COVER PAGE

Summary of the Club and APP privacy policy

CONTROLLER

AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA

PURPOSE OF PROCESSING

Communication and facilitation of the use of discount club offers and discounts

• Discount club registration and wallet
• Selection of offers of interest to the user based on their profile
• Communication of offers
• Processing of offers
• Transaction management and wallet credits
• Incident resolution
• Withdrawal from the discount club

LEGAL BASIS

• Conclusion of a contract to which the data subject is a party.
• User consent for ancillary processing. Ancillary processing is understood to be that which is different from the one initially foreseen and which complements the service provided to the User.

TARGET GROUP

Subcontractors that provide technological infrastructure services.

RIGHTS

Access, portability, restriction of processing, objection, information, rectification and erasure.
Withdrawal of consent.

Rights may be exercised by sending an email to the following address:
[email protected]

PRIVACY POLICY

This document explains how we process your personal data as a user of this Platform's services.

Before submitting any data via the registration form, make sure you fully understand the terms of the privacy policy. If you need any clarification on this matter, you can write to us at the following email address: [email protected]

The correct provision of the services we make available to users is based on the reliability of the data they provide. If they provide us with false data, they will be liable for any damage that may be caused to AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA, the contracting company, or any third party.

Who is responsible for my data?

PORTUGAL - CONSULTORES, UNIPESSOAL, LDA as the company providing the service, will be responsible for processing your data in order to provide you with offers and discounts that may be of interest to you. These are their identification and contact details:

Controller
PORTUGAL - CONSULTORES, UNIPESSOAL, LDA
Headquarters:
Avenida da Liberdade 249, 2º 1250-143 Lisboa | Portugal
VAT ID
502 381 930
Contact email address
[email protected]
Email address of the Data Protection Officer
[email protected]
Registration data

Aon Portugal - Consultores, Unipessoal, LDA is an Aon Group company in Portugal. Aon Group companies in Portugal are affiliates and/or subsidiaries of Aon Plc., a world's leading professional services company offering a wide range of risk, retirement and health solutions. You can see a complete list of the entities that are part of our group [here].

AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA offers these services to the user because they have been contracted by [Client] (hereinafter referred to as [Client]). The aforementioned organisation wants the user to benefit from several advantages, i.e. discounts and offers on goods and services. This organisation will be referred to in this document as the “contracting company”. You can find more detailed information in the definitions of the Service Terms of Use.

How is user data processed?

1. Registration management via the website

Before you start using the services offered on the Platform, please fill in a registration form in which we ask you to provide us with some data to enable us to check that you are a member of the Members Group, so that we can register you on the website.

2. Management of user preferences

Once registered on the website, the user will be able to provide more information from their user profile. Use of the Platform does not depend on completion of the user profile. If the user chooses to provide this information, we will use it to personalise the service according to their preferences.

3. Selection of contents that may be of most interest to the user and definition of profiles according to their use of the Platform.

We select the content we think may be of most interest to the user, based on the user's configuration of their profile, their activity and their searches in the club. This involves an automated analysis of the user’s profile and their preferences in order to decide what type of content may be of interest to the user and to inform them about it, unless they tell us that they do not want us to conduct this analysis of their profile by exercising their right to object, as described below.

4. Communications by electronic means

One of the main goals of the service we provide is to inform the user about the Portal content, which, depending on the services or features provided by the Contracting Company, may be of a commercial nature.
If the user does not want us to send them these communications, usually by email, they can deselect that option in their profile when they register, or at any other time. They can also choose to unsubscribe with each communication they receive. In that case, they should note that they will no longer receive information about new content or services.

5. Management of commercial transactions, when Discount Clubs or savings Wallets are activated.

If the Contracting Company has activated the service, we will process the data relating to the transactions made by the user when they start benefiting from discounts by making purchases from the club. In other words, we can identify the products or services they purchase to deal with any issues that may arise in the management of their purchases, as well as to transfer the money they saved to their wallet. We ask for the user's bank account number so that we can deposit the money in the wallet.

7. Management of the invitations sent to other users to join the club if this feature is activated.

If the Contracting Company has activated the service, the user can invite other people to that service. We do not store the email addresses of the people the user invites. They will have to complete the registration process if they want to use the service. The information we process only includes the number of people invited by the user, as it helps us assess their satisfaction with the service.

8. Incident resolution

If the user has any problems arising from the use of the service and contacts us to resolve it, we will ask for their personal data over the phone in order to resolve the incident.

9. Allowing communication with other users if this feature is enabled.

If this service is activated, users can communicate with each other via a noticeboard. The purpose of the noticeboard is to allow users to coordinate activities, post notices, etc.
If the user wishes to use the noticeboard, we will process the information that they choose to publish on the noticeboard. Please note that all users of the club will be able to see the information they publish.

Why are we asking you to accept this privacy policy?

Data protection regulation requires the existence of legal basis that justifies the processing of personal data.

This table shows the legal basis of the various operations we carry out to process your personal data:

Legal basis

Provision of the service under the contractual relationship with AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA.
By registering with the discount club, or the Wallet service, and by accepting the terms of use of the service and this privacy policy, the user creates a contractual relationship with AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA to:

• Register on the platform and manage your user profile
• Manage transactions and wallet credits
• Resolve incidents
• Organise events, activities and competitions, which will also be subject to their own legal basis

We will be unable to provide the service if the user does not accept the terms of use and privacy policy.
However, the user may, at any time, object to the profiling of their preferences in order to inform them of existing offers.

