Privacy Policy

This is an English translation of the Portuguese original. In the event of any discrepancy between the two versions, the Portuguese version prevails. Read the Portuguese original (PDF).

1. General Privacy Statement

(a) The following Privacy Policy (the "Privacy Policy") sets out our policy for the processing of your personal data which we collect on

• our website at www.mdist.pt (the "Website"); and on the
• page associated with the social networks www.facebook.pt and www.twitter.pt (the "Social Networks") (collectively, the "Sites").

Personal data is information relating, directly or indirectly, to you as a natural person ("Personal Data").

(b) M DIST DIRECT, Lda., a private limited company registered with the Conservatória do Registo Comercial de Leiria (the Leiria Commercial Registry Office) under the single registration and legal person identification number 515603481, with a share capital of € 5.000,00 and registered office at Beco do Brejo S/N, Cave, Lagoeiros Marrazes 2415-315 Leiria, is the data controller (within the meaning given by 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, repealing Directive 95/46/EC (hereinafter referred to as the "General Data Protection Regulation"), responsible for the processing of your Personal Data in relation to the Sites (hereinafter referred to as "we", "us" and "our").

(c) You may access this Privacy Policy by clicking on a link entitled "Privacy Policy" located at the bottom of each page of the Website. We ask that you read this Privacy Policy carefully.

(d) You may browse our Sites, learn exciting information while visiting them and share content with others. You may also create an account to access all the Sites connected to the Interaction Database of the companies of the M DIST DIRECT Group and take part in promotions. To find out how we use your Personal Data when you register an account, please consult this privacy policy https://mdist.pt/uploads/ mdist-politica-de-privacidade.

This Privacy Policy applies to all users of our Sites, whether registered or not.

2. What personal data do we collect about you?

a) The personal data that we collect and process about you

We collect and process the following information about you:

• Surname;
• First name;
• Sex;
• Date of birth;
• Username;
• Postal address;
• Telephone number (including home and mobile numbers);
• Email address;
• Public profile on the Social Networks: name, pseudonym, photographs, "likes", location, other public profile information;
• Content created by the user on the Social Networks: photographs, texts, videos, symbols, hashtag records that you share on the Social Networks;
• Location Information;
• Browser and device information: IP address, MAC address, Google Ad ID, Identifier for Advertisers (device ID);
• Server log file information;
• Personal Data activity/engagement (for example, date and time of the activity on the relevant Sites, number of times a Site is visited, which items are clicked).

(b) We ask that you do not send us or disclose any Sensitive Information through the Sites or in any other way.

"Sensitive Information" means Personal Data relating to sensitive aspects, such as: • racial or ethnic origin,

• political opinions,
• religion or other beliefs,
• health or medical condition,
• criminal record,
• trade union membership,
• sexual orientation.

3. How do we collect your Personal Data?

We collect your Personal Data as follows:

• Through the Sites: We collect Personal Data through the Sites.
• Offline: We collect Personal Data from you offline, such as, for example, when you contact customer support;
• When you download the Application: when you download and use the Application, we track and collect its usage data, such as, for example, the date and time at which it, on your device, accesses our servers and what information and files were downloaded to the Application, based on your device number;
• Physical location: we collect the physical location of your device, for example, through satellite, mobile phone mast or wireless local network signals;
• Through cookies: we collect your Personal Data when you browse the Sites, through cookies. Our collection and processing of your personal data through cookies is governed by the Cookie Policy https://mdist.pt/uploads/mdist-politica-de-cookies_2023-10-03-150317_cixh, which you should read very carefully. You may refuse cookies withdraw (save for the Strictly Necessary Cookies defined in the Cookie Policy) by email, by telephoning us or by writing to us using the contact information set out in section 9 of this Privacy Policy.

The Personal Data that you provide on the Sites is combined with Personal Data and other Information that you provide to us (by online and offline means) or that we otherwise obtain online or offline.

