COOKIE POLICY

Table of Contents

1. What types of cookies do we use?
2. For how long do we store the information collected by the cookies?
3. How are performance cookies stored?
4. How can you manage cookies?

1. What types of cookies do we use?

Our cookies have different functions:

Cookies may be:

• Persistent Cookies – They are temporarily stored on your access devices (personal computer, mobile phone and tablet) at the browser level and are used whenever the user returns to the website. They are generally used to guide the browsing experience according to the interests of the user, allowing us to provide a more personal service.

• Session Cookies – They are temporary and are kept in the browser cookies until you leave the website. The information obtained allows us to detect any issues and to provide an enhanced browsing experience.

2. For how long do we store the information collected by the cookies?

Depending on the type of cookie used, Onoma may store the information for a period of time ranging from 24 h to 2 years.

3. How are performance cookies stored?

The Performance Cookies used by Google Analytics are stored as follows:

_ga is used to distinguish users and expires after two years _gid is used to distinguish the users and expires after 24 hours _gat is used to throttle request rates and expires after 10 minutes.

The cookies used by Mautic (mautic_referer_id, mautic_session_id, mtc_id, mtc_sid) are stored so as to keep information about the use of the web pages and forms.

4. How can you manage cookies?

As explained above, cookies allow you to make the most of our website. Every browser allows the user to accept, refuse or delete cookies, mainly by selecting the appropriate settings in the users’ respective browser. Upon agreeing to the use of cookies, the user may always disable our cookies partially or fully.

To provide the users with a greater choice of how their data are to be collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. Find out more about the Google Analytics Browser Opt-out add-on.

To know more about cookies and their respective use, we suggest you refer to the following links, available only in English: Microsoft Cookies Guide, All About Cookies.

PRIVACY POLICY

Onoma undertakes to respect the privacy of its users.

By submitting his/her information, the user declares and certifies that he/she has the power and the capacity to communicate it. Due to the open source nature of the internet, Onoma advises the User against disclosing confidential information online.

Table of Contents

1. Name and contact of the Data Controller
2. Which data do we collect and how do we process them
3. What do we do with your data (purpose and legal basis)
4. Recipients of the data
5. For how long and where do we store your data
6. Disclosure of data
7. Transfer to third countries
8. What measures have we implemented in order to protect your data against unauthorized access, alteration or destruction
9. Your rights
10. Contact us
11. Revisions and changes

1. Name and contact of the Data Controller

The Data Controller is Onoma.

email address: geral@onoma.pt

2. Which data do we collect and how do we process them

Direct collection

As visitor, you are not required to provide any personal data in order to access the website of Onoma. The personal data of the users are only collected when the users subscribe to any of the available features required for Onoma to provide the information or clarification requested, or for accessing Newsletters, Articles, Campaigns, etc. In addition, Onoma may contact the user for purposes of presenting its offers, submitting proposals or scheduling meetings.

The following are the data we collect for the aforementioned purposes:

• Name*
• E-mail address*
• Company
• Phone number
• Subject
• Message
• Translation: source and target
• Files (texts to be translated or job application documentation)

The data marked with an * are mandatory if you intend to receive customised information about our services or if you intend to view or download exclusive information, as well as if you intend to receive our service provision Proposals and our previous or subsequent contacts pertaining to said submission of Proposals.

The communication of personal data is not a legal or contractual obligation or requirement necessary in order to enter into a contract, with the exception of cases where the application submitted by the data subject was selected by Onoma for purposes of entering into an employment contract or internship contract. In these cases, the provision of personal data is mandatory.

Indirect collection of data

Onoma, through the use of Google Analytics, also collects the following aggregate data: Geographical origin (city, country), language, type of device, operating system, browser, service provider, age, gender, date and time of access and reference data addresses, IP address.

Onoma shall monitor all statistical information pertaining to the use of the website in an aggregate, anonymous way. The data used for this purpose do not include personal identifying data or private information.

The analyses performed through aggregate statistical information will be used to interpret the patterns of use of the website and to continuously improve the standards of service provision and user satisfaction. The aggregate statistical information resulting from the analyses performed may be disclosed to third parties or publicly disclosed.

Onoma uses the software Mautic in order to collect and process the information of the contacts requested through the website, as well as the record of the browser session, with the aim of improving the use of the website and adjusting information to individual profiles.

In order to ensure the aforementioned features, Onoma uses cookies in its website so as to improve the performance and experience of the user.

‘Cookies’ are small text files which are stored in your computer or mobile device through your browser, keeping only generic information pertaining to the preferences of the User; they enable users to access specific areas of the website and allow for a quicker, more efficient browsing experience, without the need to repeatedly introduce the same information.

