1. COMTEMP PRIVACY POLICY
ComTemp – Companhia dos Temperos, Lda. (hereinafter referred to as “COMTEMP”) in the scope of supplying its goods and services, through its various channels (whether physical or online), it needs to re-enter some personal data of its customers.

On the other hand, the increasingly frequent interaction with users of the site http://www.magos.com.pt/ (hereinafter referred to as the “Site”) also requires, in some cases, (i) the collection of personal information so that they can use certain contents, functionalities or services of the Site and enjoy our products and services, (ii) the collection of data from your device (through files called cookies), to improve the performance and capacity of the Site. In this sense, this Privacy Policy aims to help our customers (hereinafter jointly referred to as “Customer(s)”) to understand what personal data we collect, how and why we use it, to whom we disclose it and how we protect your privacy when you use our products and services.

Why?
COMTEMP is committed to protecting the security and privacy of Customers. In this context, we have prepared this Privacy Policy, in order to affirm your commitment and respect for the rules of privacy and protection of personal data.

We want Customers to know our general privacy rules and the terms of processing the data we collect, in strict respect and compliance with the applicable legislation in this area, namely Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016 (“General Regulation on Data Protection”).

COMTEMP seeks to respect the best practices in terms of security and protection of personal data, promoting actions and improving systems in order to safeguard the protection of data provided by Customers.

The use and navigation of the Site, filling in our forms and providing data directly or indirectly by Customers, imply knowledge and acceptance of the conditions of this Policy and any other specific terms, policies and conditions regarding the supply of our products and provision of our services. By providing your personal data, you are authorizing their collection, treatment, use and disclosure in accordance with the rules defined herein.

Who is responsible for processing your personal data?
References in this Privacy Policy to “ComTemp – Companhia dos Temperos”, “COMTEMP” or “we” ComTemp – Companhia dos Temperos, Lda. (company registered in Portugal, headquartered in Zona Industrial do Entroncamento – 2ª Fase – Lote 11 – Casal Marcos Ferreira 2330-210 Entroncamento, NIPC and registration number 504 828 487), being considered the entity responsible for data processing, under the terms of the General Regulation on Data Protection.

What are personal data?
Personal data is understood to be any information, of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person (data subject). A person who can be identified directly or indirectly, namely by reference to an identification number or to more specific elements of their physical, physiological, psychological, economic, cultural or social identity, is considered identifiable.

What personal data do we collect?
We collect and process your personal data necessary for the purpose of supplying our goods and providing our services and managing our contractual relationship with Customers.

For more information about sharing your data with other entities, see the section “WHAT CIRCUMSTANCES IS THERE COMMUNICATION OF DATA TO OTHER ENTITIES?” below.

Special Categories of Personal Data
As part of the supply of our goods and provision of our services, for example in the organization of events and product tastings, we may collect information that may reveal data relating to your health and religious beliefs, such as dietary restrictions. Such information is considered “special categories of data” under the terms of the General Data Protection Regulation. We only collect this information if you have given us your explicit consent, namely in the context of events and product tastings. What are the purposes of collecting your personal data? The personal data of Magos Customers are generally used in the context of the supply of products and the provision and management of contracted, subscribed or reserved services. Customers’ personal data collected directly or through the Site are processed specifically for the purpose of managing the Customers’ registration as Site users, in order to allow Customers to use the Site’s features, namely processing orders and delivering the requested products. The data will also be processed by COMTEMP, in this context, for the purposes of communication with Customers, namely to respond to requests for information and clarification, complaints and requests for reimbursement, as well as comments and/or suggestions addressed to COMTEMP. More detailed information on the processing of your data within the scope of the website can be found in the Privacy and Cookies Policy available on the Website. The personal data collected will be treated under the terms and for the purposes described herein, as well as, in certain cases, for the fulfillment of our legal obligations. In this sense, we use your personal data for the following purposes:

• To manage orders, supply our products and provide our services When you order our products or request the provision of our services, we use your above-mentioned information to supply our goods and provide our services, for example, for order processing and delivery of the products.
• To communicate and manage our relationship with you. From time to time, we may contact you by email and/or SMS for administrative or operational reasons, for example, in order to send you information regarding orders and reservations requested, namely through the Site or by telephone. We will also use your personal data to respond to your requests, suggestions or contacts, to improve our services and your experience as our Customer.
• To inform you about news and offers of interest to you We may send you marketing communications, publicizing our products and services and sending newsletters, if you have indicated that you wish to receive them, for example through the Site or when you make a purchase in our Magos store. These communications can be made through any communication channel, namely through email messages, SMS, MMS or other forms of automatic calling. Please note that we do not share your personal data with other companies for marketing purposes, unless we have your consent to do so. If you do not wish to receive any more marketing communications from us or our newsletters, simply send an email to geral@magos.com.pt with the title “I do not receive newsletters” / “I do not want to receive communications”.
• To improve our services and fulfill our administrative and commercial purposes The business purposes for which we may use your information include accounting, billing and auditing, credit card or other verification, fraud analysis, security, legal and procedural effects, statistical studies, as well as systems development and maintenance.
• To comply with our legal obligations Namely, the obligation to provide your personal data to competent administrative and governmental entities under the terms of the law.

