Privacy Policy – Version 1.0 – 14-05-2018

Toogas is aware of the implications and its responsibility to comply with the changes made to the protection of personal data, notably with effect from 25 May 2018 of the General Data Protection Regulation, approved by Regulation (EU) 2016/679, of April 26, 2016.
Toogas thus undertakes to ensure the protection of all personal data made available to it, having therefore adopted various security measures, both technical and organizational, in order to protect personal data against any form of illegal processing.
Toogas is also committed to continually improving the set of procedures and techniques implemented for the protection of personal data, and to this end also relying on any suggestions that users of this site may bring to us.
This Privacy Policy applies solely to Toogas’s treatment of personal data collected through its website or commercial and promotional actions.

Personal data is collected solely for the following purposes:

  • Response to contact request from customers or potential customers;
  • Commercial management;
  • Improvement or customization of our services;
  • Sending newsletters and other promotional actions. Customers can unsubscribe from the email newsletter service by clicking on the newsletter link we send by email.

The data collected are limited to name, email address and telephone, being used for the purposes provided in this policy, and can be obtained through:

  • Website contact form;
  • In-person collection.

Prior to sending the first promotional message or newsletter, the data subject’s express consent will be required to send such messages.
This consent will be requested via email and the data subject will only receive messages if they respond positively. If the answer is no, your data will be deleted.

The personal data collected will be kept as long as the consent of the holders is kept, in the personal data where their collection requires their consent, and all other data will be kept as long as its retention is legally required or necessary for the performance of the contract.

The collected personal data may be shared for hosting and back up on servers located in Portugal only by the group of companies of the Group namely, Mbit, Suprides XXI, Mobpro, Sagres Point, iStore, iChangepro, Bastarda, High Relief and Eternal & Modern.

In accordance with current legislation on the protection of personal data, we inform you that the data subject is guaranteed:

  • Right to be informed:
    • When collecting personal data:
      • Contact details of the controller.
      • Of treatment purposes.
      • Conservation timeout.
      • Your rights as holders of personal data.
      • The possibility of resorting to the supervisory authority for filing a complaint (and its contacts).
      • The (possible) existence of automated and / or profiling decisions.
    • Ask what information Toogas has about them and why;
    • Know where they are stored, and how their data are processed;
    • Be informed of how Toogas fulfills its data protection obligations.
  • Right of access:
    • Confirmation of whether or not your personal data are processed;
    • Ask how to gain access to your data;
    • Provide a copy of the personal data processed, preferably in exportable format.
  • Right to correct, delete and block:
    • Be informed about keeping them updated;
    • Get rectification of outdated, incorrect or incomplete data;
    • Possibility of deletion of personal data that is no longer needed for the purpose;
    • Block the processing of this data to verify accuracy or opposition.
  • Right to limitation:
    • Contestation of the accuracy of personal data, for a period allowing the controller to verify its accuracy.
  • Right to removal / forgetfulness:
    • Request the removal of your data and the permanent elimination of those that do not conflict with legal obligations.
  • Right to Portability:
    • Request the portability of your data;
    • Possibility of requesting your personal data in a commonly used or common format in order to operate the transfer to another organization, even if competing.

The exercise of the rights by the holders can be done through the email address RGPD@toogas.com, as well as by post, sending a letter with the data below:
Subject: Exercise of rights – protection of personal data
A / C: Privacy Toogas, Lda
Antero de Quental Street, 351
4455-586 Perafita

In general, personal data collected on the Toogas website is not transferred to third parties unless in compliance with a legal obligation.
If data are transmitted to third parties, Toogas maintains jointly with subcontractors the responsibility for the processing of personal data in a fair, lawful and transparent manner. The subcontractor may only process personal data in accordance with instructions defined by Toogas and always in strict compliance with the law and the purposes entrusted to him under the contract concluded.
The transmission of personal data to subcontractors will only be carried out in the context of contractually established relationships with Toogas and only and only when there is a basis to justify it.
In order to ensure the confidentiality and security of data, Toogas will take legally foreseen measures to ensure that the subcontractor provides sufficient safeguards for the protection of personal data, which is a reputable entity and that it has sufficient technical and organizational security measures. , in order to protect personal data against accidental or unlawful destruction, accidental loss, alteration, diffusion or unauthorized access and against any other form of unlawful processing, agreed, inter alia, by formalization by contract between Toogas is the subcontractor to whom the latter undertakes to act only on the instructions of the former as regards the processing of personal data.
Toogas subcontractors will only process personal data for the purposes defined and agreed between the parties, and shall ensure that the retention of data, when necessary and applicable, meets the deadlines set by law and / or contractually.
Holders of personal data should be informed when collecting their data about their possible sharing with Toogas subcontractors, whenever possible with identification of the organization and its contact, as well as the purpose of such sharing.
Where data are transferred to a Toogas subcontractor in a non-EU third country, the Toogas subcontractor shall maintain a level of data protection equivalent to the protection afforded by the legislation in force in the European area, in particular that provided for in Regulation (EU). 2016/679 Of The European Parliament And Of The Council Of 27 April 2016.

For international data transfers, at least one of the following procedures must be followed:

  • Individual contract or standard contractual clauses adopted directly by the European Commission or a supervisory authority;
  • Subcontractor’s participation in an EU accredited or recognized certification system or standard to ensure an adequate level of protection;
  • Recognition that the subcontractor’s binding corporate rules guarantee an adequate level of data protection, issued by the supervisory authorities.
  • Existence of an adequacy decision concerning the third country, territory or sector specific to that third country, or concerning the international organization concerned.

The rules for cross-border data transfers shall not apply where occasional transactions necessary for the performance of a contract or in the context of litigation (judicial, administrative, or running with regulatory bodies or the like) are concerned.

The following are internal security and privacy rules:

  • Process data lawfully and fairly, gathering only the information necessary and relevant to its intended purpose;
  • Do not use the data collected for a purpose incompatible with the collection;
  • Ensure the express consent of the data subject whenever required;
  • Guarantee the right of deletion of data used when requested by the holder free of charge;
  • Have security systems that prevent the consultation, modification or destruction of data by an unauthorized person and allow the detection of intentional or unintentional misuse of information.

The Toogas website may contain links to third party / partner websites. The referred sites are not under the control of the Company and are not responsible for the content of any such sites. Toogas site users are advised to refer to pages within those sites that refer to their privacy policies when accessing other sites.

When browsing the Toogas website, cookies are used which, however, do not collect information that identifies the user. Generic information is collected, including how users reach and use the sites. The information collected is used for the purpose of tracking the number of visits and statistical studies, as well as to ensure that the site works correctly and to facilitate navigation and improve the user experience.

The use of cookies allows the browsing of the website to be constantly optimized to provide a high quality experience that exceeds the quality of the previous visit by the user. You can consult our cookie policy here.

This Privacy Policy may be subject to change or revision, without prior notice, due to legislative or regulatory requirements in accordance with applicable law. As this Privacy Policy may be revised at any time, Toogas recommends its users to review them periodically.