The users of the website, upon clicking on the cookie banner in the website of Onoma, are accepting the introduction of cookies in their computers or devices in the above mentioned terms, without prejudice to the possibility of control and management available to the user.

Every browser allows the user to accept, refuse or delete cookies, mainly by selecting the appropriate settings in the users’ respective browser. The user may decide at any time, through his/her browser, to be notified about the receipt of cookies, as well as to block their entry into his/her system. The elimination or blocking of cookies on the website may limit the access to certain areas of the website. To read about our cookie policy, click here.

Onoma may also use web beacons (including conversion pixels) or other technology intended for similar purposes, introducing them in its website, marketing emails or newsletters, in order to determine whether the messages sent were opened and the links provided received any clicks. The web beacons do not introduce any information in the users’ computers, however, they may, together with the cookies, enable the tracking of website activity. Conversion pixels are small codes located in a web page, which are activated when anyone visits said page.

3. What do we do with your data (purpose and legal basis):

Where the user has sent his/her curriculum vitae, we will consider the user to have entered a recruitment process. As such, his/her data will be sent to the Human Resources department for purposes of analysis, processing and potential selection.

Onoma collects contact details in order to provide the information or clarification requested or to enable the access to Newsletters, Articles, etc.

Onoma may also, provided it has the subject data’s due permission, use the contact details provided for marketing campaigns or to send communications regarding our services or Partners. In these cases, the user always has the possibility of objecting to receiving any subsequent communications for purposes of direct marketing, by selecting the corresponding field or by sending an email to geral@Onoma.pt

Legal basis:

• Forms: Sending the information requested and making case studies, articles and newsletters, etc. available – Legal basis: User’s consent
• Contact via email: Answer relating to the information requested by the user. Legal basis: User’s consent
• Prospective application / answer to a job advert: Selection and recruitment Legal basis: User’s consent in cases of prospective applications; in cases where an employment or internship contract is entered into, the legal basis is the performance of said contract.
• Mautic: optimising the adequacy of information to the user profile: Legal basis: Onoma’s legitimate interests
• Google Analytics: optimising the website: Legal basis: Onoma’s legitimate interests
• Facebook and LinkedIn web beacons and conversion pixels: measuring the efficacy of communication in social media; Legal basis: Onoma’s legitimate interests

• Where the legal basis for processing personal data is the User’s consent, the data subject may request from Onoma the analysis it performed regarding the prevalence of Onoma’s interests over the interests, rights and freedoms of the data subjects.

4. Recipients of the data

The recipients of the data are Onoma’s Human Resources department in cases where applications and curricula vitae were submitted.

In cases where the purpose of the contact was the submission of Proposals and provision of clarifications, the recipient is the Commercial department.

In all other cases, the recipients are the Marketing department or legal service (in the cases where the Data Subjects intend to exercise their rights).

5. For how long and where do we store your data

Onoma shall undertake the retention and maintenance of the data until: instructions otherwise from the user; their maintenance is no longer lawfully permitted; the date when Onoma ceases to have a valid legal basis for the processing of your data, in accordance with which situation occurs first.

6. Disclosure of data

Onoma shall not disclose any personal data collected, unless so required by law or by competent authorities.

7. Transfer to third countries

There shall be no transfer of data to third countries.

8. What measures have we implemented in order to protect your data against unauthorized access, alteration or destruction?

Onoma takes the necessary and legally required precautions to ensure the protection of the information collected from their users through the website of Onoma. These precautions ensure the offline security of this information.

The following are some of the technical and organisational measures to ensure the security and confidentiality of personal data that were implemented: physical security (by controlling the accesses), logical separation of records, passwords and access levels, firewalls and anti-virus software. The data are kept encrypted.

9. Your rights

All personal data is processed according to what is provided for in Portuguese Law no. 67/98, of October 26, and in Regulation (EU) 2016/679 of the European Parliament and the Council, where the personal data subjects have and are able to exercise the following rights in person in our facilities or in written form, via email addressed to geral@onoma.pt, free of charge and at any time:

Right of access: to know if Onoma has your data and, if so, to have the right to access said data.

Right to rectification: to correct or to complete incorrect or incomplete personal data.

Right to erasure: to obtain the erasure of the personal data if they are no longer necessary in relation to the purpose communicated; if consent is withdrawn; if the data are unlawfully processed and if the data subject objects to its processing and Onoma has no overriding legitimate interests.

