Effective date: May 15, 2018

OUR COMPANY:  

FABRIDOCE – DOCES REGIONAIS, LDA is a commercial company, with a registered capital of one hundred thousand euros, with headquarters in Rua da Paz, Quintã do Loureiro, Cacia – Aveiro, registered and with the number of legal person 502123400, dedicated to the production of food products, namely regional sweets, ice cream and other food products and is responsible for the following websites, through which interested users have internet access to the contents , services, products and other information provided by this company:

www.fabridoce.pt www.geladosdeportugal.pt www.oficinadodoce.com

SCOPE OF THIS PRIVACY POLICY

You should carefully read this Privacy Policy which we now designate only as “Policy” to understand FABRIDOCE’s policies and practices regarding your Personal Data and how it is processed. This Policy explains how Customer and Consumer Personal Data is collected, used and disclosed by the entities as shown below. It also includes information about how you and your Consumer can access and update your Personal Data and how to make certain choices about how your Personal Data is processed. This policy covers FABRIDOCE’s online and offline data collection activities, including Personal Data it collects, through various channels such as websites, apps, third-party social networks, customer and customer support services, points of sale and events. In addition, FABRIDOCE combines personal data that was originally collected by you or your partners. If you wish to oppose these actions, please refer to section 9. The purpose of this Policy is to inform and explain the following points:

1. PERSONAL DATA SOURCES 2. PERSONAL DATA THAT FABRIDOCE COLLECTS ABOUT THE CUSTOMER AND THE CONSUMER AND HOW IT DOES IT 3. CHILDREN’S PERSONAL DATA 4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS 5. USE GIVEN TO CUSTOMER AND CONSUMER PERSONAL DATA 6. DISCLOSURE OF THE CUSTOMER’S PERSONAL DATA 7. RETENTION OF CONSUMER AND CUSTOMER PERSONAL DATA 8. STORAGE AND/OR TRANSFER OF PERSONAL DATA OF THE CONSUMER AND THE CUSTOMER 9. ACCESS to CONSUMER AND CUSTOMER PERSONAL DATA 10. CONSUMER AND CUSTOMER CHOICES ABOUT HOW FABRIDOCE USES AND DISCLOSES YOUR PERSONAL DATA 11. CHANGES TO FABRIDOCE’s POLICY 12. DATA CONTROLLERS AND CONTACT

1. PERSONAL DATA SOURCES

This Policy applies to all Personal Data that FABRIDOCE collects from and about the Customer and the Consumer, using the methods described below (see Section 2), from the following sources:

Fabridoce Websites: Websites directed to the Consumer and Customer operated by or to Fabridoce, including websites that Fabridoce operates under its own domains/URL and mini-sites that you use on third-party social networks, such as Facebook (“Websites”).

Fabridoce mobile sites/apps: Consumer and Customer-oriented mobile sites or applications operated by or for Fabridoce, such as smartphone applications.

E-mail, text messages (SMS) and other electronic messages: Electronic communications between the Consumer and the Customer and Fabridoce.

Offline registration forms: Printed records and similar forms that Fabridoce collects through, for example, postal mail, store demos, contests and other promotions or events.

Advertising interactions: Interactions with Fabridoce advertisements (for example, if the Consumer or Customer interacts with one of Fabridoce’s ads on third-party websites, we may receive information about such interaction).

Data created by Fabridoce: During customer and customer interactions with Fabridoce, we may create Personal Data about it (e.g., purchase logs made on our websites).

Data from other sources: Third-party social networks (e.g. Facebook, Google, Instagram, etc.) or market searches (if feedback is not provided anonymously).

2. PERSONAL DATA THAT FABRIDOCE COLLECTS ABOUT THE CUSTOMER AND THE CONSUMER AND HOW IT DOES IT

The collection of information by FABRIDOCE (online, offline, telephone, etc.), depends on how the Consumer or Customer interacts with FABRIDOCE, as it is described:

Sensitive Personal Data: FABRIDOCE does not seek to collect or process sensitive personal data in the normal course of activity. Where it proves necessary to process sensitive personal data of the Consumer or customer for any reason, FABRIDOCE does so only in cases where the Consumer or customer voluntarily gives their prior express consent (for example, for marketing purposes). If FABRIDOCE processes the Consumer’s sensitive personal data for other purposes, it only does so based on the following grounds:

• 1. detection and prevention of illicit activities (including fraud prevention) and
• 2. accordance with applicable law.

