Data Officer

Direct Hit – Prestação de Serviços a Empresas, Lda, a legal entity with Tax Identification Number 504526 146, hereinafter referred to as Direct Hit, is the entity responsible for the online sites, systems or computerized applications, hereinafter referred to as channels or applications, through which Users, Service Recipients or Clients have remote access to Direct Hit services that are presented or provided, at any time, through them, and is considered the entity responsible for the processing of personal data.

The use of channels, systems or applications by any User, Service Recipient or Client may involve the processing of personal data, whose protection, privacy and security by Direct Hit, as the entity responsible for the respective processing, is ensured, in accordance with the terms of this Data Protection Policy.

Data Officer Contacts

For contact purposes with the Direct Hit Data Protection Officer, please send an email to dataprotection@directhit.eu or to each of the specific addresses identified on the websites, describing the subject of the request and indicating an email address, a telephone contact number or a postal address for reply.

For any other purpose, the following general Direct Hit contacts may be used:

– Postal Address: Rua Sousa Lopes, Nº 65, 5º Esq., 1600-307 Lisboa, Portugal;

– General Email: directhit@directhit.pt ;

– General Telephone: + 351 213 243 750;

– General Fax: + 351 213 243 759;

– Website: www.directhit.eu .

Collection and Processing of Personal Data

Direct Hit processes personal data strictly necessary for providing information and operating its channels, according to the uses made by Users, Service Recipients or Clients, whether those provided for the purpose of registering requests or obtaining information, those provided for the purpose of subscribing to those channels, or those resulting from the use of services provided by Direct Hit through them, such as accesses, consultations, instructions, transactions and other records relating to their use.

In particular, the use or activation of certain channel functionalities may involve the processing of various direct or indirect personal identifiers, such as name, home address, contact details, device addresses, or geographic location, provided that the User, Service Recipient, or Client expressly consents to this, whenever this is necessary for managing the contractual relationship or pursuing legitimate interests, or finally, for the purpose of complying with legal obligations.

In all cases, Users, Service Recipients or Clients will always be informed of the need to access such data for the use of the functionalities of the channels in question.

The personal data collected by Direct Hit is processed electronically, in certain cases in an automated way, including file processing or profiling, and within the scope of managing the pre-contractual, contractual or post-contractual relationship with Users, Service Recipients or Clients, in accordance with current national and community regulations.

Legal Principles

All data processing operations comply with the fundamental legal principles in the field of data protection and privacy, in particular regarding its circulation, lawfulness, fairness, transparency, purpose, minimization, retention, accuracy, integrity and confidentiality, and Direct Hit is available to demonstrate its responsibility to the data subject or any other third party that has a legitimate interest in this matter.

Foundations of Legitimacy

All data processing operations carried out by Direct Hit have a legitimate basis, namely, either because the data subject has given their consent to the processing of their personal data for one or more specific purposes, or because the processing is considered necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract, or because the processing is necessary for compliance with a legal obligation to which the controller is subject, or for purposes of public interest, or because the processing is considered necessary for the purposes of the legitimate interests pursued by Direct Hit or by third parties.

Purpose of Treatment

All personal data processed within the Direct Hit channels is exclusively intended for providing information to Users, managing the personal information of Service Recipients deemed necessary for relationship management or communication purposes, as well as providing services to Clients and, in general, managing the pre-contractual, contractual or post-contractual relationship with Users, Service Recipients or Clients.

The personal data collected may also, and eventually, be processed for statistical purposes, for disseminating information or promotional actions and for communication actions, namely to promote the dissemination of new features or new services, through direct communication, whether by mail, email, messages or telephone calls or any other electronic communication service.

Provided that prior information and express authorization are always obtained for these latter purposes, Users, Service Recipients or Clients may, at any time, exercise their right to withdraw consent or their right to object to the use of their personal data for purposes other than managing the relationship with the Data Controller, namely for the pursuit of legitimate interests, for sending informational communications or for inclusion in informational lists or services, and must, for this purpose, send a written request addressed to the Data Protection Office of Direct Hit, in accordance with the procedures indicated below.

Data Retention Periods

Personal data will only be kept for the period necessary for the purposes that motivated its collection or subsequent processing, ensuring compliance with all applicable legal standards regarding archiving, and specifying the concrete retention period in each of the Data Processing Information Sheets.

Use of Cookies

Direct Hit may use two main categories of cookies: cookies for online sites and cookies for direct electronic communication channels. Users or Clients are always guaranteed the option to disable cookies in either category.

