Within the scope of its activity, pur'ple, Unipessoal, Lda. ("pur'ple") provides its clients, including companies, organizations or individuals (the "Clients") with management consultancy services, including planning, organization, control, management, process design and implementation of processes, reorganization of companies and human resources management, herewith encompassing social and demographic studies, human dimensioning, definition and evaluation of performance, compensation, individual and leadership development and evaluation, training, internal communication, licensing and integration of computer systems (software), as well as technologies to support the implementation of solutions (the "Services").
PUR'PLE is strongly committed to protecting the personal data of those who use its website www.purposebypeople. com (the "Website") or its services, and through these terms and conditions of use of the Website (the "Terms and Conditions of Use") and the present privacy policy (the "Privacy Policy") pur'ple intends, on one hand, to define the conditions of access and navigation of the Website by each and every person who accesses the Website, regardless of whether or not they register on it or not (the "Website User") and, on the other hand, to provide clear and transparent information to the data subjects, through the Website or digital platforms created or managed by pur'ple ("pur'ple Platforms"), namely in relation to:
Through the Privacy Policy, you can also obtain information about your rights regarding the processing of personal data by pur'ple.
The Privacy Policy has been drafted pursuant to the European Union's General Data Protection Regulation, Regulation (EU) No. 2016/269 of 27 April ("GDPR").
It is extremely important that you read this Policy carefully and fully understand its scope. If you have any questions or concerns regarding this Policy, please do not hesitate to contact us through the channels identified in Section 9.
Access to the Website
pur'ple has the exclusive right to, at any given time, suspend, partially or totally, the availability of the Website or access to it, in particular (but not exclusively) during management, maintenance, repair, alteration, or modernization operations. pur'ple may also choose to close, definitively or temporarily, partially, or totally, at any time, the Website or any of the services, without prior notice.
General Use
The Website User must use the Website in a responsible, prudent, and careful manner, and must not disrupt or degrade the continuity, integrity and quality of the Website's features and functionalities, nor must they make any improper use of it, from it and through it, namely, but not limited to, infringing the legislation in force.
pur'ple reserves the right to suspend the availability of the Website and/or prevent access and use of the Website by any Website Users who use it improperly or violate any of the provisions of these Terms and Conditions of Use.
The Website User acknowledges that its use of the Website is at their own risk, and they are solely responsible for any damage caused to their computer system and/or equipment or other damage or loss, including loss of or damage to data, which results from the use of the materials, content or information obtained in any way through the Website.
All intellectual property rights to the Website are the property of pur'ple. All content, texts, images, and sounds, as well as the logos, names, brands, and distinctive signs of the Website are protected by intellectual property rights and are the exclusive property of or licensed to pur'ple.
The Website User is not authorized to: (i) remove or use any indication of intellectual property, including, but not limited to, trademark or other notices regarding PUR'PLE's intellectual property; (ii) reproduce, modify, make derivative works of, destroy, license, rent, sell, resell, transfer, publicly display or present, transmit, reproduce, broadcast, or in any other way exploit the services on this Website, except to the extent expressly permitted by pur'ple; (iii) create links to or reproduce through frames any part of the Website or any content made available on it; (iv) create or launch any programs or scripts to capture, index, collect or otherwise extract data from the Website, or unduly overload and/or render impossible the operation and/or functionalities of the Website; or (v) unauthorized access to the Website or impair any aspect of it.
The Website has been developed considering the interests of our different types of Website Users and the audience of pur'ple's products or services.
pur'ple will not be responsible for any damages, losses and/or losses suffered by the Website User or third parties due to the occurrence of circumstances classified as fortuitous and/or force majeure.
The User of the Website recognizes that the internet constitutes a public network and that, as such, no responsibility can be imputed for damages resulting from the use of the same. Furthermore, pur'ple is not responsible for the incorrect use of the Website and/or its services, nor for losses or damages caused by such incorrect use.
If any provision or part of the current Terms and Conditions of Use is unenforceable or contrary to applicable law, the validity of the remaining terms or conditions shall not be affected. The management, administration, use and enforcement of the Terms and Conditions of Use of the Website is governed by Portuguese law.
