Privacy policy and personal data protection



Who we are.

Our Watch Leads - OWL, Lda ("OWL") is a commercial company with registered office at Incubadora Instituto Pedro Nunes, Building C, 3030 - 199 Coimbra, Portugal, with a share capital of EUR 2,000.00, registered at the competent Commercial Registry Office under the main registration and taxpayer number PT516239538.

The present privacy and data protection policy ("Privacy Policy") relates to the processing of personal data carried out by OWL and collected through the website:

- []

Hereinafter referred to as the "Portal":

OWL is committed to protecting the personal data ("Personal Data") of its customers and users, hereinafter referred to as "Users" or individually as "User", made available on the Portal, adopting a policy subject to high standards in matters of privacy and that strives to maintain the confidentiality, loyalty and integrity of the Personal Data.

In this context, it prepared the Privacy Policy, which aims, inter alia, to inform its Users of the situations in which they proceed to the processing of Personal Data, including how and why they are collected, to whom it is disclosed, how it protects their privacy when visiting or using the services available on the Portal, as well as their rights in relation to the processing of Personal Data performed.

The collection and processing of Personal Data carried out by OWL complies with the provisions of the personal data protection legislation in force, in particular with the General Data Protection Regulation (EU) of 27 April 2016.

What is Personal Data?

Personal Data is any information, of any nature and regardless of its support, including sound and image, concerning an identified or identifiable natural person. A person who can be identified directly or indirectly, in particular by reference to an identification number or to more specific elements of his or her physical, physiological, mental, economic, cultural or social identity shall be considered identifiable.

Other important definitions:

Supervisory authority - an independent public authority established by an EU Member State, with responsibility for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of data within the European Union. In Portugal, the supervisory authority is the National Commission for Data Protection ("CNPD").

Consent - free, specific, informed and explicit expression of will, by which the data subject accepts, through a declaration or unequivocal positive act, that the Personal Data concerning him/her may be processed for a specific purpose.

Data Protection Officer ("DPO") - person or entity appointed to ensure, within an organisation, the compliance of personal data processing with the GDPR, ensuring efficient communication with the Personal Data subjects and cooperation with the supervisory authorities concerned.

Data Controller - a natural or legal person, public authority, agency or other body which, individually or jointly with others, determines the purposes and means of the processing of Personal Data.

GDPR - General Data Protection Regulation (EU) of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Sub-processor - natural or legal person, public authority, agency or other body that processes personal data on behalf of OWL, as the controller.

Personal Data Subject(s) - identified or identifiable natural person to whom the Personal Data collected on the Portal relate, i.e., the Users thereof.

Processing(s) - operation or set of operations performed on personal data or on sets of personal data, by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, erasure or destruction.

Third Party - a natural or legal person, public authority, service or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorised to process the Personal Data.

Who is the Data Controller?

OWL is the Data Controller of your Personal Data collected via the website [];

OWL, as the Controller, reserves the right to subcontract the processing of your Personal Data to third parties on its behalf and for its account.

Please be advised that OWL is not required to designate a Data Protection Officer under the GDPR.

What types of Personal Data are collected, for what purposes and on what legal grounds?

Under the GDPR, the collection of Personal Data may only be carried out if there is a legal basis for its processing.

Accordingly, OWL only processes the following categories of Personal Data collected through the website ([]), as well as for the purposes and on the legal grounds identified below:

Data Category: Contact data (email), Identification data (name) and information relating to the request for information or complaint made.
Purpose: Making a complaint or making enquiries (e.g. about a product, order status, etc.).
Legitimacy:Legitimate interest of OWL in responding to the complaint.

Data Category: Identification data: gender; name; identity document; tax number. Contact details: email address; telephone/mobile; fax; address; Demographic data: nationality.
Purpose: Respond to requests for information in legal proceedings or requests from administrative authorities or other third parties, to detect and prevent fraud.
Legitimacy: Legal obligations.

Data Category: Identification data: gender; name; identification document; tax dentification number. Contact details: email address; telephone/mobile; fax; address. Demographic data: nationality; Online interaction data: password (encrypted information that allows the system to recognise the User's password.)
Purpose: Registration and login to the website to order products and/or to obtain information about the online shop (on the Personal Data collection form, an asterisk or similar means indicates which fields must be filled in).
Legitimacy: Legitimate interest of OWL in providing information on products and/or pre-contractual steps in case of order request.

