ALL4VAPPING DISTRIBUTION is an Online Store that values the seriousness and safety of the services provided. This Privacy Policy explains what we do with your personal information. We act quite strictly in relation to privacy and data protection. The privacy and security of the data registered by the Users / Clients is a priority in our responsibilities, with only the necessary data being collected for the administrative services procedures, as well as the provision of after-sales contact services. For marketing and advertising purposes, we only act with the authorization and consent of the User / Customer, who is fully informed about our privacy policies and how we treat your data, when filling in and validating any form of registration or order in the our Online Store. At any time, our Users / Customers can consult and change their marketing preferences, as well as their data, accessing their customer area through the Link made available for this purpose, thus maintaining control over their data.

This Privacy Policy applies to the personal data of our Users / Customers of the Online Store, Suppliers and other persons who contact us in order to clarify our services or products.

For the purposes of the applicable data protection legislation (including, but not limited to, the General Data Protection Regulation GDPR [Regulation (EU) 2016/679] Under Directive 95-46-EC), the company and / or entity responsible for your personal data is ALL4VAPING DISTRIBUTION, with headquarters in Praceta Afonso Paiva Nº4 Loja G, 2910-705 – Setúbal.

We note that occasionally, whenever we deem it necessary and without prior notice, we may change this Privacy Policy. Therefore, if you want to keep up-to-date on the same, we advise you to visit this page regularly, as all changes will be published and updated here.

In case of dissatisfaction with any of the points of our Privacy Policy, you may communicate and describe them for our evaluation and further clarification.

This Privacy Policy applies to all Users / Clients of the member countries of the European Union, as well as to the different countries outside the EU. In this way we comply with all applicable data protection protections regardless of where our Users / Clients are located.


2.1 What kind of personal data do we collect?

2.1.1. USER / CUSTOMER DATA: If you are a User / Client of ALL4VAPING DISTRIBUTION, we need to collect and use information about your company, about you or people from your company within the scope of our services. The data we collect on Users / Clients is not very complex. As a rule, we only need to have your contact details, your company’s individual contact details and business registration data (such as names, tax identification number, telephone numbers, addresses and e-mail addresses), with the objective of managing the services offered. We also have information related to your consent and authorization to use data, which we use to ensure that our business and marketing communications to you are relevant, timely and of interest to you. If, for any reason, we require any additional personal data, they will be requested, with your authorization and consent.

ONLINE SHOP USERS: We may collect a limited amount of user data with or without registration in our Online Store. These data are obtained through the contact forms and inquiries (such as names, and e-mail addresses). As a rule, this type of data is used to help us improve your experience when you use our Online Store and to clarify your doubts about our services. This includes information about how you use our Online Store, how often you access it, and the times when our site is most popular.

2.1.3. OTHER TYPES OF DATAWe may collect data or information about you when you visit our Online Store. These data are captured in an automated way by computer routine, through the use of the technology of “cookies”, this situation, foreseen in our Cookies Policy. These data are used for statistical purposes, definition of routines, establishment of navigation safety standards, or others, in order to improve your experience and use of the resources of our Online Store. The non-consent of these cookies may affect the correct operation of our Online Store. For more detailed information, please see our Cookies Policy chapter.

Most of the personal data we collect about you or your business is necessary to enable us to fulfill your contractual obligations to you or to third parties. Other points may simply be needed to ensure that our business relationship runs smoothly. Depending on the type of personal data concerned and the grounds on which we may treat them, if you refuse to provide such data, we may not be able to comply with your contractual obligations or, in extreme cases, we may not be able to proceed with our business relationship.

2.2 How do we collect your personal information?

2.2.1. USER / CLIENT DATA: We collect personal data from the User / Customer in three ways:

A) Personal data that you, the User / Customer, provide directly to us;
B) Personal data we receive from other sources;
C) Personal data that we collect automatically.

Personal data you provide directly
ALL4VAPING DISTRIBUTION needs to be aware of certain information about you and your company in order to provide an adequate service and with the maximum administrative and financial rigor. Such information will allow us to adjust the best commercial relations, offers and services. There are several ways you can provide us and share your information, depending on what is best for you and your business. These may include:

– Enter your data in the Online Store of ALL4VAPING DISTRIBUTION through the User / Customer registration form, as well as through the order forms, returns and information requests;
– If you contact us, usually by telephone or e-mail proactively, or contacted by us, through our commercial processing activities;
– Send us requests for information or communicate divergences in your orders, through the contact forms available in the Online Store, or through e-mail;
– Fill out return and exchange forms available in our Online Shop.