Right to restriction of processing: in this case, Onoma may only store the data. This applies if the accuracy of the personal data is contested by the data subject; if the processing is unlawful, but the data subject opposes their erasure; and if Onoma no longer needs the personal data but they are required by the data subject for the establishment, exercise or defence of legal claims.

Right to portability: the data subject may want to receive his/her personal data from Onoma in a structured, commonly used and machine-readable format. This right applies when the data were collected based on his/her consent or on the entry into a contract with Onoma and the processing of data is carried out by automated means.

Right to object: in cases where Onoma processes your data for purposes of direct marketing, the data subject may at any moment object to the processing, and the data shall no longer be processed for such purposes. In all other cases, that is, when the legitimate interests of Onoma are the legal grounds for the processing, the data subject may at any moment object to processing on grounds relating to his/her particular situation. Similarly, Onoma may object to the use of data for purposes different from those the personal data were collected for.

When consent is the legal basis for the processing of data, the Data subject has the right to withdraw consent at any time, by contacting us for this purpose via email addressed to geral@onoma.pt.

The data subject has the right to lodge a complaint with Comissão Nacional de Proteção de Dados (the Portuguese data protection authority) or any other supervisory authority.

The data subject may at any moment exercise his/her rights of access, to erasure, to rectification and restriction of processing of personal data, without it being unfavourable to him/her.

10. Contact us

For any question related to the processing of your personal data, you may contact Onoma via phone number +351 213 929 591, or by sending an e-mail to geral@onoma.pt.

11. Revisions and changes

This Policy was created on 1 January 2019.

Onoma reserves the right to change its privacy policy at any moment. With regard to registered users, Onoma shall send emails with the new version of this Policy, in cases where relevant changes were made to the document.

TERMS AND CONDITIONS

Before accessing and using the website of Onoma, the User should carefully read the Terms and Conditions. Before accessing and using this website, the User declares that he/she has read, understood and accepted the Terms and Conditions mentioned below, without the need for any subsequent action or consent.

Onoma may at any moment decide to change the Terms and Conditions and such changes enter into force on the date they are posted on the website. These Terms and Conditions were last updated on 1 January 2019.

Table of Contents

1. Copyright and industrial property
2. Users’ conduct
3. Privacy Policy
4. Information available on the website
5. Hyperlinks to third-party websites
6. Blogging and social media
7. Applicable Law and Competent Court

1. Copyright and industrial property

All data, logos, registered trademarks and, in general, all contents from this website are property of or for Onoma’s exclusive use only, and are safeguarded by national and international legislation on Intellectual Property and Copyright protection.

Every trademark used in this website is property of its respective owners. The User is authorized to view, copy, print and share the contents from the website of Onoma for information purposes, but not for commercial purposes. The copy of such content should be followed by a declaration of copyright, stating its ownership by Onoma. No changes to the website of Onoma are authorized. The User agrees to access and use this website in accordance to the applicable laws.

2. Users’ conduct

The use of the website for unlawful, immoral or any other purposes that may be considered incompatible with Onoma’s image is expressly forbidden. The creation or introduction by the user of any types of viruses, worms, Trojan horses, scripts or any other code or software containing destructive properties or which may harm the website is strictly forbidden.

3. Privacy Policy

Onoma undertakes to respect the privacy of its users. Browsing the website of Onoma entails accepting its Privacy Policy.

Onoma reserves the right to change its privacy policy at any moment. As such, we recommend that you regularly refer to the privacy policy.

4. Information available on the website

The information made available on this website is provided free of charge and for information purposes only. It, therefore, does not entail a business relationship between the user of the website and Onoma. All information made available on the website is provided AS IS, with no guarantees of accuracy.

5. Hyperlinks to third-party websites

To improve your accessibility, Onoma may include links to other websites on the internet. When using these links to other websites, the User should read and accept the rules of these websites before using them. We cannot guarantee their quality, and assume no responsibility for the content or other features of these websites. Onoma is not liable or responsible for the content or subject matter of any other website and/or portal.

6. Blogging and social media

This website may host various blogs and services classified as social media which allow content sharing with other users (these includes all social media platforms).

Any contribution from one of our users which contains personal information or information of any other nature, and is published from a social media platform, may be read, collected and used by other users from the same social media platforms, as we have limited or no control whatsoever over said platforms.

As such, we cannot be liable or responsible for the use or inappropriate use of the content our users may have obtained through social media.

7. Applicable Law and Competent Court

These Terms and Conditions are governed and interpreted in accordance with the Portuguese law. The District Courts of Lisbon, at the exclusion of any other Courts, are the competent authority to settle disputes resulting from the interpretation and application of these Terms and Conditions for using the website of Onoma.