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Privacy Policy

Privacy Policy and information on personal data protection

The simple act of browsing the internet implies the collection and transmission of data to enable the communication between the different electronic equipment. There is also other data that can be collected and transmitted  in order to provide a more comfortable and interesting experience. Some of this data might be considered personal data.

For greater transparency and considering the diversity of processed data and its end use, we will proceed to describe and contextualise all personal information, or potentially personal information, which is processed resulting from browsing on this website.

1. Personal data processed resulting from browsing on this website

1.1 With regards to browsing on this website, the following data is processed, for which the Lisbon Municipality is responsible:

WHEN ACCESSING OUR WEBSITE WHEN USING GOOGLE ANALYTICS

WHEN PURCHASING GOODS ON THE LISBON LIBRARIES SHOP

WHAT DATA IS PROCESSED?

1) Regarding the access to our website lodged in the Lisbon Municipal server(s) the following data is sent by the user: IP and MAC address, browser used, operating system and relative  versions, and depending on the browser,  the user and origin of the browsing, and we can further collect the referrer (the page visited immediately before)

2) Through the cookie “cfduid” the information on the IP address of the users is collected and anonymized.

With regards to browsing on the present website we use Google Analytics, a web analysis service belonging to Google Inc. («Google»). In this context, anonymised user profiles are created and cookies are used. The cookies used in Google Analytics collect the following data when using our website: IP address, connection date and time, Referrer (the page visited immediately before), browser and operating system used and respective versions. 

Regarding the purchasing of goods in the Lisbon Library shops the user should only provide data which is strictly necessary for the transaction:

a) Invoice data:
>first and last name or entity name, in the case of a company name
>full address including country
>tax number

b) Data for discounts, if applicable:
>Copy of proof for such discounts

c) Contact data:
>Telephone
>E-mail

WHY IS THE DATA COLLECTED?

1) It is used to identify the device on which the page will appear and to adjust the design of the page to the Operating System which will show it.

2) It is used to deter and block malicious visits to the site, allowing visits by non-malicious users and to identify individual clients who use a shared IP, as well as to apply security configurations on a client to client basis.

It is used to monitor the use of our website, checking the most visited pages, to offer relevant information to the users or to evaluate the way and the source of access, to improve the  design of the pages. The personal data is used exclusively for the transactions, which includes the relevant invoicing, discounts, when applicable, sending of the goods and to communicate the invoicing and shipping information  and/or  to provide occasional clarification.
AT WHAT POINT IS IT COLLECTED?

1) They are collected at the moment when the Lisbon Municipal server(s) receive the user’s access request to our website.

2) The cookie is stored in the user’s device when they access the site and renewed every 30 days.

Cookies used in Google Analytics are stored in the user’s computer when it has access to our website for the first time, and are activated afterwards and automatically every time the user visits our website.

The data is collected the moment the user fills in and submits the application to  purchase goods in the Lisbon Libraries shop.
HOW LONG IS IT KEPT?

1) The transmitted and collected data is kept only for the duration of access of the user to our website, and is completely deleted when this access ends (Session Data)

2) The information collected by the cookie is kept for at least 24 hrs.

The data transmitted and collected is kept for a period of 26 months, after which it is permanently deleted.

The invoicing data is kept for a period of 10 years, as from the date of the closing of the transaction, after which it may be deleted due to the end of the statute of limitations for determination of financial restitution liability,in audit. (Law 98/97, art. 70º, nº 1).

The discounts and contact data is kept for 3 months as from the date of the closing of the transaction, at which time it is deleted.

IS IT TRANSMITTED TO OTHER ENTITIES OUTSIDE THE LISBON MUNICIPALITY?

1) The data furnished and collected is processed exclusively in the Lisbon Municipality’s server(s), and no transmission to other entities is foreseen. However, in this particular point we call your attention to the fact that the internet infrastructure is of the responsibility of the Lisbon Municipality’s external suppliers.

2) Data is processed  on the CloudFare platform, plugin is used on WordPress platform.

To know more about CloudFare privacy policy please consult:

https://www.cloudflare.com/privacypolicy/

With regards to the Cookies used in Google Analytics the collected data is transmitted to a server in the USA where it is stored.

The invoicing data is processed on the Etnaga Invoicing BOL Platform.

The discount and contact data is processed exclusively in the Lisbon Municipality server(s).

AS A USER MAY I REFUSE CONSENT TO THE PROCESSING OF DATA?

1) The furnished and collected data is not subject to user consent, as these are necessary elements for the communication protocol between the electronic equipment at stake, both the Lisbon Municipality server(s) and the user’s computer accessing our site;

2) The furnished and collected data is not subject to user consent as these are necessary elements for the communication protocol between the electronic equipment at stake.

The furnished and collected data will only be processed with the permission of our website user.

Should the user wish to withdraw permission, point 2 should be consulted. (Management of cookies and user permission). To know more about «Google» privacy policy please consult:

https://policies.google.com/privacy.

The data furnished and collected is not subject to user consent, as these are necessary elements for the transaction.

