Privacy Policy
Last Update Date: 2025-06-03
1 - INTRODUCTION
Welcome to the rewards.aralab.pt website, which operates the Aralab Rewards Portal, which is used to manage the Aralab Rewards incentive programme.
The privacy and protection of the personal data of all participants on the Aralab Rewards Portal ("Participant" or "Participants") is very important to us.
This Privacy Policy establishes the way in which Aralab and AVIVARINC, Unipessoal, Lda. use the personal data of the Participants, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation - "GDPR")) and with Law No. 58/2019, of 8 August (together "Data Protection Law").
2 - IDENTIFICATION OF DATA CONTROLLERS
Aralab, headquartered at Avenida de Santa Isabel 1, Albarraque 2635-047. Rio de Mouro, with the unique registration and legal person number 501 516 590 ("Aralab") is responsible for the processing of the personal data of the Participants in the Aralab Rewards Portal, collected and subsequently processed within the scope of the use of the same Portal and AVIVAR INC, Unipessoal, Lda., with registered office at Avenida Infante Santo Nº 23 – 10º Dto, 1350-177 Lisbon, with the single registration number and legal person 515810428, is its subcontractor.
Participants may, as data subjects, exercise all their rights, provided for in the Data Protection Law, regarding the processing of their personal data within the scope of the Aralab Rewards Portal, with Aralab. Aralab's contact details are available in section 9 of this Privacy Policy.
3 - PERSONAL DATA PROCESSED, PURPOSES AND LEGAL BASIS
Regarding browsing and using the Aralab Rewards Portal, Aralab will use cookies under the terms described in the Cookies Policy. Except for strictly necessary cookies, the use of cookies requires the consent of the Participant.
In addition, Aralab will process the following personal data ("Personal Data"):
The purposes pursued by Aralab with the processing of Personal Data are as follows:
The Participant guarantees that the Personal Data provided on the Aralab Rewards Portal is true, accurate, complete and up-to-date, and is responsible for any damage or loss, direct or indirect, that may be caused because of the breach of this obligation.
If the Personal Data provided belongs to a third party, the Participant guarantees that it has informed said third party of the information contained in this Policy and has obtained its authorization to provide its data to Aralab for the purposes indicated above.
4 - COMMUNICATION OF PERSONAL DATA
Aralab may share Personal Data with other entities, which will process the data exclusively for the purposes identified above.
In particular, and in addition to AVIVAR identified above, Personal Data may be shared with subcontractors in accounting, software supply and maintenance, cloud storage and management of digital platforms, carriers, financial advisors, lawyers, among others. Aralab will always seek to guarantee to its suppliers that they will adopt the appropriate technical and organisational measures to protect Personal Data.
Aralab may also share Personal Data with courts, criminal police bodies and/or other judicial, administrative or regulatory authorities, whenever this is necessary for the exercise of its legal defence or a right.
5 - INTERNATIONAL DATA TRANSFERS
Aralab may transfer Personal Data outside the European Economic Area ("EEA"). Whenever there is no adequacy decision in force in the country where the importer of the Personal Data is based or in which the latter provides its service, Aralab guarantees that it will adopt the appropriate or appropriate safeguards possible, namely the signing with the importer of Standard Contractual Clauses as approved by the European Commission at any time.
To obtain additional information about the appropriate or adequate safeguards that have been adopted, as well as about the means of obtaining a copy of them, or where they have been made available, the Participant must send a written request to Aralab's contact details available in section 9 of this Privacy Policy
6 - SECURITY IN THE PROCESSING OF PERSONAL DATA
The processing of Personal Data collected and processed within the scope of the Aralab Rewards Portal is protected by appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the most advanced techniques, the costs of application and the nature, scope, context and purposes of the processing, as well as the risks, of varying probability and severity, to the rights and freedoms of the Participants.
7 - PERSONAL DATA RETENTION PERIODS
Personal Data will only be kept for the period that allows the identification, directly or indirectly, of the Participants for the period necessary for the purposes for which they are processed.
Thus, and regarding the retention periods of Personal Data related to the use of cookies, they are available in the Cookies Policy.
In relation to Personal Data processed for the purpose of managing records on the Aralab Rewards Portal, they will be kept as long as this record remains active. All records whose Participants do not access the Aralab Rewards Portal for a period of more than thirty-six (36) months will be deleted, except if Aralab deems that they are necessary for the exercise of its legal defence or right.
The remaining Personal Data will also be kept for a maximum period of 36 (thirty-six) months or until the Participant demands their deletion, under the terms legally admitted.
8 - COMMERCIAL AND PROMOTIONAL COMMUNICATIONS
As described above, one of the purposes for which Personal Data is processed is to send commercial and promotional electronic communications.
Communications of this type will be addressed exclusively to Participants who have previously and expressly authorized them.
In the event that the Participants wish to stop receiving commercial or promotional communications, they may revoke the consent previously given by sending an email to the following address: suporte@avivar.com or through the link enabled for this purpose in the communications themselves.
9 - EXERCISE OF YOUR RIGHTS
In accordance with the provisions of the Personal Data Protection Act, Participants may exercise their rights of access, rectification, cancellation, limitation of processing, opposition and portability by requesting it, in writing, to the Contact Point through any of the following means, and specifying the right or rights they wish to exercise:
You may also lodge a complaint with the competent supervisory authority if you consider that the processing of your personal data by Aralab violates applicable law. In the case of Portugal, the competent supervisory authority is the National Data Protection Commission (www.cnpd.pt).
9 - LOCATION - GEO
The Aralab Rewards Portal may use the User's location to send commercial and transactional push notifications, provided that their prior and express consent has been obtained, always ensuring the protection and privacy of their personal data, in accordance with applicable legislation and best security practices.