Privacy Policy

• Company: JSCRAMBLER, S.A.

• Registered Office: Rua Alfredo Allen 455, 4200-135 Porto

• Tax Registration Number (NIPC): 508268516

• Share Capital: € 163.124,31

• Telephone: +351 227 663 702

• Email: [email protected]

The Portuguese Data Protection Law, “Lei da Proteção de Dados Pessoais” (hereinafter, “LPDP”) and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th of April 2016, hereinafter “GDPR”) shall ensure the protection of natural persons regarding the processing of personal data and the free movement of such data. According to the GDPR, personal data refers to any “information relating to an identified or identifiable natural person, “the data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that natural person.” Jscrambler maintains a database with the registration of its clients composed only of personal data provided by the data subjects at the time of registration, which is collected and processed automatically by Jscrambler, the entity responsible for the processing of the personal data (“Data Controller”). In no case shall personal data on racial or ethnic origin, political opinions, religious or philosophical beliefs, political opinions, trade union membership, data on health, genetic data, biometrics or data relating to sexual life or sexual orientation be solicited or processed.

Personal data processed will only be used for the following purposes:

• Provide the services and customer support;

• Process transactions and send notices about transactions;

• Prevent potentially prohibited or illegal activities, and enforce our License Agreement;

• Customize, measure, and improve services;

• Send targeted marketing, service update notices, and promotional offers based on communication preferences;

• Prevent unauthorized access, maintain data accuracy, and ensure the correct use of information;

• Communication and clarification requests;

• Processing of Information requests.

Jscrambler processes personal data:

• when express and free consent is provided by the data subject forto the processing of their personal data for certain purposes that require such consent;

• when necessary for the performance of a contract to which the data subject is a party or representing a party, or for pre-contractual measures at the user's request;

• to comply with legal obligations to which Jscrambler is bound to;

• for the purposes of the legitimate interests pursued by Jscrambler or by third parties, unless the interests or fundamental rights and freedoms of the data subject that require the protection of personal data prevail.

Jscrambler does not transfer personal data outside the European Economic Area (EEA). However, if such transfer ever occurs it shall be subject to the adoption of adequate guarantees and the level of protection required, in accordance with the law.

Jscrambler only stores and processes your personal data for the period that is necessary or mandatory to fulfill the purposes described above, applying information conservation criteria appropriate to each treatment and in line with applicable legal and regulatory obligations.

Jscrambler states that it has implemented and will continue to implement the security measures of a technical and organizational nature necessary to guarantee the security of the personal data provided to it, in order to protect personal data against destruction, loss, alteration, disclosure, unauthorized access or any other type of unlawful processing, taking into account the current state of the technology, the nature of the data stored and the risks to which it is exposed, and being aware and accepting that the security measures on the Internet are not impregnable. Although Jscrambler collects and processes data in a secure manner and prevents its loss or manipulation using the most appropriate techniques, it should be borne in mind that the collection of data in open networks allows personal data to be circulated without safety conditions, with the risk of being seen and used by unauthorized third parties.

Whenever Jscrambler processes personal data, it undertakes to:

• Keep all personal data confidential;

• Use the data exclusively for the purposes which were previously defined;

• Make sure that the data is handled only by the employees whose intervention is necessary to satisfy the request of the data subject, being the same obliged to the duty of secrecy and confidentiality.

If Jscrambler subcontracts other entities for the provision of services that involve personal data processing, these entities shall be obliged the same confidentiality obligations and to adopt the same technical and organizational measures to protect personal data.

Jscrambler may use personal data for the sending of electronic communications with commercial and promotional information.All communications of this type will be directed exclusively to users who have given prior and express authorization, which can be revoked at all times, by sending an e-mail to [email protected]

In accordance with the provisions of the LPDP and the GDPR, data subjects may exercise at any time their right to information, access, rectification, erasure, limitation, portability, opposition and the right to withdraw the consent at any time, by means of a written request addressed to Jscrambler through the following means:

• Through mail to the following address: UPTEC Central Building,1.26, Rua Alfredo Allen, 455, 4200-135 Porto, Portugal;

• Through e-mail to the following address: [email protected]

Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Failure to respond to data marked as mandatory implies the inability to respond to the request of the data subject.

In accordance with the law, the data subject has the right to submit a complaint regarding the protection of personal data to a competent supervisory authority, such as the National Data Protection Commission “Comissão Nacional de Proteção de Dados” (CNPD) www.cnpd.pt

Last modified on 2023-07-27