The entity responsible for processing personal data is the company pur'ple, Unipessoal, Lda. registered under the single identification and legal person number 514834242, with registered office at Rua do Açúcar, n. º 76, Armazém 4, 1950-009 Lisbon.
pur'ple has a Data Protection Officer, who can be contacted by the owners of the personal data by e-mail to the address: dataprotection@pur-ple.co, or by written communication to the address: Rua do Açúcar, no. 76, Armazém 4, 1950-009 Lisboa.
The Privacy Policy aims to provide information to the data subjects whose personal data pur'ple processes ("Data Subjects"), namely:
For the purposes of this Privacy Policy, ‘personal data’ is considered to be any information that, directly or in combination with other data, can identify a natural person.
By submitting your personal data to pur'ple, we guarantee that we will process it in accordance with this Privacy Policy.
Your personal data will not be used for any purposes other than those identified in the Privacy Policy.
The table below includes a list of the personal data collected by pur'ple from different categories of Data Subjects, depending on the area of activity concerned.
Data Subjects | Personal data collected (non-exhaustive) |
Clients, Clients' employees or business contacts from our Clients;
Potential Clients, employees of Potential Clients, or business contacts from Potential Clients; |
|
Applicants |
|
Website Users and Users of the pur'ple Platforms |
|
pur'ple is not responsible for the veracity, omissions, inaccuracies, and falsities of the personal data transmitted to it.
The personal data collected may be processed by computer and in automated or non-automated form, ensuring in all cases the strict compliance with the legislation for the protection of personal data.
pur'ple, within the scope of its activities, processes personal data for the purposes set out in the table below.
Data Subjects |
Purposes of processing Personal Data |
Legal basis for processing Personal Data |
Period of storage of Personal Data |
Clients, Clients' employees or business contacts from our Clients
Potential Clients, employees of Potential Clients, or business contacts from Potential Clients
|
Provision of the contracted services (including by video call), assistance and customer support |
|
Period necessary for the performance of contractual conditions and/or legal obligations. |
Management of the contractual relationship, including for issuing and collecting invoices for services. |
|
Period necessary for the performance of contractual conditions and/or legal obligations. |
|
Compliance with legal obligations to authorities or other relevant public entities. |
|
Period necessary for the performance of contractual conditions and/or legal obligations. |
|
Quality of service surveys, sending newsletters, sending promotional actions (offers and promotion of products and services) and invitations to events, as well as for direct marketing purposes. |
|
The period of storage is indefinite, and personal data will be kept until the data subject communicates that he or she does not wish to receive communications from pur'ple for the purposes mentioned herein. |
|
Applicants |
Submission of applications for job offers. |
|
Personal data will be kept for a period of three years. |
Spontaneous applications |
|
Personal data will be kept for a period of three years. |
|
Quality of service surveys, sending newsletters, sending promotional actions (offers and promotion of products and services) and invitations to events, as well as for direct marketing purposes. |
|
The period of storage is indefinite, and personal data will be kept until the data subject communicates that he or she does not wish to receive communications from pur'ple for the purposes mentioned herein. |
|
Website Users and Users of the pur'ple Platforms |
Website User Management |
|
Duration of registration on the Website, or up to 3 months after the last visit to the Website (depending on whether the User is registered or not, respectively). |
pur'ple Platform User Management |
|
Duration of registration on the Website, or up to 3 months after the last visit to the Website (depending on whether the User is registered or not, respectively). |
|
Answering requests for clarifications and complaints, in the context of customer support |
|
Period necessary to manage requests for clarification or complaints, in accordance with the applicable legal deadlines. |
|
Performance of the contract for the purchase of products or services subscribed by the Client through the Website or pur'ple Platforms |
|
Period necessary for the performance of contractual conditions and/or legal obligations. |
|
Compliance with legal obligations to authorities or other relevant public entities |
|
Period necessary for the performance of contractual conditions and/or legal obligations. |
|
Quality of service surveys, newsletters, promotional actions (offers and promotion of products and services) and invitations to events, as well as for direct marketing purposes. |
|
Until subscription to the newsletter is canceled or consent is withdrawn. |
|
Surveys conducted on pur'ple platforms. |
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Up to the cancellation of registration on pur'ple Platforms. |
Regarding newsletters, the processing of personal data only begins when the respective data subject submits the subscription form, ending at any time by unsubscribing through a link available in all newsletters sent. By removing the subscription, the Data Subject concerned will receive an email notification confirming the removal of their data from the mailing list of newsletters.