Personal data we receive from other sources
ALL4VAPING DISTRIBUTION may also receive personal data about Users / Customers from other sources. Depending on the relevant circumstances, as well as applicable local laws and requirements, such personal data may be received as follows:

– Our Users / Clients will be able to share their personal information with us on a voluntary basis;
– If you like or follow, in our pages of Social Networking channels, we will receive personal information from these sites;
– Requests for information or participation in activities on our Social Networking channels, such as Facebook, Twitter, Instagram, or other channels that may be implemented.

Personal data we collect automatically
Whenever you access our site, read or click on an e-mail from us, where appropriate and in accordance with local laws and requirements, we may also collect your data automatically or through your action (please see section 2.1.3 OTHER TYPES OF DATA).

2.2.2. USERS OF THE ONLINE STORE: When you visit our Online Store, there is certain information that we may collect automatically, implying or not, the use of our services. We refer to your IP address, Data. Hours and the regularity with which you access our Online Store, as well as the history of how you navigate our content. We also collect your data when you contact us through the tools and / or forms that we make available in our Online Shop.

We collect your data automatically through “cookies”, in accordance with the definitions of “Cookies” established by your browser. We may use this type of data from your browsing interaction in our Online Store for the purpose of improving other aspects of our communications with you or the services we provide you. If you’d like to know more about our Cookies policy, including how we use them, and what options you have, check out our Cookies Policy chapter.

2.3. How do we use your personal information?

Once we have collected the data and information you provide, it will be used in various ways and for different purposes, as explained in the following points.

USER / CLIENT DATA: Normally we use the data and information of the User / Client for the following purposes:

A) Registration activities, commercial services and personalized navigation;
B) Marketing activities;
C) Assist us in the declaration, exercise or defense of any kind of right.

Registration activities, commercial services and personalized navigation
As our main activity is the trade and distribution of products, we have to establish a closer and safer relationship with our Users / Customers, collecting information and data crucial to the legitimate confirmation of contractual authenticity of the services provided. In this way, we indicate below a list of several ways that we may use and process your personal and / or business data for this purpose, when appropriate and always in compliance with local laws and requirements.

– Collect your personal and / or business data through registration forms validated by you or through other sources, such as social networking channels;
– Store your data (and use them when necessary) in our database, in order to contact you for the purposes of commercial after-sales support;
– Evaluate data about you in relation to the products that we think are more appropriate and advantageous for your business;
– Fulfill our obligations arising from any contract celebrations by both parties;
– Streamline our processes of handling of orders and billing;
– Conduct user / customer satisfaction surveys;
– Comply with our legal obligations regarding the detection of crime or the collection of taxes or duties;
– Monitor your activity in the Online Store to improve the browsing experience and content presentation criteria;
– Processing your data so that we can send you relevant and relevant marketing products or other types of communications that we consider to be of interest to you.

We may use your personal data for the above purposes whenever we deem it necessary to do so for our legitimate interests. If you do not agree in certain circumstances, you have the right to object (for more information you can consult in this document the “Right to object”).

Marketing Activities
From time to time, we may send you information about products and campaigns that we consider to be of interest to you. In summary, we may need to use your data for the purposes listed below, where appropriate and in compliance with local laws and requirements:

– Allow us to develop and market other products and services;
– Send you reports, promotions, offers, or even events related to the commercial sector that we think may be of interest to you;
– Present promotional excerpts of your data in the Online Store, such as “testimonials of success” and “evaluations of products” (only when we obtain the authorization and consent expressed by you).
– Provide you with information about certain discounts, offers and advantages granted to you by right, due to your business relationship with ALL4VAPING DISTRIBUTION.

We need your authorization and consent for some aspects of these activities that are not covered by our legitimate interests (especially when collecting data through Cookies, as well as providing direct marketing to you through digital network channels) and, depending on the situation, this consent will be requested through inclusion options, also referred to as “Opt in”, “Double Opt in” and “Soft Opt in” (explained later on what these inclusion options are), where the opportunity to enter your data and authorize the use of the same for the various marketing activities.

