This Privacy Policy contains essential information on how the personal data of clients and users is used, regardless of the channel or means (online or in person) IVENS Governance Advisors, Lda., in Portugal, chooses to interact.
Transparency is essential: it is clear what is done with personal data, the implications of such use and the rights of each person. All the information in this Privacy Policy is always available and can be consulted at any time, and it also describes each data processing process.
Furthermore, the transparency obligation provided for in the EU General Data Protection Regulation (GDPR) 2016/679, as well as in applicable national laws, is complied with.
Some terms used in this Privacy Policy:
When referring to “platform”, we include all channels or means, digital or physical, used for interaction, the main means being our website: https://ivensadvisors.com/
1. Who is the Entity Responsible for Processing your data?
Ivens Governance Advisors, Lda., hereinafter “IVENS ADVISORS” is a company based in Lisbon and registered in Portugal under number 514363592.
IVENS ADVISORS is the entity responsible or co-responsible for the collection and processing of your personal data, when it decides which data is collected, the means of processing and the purposes for which the data is processed.
Additionally, IVENS ADVISORS processes personal data as a Processing Entity, on behalf of and under the instructions of other responsible entities, in the context of our professional services.
2. Our commitment
This privacy policy reflects our commitment to (i) communicating transparently about the personal data we process and under what conditions; (ii) protecting the security and privacy of personal data; and (iii) providing appropriate mechanisms for exercising the rights of data subjects.
If you are our customer, potential customer, prospective employee, alumni, supplier, partner, or user of our websites or mobile applications, we recommend that you read this document.
Ivens Advisors promotes the protection of the confidentiality and privacy of the information entrusted to it. As part of this fundamental obligation, Ivens Advisors also promotes the appropriate protection and use of personal data (referred to as "personal data", "personally identifiable information" or "PII") collected through its website.
3. What personal data do we collect and process?
Essentially, personal data is any information that, directly or in combination with other data, can identify a natural person.
Identificação e contactos
Nome, número de documento de identificação, NIF, assinatura, morada, contacto telefónico, ou endereço eletrónico.
Dados biográficos
Data de nascimento, sexo, nacionalidade, naturalidade, estado civil, agregado familiar, habilitações académicas, experiência profissional, perfil do Linkedin, ou registo criminal.
Dados financeiros
NIB, rendimentos, ou património financeiro/imobiliário.
Relação com a Ivens Advisors
Dados relativos ao envio de convites e publicações da Ivens Advisors, comentários dos titulares nos meios de presença da Ivens Advisors nas redes sociais, ou respostas dos titulares a questionários de satisfação.
Opiniões e preferências
Preferências relativas ao envio de convites e publicações da Ivens Advisors, comentários dos titulares nos meios de presença da Ivens Advisors nas redes sociais, ou respostas dos titulares a questionários de satisfação.
Conteúdos
Informação contida nas comunicações escritas entre o titular dos dados e a Ivens Advisors.
Utilização de sites e aplicações
Páginas visitadas, ou informações sobre os equipamentos utilizados (e.g. endereço IP, localização geográfica, browser utilizado).
Meios de Recolha de Dados
Dados fornecidos pelos titulares
Dados ou conteúdos fornecidos diretamente pelos titulares (i) nas interações com os profissionais da Ivens Advisors, (ii) nas cartas ou mensagens de correio eletrónicas enviadas à Ivens Advisors, (iii) na definição das preferências relativas às comunicações da Ivens Advisors, (iv) na participação em eventos, (v) na submissão de candidaturas à Ivens Advisors, ou (vi) na resposta a inquéritos de satisfação.
Dados recolhidos das redes sociais
Dados relativos à interação dos titulares nos meios de presença da Ivens Advisors nas redes sociais, ou nos perfis públicos dos titulares nas redes sociais (e.g. Linkedin, curriculum vitae para se candidatar online a um emprego na Ivens Advisors, utilizaremos a informação que nos fornecer para verificar as oportunidades de emprego disponíveis).
Dados recolhidos das entidades terceiras
Dados obtidos pela Ivens Advisors junto dos seus clientes no contexto da prestação de serviços profissionais ou junto de outras entidades terceiras (e.g. Banco de Portugal (BdP), autoridades públicas, companhias de seguros).
Cookies persistentes
Dados relativos à utilização dos sites e aplicações da Ivens Advisors (e.g. páginas visitadas, preferências do utilizador), obtidos através de cookies da Ivens Advisors ou de entidades terceiras.
