Privacy Policy

COMPROMISE

Provide Customers with a privacy policy that offers an overview of how their data is processed, and what their rights are in this matter in accordance with the provisions of Regulation 2016/679 of the European Parliament and of the Council – General Data Protection Regulation (GDPR) and other applicable legislation on privacy and data protection, including local legislation that complements the GDPR.

DATA CONTROLLER

The entity responsible for the processing of personal data is MICROSKILLS – INNOVATION AND TECHNOLOGY, LDA., a company incorporated under Portuguese law, with registered office at Rua Eng.º Adelino Amaro da Costa, n.º 177, Junqueiros, 2425-333 Carvide, parish of Monte Real e Carvide, municipality and district of Leiria, with a share capital of € 5,000.00 (five thousand Euros) (hereinafter, “YUPII“).

YUPII may also intervene in some processing activities in which it may be qualified as a joint controller or subcontractor, and this will be informed to the holder of personal data prior to processing.

DATA PROTECTION OFFICER

YUPII appoints a Data Protection Officer (“DPO”).

Any clarification regarding policies or practices regarding privacy and information processing may be requested from the designated DPO by sending an e-mail (dpo@yupii.net) or to YUPII’s headquarters, for the attention of the DPO.

The DPO may also be contacted to remove subscriptions, revoke consent, or file complaints based on a violation of law or this privacy policy.

PROCESSING OF PERSONAL DATA

The data provided, within the scope of the relationship established between the Clients and the Clients’ Employees and YUPII are processed in accordance with the following applicable principles:

  • lawfulness, loyalty and transparency;
  • determined, explicit and legitimate purposes;
  • adequate, pertinent and limited to what is necessary, considering the purposes for which the data is processed;
  • accurate and, if necessary, up to date (appropriate measures will be considered to ensure that inaccurate data will be deleted or corrected considering the purposes for which they were obtained);
  • kept in such a way as to allow the identification of their holders only for the necessary period and in accordance with the legal provisions;
  • processed in a manner that ensures their security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.

PURPOSE, FOUNDATION AND CONSERVATION

PURPOSE

YUPII processes personal data to provide services within the scope of the benefit programs.

FUNDAMENTALS

Presentation, proposal, conclusion and execution of contracts, pre-contractual diligences and support their management, with the intervention of:

  • Legitimate interest of the controller or third parties in identifying, assessing risks, informing, clarifying and advising on solutions and products;
  • Consent of the Personal Data Subject;
  • Compliance with legal and legal obligations.

CONSERVATION

To be considered until the expiration of the legal limitation period of all obligations arising from contracts with Customers.

Prospecting, commercial action, preparation of proposals, sending newsletters, promotional material and invitations to events

  • Consent of the Personal Data Subject
  • Legitimate interests in the development and growth of the activity of the controller
  • As long as there is consent for this purpose;
  • During the period in which there is a commercial relationship between the holder of the personal data and YUPII, and during the six months following the termination of such relationship.

Compliance with legal obligations (supervisory, tax, fiscal or judicial authorities)

  • Legitimate interests in monitoring the activity of the controller or third parties
  • Compliance with legal and legal obligations
  • For the exercise, declaration or defense of rights in judicial proceedings.
  • Until the expiry of the limitation period or limitation period for the exercise of rights
  • Applicable legal deadline (time for each legal and legal obligation to be fulfilled);
  • All data are received and stored for the minimum period legally established in 10 years, unless for the purposes of declaring, exercising or defending a right in legal proceedings, a longer period is justified;
  • In compliance with obligations regarding the prevention of money laundering and terrorist financing, the data will be kept for a period of 7 years

DATA COMMUNICATION

Personal data may be processed by other entities if applicable, such as a processor or joint controller, to whom YUPII may have subcontracted its processing.

YUPII employees and all parties to the contract in question who need them to comply with pre-contractual diligences, contractual or legal obligations of the insurance mediation activity have access to personal data.

The disclosure of personal information to YUPII’s business partners always presupposes that they, even if processing personal data separately, comply with data protection laws. Whenever requested, YUPII grants access to the privacy policy of the aforementioned partners.

Personal data may also be processed by other Insurers on the assumption of the settlement of claims in which they are involved.