What does “opt in” mean?
According to the basic rules in this area, for a company to make the communication of marketing campaigns it is necessary that it has a qualified and opt in basis of contacts. This means that all persons or entities that have been included in the database lists have authorized the receipt of e-mail communications, newsletters and / or promotions from the company in question. The most used method for capturing and listing people or entities interested in reading and receiving communications from a company is the use of request fields within the company’s own website, such as the following examples: “Subscribe to our newsletter” or ” Receive our campaigns and promotions by email “. Users / Customers who show interest will enter their data in the requested fields and authorize the company to send campaign or promotion communications.
In short, “Opt in” is a type of authorization required by any User / Client or individual, so that you can receive communications from a particular company.

What does “Double Opt in” mean?
The “Double Opt in” is basically an enhanced “Opt in”, ie it is not enough for the User / Customer to add their data in the form fields of a website, showing interest in receiving a newsletter or communications from a company in general. Double Opt in happens when the company that receives the initial data of the interested User / Client, then sends a notification by e-mail, indicating a confirmation link and / or activation of the subscription. In order for the communication submissions to be confirmed, it is necessary for the interested User / Client to access the email for which they subscribed the request and click on the confirmation link, reaffirming a second time their interest in receiving such communications (hence comes the use of the term “Double”).
In summary, this is a double confirmation of the interest of a User / Customer in receiving marketing communications from a company.

What does “Soft Opt in” mean?
This term refers to an implicit form of ensuring the sending of business communications to Users / Clients, assuming that there is already a previous relationship established between the parties. This option does not require registration where the Users / Clients insert their data and authorize the sending of communications. The “Soft Opt in” assumes that the relationship that already exists between both parties, allows the sending of communications by email between them.

Building a contact list through Soft Opt in is usually done through professional contacts, often held at events or trade shows, for example, when clients and companies come together to exchange ideas and information in general. famous networking). This type of inclusion of data in the contact base of a company is contemplated in certain jurisdictions in which we operate, complying with additional local legislation requirements, as a way to capture contacts, being in this way a legal action, not being considered as spam.

In any case, there is a need for common sense in this type of action. When using this type of resources, to increase the base of contacts of a company, the most correct is to inform people about the intensity of their inclusion, and to obtain their authorization for this purpose. However, under the terms of the “Soft Opt in” consent, we may consider that your consent was given unless or until you self-exclude yourself.

Whenever you disagree with our marketing activity, you have the right to withdraw your consent at any time, by excluding yourself from the receipt of marketing materials from us. We want to let you know that even if you have been excluded from our marketing communications, your data may be retrievable through public sources in a non-marketing campaign. We will try to make sure this does not happen, but if it does, we apologize. We will only do so in the circumstances in which you have re-self-exclude yourself.

Assist us in the declaration, exercise or defense of any kind of right
In exceptionally rare circumstances, we may use your personal data as an aid to the declaration, exercise or defense of a right.

2.3.2. ONLINE STORE USERS: We use your data to help us improve the experience of using our Online Store by examining, for example, your recent product search criteria, to help us submit offers or products that we think may be of interest to you. This data is applied through cookies technology (for more information about cookies, namely how we use them and what options you have, please see our Cookies Policy).

2.4. With whom do we share your personal data?

2.4.1. Where appropriate and in accordance with local laws and requirements, we may share your personal data in a variety of ways and for various reasons with the following categories of persons:

– Any employee who provides services that require the use and treatment of their data, for the various processes of operation and / or business relationship with ALL4VAPING DISTRIBUTION;
– Tax, audit or other authorities, when we consider in good faith that the law or other regulations require us to share these data (for example, due to a request from a tax authority or in connection with an early litigation);
– Third party service providers who perform functions on our behalf (including external consultants, business partners and professional counselors such as lawyers, auditors and accountants, technical support functions and IT consultants who perform testing and development work on our company’s technology systems );
– third party providers of computerized services and storage of outsourced documents, in cases where we have an appropriate treatment contract (or similar protections);
– Platforms and suppliers of marketing technology;
– In the event that ALL4VAPING DISTRIBUTION is merged with or acquired by another company or company in the future (or if there are significant conversations for such possibility), we may share your personal data with (potential) new owners of the company or society.

2.5. How do we safeguard your personal data?

2.5.1. We are committed to take all reasonable and appropriate steps to protect the personal information we have about misuse, loss or unauthorized access. We do this by creating a set of appropriate technical and organizational measures. These include measures to deal with any suspected data breach.

 If you suspect misuse, loss or unauthorized access to your personal information, please let us know immediately. Contact ALL4VAPING DISTRIBUTION through our customer service area.