Data Category: Data relating to the order(s) placed concerning a specific product/service(s): bank details, name; identification document; tax number. Contact details: email address; telephone/mobile phone; fax; address. Demographic data: nationality. Online interaction data: password (encrypted information that allows the system to recognise the User's password).
Purpose: Ordering a product/service on the website.
Legitimacy: Pre-contractual due diligence.

Data Category: Identification data: gender; name; contact data: email address; telephone/mobile phone; fax; address; Demographic data: nationality.
Purpose: Sharing of data with third parties for the purpose of the submission of commercial proposals by the third parties.
Legitimacy: With the User's informed consent*
*The collection form is sent separately via email and has a field for the User to expressly mark his/her Consent. If the User chooses to provide his/her Personal Data for the aforementioned purposes, the Consent given may be withdrawn at any time, without calling into question the Treatment carried out previously.

General note: OWL does not carry out Processing based on User profiling.

Data collected automatically by the Portal:

Browsing the Portal involves only the collection of the internet protocol address ("IP").

The domain server for the Portal registers and stores the information that is normally registered by definition by the server, i.e., the IP through which the User accessed the Internet, the date and duration of access to the Portal, the Internet address of the website that brought him or her directly to the Portal.

This information will be used to measure the number of visits to the different areas of the Portal, and to help make it more useful to Users.

Under what circumstances do we disclose your Personal Information?

OWL uses third parties to provide certain services to you or to improve your user experience. From time to time, the provision of these services may involve access to your personal information by these third parties. This may be the case with suppliers or contractors of OWL (e.g., entities that provide support services such as consulting professionals).

In such cases, OWL ensures through contracts and clauses for the Processing of Personal Data that any Sub-Contractor processing Personal Data on its behalf and for its account provides guarantees to implement appropriate technical and organisational measures so that the Processing will meet the requirements of the GDPR or other applicable law, ensuring confidentiality and data security, including compliance with the rights of the Data Subjects.

OWL may also transfer Personal Data of Users to third parties where it deems such data communications necessary or appropriate (i) under applicable law, (ii) in compliance with legal obligations/court orders, (iii) to respond to requests from public or governmental authorities and other administrative authorities, (iv) where necessary to comply with a legal, regulatory or other obligation, as well as (v) to ensure the security of the Personal Data Subjects or otherwise prevent fraudulent conduct.

If you expressly consent in writing, your Personal Data may be shared with OWL's business partners for the purpose of accessing commercial and promotional offers. OWL will only share your Personal Data with such partners to the extent strictly necessary.

As a rule, Users' Personal Data is not transferred to third countries (outside the European Union) but kept on servers located within the European Union. However, should Subcontractors transfer data to third countries, OWL will implement the necessary and appropriate measures under applicable law to ensure the protection of the Personal Data subject to such a transfer, strictly complying with the legal provisions set out in the GDPR or other applicable legislation relating to such transfers.

What is the retention period for Personal Data?

The period of time during which Personal Data are stored and retained varies according to the purpose for which they are used, the rule being that they are retained only for the period necessary for each purpose. There are, however, legal obligations (e.g., tax) that may require the retention of Personal Data for a longer period of time and, in this case, the data will be retained only for the period necessary to comply with the legal obligation imposed.

The Personal Data collected is processed in strict compliance with the applicable legislation and is stored in specific databases created for this purpose. Such data shall be kept in a format that permits identification of the Holders of the Personal Data.

If Processing is based on Consent, OWL keeps the User's Personal Data in accordance with the Consent given and/or until such Consent is revoked.

What are your rights as a Data Subject?

OWL guarantees Users, as Holders of Personal Data and at all times, the right to access, rectify, update, limit and delete their Personal Data, the right to object and to withdraw Consent, without this compromising the lawfulness of the processing carried out under that Consent, as well as the right to data portability:

Right of access: Whenever the User requests, he/she may obtain confirmation regarding the Processing carried out by OWL on his/her Personal Data, in particular to obtain the following information:

(i) reasons why the Personal Data is processed;

(ii) types of Personal Data which are processed;

(iii) the entities to whom OWL may transmit Personal Data;

(iv) the period for which the Personal Data will be kept or, if this is not possible, the criteria for fixing this period;

(v) the rights you have in relation to the processing of Personal Data.

