Identification of the Controller

MINDERA GROUP and all its affiliate companies (hereinafter “Mindera”) is the data controller for the information you provide unless otherwise stated. If you have any queries about the process, how we handle your information, or if you do not understand any aspects of this document, please feel free to contact us at dpo@mindera.com and speak with our Data Protection Officer, Patrícia Macedo Alves.

Without prejudicing the need to read this document, you should also consult our Terms & Conditions, which provide a more detailed explanation of the objectives of this website, our mission, and how we use and protect your personal data. You can find further information on how we use and protect your personal data by reading our Cookie Policy.

Information

The General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, hereinafter referred to as "GDPR") ensures the protection of individuals with regard to the processing of personal data and the free movement of such data.

The GDPR defines personal data as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

When a user fills in our Contact Us form, with a request for more information related to the available subjects, identification data (first and last name) and contact data (e-mail), professional data (role & company) are requested but only identification and contact data will be mandatory. You may be required to pass a CAPTCHA in order to submit a reply to the form.

The categories of personal data collected will, as you can see, differ depending on the data subject's interaction with our website and according to their own interests during each visit.

In no case will personal data of racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, concerning health and sex life, genetic, biometric, or regarding life or sexual orientation be requested without the express and free consent of the individual the data relates to.

Purposes of the processing of Personal Data

Personal Data processed will only be used for the following purposes:

• Communication and clarification.
• Processing of information requests.
• Verifying, maintaining, and developing systems or statistics.
• Access Mindera’s technology and developments(its different workflows) directly or through third parties.
• Management of spontaneous applications and recruitment processes.
• Newsletter purposes (for the user to receive information about content published on the website) blog articles, news about Mindera, events and related occurrences.
• Branding purposes.
• Opting for marketing purposes.
• Events promoted by Mindera.
• You receive an email from us (source: online professional communities).
• Manage subscription to our newsletter.
• Human Verification CAPTCHA.

Mindera guarantees the confidentiality of all personal data provided. Mindera collects and processes data in a secure manner and prevents its loss or manipulation by using the most appropriate techniques. It should be kept in mind that the collection of data and its flows, in open and not controlled networks, allows personal data to circulate without safety conditions, with the risk of being seen and used by unauthorised third parties, for which Mindera won’t be liable.

Marketing Data

We may use your professional contact details to send you marketing communications, by email, about products or services that may be relevant to your role. These communications are always personalised to your professional context and are never mass, generic mailings.

The data we process for this purpose will be limited to your name, professional email address, and job title. We do not process personal email addresses or any other category of data for this purpose.

This processing is based on our legitimate interest in contacting professionals whose role relates directly to our offering. Before each campaign, we assess whether this legitimate interest is overridden by your rights and reasonable expectations as a data subject, and we document this assessment together with the source of your data. Where this justification cannot be established, the contact is excluded from any campaign.

ReCAPTCHA

In order to interact with our website, you will be required to complete a CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) to ensure that any communications to Mindera are legitimate.

Our CAPTCHA system is provided by Google and governed by this policy. As a result, International Data Transfers will take place when you complete it, Mindera has entered into a Data Processing Agreement that includes Standard Contractual Clauses to safeguard these transfers of data.

Transfers of Personal Data

In no case will Mindera transfer the personal data provided through this website to third parties without the prior consent of the user, unless it’s a legal obligation to do so or we find it a legitimate interest, as long as the appropriate safeguards are guaranteed.

This consent, whenever requested, for the most diverse purposes, will always be free, clearly expressed, and enshrined in a clear and unequivocal commitment that its withdrawal, if desired by the user, will be possible at all times.

Rights of the Data Subject

In accordance with the provisions of the GDPR, the user may exercise at any time his/her/their right to information, access, rectification, erasure, limitation, portability, opposition, and the removal of consent by means of a written request addressed to Mindera, through the following means:

• Through paper mail to the following address: Rua Gonçalo Cristóvão, n.º 347, 4.º piso, sala 404,4000-270 Porto, Portugal.
• Through email to the following address: dpo@mindera.com.

You can also opt-out of marketing communications at any time. Just click the unsubscribe/opt-out link in any marketing email we send, or reply directly and tell us.

There's no form to fill in and no waiting period: as soon as we receive your request, we stop sending you marketing emails and add you to our suppression list so it stays that way going forward, even if we later acquire your contact from a different list or source.

If you are in the United Kingdom, you may also exercise your right to complain, through the same means mentioned above.

If these rights are exercised, then the user must specify the nature of their claim and identify themself. Once the identity of the user has been confirmed, to ensure the request isn’t being made by a non-authorised third party, the claim will be attended to in full accordance with the necessary legal requirements/deadlines.

Where the GDPR is not applicable, we will respond to such requests within the prescribed time period under applicable law.