 

1.2 With regards to browsing on this website, the following data is processed, for which the Lisbon Municipality is not responsible:

EMBEDDED CONTENT RESPONSIBLE ENTITY AS A USER MAY I REFUSE THE PROCESSING OF DATA?
On this site we allow content lodged on the Youtube platform. This platform has its own privacy policies of which we have no control. If you opt to watch these videos, you should be aware that while you are watching them Google privacy policies are applied, to which the Youtube Platform belongs.

Data processed by Google.

To know more about Google’s privacy policy: https://policies.google.com/privacy?hl=pt-BR&gl=br

No, because this data is collected directly by the destination platform. In this case Google.

 

2. Cookie management and user consent

You may manage your cookie preferences, as well as the consent given for data processing, in the following way:

2.1. For specific management of Google Analytics you may install Google’s add-on, available at:

2.2. For general management of cookies on the main browsers, you may consult help  by clicking on:

For information regarding the management of cookies and other browsers, we suggest you consult the website of the supplier itself.

Should you wish to know more about cookies, how they work in general, please consult websites www.aboutcookies.org and www.allaboutcookies.org. However, bear in mind that there may be some discrepancies regarding the law stated on these websites and the Portuguese Law.

3. Personal Data holders rights
WHAT RIGHTS DO I HAVE AS THE HOLDER OF THE DATA IN REGARDS TO THE DATA THAT APPLY TO ME? HOW CAN I EXERCISE MY RIGHTS?
  • Right to information

  • Right to access the data

  • Right to correct the data

  • Right to delete the data

  • Right to limiting the processing

  • Right to transferability of the data

  • Right to opposing the processing

  • Right not to be subject to automatized decisions only, including profile definitions.

  • When consent is given, the right to withdraw consent at any given time, without compromising the legality of the processing already done based on earlier consent given.

You can speak to the Municipal Culture Direction/Library Network Division, in the Lisbon Municipality, who  are responsible for these matters, (by email: blx@cm-lisboa.pt or letter:  Rua da Boavista, 9, 1200-066 Lisboa).

In its practical application, the listed rights may be limited by the legitimate  rights or interests of other natural or legal persons, or on other serious grounds. This, however, does not prevent you from making a request you may deem justified. The aforementioned service and the  Data Protection Chief Officer of the Lisbon Municipality are available to evaluate specific situations.

 

To find out more about your above mentioned rights we suggest visiting the Data Protection National Commission website through the following link: https://www.cnpd.pt/home/direitos/direitos.htm#dir_acesso

 

WHAT RIGHTS DO I HAVE AS THE HOLDER OF THE DATA IN REGARDS TO THE DATA THAT APPLY TO ME? (Cont.) HOW CAN I EXERCISE MY RIGHTS? (Cont.)
  • The right to contact the chief data protection officer regarding all issues pertaining to the processing of your personal data and exercising the rights that are conferred to it by law on personal data protection.

To speak to the  Data Protection Chief Officer  of the Lisbon Municipality (by email: dpo@cm-lisboa.pt or letter: Campo Grande, 25, Bloco E, 2º Piso, 1749-099 Lisboa)
  • The right to lodge a complaint to a supervisory authority.

(This “complaint” should be understood according to  article 77º of the Data Protection General Regulation. Should you wish to lodge a complaint, as an objection to an administrative act, against the offender, with a view to request its repeal,  annulment, change or substitution or  to go against the unlawful omission of administrative acts,   this should follow the rules of the Administrative Procedure Code applicable to the specific situation).

To speak to the competent supervisory authority.

In Portugal, the National Commission for Data Protection, using the form and contacts described in https://www.cnpd.pt

  • The right to legal action, be it against a supervisory authority or against the processing controllers or subcontractor, and

  • The right to compensation for damage suffered due to the violation of the law regarding the personal protection data.

To speak to the competent courts.

 

4. Applicable Legislation

There are several laws applicable to personal data protection and to the internet, in this context the most relevant being the following:

  • General Regulation for the Protection of Data: (EU) 2016/679 of the European Parliament and Council, 27 April 2016, regarding the protection of natural persons regarding the processing of personal data  and the free movement of such data, and repealing Directive 95/46/CE, which can be consulted on the following link:
  • Law No. 58/2019, of 8 August, which ensures the execution, in Portuguese legal order, of the above-mentioned Regulation and can be consulted through the following link:
  • Article nº 5º of the Law nº 41/2004, 18 August, with the amendments made by Law nº 46/2012, 29 August ( «storage and access to information»), transposing to the national legal system Directive nº 2002/58/CE, of the European Parliament and Council, of July 12, regarding the processing of personal data and protection of privacy in the electronic communication sector which can be consulted on the following link:

5. Privacy Policy Maintenance and  information about Personal Data Protection

With a view to maintaining the information available to the users always updated, occasionally, the Municipality of Lisbon may amend the current Privacy Policy and information on the Personal Data Protection, and so we ask that you consult this document periodically so as to keep updated.

Should you find any divergence on our website, please report it immediately to the above mentioned competent service, as we wish to maintain high standards of accuracy and transparency for our users.

Version 1.0 | Approved 04/08/2020