Privacy Policy

This Privacy Policy governs the processing of personal data provided by users of the website www.klayandmary.com to Klay & Mary, the entity responsible for its collection and processing.

By providing their personal data, users expressly declare their acceptance of the terms of this Privacy Policy, which is supplemented by the Terms and Conditions of Use available for consultation.

In line with the General Data Protection Regulation (Regulation (EU) 2016/679), hereinafter referred to as GDPR, and other applicable legislation, this Privacy Policy additionally establishes the rights of the holders of the personal data provided, as follows:

1. Who are we?

Klay & Mary is an online store operated by Clara Maria Lemos, with a professional domicile at Rua São Vicente N 435, 4650-502 Sousa,
Felgueiras, Portugal, tax identification number 210910178.

Klay & Mary prioritizes the protection of the privacy and personal data of the Customers of the services it offers, and similarly, the personal data of their respective holders in all situations where their personal data is processed.

2. Why this Privacy Policy?

Transparency. With this privacy policy, we aim to inform Customers about the general rules of personal data processing, which are collected and processed in strict compliance with the legislation on personal data protection in force at any given time, particularly the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), and any other applicable legislation on this matter that may come into effect.

Klay & Mary is committed to the protection and confidentiality of personal data, having adopted measures it deems appropriate to ensure the accuracy, integrity, and confidentiality of personal data, as well as all other rights that assist the respective holders of these personal data.

Klay & Mary complies with the best practices in the field of data security and protection and has adopted the technical and organizational measures necessary to comply with the GDPR and ensure that the processing of personal data is lawful, fair, transparent, and limited to the authorized purposes under the GDPR and other applicable legislation.

Thus, this Privacy and Data Protection Policy also aims to conclude the provisions on the protection and processing of personal data outlined in the contracts that Customers/Users have established or will establish with Klay & Mary, as well as the rules provided in the terms and conditions that regulate the offer of the various services and are duly advertised on our online site.

3. Personal data security measures

It is a priority for Klay & Mary to ensure the protection and security of the personal data provided to us. Thus, Klay & Mary has implemented an internal

security policy, and compliance with these rules is an obligation of all those who legally access them, namely its employees.

These rules and security measures, which are technical and organizational in nature, aim to protect personal data against dissemination, loss, misuse, alteration, processing, or unauthorized access, as well as against any other form of unlawful processing.

Moreover, third parties that process personal data of the Customer on behalf of and for Klay & Mary within the scope of service provisions are required, in writing, to carry out appropriate technical and security measures that, at each moment, meet the requirements stipulated in the GDPR and any other potentially applicable legislation and aim to safeguard the rights of the data holder.

As part of Klay & Mary’s internal security policy, all forms of online personal data collection are encrypted and securely stored, and physical and logistical security measures have also been implemented.

However, such actions by Klay & Mary do not exempt Customers from adopting security measures, especially regarding the use of personal online defense systems (firewall, antivirus, anti-spyware, tools for verifying website reliability, etc.).

4. What are “Personal Data”

In accordance with paragraph 1 of Article 4 of the GDPR, “personal data” means information relating to an identified or identifiable natural person (“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, electronic identifiers, or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

5. Processing of personal data

In line with paragraph 2 of Article 4 of the GDPR, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

The personal data collected are processed in strict compliance with all provisions of the applicable legislation. This means that all data will be retained according to their respective purposes and respecting the applicable legal deadlines.

Thus, whenever there is no specific legal requirement, the data will be stored and preserved only for the period appropriate and to the extent necessary for the purposes for which they were collected, except if the right to object, the right to erasure, or withdrawal of consent is exercised within legal limits.

6. Who is responsible for data processing

Klay & Mary, through its legitimate owner, is responsible for the processing of personal data according to the purposes and means of processing at any given time.

For the purposes established in this policy or within the scope of the GDPR, should the data subject need to contact Klay & Mary, they may do so via the email address info@klay&mary.com or by written correspondence addressed to our professional domicile: Rua São Vicente N 435, 4650-502 Sousa,
Felgueiras, Portugal.

7. Data Protection Officer

Klay & Mary has appointed a Data Protection Officer who can be contacted via the email address: info@klay&mary.com.