Security Measures

Mindera states that it has implemented and will continue to implement the security measures (of a technical and organisational nature) necessary to guarantee the protection of the personal data we are provided. We’ve implemented and continue to implement these measures to prevent the data’s alteration, loss, unauthorized treatment and/or access, taking into account the current state of the technology, the nature of the data stored, and the risks that it is exposed to.

Mindera guarantees the confidentiality of the data provided through this website. All data will be in a secure infrastructure that is safeguarded through the use of data encryption. You may find that your browser communications are secure if a block appears in the web address bar, or if the address starts with HTTPS instead of HTTP only.
However, as the internet is not completely secure, we warn that your personal data can circulate on open networks, without security conditions, that Mindera is not responsible for and cannot be held responsible for, at the risk of being seen and used by unauthorized third parties. This means that any transmission of your personal data will be at your own risk.

Retention of Personal Data

In accordance with applicable data protection laws, we do not store personal data for longer than needed for the purposes of the respective processing activity. The relevant retention periods depend on the national legislation of the country you are based in.

If the personal data is no longer required for the performance or enforcement of contractual or legal obligations, we will either delete it or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from further processing until deletion is possible. We may retain your data for longer than the usual retention period if it is still necessary to:

• fulfil obligations pursuant to the agreement with the client;

• fulfil obligations pursuant to the employment agreement or other agreements with you, including payment of holiday allowance;
• establish, exercise, and defend a legal claim;
• deal with and resolve requests and complaints;
• fulfil statutory obligations to which Mindera is subject, such as continued storage pursuant to accounting legislation.

For more detailed information about the retention periods of the personal data that Mindera processes, you can request a copy of our Retention Policy via email: privacy@mindera.com

Other Considerations

Mindera is not responsible for any acts or omissions of third parties, namely, links to other websites and their contents.

In case of a merger, division, transformation, dissolution, or insolvency of the Mindera commercial company, your data may be transferred to third parties, as a commercial asset. In the event of this happening, the transfer of your data will always be in compliance with the applicable law and will always maintain your rights as the data owner, namely as to the consent given and the rights of opposition, access, rectification, deletion, limitation, and portability.

In the event of any legislative or commercial changes, Mindera reserves the right to change this policy at any time, so you should consult it whenever you use this website.
For more information, please contact us by email at dpo@mindera.com.

Internal AI use

We also use AI tools internally to support and optimise our own operations, including productivity and collaboration assistants, agents and automations, AI coding assistants, customer support tooling, and tools that help our teams draft, summarise, analyse, categorise, upload and download data.

• These disclosures apply to all categories of data subjects in the scope of this Policy. These disclosures are either necessary for the purpose of performing our contract with you or necessary for the purposes of our legitimate interests (that are to provide a better and more efficient service).

AI safeguards

When we integrate third-party large language models, we commit to strict privacy safeguards. We do not use Personal Data to train large language models, and we contractually require our suppliers not to use Personal Data to train their AI models.

We contractually ensure that Personal Data is not available. Our AI Services exclude automated decision-making that produces legal or similarly significant effects on individuals without human intervention.

Many of our AI Services are also optional, and we identify which ones process personal data so that our use of AI remains transparent and compliant. We use the lowest data retention periods possible for any Personal Data in AI Services.

Cookie Policy

You can read about Mindera’s Cookie Policy here.

Terms & Conditions

You can read about Mindera’s Terms & Conditions here.

Supervisory Authority

In accordance with the law, the data subject has the right to submit a complaint regarding the protection of personal data to the competent supervisory authority.

Other Privacy Choices

Although restricting access to certain data might affect your experience, you can always make changes, such as:

• Disable optional cookies: you can block optional cookies in your web browser (check your browser's Help page) or via the cookie manager on our Website.
• Don't provide personal data: you can still navigate the Website and access all our features that don't require your personal information.
• You can withdraw your consent for marketing communications: we will contact you directly if we receive your consent to send marketing communications, but if you don't wish to hear from us again, please click the unsubscribe button on the communication.

Data of minors

We do not knowingly collect any personal data from persons under the age of 18. If you are under the age of 18, please do not submit any personal data through our Website or Services.

We may collect personal data of persons under the age of 18 from their legal representatives registered on our Platform when necessary for compliance with a legal obligation to which Mindera is subject (e.g. to provide flexible working arrangements for Employees with young children).

If you have reasons to believe that an individual under the age of 18 has provided personal data to us through our Website or Services, please contact us.

Changes to the Privacy Policy

Mindera may change this Privacy Policy at any time. So, it is recommended that users check our Privacy Policy regularly and/or each time they access this website, where it will be properly advertised and easily accessible.

This Policy may also be supplemented by additional privacy notices, depending on where you live.