Our commitment

The Life Curators Lda. is firmly committed to the privacy and rights of data subjects and acts in accordance with the provisions of the General Data Protection Regulation (GDPR) and other applicable legislation.

Privacy policy

We want you to be familiar with the way The Life Curators processes your personal data and with your rights as data subject.

The aim of this Policy is to answer the following questions:

1. What data does The Life Curators process, who does it concern and how is it collected?
2. For what purposes and on what lawful basis does The Life Curators process personal data?
3. How long do we keep your personal data for?
4. Who does The Life Curators transfer your personal data to?
5. Is your personal data safe?
6. What rights do you have as data subject?
7. How can you exercise your rights?
8. How can you contact us?
9. How can you stay informed about the processing of your personal data?
10. What data does The Life Curators process, who does it concern and how is it collected?

Personal data is any information relating to an identified or identifiable natural person. 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, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The Life Curators may process the following categories of personal data:

1.   a) Identification data(g., name, date of birth, gender, address, contact details, citizen’s card data, passport data, tax number, nationality);
   b) Data relating to education and work experience (e.g., education, qualifications, certifications, curriculum vitae, information from previous employer);
   c) Professional data (e.g., title, position, job description, company, office address);
   d) Professional activity data (e.g., business activities, information about cases and briefs, experience;
   e) Invoicing and expenses data (e.g., fees, client-related travelling and communications expenses); and
   f) Recorded image and sound data (e.g., photographic and video images).

Data subjects are the individuals to whom the data refers.

The personal data categories listed above may belong to different categories of data subjects, such as clients, employees of corporate clients or applicants of The Life Curators.

The Life Curators collects personal data in various ways and at different times, including when you send us an e-mail or reply to an invitation, when you give us your visiting card, when you sign up for our information or events, when you apply for a position with us or when you engage our services.

In some cases, The Life Curators may collect personal data indirectly from public sources. When The Life Curators processes personal data that has been collected indirectly, it will provide all the information about the processing of that data to the relevant data subject at the earliest opportunity.

2. For what purposes and on what lawful basis does The Life Curators process personal data?

The Life Curators may process personal data for the following purposes and on the following lawful bases:

1. a) Provision of services, which may include:

• Opening a client dossier;
• Keeping a record of services proposals received;
• Communications with the clients or other parties; and
• Keeping documents on file in digital and physical formats.

The lawful basis is contractual performance and legitimate interest:

• The Life Curators interest in processing clients’ information in a sustained and efficient manner, which ensures its quality and integrity and enables the provision of excellent services; and
• Interest of the clients represented and advised by The Life Curators.

1. b) Communications and sending of information (e.g. newsletters, briefings);

The lawful basis is legitimate interest:

• Reply to requests from persons that fill in The Life Curators website forms with the relevant suitable correspondence.

1. c) Event management, which includes:

• Sending invitations for events and registering event participants; and
• Publicising events within and outside the firm.

The lawful basis for this management are legitimate interest and consent (*):

• Reply to requests from persons that fill in The Life Curators website forms with the relevant suitable correspondence; and
• Publicise events arranged by The Life Curators.

1. d) Protection of persons and goods, which includes collecting CCTV images.

The lawful basis is legitimate interest, in order to ensure the protection of The Life Curators premises and the persons on those premises.

1. e) Complying with statutory compliance obligations

The lawful basis is compliance with statutory obligation.

1. f) Invoicing and accounts management, which includes:

• Booking expenses, monitoring costs and refunds (e.g. travelling to be paid by clients);
• Invoicing and management of current accounts; and
• Keeping accounting records and supporting documents on file.

The lawful basis includes contractual performance; legitimate interest; and compliance with statutory obligation: manage efficiency, invoice the services provided correctly and in a timely fashion, and ensure compliance with the applicable statutory obligations.

1. g) Judicial and non-judicial claims, which includes the collection and recovery of amounts owed by clients.

The lawful basis is legitimate interest: The Life Curators has a legal interest in satisfying its debt-claims and defending its rights.

1. h) Recruitment and selection, which includes analysing applications and CVs, as well as the internal selection process for staff according to the firm’s needs.

The lawful basis is pre-contractual audit at the request of the data subject and legitimate interest: The Life Curators interest in analysing applications and having applicants undergo an internal selection process, in accordance with pre-defined criteria.

(*) The data subject’s prior consent will be requested in cases where sound or image recordings are made or if photographs are taken.

3. How long do we keep your personal data for?

The Life Curators will only keep your data for the period of time necessary to achieve the purposes established in this Policy or during the period required by the applicable legislation or regulations.

The personal data storage periods, depending on each processing purpose, are as follows:

Processing purpose > Storage period

• Provision of services > For the duration of the client/firm relationship, plus 20 years.
• Communications and sending of information > Until the data subject objects.
• Event management > five years from the contact date or attendance at the event (as the case may be) if there is no contact or attendance at another event by the data subject.
• Protection of persons and goods > 30 days.
• Complying with statutory compliance obligations > seven years from the time the client’s identification is processed or, in the case of business relationships, after the end of the same.
• Invoicing and accounts management > 10 years.
• Judicial and non-judicial collection and complaints > Until payment of the amounts in debt or settlement of the dispute, whichever is applicable.
• Recruitment and selection > two years from the time the application or CV is received if the applicant (staff) is not selected); and

For the duration of the professional relationship with The Life Curators in the remaining cases.