Legitimate interest regarding the features you use.

• To keep the user informed by electronic means, usually by email, about products and services related to the features they use.
• To suggest a selection of offers that may be of interest to the user, based on their profile settings and purchasing preferences.

Users can object to this processing in two ways: by using the unsubscribe option in any of the communication they receive, or by stating in their profile settings, during the registration process or at any other time, that they no longer wish to receive emails. In that case, they will only receive emails relating to technical and operational issues on the platform, such as updates to the privacy policy or terms of use.

Consent

We may ask for your consent for processing operations other than those initially foreseen, such as when you accept cookies that record your browsing history, which are not necessary for the operation of the platform, or the app.

Users can cancel their subscription to the club service at any time, by accessing their profile and cancelling their account.

Users can also exercise the rights listed below in order to ask us about what we do with their data.

Who are the recipients of your data?

Users can benefit from the services offered by the club because the Contracting Company has chosen INSPIRING to give them the opportunity to use these services. That’s why we provide the Contracting Company with a user identifier (usually a CC or other similar ID) and an email address to control the registration and cancellation of club memberships.

In addition to the above, the provision of the service does not involve the disclosure of data to third parties without your prior consent.

Notwithstanding the above, we use suppliers to provide services, some of which are located outside the European Economic Area. In that case, we request the necessary guarantees to safeguard your privacy as a user, in addition to the corresponding data access contract, or Data Processing Addendum, in which we require them to comply with the strictest security measures.

You can contact us if you would like more information about whether your data will be disclosed to foreign recipients, or about the safeguards we have put in place (including a copy of the relevant contractual commitments, to the extent that this is permitted for reasons of commercial confidentiality) to ensure that your personal data is adequately protected. Do we transfer your personal data between geographical regions?

Aon Portugal operates in the global market and worldwide, and therefore reserves the right to transfer the user’s personal data to other countries for processing for the purposes stated in this Policy. We make these transfers to provide and manage the services provided to our clients, and to improve the efficiency of our business operations. We endeavour to ensure that these transfers comply with all applicable data protection laws and regulations and ensure adequate protection of the rights and freedoms that this legislation grants to data subjects.

When we collect personal data about users in Portugal, or the European Economic Area (the "EEA"), we may transfer personal data outside Portugal, or the EEA, for the processing purposes set out in this Policy. This may include transfers to countries that, according to the European Commission (the "EC") and the Portuguese data protection authority, offer adequate data protection safeguards, and to some countries that are not subject to a decision on adequacy. When we transfer personal data to countries that are not subject to a decision on adequacy, we will implement appropriate safeguards, such as data transfer agreements approved by the EC, or the Portuguese data protection authority, as appropriate. If necessary, you can obtain additional information regarding these safeguards from our global data protection department ("GPO").

Termination of the service by the Contracting Company

Termination of the service by the Contracting Company implies the cancellation of your user data, which will remain duly blocked for five years, for the sole purpose of allowing us to respond to requests made by administrative or judicial authorities. Your user data will be deleted permanently after that period.

What rights do users have to ensure that we take proper care of their data?

Data subjects can control how we use their information by exercising the following rights:

Rights of access, portability, restriction of processing, objection, rectification and erasure of your data. You can also withdraw your consent, where processing is based on consent, though this does not affect the lawfulness of processing carried out prior to such withdrawal.
You may object to the processing of your data for the purpose of sending commercial communications by electronic means.
You can also exercise your right to object to the processing we carry out, in order to decide which offers may be more interesting to you, based on an analysis of your purchase profile.

You can exercise any of the above rights by sending an email to the following address:
[email protected]
In any case, if you consider that we have not respected your rights adequately, you may lodge a complaint with our Data Protection Officer ([email protected]) or, where applicable, the Comissão Nacional de Proteção de Dados, at https://www.cnpd.pt/.

For how long do we retain your data?

The personal data provided to us by users will be retained for as long as the service is used.

If you decide to unsubscribe, we will never process your data for any purpose other than the use of the services of the Club website. The data will be blocked for five years, to enable us to respond to requests made by administrative or judicial authorities, after which we will erase the data.

Do we ensure the security of your data?

AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA. has taken the necessary technical and organisational measures to prevent the loss, misuse, alteration, unauthorised access and theft of your personal data.
We have also implemented procedures to respond in a timely manner to any security breach of the user’s personal data.

Likewise, we have contracted and commit to always contract suppliers that implement adequate security measures to protect user data when they host our technology. We also ensure that the user's data remains within the European Economic Area or, if it is located outside of it, that equivalent safeguards apply.
These suppliers process the data on behalf of AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA. as controllers.

Why do we use cookies?

We analyse user browsing data via the use of cookies. See our cookies policy for more information on which cookies we use and the reasons we use them.

What about the links on the club page that link to third-party websites?

There may be links to other websites on the club. AON PORTUGAL - CONSULTORES, UNIPESSOAL, LDA. has no control over how those websites process the user’s personal data. You should read their privacy policies to find out how they process your personal data.

Will we change this privacy policy?

Yes. This policy may be amended from time to time as a result of legal or commercial changes, in which case we will notify you by email or through a notice made available on the portal and publish the changes on this page.

SPECIFIC POLICIES

Discount button

The discount button, which you can choose to install on your browser, does not collect data about your identity, or activity. The button merely identifies and informs the user, when browsing the Internet, about the Club offers available regarding the product, or service they visited. These actions are implemented on your browser, and no information about your browsing history is sent to our platform.