This Privacy Policy explains how GANIMET, UNIPESSOAL LDA (“GANIMET”, “we”, “us” or “our”) collects, uses and protects personal data when you visit ganimet.dev, contact us through the Website or otherwise communicate with us in connection with an enquiry submitted through the Website.
GANIMET processes personal data in accordance with applicable data protection legislation, including Regulation (EU) 2016/679 (the General Data Protection Regulation — GDPR) and applicable Portuguese data protection legislation.
01Data Controller
The controller responsible for the processing of personal data described in this Privacy Policy is:
GANIMET, UNIPESSOAL LDA Registered address: Rua da Alegria, Nº 31, 1 F, 9000-040 Funchal, Portugal
Email: legal@ganimet.dev
Questions concerning this Privacy Policy or the processing of your personal data may be sent to the email address above.
02Scope of This Privacy Policy
This Privacy Policy applies to personal data processed in connection with:
your visit to and use of the Website;
enquiries submitted through the Website;
communications relating to potential projects or services;
technical operation, maintenance and security of the Website.
This Privacy Policy does not govern personal data processing carried out under a separate client, supplier, employment or other contractual relationship where a separate privacy notice or contractual arrangement applies.
03Personal Data We Collect
Depending on how you interact with the Website, we may process the following categories of personal data.
3.1Information You Provide Through the Contact Form
When you submit a project enquiry through the Website, we may collect:
your name;
your work email address;
the name of the company you represent;
the type of project or service you are interested in;
information included in your project brief;
any other information you voluntarily provide in your communication with us.
Please do not submit unnecessary personal data through the project brief field.
You should not provide special categories of personal data, such as information concerning health, racial or ethnic origin, political opinions, religious beliefs, biometric data, sexual orientation or other sensitive information unless there is a specific and legitimate reason for doing so and appropriate arrangements have been made.
3.2Communications
If you communicate with us after submitting an enquiry, we may process:
your name;
business contact details;
company and professional information;
the contents of your correspondence;
information relating to the proposed project or cooperation;
records of communications between you and GANIMET.
3.3Technical and Usage Data
When you access the Website, certain technical information may be processed automatically by our hosting, infrastructure or security systems.
This may include:
IP address;
date and time of access;
browser type and version;
device and operating system information;
requested pages or resources;
referring website or URL;
technical logs;
information relating to errors, security events or suspicious activity.
Such information is processed only to the extent reasonably necessary for the operation, security, maintenance and technical performance of the Website.
04Purposes and Legal Bases for Processing
We process personal data only where there is an appropriate legal basis under applicable data protection law.
4.1Responding to Enquiries
We process information submitted through the Website in order to:
review your enquiry;
understand the nature and scope of a potential project;
respond to your questions;
discuss GANIMET's services;
determine whether GANIMET can provide the requested services;
prepare for potential commercial cooperation.
Where you contact us personally with a view to entering into an agreement, processing may be necessary to take steps at your request prior to entering into a contract, pursuant to Article 6(1)(b) GDPR.
Where you contact us as an employee, representative or other contact person of a company, processing is generally based on GANIMET's legitimate interests under Article 6(1)(f) GDPR in communicating with potential business clients and developing commercial relationships.
4.2Business Communications
We may process business contact details and correspondence where necessary to:
continue discussions initiated by you or your company;
clarify project requirements;
prepare proposals or other commercial documentation;
manage our business communications;
maintain appropriate records of discussions concerning potential cooperation.
Such processing is based, as applicable, on pre-contractual steps under Article 6(1)(b) GDPR or our legitimate interests under Article 6(1)(f) GDPR.
4.3Operation and Security of the Website
Technical information may be processed in order to:
operate and maintain the Website;
diagnose technical problems;
prevent abuse, fraud and malicious activity;
protect the Website and its infrastructure;
investigate security incidents;
ensure the reliability and integrity of our systems.
This processing is based on our legitimate interests under Article 6(1)(f) GDPR in maintaining a secure and functional Website.
4.4Compliance With Legal Obligations
We may process personal data where necessary to:
comply with applicable legislation;
respond to lawful requests from courts, regulators or competent public authorities;
comply with accounting, corporate, tax or other statutory obligations;
establish, exercise or defend legal claims.
Where processing is required by law, the legal basis is Article 6(1)(c) GDPR.
Where processing is necessary for the establishment, exercise or defence of legal claims or protection of our legal interests, processing may also be based on Article 6(1)(f) GDPR.
4.5Cookies and Similar Technologies
Where the Website uses cookies or similar technologies that are not strictly necessary for the operation of the Website, such technologies will be used only where an appropriate legal basis exists and, where required, after obtaining your consent.
Further information about the use of cookies and similar technologies is provided in our Cookie Policy.
05We Do Not Use Contact Enquiries for Unrelated Marketing by Default
Submitting a project enquiry does not automatically subscribe you to a marketing mailing list.
Information provided through the Website will not be used for unrelated promotional email campaigns merely because you contacted GANIMET.
If GANIMET introduces newsletters or other direct electronic marketing in the future, such processing will be carried out in accordance with the legal requirements applicable to electronic marketing communications.
06Recipients of Personal Data
Access to personal data within GANIMET is limited to persons who reasonably require such access for the purposes described in this Privacy Policy.
We may also disclose or make personal data available to service providers that assist us with the operation of our Website and business infrastructure, including providers of:
website hosting and infrastructure;
cloud services;
email and business communications;
IT administration and technical support;
cybersecurity and fraud prevention;
website maintenance;
professional legal, accounting or compliance services, where necessary.
