such data, as well as applicable national legislation. We take the necessary technical and organizational measures to comply with the GDPR and ensure that the processing of personal data is lawful, fair, transparent, and limited to authorized purposes.


UpFamilies project partners has implemented security practices and adopted procedures with the aim of ensuring their implementation in the areas of UpFamilies's intervention.


The protection of citizens, organizations, or companies concerning the processing of personal data is a fundamental right. Therefore, it is important to clarify the personal or organizational data collected by UpFamilies project partners and the purposes for which they are used.


Data Controller 


The data controller is O Mundo da Carolina - Associação de Apoio a Crianças e Jovens, with the national identity number 510 959 873.


Telephone in Portugal: 00351 969 059 898


Address in Portugal:

CIEC – Centro de Inovação Empresarial da Covilhã

Rua António Augusto de Aguiar, 60

6200-053 Covilhã, Portugal


Email address: geral@omundodacarolina.pt


Commitment


UpFamilies project partners ensures that the processing of personal data is carried out within the scope of the purpose(s) for which they were collected, or for purposes compatible with the initial purpose(s) for which they were collected.


UpFamilies project partners commits to implementing a data minimization culture, where only the personal data strictly necessary for the development of its activities and the satisfaction of citizens' interests are collected, used, and retained.


UpFamilies project partners commits not to disclose or share personal data for commercial or advertising purposes.


Objective


UpFamilies project partners aims to ensure a consistent and high level of protection for individuals, regardless of their nationality or place of residence, regarding the processing of their personal data.


The protection should apply to the processing of personal data by automated means, as well as to manual processing, if the personal data are contained or are intended to be part of a filing system.


The processing of personal data must be carried out lawfully and fairly.


Object


The principles of data protection should apply to any information concerning an identified or identifiable natural person. Personal data that have been pseudonymized, which could be attributed to a natural person by using additional information, should be considered information about an identifiable natural person.


Collection and Processing of Personal Data


UpFamilies project partners collects and processes personal data that is voluntarily provided by the data subject (hereinafter referred to as the data subject) through the completion of various forms.


Any information provided by the data subject will only be used for the purpose described and in compliance with data protection legislation.


The period during which data is stored and retained depends on the purpose for which the information is processed and the existence of legal requirements that may necessitate keeping them for a minimum period.


These purposes are:


Purpose 

Legal basis

Receivers

Retention period

“Query” Manage and respond to queries raised
Manage and respond to queries raised through the UpFamilies website or the UpFamilies app.
Data may be transferred to UpFamilies’ partner organisations on the legal basis of the legitimate interest to respond to your request for information. It may also be transferred to the European Commission and its representative entities in Spain that are in charge of reviewing the UpFamilies project for justification purposes, both technical and financial, regarding the project activities.
Until the resolution of your request for information
“Account” For organisations to have an account where they can create a profile for their organization on the app to publicise their services to its users.
Create the account and manage this information the app.

Data may be transferred to UpFamilies’ partner organisations on the legal basis of the legitimate interest to manage the app and avoid errors. It may also be transferred to the European Commission and its representative entities in Spain that are in charge of reviewing the UpFamilies project for justification purposes, both technical and financial, regarding the project activities.

Until either the organisaton which created the account, or the app creators decide it is no longer valid or relevant to the app management or its users.


In the absence of specific legal requirements, data will be stored and retained only for the minimum period necessary, for the purposes that prompted their collection or subsequent processing, after which they will be deleted.


Some data may be retained for purposes of public interest archiving, scientific or historical research, or for statistical purposes. In such cases, appropriate technical and organizational measures will be used to safeguard the rights and freedoms of the data subject.


Nevertheless, it is possible that the website or app keeps the data beyond the date of closure of your account or query if it is considered necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, avoid cases of fraud or abuse, apply our Terms of Use or fulfil a request to unsubscribe from future messages you might receive from the website.


The User hereby states that all Personal Data provided is true and correct and commits to bring to our attention any change or modification to it. In the case of provision of data from third parties, the User is responsible for having informed them and obtained their consent for their use to the ends specified in the Record of Processing Activities.