Personal contact details:

It includes any information provided by the Consumer and/or the Customer, allowing FABRIDOCE to contact them, such as their name, postal address, email address, social media details or telephone number.

Third-party social media information: Refers to any information that the Consumer or customer publicly shares on a third-party social network or information that is part of their profile on a third-party social network (such as Facebook) and that the Consumer or Customer allows the third-party social network to share with FABRIDOCE.

Examples include basic customer account information (e.g. name, email address, gender, date of birth, current city, profile picture, user ID, friends list, etc.) and any other additional information or activities that the Consumer or Customer allows the third-party social network to share. FABRIDOCE receives consumer profile information from the social network of third parties (or parts of them) whenever Fabridoce downloads or interacts with an application of its own on a third-party social network, such as Facebook, whenever it uses a social network feature integrated into a FABRIDOCE website (such as Facebook Connect) or whenever it interacts with FABRIDOCE through a third-party social network.

Telephone calls: Communications with FABRIDOCE may be recorded or listened to in accordance with applicable laws for local operational needs (e.g. for training or quality). Payment card details are not recorded. When required by law, the Consumer or customer will be informed of such registration at the beginning of their call.

Account access information: Any information required to access the Customer’s or Customer account profile, including the customer’s login/email address ID, username, password in unrecoverable form, and/or consumer or Customer’s security question and answer.

Demographic information and interests: Any information describing the demographic or behavioral characteristics of the Consumer or Customer, including the date of birth, age or age group, gender, geographic location (e.g. zip code), favorite products, hobbies, interests and household information and the Consumer’s lifestyle.

Technical information about the computer / mobile device: Any information about the computer system or other technological devices that the Consumer or the Customer uses to access one of FABRIDOCE’s websites or applications, such as the Internet protocol address (IP) used to connect your computer or device to the Internet, type of operating system and type and version of internet browser. If the Consumer or Customer accesses a FABRIDOCE website or application through a mobile device, such as a smartphone, the information collected will also include, where permitted, the unique device ID, advertising identification, geographic location and other similar data of the mobile device.

Information about the use of Websites/communications: When the Consumer or the Customer browse through the WEBSITES or newsletters of FABRIDOCE, interacting with them, the Consumer uses technologies of automatic collection of data to obtain certain information about the actions of the Consumer or the Customer. This includes information such as the links where the Consumer or Customer clicks, the pages or content you view and for how long, and other similar information and statistics about your interactions, such as page response times, download errors and duration of visits to certain pages. This information is captured using automated technologies such as cookies (browser cookies, flash cookies) and web beacons. The Consumer or the Customer has the right to oppose the use of such technologies. For more details, see point 4.

Market research and customer feedback: This includes information that the Consumer or customer voluntarily shares with FABRIDOCE about their experience in using the products and services it offers.

Content generated by the Consumer or Customer: Any content that the Consumer or Customer create and then share with FABRIDOCE on the social networks of third parties or upload to one of its websites or applications, including the use of third-party social networking applications such as Facebook, such as photographs, videos, personal stories or other similar means and content. Where permitted, FABRIDOCE may collect and publish content generated by the Consumer or customer, relating to a variety of activities, including contests and other promotions, website attributes, Consumer or Customer involvement and third-party social networks.

Payment and financial information: Any information required to complete an order or that the Consumer or Customer uses to make a purchase, such as details of your debit or credit card (cardholder’s name, card number, expiration date, etc.) or other forms of payment (if available). In any case, FABRIDOCE or its Employees handle payments and financial information in accordance with applicable laws, regulations and safety standards.

3. CHILDREN’S PERSONAL DATA

We do not voluntarily request or collect personal data from children under the age of 14. If we discover that we have inadvertently collected personal data from a child under the age of 14, we will immediately delete that child’s personal data from our records. However, FABRIDOCE may collect personal data about children under the age of 14 by their parents or by a legal guardian who expressly consents to such collection.

4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS

Registration Files: FABRIDOCE may collect information in the form of log files that record website activity and collect statistics on consumer or customer browsing habits. These entries are automatically generated and help FABRIDOCE troubleshoot errors, improve performance and maintain the security of its websites.

Cookies/similar technologies: Cookies are small text files that a website, when visited, places the user of the device (computer, mobile phone, iPad, tablet, etc.) through the internet browser (browser). Whenever we use cookies it will be to improve performance and your experience as a user of our website. And cookies help us recognize your device on your next visit. Cookies collect only information related to your preferences. The user, after activating a cookie can at any time disable it.