Ivens Advisors may process other personal data as a responsible or co-responsible entity, including special categories of data, in the exercise of professional service provision activities.
Ivens Advisors obtains the personal data listed above through the following collection methods:
4. Automatic collection of personal data
In some cases, Ivens Advisors and its service providers use cookies and other technologies to automatically collect certain types of data when you visit our website. Collecting this information will allow us to optimize your user experience and better understand and optimize the performance, usability and effectiveness of the Ivens Advisors website and evaluate the effectiveness of our marketing activities.
— IP addresses
An IP address is a number assigned to your computer whenever you access the Internet. It allows computers and servers to recognize each other and communicate with each other. The IP addresses from which visitors access our website may be logged for security and diagnostic purposes of our information systems. This information may also be used in aggregate form to see website trends and analyze performance.
— Cookies
Cookies may be installed on your computer or device whenever you visit our website and are used by the website to remember your computer or device.
On our website, a window will appear asking whether you wish to accept cookies or not. If you do not accept cookies, your computer or device will not be tracked for marketing purposes. A secondary type of cookie, user input cookies, may also be requested. These cookies cannot be blocked through the initial window. Your choice is saved in a cookie and is valid for a period of 365 days. To change this option, simply clear the cookies from your browser.
Although most browsers automatically accept cookies, you can choose whether or not to accept them through your browser settings (usually through Tools or Preferences). You can also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to experience the full functionality of our website.
You can find more information about how to manage cookies through your browser's help file or through some websites, such as www.allaboutcookies.org .
Below is a list of the types of cookies used on our website:
Our websites may also use third-party tools and widgets to provide additional functionality. The use of these tools and widgets may result in a cookie being placed on your device to facilitate your use of the services of these features and to ensure that your interaction with our websites appears appropriate.
Cookies do not identify your email address or otherwise identify you personally. We may obtain other means of identification through our analytics reports, such as IP addresses, but only to help us determine which areas of the Site our visitors prefer and not to identify individual visitors.
— Social media widgets and applications
The Ivens Advisors website may include features to facilitate sharing via external social media applications, such as the LinkedIn “Like” button. These applications may collect and use information about your use of the Ivens Advisors website (see details on “Social Sharing” cookies). Any personal information you provide through these applications may be collected and used by other members of these social networks and such interactions are governed by the privacy policies of the companies providing the applications. We have no control over these companies or their use of your information and we are not responsible for them or their use of your information.
Additionally, the Ivens Advisors website may host blogs, forums, crowdsourcing and other applications or services (collectively referred to as social media sources). The purpose of social media sources is to facilitate the sharing of knowledge and content. Any personal information you provide on any of Ivens Advisors’ social media resources may be shared by other users of those resources (unless otherwise stated at the time of collection), over which we have no control or limited control.
Children
Ivens Advisors recognizes the importance of protecting children’s privacy, especially in the interactive online world. Our website is not designed or intentionally directed to children under the age of 13. It is not our policy to intentionally collect or maintain information about anyone under the age of 13, except as part of a contract for the provision of professional services.
Options
In general, you are not required to provide any personal data when you visit our website, but Ivens Advisors may ask you to provide certain personal data so that you can receive additional information about our services and events. Ivens Advisors may also ask for your consent to certain uses of your personal data, and you may accept or decline such uses.
If you choose to subscribe to certain services or communications, such as an electronic newsletter, you may unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will attempt to remove your data promptly, although we may ask you for additional information before we can process your request.
As described above, if you wish to prevent cookies from identifying you while browsing our website, you can
reset your browser to refuse all cookies or to inform you when a cookie is being sent. However, please note that some areas of our website may not function properly if you choose to refuse cookies.
Links to other sites
Please note that the Ivens Advisors website may contain links to other websites, including websites maintained by other Ivens Advisors member companies that are not subject to this Privacy Policy, but rather to other privacy policies that may differ in some respects. We recommend that users read the privacy policy of each website visited before transmitting any personal data.
By registering on the Ivens Advisors website and navigating to other websites with your login, you agree to the use of your personal data in accordance with the Privacy Policy of the Ivens Advisors website you are visiting.
5. How we process personal data
Data processing is an operation or set of operations performed on personal data by manual or automated means, including collection, storage, use, copying and transfer.