2.6. How long do we keep your personal information?

2.6.1. Your personal data will be kept legally for the time strictly necessary for the proper functioning and fulfillment of your business relations with ALL4VAPING DISTRIBUTION.

 We will “erase” your personal data from our systems when there is no relevant type of activity in a period of time equal to two years. Before completing this period of time, you may be contacted to inform us that your registration data will expire due to lack of activity, giving you the opportunity to revalidate your permanence as a User / Customer in our Online Store, otherwise, after after that time, their data are no longer relevant for the purpose for which they were collected. Your data will also be erased as soon as the business link with ALL4VAPING DISTRIBUTION is broken, in case you have requested your right to opposition and forgetfulness, or whenever you confirm the misconduct and inappropriate use of our services by the User / Customer, ALL4VAPING DISTRIBUTION reserves the right to unlink and delete the User / Customer data and registration.

 When we refer to the term “relevant activity”, we are referring to, for example, communication between us (verbal or written) or resulting from contact with our online services (either through social networking channels, e-mail or forms available for this purpose in our Online Shop). In this way, we consider it to be a relevant activity among us, sending requests for information, requested by both verbal and written communication, or if you have clicked and accessed the information contained in our marketing communications. Your receipt, opening or reading of digital messages from us will not be considered a relevant activity, the opposite occurring only in cases you have clicked or responded directly.

2.7. How can you access, change or remove the personal information you have provided us?

2.7.1. One of the main objectives of the GDPR is to protect and clarify the rights of European citizens (EU) and people in EU territories as regards the privacy of their data. This means that you have multiple rights to your data, even if you voluntarily provided it. We will now describe these rights in more detail.

2.7.2. You have the “right to object” to the treatment of our part of your personal data when we do so for the following reasons: (1) our legitimate interests; (2) to enable us to perform a task of public interest or official authority; (3) to send you direct marketing materials; (4) for scientific, historical, research or statistical purposes.

 With regard to “legitimate interests” and “direct marketing” are the most likely to be applied to Registered Users / Customers and Users not registered in our Online Store. If your objection concerns the processing of your personal data on our part, we may consider that these are necessary for our legitimate interests, referring us to the duty to act according to your objection, ending the activity in question, except if we can demonstrate that there are legitimate compelling reasons for the treatment which overlap with their interests, or if we are processing their data for the purposes of declaration, exercise or defense of a right.

 If your objection is of direct marketing action, it is our obligation and duty to act according to your objection, immediately putting terms to this activity.

2.7.5. Right to withdraw consent: If we have obtained your consent to process your personal data for certain activities (such as marketing agreements), you may withdraw this consent at any time, leaving our services to perform this type of activity that gave consent previously, unless we consider there is an alternative reason to justify the continued treatment of this data for this purpose, and we will inform about this condition.

 Data Holder Access Request: You may at any time request us to confirm the information we have about you, having the right to request us to change, update or delete this information. It is up to us, the right to verify your identity, requesting information that identifies you, or more information about your request. If you confirm the right of access to the information we have about you, you will not be charged unless your request is “manifestly unfounded or excessive.” In cases where we are legally permitted, we may deny your request. If this happens, you will always be informed about the reasons why you have taken this decision.

Right to delete: in certain circumstances, you have the right to request that we delete your personal data. To this end, some of the following criteria should be taken into account:

– The data is no longer necessary for the purpose for which it was originally collected and / or processed;
– When you have previously consented, you have withdrawn your consent to proceed with the processing of your data, and there is no other implicit reason why we should continue to treat them;
– The data were treated illegally, that is, not complying with GDPR;
– It is necessary to erase the data, in the fulfillment of our legal obligations, as data controllers;
– If we treat the data as we consider it to be indispensable to our legitimate interests, it opposes the treatment and does not make it impossible for us to demonstrate legitimate imperative reasons for our continued treatment.

 Refusal of your request: We can only refuse to comply with your request for one of the following reasons:

– To exercise the right to freedom of expression and information;
– To fulfill legal obligations or to perform tasks of public interest, as well as, in the exercise of an official authority;
– for reasons of public health in the public interest;
– For archival, research or statistical purposes;
– For the exercise or defense of a right.

2.7.9. Upon complying with a valid data erasure request, we will use all due diligence and security practices to erase the relevant data.