Web Beacons. Web beacons (also known as “web bugs”) are small sequences of code that provide a graphical image on a web page or in an email for the purpose of re-transferring the information to FABRIDOCE. Information collected through web beacons will include information such as the IP address and information about how the Consumer or Customer responds to an email campaign (for example, at what time was the email opened, which links the Consumer clicked on the email, etc.). FABRIDOCE will use web beacons on its websites or include them in the emails it sends to the Consumer or customer. FABRIDOCE uses information from web beacons for various purposes, including, but not limited to, reports on website traffic, unique visitor count, auditing and reporting on emails, advertising and personalization.

5. USE OF CONSUMER PERSONAL DATA

FABRIDOCE collects and uses the Personal Data of the Consumer and the Customer, as well as the different types of Personal Data that are collected for the following purposes:

Customer and Consumer Service: FABRIDOCE uses the Personal Data of the Consumer and the Customer for the purpose of providing them with support, namely to answer their questions. This usually presupposes the use of certain personal contact information and information about the reason for the question (order status, technical questions, questions about a product, general questions…). Contests, marketing and other promotions: With the consent of the Consumer or the Customer, when necessary, FABRIDOCE uses your Personal Data to provide you with information about goods and services (marketing communications, campaigns and promotions), to be made, via email, advertisements, SMS, telephone calls and letters, within the limits of applicable law.

Third-party social networks: FABRIDOCE uses Personal Data of the Consumer or customer when he interacts with the tools of the social networks of third parties, such as the functions “Like”, to serve them with advertisements and interact with them through third parties.

Personalization (offline and online): FABRIDOCE uses the Personal Data of Consumers or Customers to, inter alia:

• 1. analyze your preferences and habits;
• 2. anticipate their needs based on the analysis carried out on their profile;
• 3. improve and personalize your experience on FABRIDOCE websites and applications;
• 4. ensure that the content of FABRIDOCE’s websites/applications is optimized for the Consumer and the Customer and their devices;
• 5. provide targeted advertising and content;
• 6. allow the Consumer or customer to participate in interactive tools.

Order processing: FABRIDOCE needs to use the Personal Data of the Consumer and the Customer, namely to send, inform the status of orders, correct addresses, confirm identities, as well as other fraud detection activities.

Other purposes: FABRIDOCE may also use Personal Data to conduct internal or market research, measure the effectiveness of advertising campaigns, reconcile consumer or customer accounts, there are several and ensure their safety.

Legal reasons: In the event of a merger or acquisition of FABRIDOCE, Fabridoce will share the Personal Data collected under the legal terms. Fabridoce may also disclose the Personal Data it has:

• 1. when legally required;
• 2. in response to legal proceedings;
• 3. in response to a request from a competent enforcement body;
• 4. to protect the generic rights, privacy, security or proprietary rights of FABRIDOCE or the public;
• 5. to enforce the terms of any contract or the terms of Fabridoce’s website.

It is the fulfillment of contractual and legal obligations in the legitimate interest of FABRIDOCE, in order to improve its efficiency and develop new products and services, as well as to protect the goods and interests of FABRIDOCE and its employees.

In all these situations described, the Consumer or the Customer may oppose the use of your Personal Data.

6. DISCLOSURE OF CONSUMER OR CUSTOMER’S PERSONAL DATA

In addition to the FABRIDOCE entities or ad-hoc partners in the country (responsible for their operations) mentioned in the section of data and contact controllers (refer to point 12.), FABRIDOCE shares the Personal Data of the Consumer and the Customer with the following organizations:

Service providers: These are external companies that FABRIDOCE uses for assistance and support in its business (e.g., order processing, payment processing, fraud detection and identity verification, operation of websites, market research companies, support services, promotions, website development, data analysis, Commissioners, jurists, Official Accountants, Statutory Auditors, etc.). Service providers and their selected team are only allowed to access and use the Consumer’s or Customer’s Personal Data on behalf and on behalf of FABRIDOCE, for the specific tasks requested from them, based on the instructions given by the Consumer and Customer, and are required to keep the Personal Data of the Consumer and customer confidential and secure. Where required by applicable law, the Consumer or customer may obtain a list of suppliers who process their Personal Data (see point 11. to contact FABRIDOCE).

Credit /collection information agencies: To the extent permitted by applicable law, credit and collection information agencies are external companies that FABRIDOCE uses for assistance in verifying the credit worthiness of the Consumer or customer (in particular for orders with invoice) or to collect outstanding invoices, which are also subject to the restrictions indicated in the previous point.