8. Types of data that may be subject to processing

Considering the activities carried out by Klay & Mary, this entity processes the personal data necessary for the provision of services, supply of goods, or in its social responsibility activities, processing personal data such as the name, address, telephone number, and email address.

The information collected may be more or less extensive depending on the information provided by the Customer. Except for obligations arising from legal compliance, all data will be exclusively processed by Klay & Mary to the extent necessary for the development of its activity, also allowing the Customer to access, for example, specific functionalities of the services.

Where there is prior consent from the Customer, it may be withdrawn at any time, without, however, affecting the lawfulness of processing based on consent

before its withdrawal. To withdraw consent, you may use the email address info@klay&mary.com.

9. Purposes and Legal Basis for Data Collection and Processing

Klay & Mary may process personal data for the following purposes:
a) Provision of commercial services (opening client files, recording proposals and orders, communications with clients, and archiving); – The legal basis in this case is contract execution, specifically the interest of Klay & Mary in effectively and efficiently processing their clients’ information, ensuring the quality of their services.
b) For statistical analysis purposes on Google Analytics, without collecting any specific personal data (such as names, addresses, IPs);
c) For billing and accounting management; – To maintain efficient management control, ensuring timely billing and compliance with applicable legal obligations; d) For billing and legal and extrajudicial claims, which includes billing and recovery of amounts due from clients; – The legal basis is the legitimate and legal interest of Klay & Mary in satisfying their credits and defending their rights.

10. Circumstances of Processing by Subcontractors

In the context of its activities, Klay & Mary uses third parties to provide certain types of services which may involve access by these entities to clients’ personal data.

When this occurs, Klay & Mary ensures that the subcontractors comply with the GDPR and any other applicable legislation, as well as certain standards similar to our internal security policy.

In cases of communication of personal data to other subcontracted entities, Klay & Mary continues to be responsible for these personal data.

11. Destination of Personal Data

The personal data are intended solely for Klay & Mary and may only be used by third parties for the purpose of fulfilling legal obligations.

12. Collection of Personal Data

Klay & Mary only collects personal data via telephone, contractually, through its website, and always ensuring the prior consent of the data subjects.

It is important to note that some personal data are essential for the execution of contracts, and in cases of absence or insufficiency of such data, this may compromise the provision of services by Klay & Mary. The rules of this policy apply to data subjects who are not Klay & Mary clients.

The collected personal data may be processed both computationally and in an automated or non-automated manner. Klay & Mary ensures compliance with the GDPR and any other applicable legislation.

The personal data are stored in specific databases created for this purpose. The personal data will never be used for a purpose other than that for which they were collected or for which consent was provided by the data subject.

13. Conservation of Personal Data

The conservation and storage of personal data are necessarily related to the

purpose for which the information was collected and processed.

Except in cases where there may be a legal obligation to maintain the personal data, such data will only be stored and preserved for the minimum period necessary for the purpose for which they were collected.

14. Transfer of Personal Data

Klay & Mary does not transfer personal data and, should this ever occur, it will

be done in accordance with the GDPR and any other applicable legislation.

However, this does not affect the exercise of the right to data portability by the data subject.

15. Your Rights and How to Exercise Them

As a data subject, Klay & Mary guarantees you, at any time, the right to access, rectify, update, limit, and erase your personal data (except for the data that are indispensable for the provision of services or the supply of goods where the contractual relationship still endures), the right to object to their use for commercial purposes by Klay & Mary and to withdraw consent, as well as the right to data portability.

To exercise these rights, you can contact us via the email address info@klay&mary.com or by written communication addressed to our professional domicile: Rua São Vicente N 435, 4650-502 Sousa,
Felgueiras, Portugal.

16. Complaints

Although you can directly submit any complaints to Klay & Mary as mentioned above, you can also file a complaint directly with the Contract Authority, which in Portugal is the National Commission for Data Protection (CNPD).

17. Changes to the Privacy and Personal Data Protection Policy

Klay & Mary reserves the right to make changes at any time and as necessary, with such changes being subject to publicity through the channels used by Klay & Mary.

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