When personal data is processed by pur'ple, under the terms of Section 4 above, based on the performance of a contract to which the Data Subject is a party, or for pre-contractual diligences, under the terms of Article 6.1(b) of the GDPR, pur'ple reserves the right not to enter into a contract or not to provide the services in question, in the event that the Data Subject does not provide the necessary personal data.
All personal data referred to in Section 3 above that are processed based on the performance of a contract to which the Data Subject is a party correspond to personal data that are adequate, relevant, and limited to what is necessary, considering the purpose for which they are processed.
Where personal data is processed by pur'ple, under the terms of Section 4 above, based on the Data Subject's consent, on the grounds of Article 6.1(a) of the GDPR, the Data Subject shall have the right at any time to withdraw his or her consent to the processing of the data, without compromising the lawfulness of the processing carried out under the consent previously given.
Personal data processed by pur'ple, as described in Sections 3 and 4 above, is collected in accordance with the provisions in the table below.
Means of collecting Personal Data |
Examples |
Personal data provided by the Data Subjects |
Personal data may be collected by pur'ple directly from Data Subjects, among others, in the following ways:
|
Data collected through social networks |
pur'ple will process personal data relating to the interaction of the Data Subjects with pur'ple's digital presence on social networks. pur'ple may also collect personal data through public profiles of the Data Subjects on social networks (e.g., LinkedIn), namely for the verification of curriculum vitae, for the purpose of analysis of the suitability for job offers. |
Data collected from third parties |
pur'ple may collect personal data through third parties, namely in the context of the provision of its professional services, or from other third parties (e.g., personal data of employees sent by pur'ple customers, in the context of the services to be provided by the latter). |
Cookies |
The collection of personal data through Cookies will be done in accordance with the Cookie Policy, provided below. |
pur'ple partially processes personal data through automated individual decision-making, including profiling - for the purposes identified above, and always in compliance with applicable personal data protection legislation.
Please be advised that the Data Subject has the right to obtain human intervention from pur'ple regarding the processing of his personal data by automated means, as well as regarding profiling, and to express his point of view and contest the decision.
Which Personal Data processing operations are operated by pur'ple through automated means?
pur'ple proceeds with the automated collection of personal data through the Website as well as through pur'ple Platforms. The processing of personal data through automated means is used:
Consent is always sought from Data Subjects for this effect.
How important are automated decisions and profiling, and what are the consequences of automated decisions for the Data Subject?
Automated decisions and profiling allow the Data Subjects to receive communications from pur'ple, namely quality of service surveys, newsletters, promotional actions (offers and promotion of products and services), invitations to events and direct marketing.
Additionally, automated decisions and profiling allow pur'ple to improve the Data Subjects' experience on the Website and pur'ple Platforms, by viewing personalized content and monitoring their progress throughout the various interactions and comparisons with other users of the Website or pur'ple Platforms with similar profiles.
Specifically, in relation to the Violet Platform, pur'ple will process personal data in an automated manner, including through profiling, with the aim of enabling the Data Subject to make effective use of the well-being surveys made available, providing information in relation to the results and possible measures to be taken.
pur'ple will only process personal data in an automated manner for the purposes set out in this section of the Privacy Policy.
The processing of personal data, through automated decisions, allows pur'ple to provide a better and more adequate service to the needs of each Client, Candidate, Website User or User of the pur'ple Platforms.
What is the logic behind the processing of Personal Data through automated decisions and profiling?
pur'ple intends to improve the experience of Website Users and Users of the pur'ple Platforms, as well as track their progress and allow for comparison with other users with similar profiles.
The Data Subject is guaranteed the right to access his personal data at any time, as well as the right to rectify, delete, portability, limitation and/or opposition to processing.
As the Data Subject, you are also entitled to withdraw your consent at any time. The withdrawal of consent does not compromise the lawfulness of the processing carried out under the consent previously given.