Third-party companies using Personal Data for their own marketing purposes: FABRIDOCE does not license or sell Consumer or Customer Personal Data to third-party companies for their own marketing purposes, except in situations where the Consumer or Customer has given consent. The identity of these third parties will be disclosed at the time the Authorization of the Consumer or customer is requested.

Third party recipients using Personal Data for legal reasons or due to merger/acquisition: FABRIDOCE will disclose Consumer Personal Data to third parties for legal reasons or in the context of an acquisition or merger (see paragraph 5. for more details).

7.RETENTION OF CONSUMER AND CUSTOMER PERSONAL DATA

FABRIDOCE will take the necessary measures to ensure that Personal Data will only be processed for as long as necessary to fulfill the purposes set out in this Privacy Policy, and the criteria for determining the period of retention of consumer personal data are the following:

• 1. FABRIDOCE will keep copies of the Personal Data in a way that allows identification during:- the duration of the relationship with the Consumer and the Customer (e.g. when the Consumer or the Customer is included in a newsletter sending list and has not ceased to subscribe to it);- the period in which the Personal Data is necessary in connection with the purposes set out in this Privacy Policy and FABRIDOCE has legal basis to maintain it;
• 1. The duration of:- any applicable legal period (e.g. period legally provided for the Consumer or Customer to bring a legal action) and an additional period of 2 months after the period described above (so that FABRIDOCE can identify any Personal Data of a consumer or Customer that may bring a legal action after the period provided above. During the situations described herein, FABRIDOCE will restrict the processing of data to storage and to apply its security measures, unless such Personal Data needs to be reviewed or accessed following any claim or any legally provided obligation.
• 1. In addition, if any relevant legal actions are brought, FABRIDOCE may continue to process the Consumer’s Personal Data for the period necessary for the duration of the respective legal action.

After the periods foreseen in any of these preceding points have been completed, FABRIDOCE will permanently delete or destroy the Personal Data of the Consumer or customer and, alternatively, may also anonymize it.

8.DISCLOSURE, STORAGE AND/OR TRANSFER OF PERSONAL DATA OF THE CONSUMER AND THE CUSTOMER

FABRIDOCE uses various measures to keep the Personal Data of the Consumer and customer confidential and secure, namely:

Persons who can access Consumer Personal Data: Consumer and Customer Personal Data will be processed by FABRIDOCE employees or authorized service providers, accessing only the strictly necessary data, depending on the specific purposes for which the Consumer’s or Customer’s Personal Data was collected.

Measures applied in operational environments. FABRIDOCE stores Consumer Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. The transmission of information over the Internet is unfortunately not completely secure and, although FABRIDOCE makes every effort to protect the Personal Data of the Consumer and the Customer, it cannot guarantee the security of the data during transmission through the websites or applications of FABRIDOCE.

Measures that the Consumer should take: It is important that the Consumer and the Customer also have an active role in keeping their Personal Data safe and secure. When signing up for an online account, the Consumer or Customer must choose a password that is difficult for others to guess and never reveal their password to anyone. The Consumer and customer are responsible for any use of their account and for keeping that password confidential. If the Consumer or Customer uses a shared or public computer, he should never select the option to remember his/her access data, email or password and make sure that he/she logs out each time he leaves the computer.

Transfer of Consumer Personal Data: The storage and processing of the Consumer’s and Customer’s Personal Data described above may require that Personal Data may ultimately be transferred/transmitted to and/or stored in a country other than the residence of the Consumer or customer.

It should be noted, however, that these protections do not apply to information that the Consumer or Customer chooses to share in public areas, such as third-party social networks.

9. CONSUMER RIGHTS IN RELATION TO HIS/HER PERSONAL DATA

Access to personal data: The Consumer or the Customer has the right to access, review and request a physical or electronic copy of the information held about it and to request information about the origin of their Personal Data.

These rights may be exercised by sending us an email to geral@fabridoce.pt upon proof of identification. If the order is submitted by a person other than the Consumer or the Customer, without providing evidence that the request was legitimately made on his behalf, it will be rejected.

Additional rights (e.g. modification, deletion of Personal Data): Where provided by law, the Consumer or customer may:

• 1. request the deletion, portability, correction or review of your Personal Data;
• 2. limit the use and disclosure of Personal Data and
• 3. consent to any of FABRIDOCE’s data processing activities.

