1. Privacy Policy

This Privacy Policy is part of the Terms and Conditions and aims to inform Users about how Pluggable processes personal data and ensures their privacy, security, and integrity in the development and execution of its activities.

It is recommended to carefully read the Privacy Policy, along with the Terms and Conditions and the Cookie Policy, before using the Website.


2. Data Controller

The processing of personal data is the sole responsibility of Pluggable, as identified in point 1 of the General Terms and Conditions of Use.


3. Processing of Personal Data

Pluggable collects personal information from Users, both mandatory and optional, through subscription, application, and registration forms available on the Website.

Under the data protection legislation in force in the European Union, the processing of personal data is only permitted if at least one of the following conditions is met:

  • When the data subject has given consent for the processing of their personal data (for this purpose, a consent form will be presented to the User for the use of their data, which may later be withdrawn);
  • When data processing is necessary to conclude a contract with the data subject or to carry out its execution;
  • When data processing is necessary to comply with legal obligations to which Pluggable is subject;
  • When data processing is necessary to protect the vital interests of the data subject or another natural person;
  • When data processing is necessary to achieve a legitimate interest pursued by Pluggable or a third party, provided that these interests outweigh the rights of the data subject requiring the protection of their personal data.

4. Data We Collect

The types of data we may collect about the User, depending on their use of the Website, include:

  • Identification data (name);
  • Contact details (email address, phone number, and LinkedIn profile);
  • Curriculum vitae;
  • Associated company data (name);
  • Any other information the User decides to provide when contacting us through the Website.

Some personal data are mandatory and are duly marked. The lack or insufficiency of such data may prevent or delay contact, application, and/or registration.


5. Purpose of Personal Data Collection

Pluggable uses Users’ personal information, obtained through the completion of contact, application, or registration forms, for:

  • Responding to inquiries submitted through contact forms;
  • Contacting Users following a job proposal;
  • Executing contracts concluded with Users for specific services;
  • Contacting Users regarding existing or potential business relationships;
  • Keeping Users updated on Pluggable’s services; and
  • Promoting events in which Pluggable participates.

6. Your Rights

Unless otherwise indicated by the data subject, Pluggable will assume that the collected data was entered by the User and that its entry was authorized, being true and accurate.

We kindly ask Users to inform Pluggable of any subsequent changes to the collected data so that it can maintain correct and updated information in its database and, consequently, fully comply with the intended purposes.

Users may request the restriction of their personal data processing whenever:

  • They contest the accuracy of personal data, for a period allowing Pluggable to verify its accuracy;
  • Processing is unlawful (for example, if it does not occur for the purposes outlined in point 5 of this Privacy Policy);
  • Pluggable no longer needs the personal data for processing purposes, but the data are required by the subject for legal claims, defense, or legal proceedings;
  • They object to data processing.

Regarding the last case, Users may object to the processing of their personal data at any time, and it will be immediately ceased. However, withdrawing consent does not affect the legality of prior processing based on consent or other legally required processing activities.

Users also have the right to request the deletion of their personal data from Pluggable’s database ("right to be forgotten"), which may occur at any time and without undue delay.

To exercise the above-mentioned rights, Users should contact Pluggable via email at info@pluggableai.pt.


7. Security

Pluggable employs a variety of security measures, including encryption and authentication tools, to help protect and maintain the security, integrity, and availability of Users’ personal data.

Although data transmission over the internet or website cannot guarantee complete protection against intrusions, Pluggable makes every effort to implement and maintain physical, electronic, and procedural security measures designed to safeguard Users’ personal data on the Website, in compliance with applicable data protection regulations.

Among others, Pluggable has implemented the following security measures:

  • Restricted personal access to Users’ personal data based on the "need-to-know" principle and only within the scope of the purposes outlined in point 5 of this Privacy Policy;
  • Only authorized personnel bound by confidentiality and secrecy obligations may access personal data (all Pluggable employees and collaborators are required to keep personal data obtained in the course of their duties confidential);
  • Encryption of collected data during transmission;
  • Storage of highly confidential data in encrypted form;
  • Protection of information technology systems using firewalls to prevent unauthorized access to Users’ personal data;
  • Continuous monitoring of access to information systems to prevent, detect, and stop unauthorized use of Users’ personal data;
  • Retention of data only for the period strictly necessary for processing purposes or as required by legal or regulatory provisions.

Pluggable strives to apply the best organizational and security measures to protect Users’ personal information on its Website, preventing its loss, misuse, alteration, or destruction, thereby ensuring its integrity, availability, and confidentiality.


8. Sharing of Personal Data

As a rule, Pluggable does not transfer or share Users’ personal data from the Website with third parties, unless required by law.

However, Pluggable may subcontract service providers when necessary, which may involve sharing personal data. In such cases, Pluggable will take all necessary measures to ensure that service providers offer full safeguards for the protection, security, and confidentiality of the shared personal data. These service providers act strictly according to instructions given by Pluggable, which entails a contractual agreement governing the relationship.

Users’ personal data may also be transmitted to judicial, administrative, supervisory, or regulatory authorities, as well as entities that lawfully carry out data collection, fraud prevention and combat, market research, or statistical studies.


9. Data Retention Period

Pluggable retains personal data only for the period necessary to fulfill the specific purposes for which they were collected, as outlined in point 5 of this Privacy Policy. Once the data are no longer needed, personal data will be irreversibly anonymized (with anonymized data possibly being retained) or securely destroyed.

However, Pluggable may be required to retain some personal data for a longer period, taking into account factors such as:

  • Legal obligations under applicable laws requiring the retention of personal data for a specific period;
  • Prescription/statute of limitations under applicable laws;
  • Litigation; and
  • Guidelines issued by competent data protection authorities.

During the personal data processing period, Pluggable ensures that data are handled in accordance with this Privacy Policy.


10. Changes to This Privacy Policy

Pluggable may modify this Privacy Policy whenever it deems necessary or whenever required by law. Whenever such changes occur, the new version will be published on the Website and will take immediate effect, so we advise regular consultation. Additionally, Website Users will be required to provide new consent regarding these modifications or updates. Refusal of consent may, depending on the specific case, result in restricted access to the Website.

In case of conflict between this Privacy Policy and subsequent versions published following modifications, the most recent version shall prevail.


Last updated: November 25, 2024