Privacy Policy

Introduction

Velvetformula lda. (hereafter referred to as “Velvetformula”, “we”,“us”), a company having its registered office at Rua Horta de Fanares 30 loja Esq, Mem Martins, Portugal, is strongly committed to protecting personal data and this Privacy Notice aims to explain in a simple and transparent way what personal data we gather about you and how we process it.

Terms in this Privacy Notice (such as “personal data” and “processing”) have, in whatever conjugation, the meaning referred to in the Regulation 2016/679 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.

If you have questions or want to know more about Velvetformula’s data policies and how we use your personal data, please contact our Data Protection Officer:

  • Email: info@velvetformula.com
  • Post: Data Protection Officer, Velvetformula lda., Rua Horta de Fanares 30 loja Esq, Mem Martins

When you contact us, we will have to identify you before carrying out your request.

We may amend this Privacy Notice to remain compliant with any changes in law and/or to reflect how our business processes personal data. The latest version of the notice will always be available on our website.

When do we collect personal data?

Velvetformula collects personal data in the following ways:

  • if you use our website, correspond with us by email, phone or otherwise;
  • if you are one of our clients;
  • if you are a service provider;
  • we may also collect personal data about you online to the extent that you have made this information publicly available. For example, we may find your profile on professional social media websites (such as Linkedin) and contact you about job opportunities at Velvetformula.

What types of data do we process about you?

Identification data, such as your name, surname, date and place of birth, ID number, phone number, company address, function, e-mail address and the IP address of your computer or mobile device.

How do we use your personal data?

We may use your personal data to:

  • administer the services we deliver;
  • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
  • detect, investigate, report, and seek to prevent financial crime and anti-money laundering, for example through KYC checks;
  • comply with other applicable laws and regulations;
  • communicate effectively with you.

We only use your personal data under one of the following legal bases:

  • to conclude and carry out our contract with you;
  • to comply with our legal obligations;
  • for our legitimate business interests. The use of your personal information is in our legitimate interest as a commercial organisation to provide services to our clients, provided our use is proportionate and respects your privacy rights;
  • when you have provided your consent. In this case, you may withdraw your consent at any time.

To be able to offer you the best services, we may share your information internally and externally. This includes:

  • within Velvetformula for operational, regulatory and reporting purposes;
  • with third parties who help manage our business and deliver services. These third-parties have agreed to confidentiality restrictions;
  • with agencies working to prevent fraud in financial services such as money laundering and terrorism;
  • with Government authorities such as public authorities and supervisory bodies, judicial/investigative authorities or lawyers, for example, in case of bankruptcy.

Whenever we share your personal data internally or with third parties, we ensure the necessary safeguards are in place to protect the data.

How long do we keep your personal data?

We will store your personal information for as long as it’s still necessary for the purpose for which we originally collected.

What cookies and other technologies do we use?

We may use cookies on Velvetformula’s website (www.velvetformula.com) to distinguish you from other users, to improve your experience when accessing the website, and for improvement purposes. Detailed information on the cookies we use and the purposes for which we use them are set out in our Cookie Policy.

Your rights and how we respect them?

We respect your individual rights to determine how your personal information is used. These rights include:

  • Right to access information: you have the right to ask us for an overview of your personal data that we process.
  • Right to rectification or erasure: if your personal data is incorrect, you have the right to ask us to rectify it. You can also request that we erase your personal information if:
    • it is no longer needed for the purposes for which it was collected;
    • you have withdrawn consent;
    • following a successful right to object;
    • Velvetformula unlawfully processes your data;
    • a law of the European Union or a member state of the European Union requires Velvetformula to erase your personal data.
  • Right to restrict processing: you have the right to ask us to restrict using your personal data for the period necessary to Velvetformula for its verifications if:
    • you believe the information is inaccurate or we are processing the data unlawfully;
    • you have objected to us processing your data for our own legitimate interests;
    • if Velvetformula no longer needs the data, but you want us to keep it for use in a legal claim.
  • Right to data portability: in some circumstances you have the right to ask us to transfer your personal data directly to you or to another company in a structured, commonly use, machine-readable format.
  • Right to object: You have the right to object to Velvetformula treating your personal data for its own legitimate interests. We will consider your objection and stop processing your data unless we assess that we have legitimate grounds that justify processing your data.
  • Right to complain: if you have concerns about how we are processing your personal information, you have the right to lodge a complaint with us by email: info@velvetformula.com or by post: Data Protection Officer, Velvetformula lda., Rua Horta de Fanares 30 loja Esq, Mem Martins or with the Comissão Nacional de Protecção de Dados, address: Av. D. Carlos I, 134 – 1.o 1200-651 Lisboa, Portugal, website: www.cnpd.pt.

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    Misha Alefirenko

    Founder and CEO