Right of rectification: Where the User considers that Personal Data (objective Personal Data provided by him/her) is incomplete or incorrect, he/she may request that it be rectified or completed.

Right to erasure: The User may request that Personal Data be erased when one of the following situations occurs:

(i) the Personal Data is no longer necessary for the purpose for which it was collected or processed;

(ii) when the Consent on which the Treatment is based is withdrawn and there is no other legal basis for the Treatment;

(iii) where an objection to the Processing is lodged and there are no overriding legitimate interests justifying the Treatment;

(iv) where the Personal Data have been unlawfully processed; and

(v) where the Personal Data must be erased pursuant to a legal obligation.

The right to erasure shall not apply where Processing is necessary for the following purposes:

(i) exercise of freedom of expression and information;

(ii) compliance with a legal obligation requiring the Treatment;

(iii) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes to the extent that exercising the right to erasure would seriously prejudice the achievement of the purposes of such Processing; or

(iv) establishment, exercise or defence of legal claims.

Right to restriction of processing: Restriction of processing allows the User to request the Controller to restrict access to certain Personal Data or to suspend certain activities of the Controller. In particular, the User may request the limitation of the Processing of Personal Data in the following cases:

(i) if you contest the accuracy of the Personal Data, for a period of time that allows OWL to verify such accuracy;

(ii) if OWL no longer needs the Personal Data for a particular Processing purpose;

(iii) if you have objected to the processing, unless it is established that OWL's legitimate interests prevail over your interests.

Right to portability: The User may request to receive the Personal Data provided by him/her in a structured, commonly used and machine-readable format. You also have the right to request that this data be transmitted to another Controller, provided that this is technically possible. The right to portability applies to the following cases:

(i) where the Treatment is based on your express Consent or the performance of a contract; and

(ii) where the Processing in question is carried out by automated means.

Right to object: You have the right to object to the Processing in the following situations:

(i) where the Treatment is based on the legitimate interest of the Controller;

(ii) where the Processing is carried out for purposes other than, but compatible with, those for which the data was collected;

(iii) where the Processing is carried out for direct marketing purposes.

In such cases, OWL shall cease to process the Personal Data, unless it has legitimate reasons for carrying out such Processing, and these overriding the interests of the Users.

Right to withdraw consent: Where Processing is based on legitimate consent, Users may withdraw their consent at any time.

Right to lodge complaints with the Supervisory Authority: Should the User wish to lodge a complaint regarding matters related to the Processing of Personal Data, he or she may do so with the National Commission for Data Protection, the competent Supervisory Authority in Portugal.

For further information, please visit

How can you exercise your rights as a Data Subject?

To deal with matters relating to the protection of Personal Data on the website [] , you should contact OWL through one of the following means:

E - mail to the following address: [email protected] .

Letter addressed to OWL to the following address: Incubadora Instituto Pedro Nunes, Edifício C, 3030 - 199 Coimbra, or contact by telephone: (PT)915619977.

What measures does OWL adopt to ensure the security of Users' Personal Data?

OWL is committed to ensuring the protection of the security of Personal Data that is made available on the Portal. Demonstrating OWL's great concern and commitment to privacy issues, several technical and organisational security measures have been adopted in order to protect the Personal Data provided on the Portal against diffusion, loss, misuse, alteration, unauthorised processing or access, as well as against any other form of unlawful processing (e.g., use of https).

In this sense, the Portal requires secure browser connections, guaranteeing that all personal data provided are stored securely in our systems which, in turn, are located in a data centre covered by all the physical and logical security measures that OWL considers indispensable for the protection of the Users' Personal Data.

Notwithstanding the security measures adopted by OWL, Users browsing the Portal should adopt additional security measures, namely by ensuring that they use an up-to-date browser in terms of security patches, properly configured (e.g., active firewall, antivirus and antispyware). Finally, Users should ensure the authenticity of the platforms they visit on the Internet, and should avoid websites with an unreliable reputation.

How can the User be aware of any changes to the Privacy Policy?

It is OWL's policy to comply with the legal provisions, regulations and standards governing privacy and the protection of Personal Data in all countries where it operates, without exception, so that, where necessary, it will adjust the Privacy Policy in accordance with the legal requirements imposed, as well as updating it in accordance with changes made in the treatment of Users' Personal Data.

Thus, OWL will duly publish on the Portal, the information regarding the changes made in the Privacy Policy.

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