Direct Hit uses cookies on its online sites to improve the performance and browsing experience of Users and Clients, increasing the speed and efficiency of response and eliminating the need to repeatedly enter the same information.

The use of cookies helps websites recognize Users’ and Customers’ devices the next time they visit, and in some cases, is essential for their operation.

The cookies used by Direct Hit, across all its channels, do not collect personal information that allows the identification of Users or Customers, only storing generic information, such as the method or geographical location of access and how they use the channels, among others. Cookies only retain information related to the preferences of Users and Customers, and no personal identifiers are recorded.

Users, Service Recipients, and Clients may, at any time, through the computer application they use to browse the internet (“browser”), decide to be notified about the receipt of “cookies,” as well as to block their entry into their system.

Regarding the type of intended purposes, Direct Hit may, whenever justified, use three different types of “cookies,” according to the following specifications:

(i) essential “cookies” – some “cookies” are essential to access specific areas of online channels, allowing navigation and use of their applications, such as access to secure areas of the sites, through user registration – without these “cookies,” the services that require them cannot be provided;

(ii) Functional cookies – Functional cookies allow us to remember user preferences regarding navigation on online sites, thus eliminating the need to reconfigure and personalize them each time they visit;

(iii) Analytical cookies – These cookies are used to analyze how users use online sites, allowing us to highlight articles or services that may be of interest to users, monitor site performance, as well as identify the most popular pages, the most effective method of linking between pages, or determine why some pages are receiving error messages – these cookies are used only for statistical creation and analysis purposes, never collecting personal information.

For these purposes, Direct Hit can provide a high-quality experience to Users, Service Recipients, or Clients by personalizing information and offers and identifying or correcting any problems that may arise in the context of their use.

Regarding the type of validity, there are two types of “cookies”:

(i) Permanent “cookies” – these are “cookies” that are stored on the devices used to access the channels (computers, mobile phones, etc.), at the level of the computer application used to browse the internet (“browser”), and are used whenever Users or Clients visit any channel again – in general, they are used to direct navigation according to the User’s or Client’s interests, allowing Direct Hit to provide a more personalized service;

(ii) Session cookies – these are temporary cookies that are generated and are only available until the session ends, since the next time the Client/User accesses their internet browser, the cookies will no longer be stored – the information obtained allows for session management, identification of problems, and provision of a better browsing experience.

Users, Service Recipients, or Clients may disable some or all cookies at any time – to do so, they must follow the instructions available in each of the computer applications used to browse the internet (“browser”), however, disabling cookies may result in the loss of access to some website functionalities.

Direct Hit, within the scope of direct electronic communication channels, may also use “cookies” when opening different electronic communications sent, such as newsletters and emails, for statistical purposes – allowing us to know if these communications are opened and to track clicks through links or advertisements within those communications.

Also in this category of “cookies,” Users, Service Recipients, or Clients always have the option to disable the sending of electronic communications through the specific option in the footer of those communications.

Data Recipients

Except in the context of fulfilling legal obligations, executing contracts, or pursuing legitimate interests, under no circumstances will personal data of Users, Service Recipients, or Clients be communicated to third parties other than subcontractors or legitimate recipients, nor will any other communication be made for purposes other than those mentioned above.

International Data Transfers

Any transfer of personal data to a third country or international organization will only be carried out in compliance with legal obligations or with the guarantee of conformity with applicable Community and national legal standards in this matter.

Exercising the Rights of Personal Data Holders

Users, Service Recipients, or Direct Hit Clients, as holders of personal data, may at any time exercise their data protection and privacy rights, including the rights of access, rectification, erasure, portability, restriction of processing, or objection to processing, under the terms and with the limitations provided for in the applicable regulations.

Any request to exercise data protection and privacy rights must be addressed in writing by the respective holder to the Data Protection Officer, in accordance with the procedure and contact described below.

Express Consent and Acceptance

The terms of the Data Protection Policy are complementary to the terms and provisions regarding personal data set out in the Specific Terms of Use of each of Direct Hit’s channels.

The free, specific and informed provision of personal data by the respective owner implies knowledge and acceptance of the conditions contained in this Policy, it being considered that, by using the channels or by providing their personal data, Users, Service Recipients and Clients are expressly authorizing its processing, in accordance with the rules defined in each of the applicable channels or collection instruments.

Data Protection Officer

To exercise any type of data protection and privacy rights, or for any matter relating to data protection, privacy and information security, Users, Service Recipients and Clients who interact with Direct Hit may contact the Data Protection Officer via email at dataprotection@directhit.eu , describing the subject of the request and indicating an email address, a telephone contact address or a postal address for a reply.