2.7.10. Right to restrict treatment: In certain circumstances, you have the right to restrict the treatment we make of your data. This means that we will only be able to continue to store your data, restricting you to any treatment activities with them, until: (1) one of the following circumstances is resolved; (2) your consent; (3) further processing is required for the declaration, exercise or defense of a right, protection of the rights of another person or for reasons of important public interest of the EU or a Member State.

The circumstances in which you have the right to request that the restriction of the processing of your personal data is:
– In case you dispute the accuracy of the personal data we deal with. In this case, the processing of our part of your personal data will be restricted for the period during which the accuracy of the data is verified;
– In the event you object to the processing of your personal data for our legitimate interests. In this situation, you may request that the data be restricted while verifying our grounds for the processing of your personal data;
– If the treatment we make of your data is illegal, but we prefer to restrict the treatment we make of them instead of their erasure;
– If we no longer need to process your personal data, but you need the data for the declaration, exercise or defense of a right.

If we have shared your personal data with third parties, they will be notified of the restricted treatment, unless this is impossible or involves a disproportionate effort. We will, of course, notify you before lifting any restriction on the processing of your personal data.

2.7.11. Right of rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we have about you. If we have shared such personal data with third parties, they will be notified of the rectification, unless this is impossible or involves a disproportionate effort. Where appropriate, we will also tell you to which third parties we have disclosed inaccurate or incomplete personal data. In cases where we consider that it is reasonable not to comply with your request, we will explain the reasons for the decision.

 Right to data portability: if you so wish, you have the right to transfer your personal data to controllers. In effect, this means that you can transfer the data from your ALL4VAPING DISTRIBUTION account to any other platform. To enable you to do so, we will provide you with your data in an automatic read-only format in common use so you can transfer the data to another platform. Alternatively, we can directly transfer the data for you. This right to portability of data applies to: (1) personal data that we treat automatically (ie without any human intervention); (2) personal data provided by you; (3) personal data that we treat based on your consent or to fulfill a contract.

 Right to complain to a supervisory authority: you also have the right to complain to the Portuguese supervisory authority

The “CNPD – Comissão Nacional de Protecção de Dados” (National Commission of Data Protection). You can contact her in the following ways:
– Telephone (+351) 213928400 / Privacy Line: +351 21 393 00 39
– E-mail:
-Requests for information online:
– Complaints Online Submissions:
– Address: Rua de São Bento, nº 148-3º, 1200-821 Lisboa
– Fax: +351 21 397 68 32

 It is important that the personal information we have about you is accurate and current. Whenever there are changes in your personal information during the period in which we keep your data.

2.8. Who is responsible for the processing of your personal data in the ALL4VAPING DISTRIBUTION Online Store?

2.8.1. The entity responsible for processing your personal data is ALL4VAPING DISTRIBUTION, headquartered at Praceta Afonso Paiva Nº4 Loja G, 2910-705 – Setúbal, e-mail:

If you have any comments or suggestions about the Privacy Policy, you can do so through the contacts that we offer of our services. Privacy is very important to us and we will respond as soon as possible.


3.1. What is a cookie?

3.1.1. A cookie is an information store that is stored on your computer’s hard drive and records your browsing on a website so that when you revisit that site you can present custom options based on the information stored on your last visit. We may also use cookies to analyze traffic and for advertising and marketing purposes.

They are used by almost all sites and do not harm your system. If you want to check or change the type of cookies you accept, you can usually do so in your browser settings.

3.2. How do we use cookies?

3.2.1. We use cookies to do two things:
– To track your use of our Online Store. This allows us to understand how you use the Online Store and track any patterns that may arise, which will help us to develop and improve our Online Store and services in response to what our Users / Clients want and need;
– To help us advertise products that we think may be of interest to you. We hope this process means you spend less time scrolling through pages and we can get you the product you want faster.

 The cookies are:
– Session cookies: These are only stored on your computer during your web session and are automatically deleted when you close the browser – they usually store an anonymous session ID allowing you to navigate a site without having to log in to each page, but they do not collect any information from your computer;
– Persistent Cookies: A persistent cookie is stored as a file on your computer and is maintained when you close your Web browser. The cookie can be read by the site that created it when you return to that site. We use persistent cookies for personalization.