At Ivens Advisors we process personal data lawfully, fairly and transparently and for specific purposes. Any additional secondary data processing is only carried out if (i) it is compatible with the purposes authorized and communicated to the data subjects or (ii) if it is subject to specific and explicit consent from the data subjects.
The following sections describe and illustrate the main purposes of processing at Ivens Advisors, framed within their respective legal bases.
Contract execution
Ivens Advisors carries out the data processing necessary for the conclusion, execution and management of contracts to which the data subject is a party, or for pre-contractual steps at the request of the data subject:
Compliance with legal or regulatory obligation
Ivens Advisors carries out the necessary data processing to ensure compliance with the various legal and regulatory obligations to which it is subject, including in particular the Commercial Code, the Civil Code and tax legislation:
Legitimate interest
Ivens Advisors carries out the necessary data processing to safeguard its legitimate interests:
Consent of the data subject
Ivens Advisors may carry out other processing of personal data when it has the express consent, in writing, orally or through an unequivocal, informed, free and for specific purposes of the data subject:
6. What are the retention and processing periods for personal data?
Ivens Advisors stores and processes personal data for as long as necessary and as long as the legitimate purposes for which the data are processed subsist, to comply with contractual, legal and regulatory obligations, or to protect the legitimate interests of Ivens Advisors:
7. What are your rights as a data subject?
Ivens Advisors guarantees the exercise of the rights of data subjects in relation to their processing.
Data subjects may exercise their data protection rights, free of charge, by writing to the Head Office address : Ivens Advisors – Av- Álvares Cabral 63-2º, 1250-017 Lisbon, Portugal, or to the email address djpf@ivensadvisors.com. Ivens Advisors will respond to requests within a maximum period of 30 days, except for particularly complex requests. In such cases, Ivens Advisors will inform data subjects of the need to extend the response period by an additional maximum period of 30 days and the respective justification.
Whenever Ivens Advisors considers that it is not possible to respond to requests, data subjects will be informed of Ivens Advisors' reasons, within the timeframes established above.
8. What personal data we share
Ivens Advisors may transfer personal data to third parties in the context of its legitimate business activities:
Public Bodies and Institutions and supervision - CMVM, Banco de Portugal, AGT, Courts, whenever there is a legal or regulatory obligation to do so.
Service providers - Service providers acting on behalf of or under the instructions of Ivens Advisors (e.g. providers of document management and archiving services). In these cases, the transfer of personal data is subject to a specific contract that ensures that these entities process the data under the prior instructions of Ivens Advisors and comply with all legal obligations regarding data protection.
In its relationship with third parties, Ivens Advisors may transfer data to countries outside the European Union, provided that it has the necessary confidence that personal data is adequately protected, in accordance with rules formally defined through a contract or equivalent instrument.
9. How we protect personal data
Protecting the confidentiality and integrity of data is (i) a legal and regulatory obligation, and (ii) one of the pillars in building relationships of trust between Ivens Advisors and its clients, employees, regulatory entities and business partners.
Ivens Advisors has implemented appropriate organizational measures, processes and security systems to protect your personal data against unauthorized destruction, alteration and access, including: (i) mechanisms for controlling access to information systems and data; (ii) specialized security systems (e.g. firewall, antivirus, vulnerability management); (iii) mechanisms for recording actions carried out by employees and other users of information systems; (iv) data encryption, pseudonymization and anonymization mechanisms; (v) encryption measures for equipment and mobile devices; (vi) physical security measures to protect facilities (e.g. physical access control, video surveillance); and (vii) an awareness and training program for Ivens Advisors employees and partners on information security and personal data protection.
10. Changes to the privacy policy
Ivens Advisors reserves the right to make changes to this policy at any time to adapt it to best market practices or future legislative or regulatory changes. When we make changes to this statement, we revise the “updated” date at the top of this page. We recommend that you read this Privacy Policy periodically so that you are aware of how Ivens Advisors protects your information. The updated version will always be available for consultation on our website https://ivensadvisors.com/
11. Our contacts
Ivens Advisors is committed to protecting the privacy of your personal information. Any questions, comments or requests regarding the protection of personal data can be sent to the email address djpf@ivensadvisors.com.
You may also use this email address to communicate any concerns you may have regarding compliance with our Privacy Policy.
In any case, you always have the right to file a complaint with the National Data Protection Commission in Portugal.