4. How do we use your Personal Data?

We use your Personal Data for the following purposes:

(a) Responding to your requests/Administrative interactions

• To respond to your requests for information, questions and comments and to fulfil your requests.
• Order processing;
• Communication with customers and clarification of queries;
• Processing of requests for information;
• Processing of complaints;
• Statistical analysis activities;
• Verifying, maintaining and developing systems and statistical analyses;
• Direct marketing communications (where you have consented to the processing of your personal data for this purpose);
• Prevention of and action against fraud;
• Requesting comments on products or services purchased;
• Carrying out satisfaction surveys.
• Management of and participation in events, competitions and campaigns.

Legal basis for the processing: our legitimate interests in responding to your questions.

• To send you administrative information, such as, for example, information relating to the Sites, changes to our terms and conditions and changes to this Privacy Policy.

Legal basis for the processing: our legitimate interests in informing you about the development of our Sites, the changes to our terms and conditions and the changes to this Privacy Policy, in a timely manner.

(b) Data analyses using the public profile of your Social Networks and shared content

• We collect your Personal Data to assess your engagement with our Social Networks and to analyse your interests. Specifically, we collect the content that you share on the Social Networks and your public profile on the Social Networks, in order to analyse this information and infer consumption trends and patterns. This helps us to know our Social Network users better, what they like, how they react to our products, services and content. By knowing the users of our Social Networks better, we can adapt our Sites to their identified preferences, but likewise, more generally, improve M DIST DIRECT products and services.

Legal basis for the processing: your consent

You may withdraw your consent to the collection and use of your Personal Data for the purposes mentioned above by email, by calling us or by writing to us, using the contact information set out in section 9 of this Privacy Policy. Once your consent has been withdrawn, we will cease processing personal data for the purpose in question.

(c) Data analyses relating to your activity on the Sites

• We collect your Personal Data, including location data, to measure your engagement on the Sites (for example, to know how you use them, how often you use them, with which device, how long you stay there, which items you click) and to infer consumption trends and patterns from this analysis. This helps us to know the users of our Sites better and to adapt them to the identified preferences of users, but likewise, more generally, to improve M DIST DIRECT products and services.

Legal basis for the processing: your consent

You may withdraw your consent to the collection and use of your Personal Data for the purposes mentioned above by email, by calling us or by writing to us, using the contact information set out in section 9 of this Privacy Policy. Once your consent has been withdrawn, we will cease processing personal data for the purpose in question.

(d) Storing and sharing the content that you publish on the Social Networks • You may share content on our Social Networks, such as, for example, photographs of yourself, texts, hashtag records, videos and recordings. When you communicate that content on our Social Networks, we may decide to share some of this content (and your public profile on the Social Networks) on our Sites, in the context of marketing campaigns and, more generally, to present and highlight M DIST DIRECT products and services on our Sites. When we do so, we store your Personal Data in the Interaction Database of the M DIST DIRECT Consumer Centre.

Legal basis for the processing: your consent

You may withdraw your consent to the collection and use of your Personal Data for the purposes mentioned above by email, by calling us or by writing to us, using the contact information set out in section 9 of this Privacy Policy. Once your consent has been withdrawn, we will cease processing personal data for the purpose in question.

(e) IT administration

• We use your Personal Data to diagnose problems with the server, to administer the Sites and to confirm whether they are working properly.

Legal basis for the processing: our legitimate interests in administering our IT systems and networks, in order to ensure the proper functioning of the Sites.

(f) Compliance with our legal obligations

• To comply with our legal obligations, legal proceedings or orders of governmental authorities, which may include orders of governmental authorities outside your country of residence, where we reasonably believe that we are legally obliged to do so and that the disclosure of your Personal Data is strictly necessary to comply with those legal obligations, proceedings or government orders.

Legal basis for the processing: compliance with our legal obligations.

(g) Legal protection of our interests

• To legally enforce our terms and conditions, protect our operations or those of our affiliates, protect our rights, privacy, security or property and/or those of our affiliates and so that we may invoke legal remedies or limit the damage that we may suffer. Legal basis for the processing: our legitimate interests in legally protecting our company.

(h) Company operations/M&A

• To carry out any reorganisation, merger, sale, joint venture, assignment, transfer or other disposal of all or any part of our company, assets or inventory (including in connection with any bankruptcy or similar proceedings).