4. Who does The Life Curators transfer your personal data to?

The Life Curators does not transfer your personal data to third parties, except in cases where this proves to be necessary for the provision of the services you have engaged or for compliance with the obligations to which The Life Curators is subject.

The transfer of data to third parties is carried out in accordance with the applicable data protection legislation and within the limits of the purposes and lawful bases established in this Policy.

The Life Curators may share your personal data with the following entities:

• Relevant parties for the advisory services we provide;
• Service providers that supply services to The Life Curators for the purposes described above, such as Information Technologies (IT) providers, communications services, translation services and digital and physical archive services.

In cases where the transfer of personal data to the above-mentioned entities involves an international transfer of personal data (i.e. outside of the European Union), The Life Curators

(i) will carry out this transfer on the basis of a Commission adequacy decision, according to which the country or international organisation in question guarantees a level of personal data protection equivalent to that under European Union law; or

(ii) if there is no Commission adequacy decision, it will ensure that such transfers are made in stringent compliance with the law and that appropriate guarantees are implemented to ensure the protection of your personal data.

The existing adequacy decisions are available at www.eur-lex.europa.eu.

5. Is your personal data safe?

The Life Curators has a very strict security policy, from a technical and organisation viewpoint, in order to protect your personal data from unauthorised destruction, loss, alteration, disclosure or access and against any other form of unlawful or abusive treatment.

The technical and organisational security measures created and implemented by The Life Curators are also required of the The Life Curators service providers that may process personal data on their own behalf.

If you have any questions about this matter, or if you would like more details about our data security, or if you know of any inappropriate situation, please contact us through either of the channels in point 9. below.

6. What rights do you have as data subject?

As data subject, you have the following rights:

• Right of access

You may ask The Life Curators at any time for confirmation as to whether it processes your data, for access to your personal data and for information about that processing.

You may also obtain a copy of the personal data that is processed.

• Right to rectification

If your personal data is incorrect or incomplete, you may ask for it to be rectified or completed.

• Right to erasure or to be forgotten

In certain situations, you have the right to request the erasure of your personal data.

This right may be restricted in certain situations if the processing of the data is necessary for compliance with statutory obligations to which The Life Curators is subject or when the processing is necessary for the purposes of declaring, exercising or defending a right in legal proceedings.

• Right to restrict processing

In certain situations, you may ask The Life Curators to limit access to personal data or suspend processing activities. This will happen, for example, in cases where you dispute the accuracy of your personal data, for a period of time which enables The Life Curators to check its accuracy, or in cases where you have objected to the processing, until it is verified whether the legitimate interests of The Life Curators or of a third party prevail over yours.

• Right to data portability

In cases where the processing of data is based on a contract to which you are a party or on your consent, you may ask The Life Curators to hand over to you the data you supplied in a structured, current and automatic reading format. You may also ask The Life Curators to transfer this data to other data controllers, as long as this is technically possible.

• Right to object

When the data processing is based on the The Life Curators legitimate interest or when it is carried out for purposes other than those for which the data was gathered, but which are compatible with the same, you have the right to object to the processing of your data for reasons related to your own personal situation.

The Life Curators will cease to process your personal data in such cases unless it has legitimate reasons to carry out this processing and these reasons prevail over your interests.

• Right not to be subject to automated decision-making

The Life Curators make no automated individual decisions, including profiling, which have an effect on your legal status or significantly affect it in a similar way.

• Right to withdraw consent

In cases where the processing of the data is based on your consent, you may withdraw your consent at any time.

If you withdraw your consent, your personal data will no longer be processed, unless there is another lawful basis that permits processing.

• Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with the relevant supervisory authority about matters related to the processing of your personal data.

In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados [National Data Protection Commission).

For more information, visit www.cnpd.pt.

Please note that the exercise of the above-mentioned rights may be restricted by virtue of third-party rights and freedoms, statutory obligations or confidentiality obligations or the prevailing legitimate interests of The Life Curators or a third party.

7. How can you exercise your rights?

You may exercise your right in either of the following ways:

• E-mail: by sending an e-mail to  info@thelifecurators.com ; or
• Letter: by sending a letter addressed to Alameda das Linhas de Torres, n. 152, 2º andar – escritório 11 – 1750-149 Lisboa – Portugal

There is no charge for exercising your rights.

8. How can you contact us?

If you have any questions or need more information about the processing of your personal data or your rights as data subject, please contact us at the addresses below:

• E-mail:by sending an e-mail to  info@thelifecurators.com ; or
• Letter: by sending a letter addressed to Alameda das Linhas de Torres, n. 152, 2º andar – escritório 11 – 1750-149 Lisboa – Portugal.

9. How can you stay informed about the processing of your personal data?

The Privacy Policy may be updated from time to time and we recommend that you check it regularly for any changes.

You can obtain more information about personal data processing from the Cookie Policy available on our website.