3.2.3. Cookies can be categorized as follows:
– Cookies strictly required: These cookies are essential to allow you to use the Online Store effectively, such as when you place an order online, so they can not be disabled. Without these cookies, the services that are available to you in the Online Shop can not be provided. These cookies do not collect information about you that can be used for marketing or remember where you were on the Internet.
– Performance Cookies: These cookies allow us to monitor and improve the performance of our Online Store. For example, they allow us to count visits, identify traffic sources and see which parts of Online Store are most popular.
– Functional Cookies: These cookies allow our Online Store to remember the choices you make (such as your username, language or region you are) and provide enhanced functionality. For example, we may provide you with news or updates relevant to the services you use. These cookies may also be used to provide services you have requested, such as viewing a video or commenting on a social network channel. The information that these cookies collect is usually anonymized.
– Customization cookies: These cookies help us present data on potential products that we think may be of interest to you. These cookies are persistent (as long as you are registered with us) and mean that when you log in or return to the Online Store, you may see product suggestions similar to the products you searched for or viewed previously.


– Article 6 (1) (f) of the GDPR is that which is relevant in this case – states that we may process your data if it is “necessary for the legitimate interests pursued by us or by third parties, except where the interests or fundamental rights and freedoms of the holder [you] requiring the protection of personal data prevail. “

– We do not consider any of the following activities to be detrimental in any way – they actually help us to offer you a more adapted and efficient service and therefore everyone wins! However, you effectively have the right to object to our handling of your personal data on this basis.

– Please note that in certain jurisdictions where we operate, in some cases a different legal basis may apply to data processing. For more information regarding your jurisdiction, click here.

4.1. User / Customer Data

4.1.1. In order to ensure that we provide you with the best possible service, we store your personal data and / or personal data of individual contacts in our company, as well as keep records of our communications, emails, orders, or other information through our Online Shop. On a routine basis, we may also ask you to conduct a customer satisfaction survey. We believe that the use of your data is necessary for our legitimate interests as a service provider.

4.1.2. We want to offer you customized product recommendations in order to help you find the best products. We therefore consider it reasonable to process your data to ensure that we send you and submit the most appropriate content.

4.1.3. We have to ensure that our activity unfolds without problems, so that we can continue to provide the best services to Users / Clients like you. Therefore, we also need to use your data for our internal administrative activities, such as billing handling and parcel post processing.

We have our own obligations under the law, whose fulfillment is our legitimate interest! If we believe in good faith that it is necessary, we may share your data for the purpose of detecting crime, collecting taxes or litigation in advance.

4.2. Data we receive from unregistered users, such as information request contacts

4.2.1. If a particular user, or potential unregistered customer, requests information or clarification of doubts through our dedicated contact forms available in our Online Shop, we use your personal data to contact you, help you to better resolve the requested information. This is part of the quality assurance procedure and therefore we consider it necessary for our legitimate interests as a company that provides a product sales and distribution service.


5.1. In certain circumstances, we are required to obtain your consent for the processing of your personal data in relation to certain activities. Depending on what exactly we are doing with your information, this consent will be consent for inclusion or consent of type “Opt in”, “Double Opt in” or “Soft Opt in”.

Article 4 (11) of the GPDR indicates that consent (inclusion) is “a free, specific, informed and explicit manifestation of will, by which the data subject accepts, by means of a statement or an unequivocal positive act, that the personal data concerning him are being processed “. In simple language, this means that:

– You must give us your consent freely, without any kind of pressure on our part;
– You must know what you are consenting to – we will therefore make sure that we provide you with sufficient information;
– Must have control over what treatment activities gives consent or not. We have made these more specific controls in your User / Client area.
– You must have a clear unambiguous act in transmitting your consent – we are likely to provide a box (for example, a check box with the “I allow” and “I do not allow” options) to tick so that this requirement is met clearly and unambiguously.

We will keep records of the consents given by you in this way.

5.3. As we have already mentioned, in some cases it may be based on “soft opt-in” consent. We are permitted to market products or services that are related to the services we provide, as long as you do not actively exclude yourself from those communications.

5.4. Please note that in certain jurisdictions where we operate, we comply with additional local law requirements for consent to receive marketing materials.

As mentioned, you have the right to withdraw your consent to these activities. It can do so at any time, as has already been explained in previous points on this subject.


6.1. It may sometimes be necessary to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data regarding exercise or advocacy. Article 9 (2) (f) of the GPDR permits such processing when it “is necessary for the declaration, exercise or defense of a right in a judicial proceeding or whenever the courts act in the exercise of their judicial function” .

This may arise, for example, in cases where we need to obtain legal advice regarding legal proceedings or if we are required by law to retain or disclose certain information as part of a legal process.

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