Any loss or damage caused to the website, the controller of the web portal or any third party due to the provision of erroneous, incorrect or incomplete information by the User will be the sole responsibility of the User.


Responsability


UpFamilies project partners is responsible for the processing of the collected personal data, as well as for the development of this Privacy Policy.


The data subject accepts that, by not providing all the requested information, they may not achieve the correct operation of some features on the website and app, as well as jeopardize any computer processing, consultation, or contact.


UpFamilies project partners uses personal data to respond to citizens' requests, including processing their cases, providing information on UpFamilies project for justification purposes.


UpFamilies project partners ensures that these data will be limited in access to individuals within the UpFamilies project partners community who have the need to know them.


Nevertheless, it is possible that we keep your data beyond the date of closure of your account if it is considered necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, avoid cases of fraud or abuse, apply our Terms of Use or fulfil a request to unsubscribe from future messages you might receive from the website.


The data subject hereby states that all Personal Data provided is true and correct and commits to bring to our attention any change or modification to it. In the case of provision of data from third parties, the data subject is responsible for having informed them and obtained their consent for their use to the ends specified in the Record of Processing Activities.


Any loss or damage caused to the website, the controller of the web portal or any third party due to the provision of erroneous, incorrect, or incomplete information by the data subject will be the sole responsibility of the data subject.


Minors


Neither the website nor the app will knowingly process personal information of individuals younger than 14 years old.
If while carrying out a check, the website or app discover that it is unconsciously collecting information regarding minors younger than 14 years of age, it will undertake the necessary measures that it is obliged to as a service provider and the party responsible for the data handling, and thereby will delete such information as quickly as possible, except in hypothetical circumstances where existing legislation would require it to be retained.
Pursuant to the European Regulation on Data Protection, individuals older than 13 are legally allowed to provide their consent, except in those cases where the law demands approval from the holder or parental or custodial responsibility for consent to be given.


Principles applicable to data processing


UpFamilies project partners commits to ensuring that the data of the data subject processed by it are:


  • subject to lawful, fair, and transparent processing in relation to the data subject.
  • collected for specific, explicit, and legitimate purposes, not processed subsequently in a manner incompatible with those purposes.
  • adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
  • accurate and updated whenever necessary.
  • stored in a way that allows the identification of data subjects only for the period necessary for the purposes for which they are processed.
  • processed in a way that ensures their security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, with appropriate technical or organizational measures adopted.


    Data Subject Rights


    1. Right to Information


    When data is collected from the data subject, they must be informed by UpFamilies project partners about:


  • the identity and contact details of the data controller.
  • the purposes of the processing for which the personal data are intended, as well as the legal basis for the processing, if applicable.
  • if the processing of data is based on the legitimate interests of UpFamilies project partners or a third party, the indication of such interests.
  • the recipients or categories of recipients of the personal data, if applicable.
  • the retention period for the personal data.
  • the right to request from UpFamilies project partners access to personal data, their rectification, erasure, or restriction.
  • the right to request from UpFamilies project partners access to personal data, their rectification, erasure, or restriction.
  • the existence of a legal or contractual obligation to provide personal data or if it is a necessary requirement for the conclusion of a contract, as well as whether the data subject is obliged to provide personal data and the possible consequences of not providing such data.
  • the existence of automated decisions, including profiling, and information about the underlying logic, as well as the significance and envisaged consequences of such processing for the data subject, if applicable.


    The above-mentioned information is provided in a concise, transparent, intelligible, and easily accessible manner, free of charge and without undue delay.


    If UpFamilies project partners intends to further process the data of the data subject for a purpose other than that for which the data were collected, prior to that processing, it will provide the data subject with information about that purpose and any other relevant information, in accordance with the above-mentioned terms.