The Data Subject has the right not to be subject to any decision taken solely under automated processing, including profiling. The Data Subject also has the right to obtain human intervention from pur'ple, to express their point of view and to challenge the decision to proceed with data processing by automated decisions and profiling.
The exercise of any of these rights must be done in writing, addressed to pur'ple, either to the address of its head office located at Rua do Açúcar, n.º 76, Armazém 4, 1950-009 in Lisbon, or to the following e-mail address: dataprotection@pur-ple.co
Additionally, Data Subjects may always file any complaints they deem necessary with the competent authority for this purpose (currently the CNPD - Comissão Nacional de Proteção de Dados).
pur'ple is committed to ensuring the security, integrity, and availability of the personal data it collects and processes. To this end, it has adopted the following measures:
pur'ple informs that these security measures will be revised and updated according to the needs and requirements of these matters.
If, for any reason, there is a breach of security that causes, accidentally or unlawfully, the destruction, loss, alteration, unauthorized disclosure of or access to personal data, pur'ple undertakes, under the terms of the applicable legislation, to communicate this to the competent authorities, without undue delay and, whenever possible, within 72 hours of becoming aware of such an occurrence.
Additionally, and in the terms referred to in the previous paragraph, pur'ple undertakes to communicate the violation of personal data to the respective Data Subject.
Whenever pur'ple shares personal data with third parties, it commits, under the terms of the contracts to be executed with the latter, to adopt the necessary and adequate measures to ensure that all entities that have access to such personal data offer high-security guarantees, limiting the communication of the personal data to only to the strictly necessary.
Whenever necessary, and as part of pur'ple's contracting of third parties, personal data may be transferred outside the European Economic Area (the "EEA"), to locations that may not guarantee the same level of protection. However, where applicable, pur'ple will only transfer personal data outside the EEA in accordance with the following measures:
pur'ple may share your personal data, as part of its activity, with the categories of recipients best described in the table below.
Data Subject |
Category of Recipients of Personal Data |
Clients, Clients' employees or business contacts from our Clients
Potential Clients, employees of Potential Clients, or business contacts from Potential Clients
|
pur'ple may, for purposes of legal obligations, share personal data with Public Entities (e.g., Tax Authority).
We may also transfer personal data to our external service providers, such as our (IT) systems providers, our hosting providers, our legal advisers and other providers of goods and services. |
Applicants |
N/A |
Website Users and Users of the pur'ple Platforms |
N/A |
pur'ple will not share your personal data with third parties for the purpose of using that information for direct marketing.
In addition to the above, pur'ple may share your personal data if there is a legal obligation to do so.
pur'ple intends to ensure that Website Users and Users of the pur'ple Platforms have a unique and personalized experience. For this purpose, pur'ple uses cookies.
What are Cookies?
Cookies are very small text files that are stored on the Website User's computer or mobile device when visiting a website.
pur'ple uses cookies for various purposes and to enhance the Website User's online experience on its Website and its Platforms. The Website User can change their preferences and refuse certain types of cookies to be stored on their computer or mobile device while browsing the Website or the pur'ple Platforms.
The Website User may also remove any cookies already stored on their computer or mobile device but deleting cookies may prevent the use of parts of the Website or the pur'ple Platforms.
What type of Cookies are used by pur'ple?
The pur'ple Website and Platforms do not use third-party cookies to provide targeted advertising.
Please contact pur'ple if you want more detailed information about the Cookies used.
What is the basis for pur'ple's use of cookies?
pur'ple will collect explicit consent from Users of the pur'ple Website or Platforms for the use of cookies, in accordance with Directive 2002/58/EC of the European Parliament and of the Council, from 12 July 2022, as per its last amendment.
Google Analytics
To provide visitors with more choice on how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the site visit should not be sent to Google Analytics. The Google Analytics Browser Opt-out Add-on does not prevent information from being sent to the site itself or to other web analytics services. Learn more about Google Analytics Brower Opt-out extra.
pur'ple reserves the right to make amendments to the Terms and Conditions of Use and Privacy Policy at any time, and such changes will be duly posted on the Website.