What is the retention period of your personal data?
Your personal data necessary for the purposes of processing your orders and purchases will be kept for the period in which your relationship with the Customer is in force or as long as you keep your online account active, and may be kept for a longer period, established by law (for example, 10 years in the case of billing and accounting documents) or for the defense of rights/interests in legal proceedings. The data processed for the purpose of sending direct marketing communications will be kept as long as you are interested in receiving said communications or do not withdraw your consent. What are the rights of data subjects? Under the terms provided for by law, you may, at any time, access your rights regarding personal data concerning you:

• Right of Rectification, means that you have the right to obtain from COMTEMP the rectification of inaccurate personal data concerning you, as well as the right to have your personal data completed incomplete;
• Right to Delete your Data, means that you have the right to request the deletion of your data in certain cases, namely, but not limited to, personal data that is no longer necessary for the purpose that motivated its collection or treatment, in which you withdraw the consent on which the data processing is based, among others;
• Right of Data Portability, means that in certain cases you can request the personal data concerning you and that you have provided to COMTEMP, in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller;
• Right to Limitation of Treatment, means that you have the right to request the limitation of the processing of your data in certain cases, namely, in return if the treatment is unlawful and you oppose the erasure of your data, COMTEMP no longer needs the personal data for processing purposes, but these are required by you for the purposes of declaration, exercise, or defense of a right in a judicial process, among others;
• Right of Opposition, you may object to the processing of your data, for reasons related to your particular situation, and in cases where the data are processed (i) for the purposes of legitimate interests pursued by COMTEMP or by third parties, or are processed for purposes other than those for which the data were collected and is not carried out with the consent of the data subject or based on provisions of Union or Member State law, or (ii) personal data are processed for the purposes of direct marketing, including profiling or (iii) the personal data are processed for scientific or historical research purposes or for statistical purposes.

You may exercise these rights directly through the User’s reserved area on the Site or upon written request addressed to COMTEMP to the email address geral@magos.com.pt or to the address Zona Industrial do Entroncamento – 2ª Fase – Lote 11 – Casal Marcos Ferreira 2330-210 Entroncamento. Under the terms of the law, you are also guaranteed the right, through the aforementioned means, to withdraw your consent for the processing of data whose consent constitutes the basis for the legitimacy of the respective processing. For this purpose, you have the right to withdraw your consent at any time, which does not, however, invalidate the treatment carried out up to that date based on the consent previously given. Without prejudice to any other administrative or judicial remedy, the data subject is entitled to file a complaint with the CNPD or another competent control authority under the terms of the law, if he considers that his data is not being subject to legitimate treatment by COMTEMP, under the terms of the applicable legislation and this Policy.


Magos Online Store Users
This Privacy Policy fully applies to all users of the Magos Online Store available on our Site, and must be complemented by the provisions of the Site’s Privacy and Cookies Policy.

What are the security measures adopted by COMTEMP?
COMTEMP makes its best efforts to protect Customers’ personal data against unauthorized access via the Internet. To this end, it maintains in operation all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, disclosure, loss or destruction and misappropriation of personal data provided or transmitted, committing to respect the legislation on the protection of personal data of Customers and to treat this data only for the purposes for which it was collected, as well as to ensure that this data is treated with adequate levels of security and confidentiality. It is, however, the Customer’s responsibility to guarantee and ensure that the computer they are using is adequately protected against harmful software, computer viruses and worms. Additionally, you should be aware that, without the adoption of adequate security measures (for example, the safe configuration of the navigation program, updated antivirus software, security barrier software and the use of software of dubious origin), the risk of personal data and passwords being accessed by third parties, without authorization to do so, is aggravated. However, it should be noted that whenever data collection is carried out on open networks, such as the Internet, your data may circulate without security conditions, with the risk of being seen and used by unauthorized third parties. As described in this Privacy Policy, we may in some cases transmit your personal data to third parties. COMTEMP has defined clear rules for contracting the processing of personal data with its subcontractors, and requires that they adopt appropriate technical and organizational measures to protect their personal data. However, in some cases, we may be required by law to disclose your personal data to third parties (such as supervisory authorities or judicial authorities) over whom we have limited control regarding the protection of personal data.

Under what circumstances is data communicated to other entities?
COMTEMP uses other entities to provide certain services. Eventually, this provision of services may imply access, by these entities, to the personal data of their Customers. Thus, any subcontracting entity of COMTEMP will process the personal data of our Clients, in the name and on behalf of COMTEMP, under the strict obligation to follow our instructions. COMTEMP ensures that such subcontracting entities offer sufficient guarantees for the execution of appropriate technical and organizational measures so that the processing meets the requirements of the applicable law and ensures the security and protection of the rights of data subjects, under the terms of the subcontracting agreement entered into with said subcontracting entities. In certain situations, the personal data of Customers may also be transmitted to third parties, when such data communications are necessary or appropriate (i) in light of the applicable law, (ii) in compliance with legal obligations/judicial orders, (iii) by determination of the National Data Protection Commission or another competent control authority, or (iv) to respond to requests from public or governmental authorities. In any of the situations mentioned above, COMTEMP undertakes to take all reasonable measures to guarantee the effective protection of the personal data it processes. Contact us You can contact COMTEMP to obtain more information about the processing of your personal data, as well as any questions related to the exercise of the rights attributed to you by the applicable legislation and, in particular, those referred to in this Policy, through the following contacts:

Telephone: +351 249 715 257 (National fixed network call)
E-mail: geral@magos.com.pt

How can you find out about any changes to our Privacy Policy?
We may change this Privacy Policy at any time. These changes will be duly publicized through the pages of the Site and, if they imply a substantial change in the way your data is treated, you will be notified, through the contact details you have made available to us. However, whenever relevant changes are made to the User of the Site, in terms of cookies, he will again display a pop-up window so that, depending on the type of cookie in question, he can access the information and/or consent to its use and storage.