    2. Right of Access to Data


    The data subject has the right to obtain confirmation as to whether personal data concerning them are being processed or not. If so, they have the right to access their personal data and the following information:


  • The purposes of the processing of data.
  • The categories of personal data concerned.
  • The retention period for personal data.
  • The procedure for requesting UpFamilies project partners to rectify or limit the processing of personal data.
  • Information available about the origin of the data, if not collected from the data subject.
  • The existence of automated decisions, including profiling, and information about the underlying logic, as well as the significance and envisaged consequences of such processing for the data subject. Upon request, UpFamilies project partners will provide the data subject, free of charge, with a copy of their data undergoing processing. The provision of further copies requested by the data subject may incur administrative costs.


    3. Right to Rectification of Personal Data


    The data subject has the right to request, at any time, the rectification of their personal data and the right to complete them if they are incomplete.


    In the event of rectification of the data, UpFamilies project partners communicates the rectification to each recipient to whom the data have been transmitted, unless such communication proves impossible or involves a disproportionate effort.


    If the data subject requests it, UpFamilies project partners provides information about these recipients.


    4. Right to Limitation of the Processing of Personal Data


    The data subject has the right to obtain the limitation of the processing of their data when:


  • dispute the accuracy of personal data, for a period that allows UpFamilies project partners to verify its accuracy.
  • the processing is unlawful, and the data subject opposes the erasure of the data, instead requesting the limitation of their use.
  • UpFamilies project partners no longer needs the data of the data subject for processing purposes, but these data are required by the data subject for the establishment, exercise, or defense of legal claims.
  • the data subject has objected to processing, pending verification that UpFamilies project partners's legitimate grounds prevail over those of the data subject.


    5. Right to Data Portability


    The data subject has the right to receive the personal data concerning them, which they have provided to UpFamilies project partners, when the following conditions are cumulatively met:


  • The personal data requested are provided by the data subject and concern them.
  • The processing is carried out by automated means, based on the data subject's prior consent or the performance of a contract in which the data subject is a party.
  • The exercise of this right does not prejudice the rights and freedoms of third parties.


    The information should generally be provided free of charge and in a structured, commonly used, and machine-readable format.


    When the data subject requests it and it is technically feasible, UpFamilies project partners is obliged to transmit the data directly to another organization or entity.


    6. Right to Object to Processing


    The fact that the processing of personal data is lawful, based on the exercise of functions of public interest, public authority, or for the legitimate interests pursued by UpFamilies project partners or third parties, does not prevent the data subject from having the right to object to the processing of personal data concerning their specific situation.


    In this situation, UpFamilies project partners will cease processing the data of the data subject, unless it can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims by UpFamilies project partners in judicial proceedings.


    Exercise of Rights by Data Subject


    The right of access, rectification, erasure, and portability, as well as the right to object, can be exercised by the data subject by contacting UpFamilies.


    UpFamilies project partners will respond to the data subject's request within a maximum period of one month from the receipt of the request, except in cases of special complexity, where this period may be extended to two months.


    If the requests made by the data subject are manifestly unfounded or excessive, especially due to their repetitive nature, UpFamilies project partners reserves the right to charge administrative costs or refuse to proceed with the request.


    When the processing of the data subject's data is carried out by UpFamilies project partners based on their consent, the data subject has the right to withdraw that consent at any time. However, the withdrawal of consent does not affect the lawfulness of the processing carried out by UpFamilies project partners based on the previously given consent.


    For the exercise of the rights of data subjects provided for in EU regulations and national legislation on the protection of personal data, UpFamilies project partners has appointed a Data Protection Officer (DPO), who can be contacted through the website www.upfamilies.eu on the contact page.


    Applicable Legislation


    Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals regarding the processing of personal data and on the free movement of such data.


    Law No. 58/2019, of August 8, ensuring the implementation, in the national legal order, of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals regarding the processing of personal data and on the free movement of such data.


    Law No. 41/2004, of August 18, transposing into the national legal order Directive No. 2002/58/EC of the European Parliament and of the Council, of July 12, on the processing of personal data and the protection of privacy in the electronic communications sector.


    Law No. 67/98, of October 26 (Personal Data Protection Law).


    Changes to the Privacy Policy


    UpFamilies will update it’s Privacy Policy whenever there are relevant changes to the applicable legislation or other factors that imply changes in data collection and/or processing. The latest version will always be provided on the UpFamilies website and app.


    Last Update: 07/02/2024