Such service providers may process personal data on our behalf and, where required by applicable law, are subject to appropriate contractual and data protection obligations.
We may also disclose personal data where required by law, court order or a lawful request from a competent authority.
We do not sell personal data.
07International Transfers of Personal Data
Some of our service providers may operate or process information outside Portugal or outside the European Economic Area (“EEA”).
Where personal data is transferred outside the EEA, GANIMET takes reasonable measures to ensure that the transfer is carried out in accordance with applicable data protection law.
Depending on the relevant country and service provider, such transfers may rely on:
an adequacy decision adopted by the European Commission;
Standard Contractual Clauses approved by the European Commission;
another valid transfer mechanism recognised under the GDPR.
Where required, additional safeguards may be implemented taking into account the circumstances of the transfer.
You may contact us at legal@ganimet.dev if you wish to obtain further information concerning the safeguards applicable to a particular international transfer of your personal data.
08Data Retention
GANIMET retains personal data only for as long as reasonably necessary for the purposes for which it was collected and in accordance with applicable legal requirements.
Project Enquiries
Where an enquiry does not result in a contractual relationship, information relating to the enquiry may normally be retained for up to 24 months following the last substantive communication, where reasonably necessary to maintain a record of the enquiry, respond to follow-up communications and manage potential business relationships.
We may delete such information earlier where it is no longer necessary.
Contractual Relationships
Where an enquiry results in a contractual relationship, relevant information may become part of the client or project records and may be retained for the period required under the applicable agreement and applicable legal, accounting, tax and limitation requirements.
Technical and Security Data
Technical logs and security-related information are retained only for a period reasonably necessary for Website operation, troubleshooting, security monitoring and investigation of incidents.
Information may be retained for a longer period where necessary to investigate an actual security incident, comply with legal obligations or establish, exercise or defend legal claims.
09Security
GANIMET applies appropriate technical and organisational measures designed to protect personal data against:
unauthorised access;
unlawful processing;
accidental loss;
alteration;
destruction;
unauthorised disclosure.
The measures used are selected taking into account the nature of the information, the purposes of processing and the risks associated with the relevant processing activity.
However, no method of transmitting or storing information electronically can provide an absolute guarantee of security.
10Your Rights
Subject to the conditions and limitations provided by applicable data protection law, you may have the following rights in relation to your personal data.
Right of Access
You may request confirmation as to whether GANIMET processes personal data concerning you and, where applicable, obtain access to that data.
Right to Rectification
You may request correction of inaccurate personal data and completion of incomplete personal data.
Right to Erasure
You may request deletion of personal data where the conditions established by applicable law are satisfied.
Right to Restriction of Processing
You may request that processing of your personal data be restricted in circumstances provided by the GDPR.
Right to Object
Where processing is based on legitimate interests, you may object to the processing on grounds relating to your particular situation.
GANIMET will cease the relevant processing unless there are compelling legitimate grounds for continuing the processing or the processing is necessary for the establishment, exercise or defence of legal claims.
Right to Data Portability
Where processing is based on consent or a contract and carried out by automated means, you may have the right to receive personal data you provided to us in a structured, commonly used and machine-readable format and, where technically feasible, request its transmission to another controller.
Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
11Exercising Your Rights
Requests concerning your personal data may be sent to:
To protect personal data from unauthorised access or disclosure, we may request reasonable information necessary to verify your identity before acting on a request.
We will handle requests in accordance with the time limits and requirements established by applicable data protection legislation.
12Right to Lodge a Complaint
If you believe that GANIMET's processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority.
In Portugal, the supervisory authority is:
Comissão Nacional de Proteção de Dados (CNPD) Av. D. Carlos I, 134, 1.º 1200-651 Lisboa Portugal
Website: www.cnpd.pt
You may also have the right to lodge a complaint with another competent data protection authority in the European Union where permitted by the GDPR.
13Automated Decision-Making and Profiling
GANIMET does not use personal data collected through the Website to make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
GANIMET does not currently conduct profiling of Website visitors for such purposes.
14Children's Personal Data
The Website is intended for business and professional audiences and is not directed at children.
GANIMET does not knowingly collect personal data from children through the Website.
If you believe that a child has provided personal data through the Website, please contact us at legal@ganimet.dev.
15Third-Party Websites
The Website may contain links to third-party websites or services.
GANIMET does not control and is not responsible for the privacy practices of third parties.
Where you access a third-party website or service, the processing of your personal data by that third party is governed by its own privacy policy and terms.
16Cookies
The Website may use cookies and similar technologies necessary for its operation and may, subject to applicable requirements, use optional technologies for analytics or other purposes.
Where consent is legally required, optional cookies will not be activated before the required consent has been obtained.
Detailed information concerning cookies, their purposes, providers and retention periods is available in the Cookie Policy.
17Changes to This Privacy Policy
GANIMET may update this Privacy Policy from time to time to reflect:
changes to the Website;
changes to our processing activities;
changes to service providers or technologies;
changes in applicable law or regulatory guidance.
The current version will be published on the Website and will state the date of the latest update.
Where changes materially affect the way personal data is processed, GANIMET will take reasonable steps to provide appropriate notice where required by applicable law.
18Contact Us
For questions concerning this Privacy Policy, the processing of your personal data or the exercise of your data protection rights, please contact:
GANIMET, UNIPESSOAL LDA Rua da Alegria, Nº 31, 1 F 9000-040 Funchal Portugal
Email: legal@ganimet.dev