RIGHTS OF DATA SUBJECTS

The Personal Data Subject has the right to request YUPII by means of a written request addressed to the DPO:

  • Access, under the terms and conditions provided for by law, to Personal Data concerning you and that are subject to processing;
  • The correction or updating of inaccurate or outdated Personal Data concerning you;
  • The processing of missing Personal Data when it is incomplete;
  • The erasure, in the cases specifically provided for by law, of Personal Data concerning you;
  • The limitation, subject to the conditions provided for by law, of the processing of Personal Data with regard to it.
  • Data portability, requesting personal information whenever the processing of this information is based on consent or in the execution of a contract to which it is a party.
    Objection to the processing of personal information, when it demonstrates the applicable legal basis and a legitimate interest.

Upon written request, addressed to the DPO, the Personal Data Subject also has the right to:

  • Withdraw the consent given, although the withdrawal of consent does not compromise the lawfulness of the processing carried out on the basis of the consent previously given;
  • Object to processing on grounds relating to your particular situation, where the data processing is based on the legitimate interest of the controller or of a third party;
  • Receive from the controller, in a commonly used and machine-readable digital format, the personal data concerning you and that have been provided by you, processed by automated means on the basis of:
    • in consent given by the Personal Data Subject or,
    • in a contract entered into, and may request, in writing, the respective transmission directly to another responsible party, whenever this is technically possible.

The Data Subject may also request detailed information from the DPO (purpose / lawfulness / retention periods) as well as submit complaints about the way in which their personal data is processed, without prejudice to the possibility of also doing so with the competent entity (National Data Protection Commission).

DATA COLLECTION

Within the scope of the purpose of managing the pre-contractual and contractual relationship and within the framework of the fulfillment of the duties of information, clarification, transmission, advice, assistance and registration imposed on it by the applicable legislation, YUPII may collect information regarding the Personal Data Subject that it considers relevant for the assessment of the risk to be insured and setting by the Insurers the contractual conditions of the insurance.  from publicly accessible sources, public bodies, industry associations, existing IT platforms or specialized companies, to complement or confirm the information provided by the Personal Data Subject.

The collection of data by YUPII is carried out under the strictly necessary terms and includes the name, email, address, telephone and mobile phone numbers, as well as relevant information such as profession, language, postal code and location.

LEGAL AND CONTRACTUAL OBLIGATIONS OF THE PERSONAL DATA SUBJECT

The Personal Data Subject who is a client of YUPII or a Client’s Employee will be legally or contractually obliged to provide some personal data necessary for the fulfillment of the pre-contractual and contractual obligations and diligences derived from it, as well as those that YUPII is legally obliged to collect.

The Personal Data Subject has the obligation to keep YUPII informed of any changes to their personal data, namely in the terms and conditions provided for in the respective policies.

TRANSMISSION OF PERSONAL DATA TO ANOTHER COUNTRY OR INTERNATIONAL ORGANIZATION

The transmission of personal data to countries outside the European Union only occurs if it is necessary for the execution of orders or requests by the Personal Data Subject, by legal requirement or if you have granted us express authorization for this purpose.

In the event that it is necessary to use service providers from third countries, they will be obliged to comply with the written instructions in this matter, by signing an agreement with the European Union’s standard contractual clauses and certification models, in order to comply with the level of data protection applicable in the European Union.

The Data Subject will always be informed of any data transmission under the terms indicated above prior to the transmission.

SECURITY OF PERSONAL DATA

YUPII employs the best means at its disposal to protect Users’ personal data against unauthorized access, disclosure, modification, or unauthorized destruction of data. To ensure the security of the User’s data and maximum confidentiality, YUPII.

It treats the information in an absolutely confidential manner, in accordance with internal security and confidentiality policies and procedures, which are periodically updated as needed, as well as in accordance with the terms and conditions provided for by law. Depending on the nature, scope, context and purposes of the data processing, as well as the risks arising from the processing for the rights and freedoms of the User, YUPII undertakes to apply, both at the time of defining the means of processing and at the time of the processing itself, the technical and organizational measures necessary and appropriate for the protection of the User’s data and compliance with legal requirements.

PROFILING

As a rule, we do not process data in an automated way for the purpose of defining commercial profiles, however we may have to define profiles within the scope of the contracted services or to be contracted.

We may proceed with profiling to be able to inform and advise on products and services, using evaluation tools, in which case the holder of the personal data covered will be informed in advance. This allows for demand-driven communication and advertising. YUPII applies all appropriate measures to safeguard your rights and freedoms in this area. In the case of the creation of customer profiles exclusively for commercial purposes, you may oppose the definition of such profile, by contacting the Data Protection Officer, to the contacts indicated above.

COOKIES

See YUPII’s Cookie Policy.

CHANGES TO THE PRIVACY POLICY

YUPII reserves the right to change this privacy policy at any time and without prior notice, so it is recommended that you periodically consult our Privacy Policy.