And, in accordance with applicable law, the Consumer and customer also have the following rights relating to their Personal Data:

• 1. the right of opposition, based on particular situations of the Consumer or the Customer, in the use of Personal Data by FABRIDOCE, or its representatives; And
• 2. the right to oppose the processing of Personal Data by FABRIDOCE or its representatives for direct marketing purposes.

It should be noted that, in certain circumstances, FABRIDOCE will not be able to delete the Personal Data of the Consumer or the Customer without also deleting its user account. FABRIDOCE may be obliged to retain some of the Personal Data of the Consumer or the Customer after the latter has requested the deletion, in order to meet its contractual or legal obligations. FABRIDOCE may also be authorized by applicable laws to retain some of the Customer’s or Customer’s Personal Data to meet your business needs. When available, FABRIDOCE websites have a dedicated tool through which the Consumer or Customer may review and edit the Personal Data you have provided. Please note that FABRIDOCE requires its registered Consumers and Customers to confirm their identity (e.g. login ID/email address, password) before they can access or make changes to their account information. This helps to prevent unauthorized access to the Consumer’s account or the Cliente.Se the Consumer or the Customer have unresolved questions/issues, they also have the right to complain to the competent data protection authorities.

10. CONSUMER AND CUSTOMER CHOICES ABOUT HOW FABRIDOCE USES AND DISCLOSES YOUR PERSONAL DATA

FABRIDOCE gives the Consumer and the Customer control over their Personal Data, through the following mechanisms:

Cookies/similar technologies: The Consumer manages his consent through:

• 1. Fabridoce’s consent management solution or
• 2. browser, to refuse all or some cookies/similar technologies, or to receive alerts when they are in use. See point 4. above.

Advertising, marketing and promotions: The Consumer or customer may consent to FABRIDOCE using its Personal Data to promote its products or services, it may indicate it through its relevant check box(s) located on the registration form or by answering questions submitted by commercial demonstrators or FABRIDOCE Employees. If the Consumer or Customer decides that they do not wish to continue receiving such communications, they may unsubscribe from marketing-related communications at any time, following the instructions provided in each communication. In order not to receive marketing communications sent by any means, including third-party social networks, the Consumer or customer may disable them at any time by accessing the website/application or social networks of third parties and adjusting their user preferences in the account profile, unchecking the relevant boxes or by calling FABRIDOCE. But even if the Consumer or Customer chooses not to receive marketing communications, they will still receive operational communications from FABRIDOCE, such as order confirmations or other transactions, notifications about account activities (e.g., account confirmations, password changes, etc.) and other important non-marketing-related advertisements.

Personalization (offline and online): Where required by law, if the Consumer or Customer wishes your Personal Data to be used by FABRIDOCE to provide you with a personalized experience/advertising and targeted content, you may indicate it through the relevant verification box(s) on the registration form or by answering the question(s) submitted by the commercial demonstrators or their Collaborators.

If the Consumer or the Customer decides that they do not wish to benefit more from such a situation, they may cancel the reception at any time by accessing the website/application and adjusting their user preferences in the account profile, by clearing the relevant boxes or by calling FABRIDOCE.

11. CHANGES TO FABRIDOCE POLICY

FABRIDOCE may update this privacy policy if it changes the way it treats The Consumer’s and Customer’s Personal Data. FABRIDOCE reserves the right to make changes to its practices and this Policy at any time. In the event that relevant changes are made to its privacy policy, FABRIDOCE will promote the dissemination of such changes through the normal channels of communication with consumers and customers. To this end should be regularly consulted the means of communication used by FABRIDOCE, in order to become aware of such changes.

12.RESPONSIBLE FOR THE PROCESSING OF DATA AND CONTACTS

For the exercise of the rights of holders of Personal Data mentioned above, or to ask questions or comments about this policy and the privacy practices of FABRIDOCE or to submit a complaint about its compliance with applicable privacy laws, please contact FABRIDOCE through the following:

392. a) e-mail: geral@fabridoce.pt b) Address: FABRIDOCE – DOCES REGIONAL, LDA, Rua da Paz 117, Quintã do Loureiro, 3800-587 Cacia, Aveiro. c) Phone: 234 913 392. On every weekday from 8:00 a.m. to 6:00 p.m.

FABRIDOCE will confirm receipt and investigate any complaint about how it processes Personal Data (including claims alleging that FABRIDOCE has violated the rights of the Consumer or customer under applicable privacy laws).