In this Policy, the following terms shall have the following meanings:

“personal data"

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our/Fondation Luis y Antonio Portabella"

means Fondation Luis y Antonio Portabella, a Foundation registered in Luxembourg, whose registered address is 48 rue de Bragance - L-1255 Luxembourg - Luxembourg.

2.1

Our Site is owned and operated by Fondation Luis y Antonio Portabella, a Foundation registered in Luxembourg, whose registered address is 48 rue de Bragance - L-1255 Luxembourg - Luxembourg.

2.2

Our Data Protection Officer is Alexandra Da Silva, and can be contacted by email at contact@lyap-fondation.com, by telephone on +352 22 59 02 1, or by post at 48 rue de Bragance - L-1255 Luxembourg - Luxembourg.

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.1

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.2

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you.

4.3

For further information about your rights, please contact the CNPD.

Depending upon your use of Our Site, we may collect some or all of the following personal data:

5.1

name, business/company name;

5.2

contact information such as email addresses and telephone numbers;

5.3

demographic information such as post code;

5.4

IP address;

5.5

web browser type and version;

5.6

operating system;

6.1

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2

Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, we may use your data for the following purposes:

6.3

You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.4

We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

7.1

We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2

Your data will only be stored in Luxembourg.

7.3

Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

8.1

Subject to section 8.2, We will not share any of your data with any third parties for any purposes.

9.1

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2

In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10.1

In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at contact@lyap-fondation.com or using the contact details below in section 13.

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at contact@lyap-fondation.com, by telephone on +352 22 59 02 1, or by post at 48 rue de Bragance - L-1255 Luxembourg - Luxembourg. Please ensure that your query is clear, particularly if it is a request for information about the data, we hold about you (as under section 12, above).

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.