Legal basis for the processing: our legitimate interests in developing our business strategy.

5. What profiling do we carry out?

(a) We use your Personal Data to carry out scoring and profiling, in an automated manner, with the help of Google UID. This scoring and profiling is carried out in order to achieve the following purposes described in section 4 of the Privacy Policy: (i) Data analyses relating to your activity on the Sites and (ii) Data analyses using the public profile of your Social Networks and shared content.

(b) This profiling has no legal consequences for you, nor any effects on your experience on the Sites. It does not in any way involve any monitoring or tracking of your individual behaviour, action or movement. It is used only to help us to know better the preferences and behaviours of the users of the Sites in general and, from this analysis, to improve the Sites, as well as M DIST DIRECT products and services.

6. Third party sites/third party service providers

This Privacy Policy does not address, and we accept no responsibility for, the processing and data protection practices of any third parties, including any third party operating any site containing a link to these Sites. The inclusion of any link on the Sites does not imply any endorsement of the linked site by us or by our affiliates.

We have no control over, and accept no responsibility for, the use or disclosure by these third parties of your Personal Data, nor do we support those third parties or endorse their websites. We make no representation as to the accuracy, completeness, timeliness or adequacy of the information in those third parties' own privacy policies. It is your responsibility to read carefully the privacy policies on third party websites before using them

7. Third party advertising relating to suppliers

Please note that our suppliers relating to online and email advertising may use "pixel tags", ”web beacons”, "clear GIFs" or other similar technologies, in connection with the Sites, to help manage their online and email advertising campaigns and to enhance their effectiveness. For example, if a supplier has placed a unique cookie on your computer, it may use "pixel tags", ”web beacons”, "clear GIFs" or other similar technologies to recognise the cookie during your visit to the Sites, and to learn from which online advertisements you made purchases on our Sites, and the supplier may provide us with other information for our use. Please note that we may link that other information, provided to us by our suppliers, to the Personal Data about you collected previously.

We may use third party advertising companies to serve advertisements for our Sites. These companies may use information (not including your name, address, email address or telephone number) about your visits to the Sites in order to serve advertisements about products and services of interest to you.

8. What are your rights with regard to the processing of your Personal Data, how can you exercise them and how can you contact us?

(a) Your rights with regard to the processing of your personal data

You have the right to:

• receive a copy of any Personal Data that we hold about you;
• ask us to update or correct any incorrect Personal Data or to complete any incomplete Personal Data;
• ask us to suspend the processing of your personal data for direct marketing purposes.

You also have the right, in certain circumstances:

• to object to the processing of your personal data;
• to ask us to erase your Personal Data;
• to restrict our processing of your personal data; and
• to ask us to transmit to you some of your Personal Data or to transfer it or arrange for its transfer to another data controller.

(b) The exercise of your rights

Should you wish to exercise any of your rights referred to above, you may contact us through one of the options below.

• You may send us an email to the following address [email protected]
• You may call us on: 244 815 036
• You may write to us at the following postal address: Beco do Brejo S/N, Cave, Lagoeiros Marrazes 2415-315 Leiria

(c) Right to lodge a complaint with the competent data protection authority

You have the right to lodge a complaint with the relevant supervisory authority (in particular in the Member State of your habitual residence, place of work or of the alleged infringement), should you believe that any of your Personal Data has been processed in a manner that constitutes an infringement of EU General Data Protection Regulation no. 2016/679, dated 27 April 2016.

9. For how long do we retain your Personal Data?

(a) It is our intention to keep your Personal Data accurate and up to date. We will erase the Personal Data that we hold about you when it is no longer necessary.

(b) We retain your Personal Data, which we use for the purposes described in this Privacy Policy, for a maximum period of two years, unless a longer or shorter period applies by virtue of legal requirements.

(c) To find out for how long we retain cookies on your terminal equipment, please consult our Cookie Policy https://mdist.pt/uploads/mdist-politica-de-cookies_2023-10-03-150317_cixh

10. Use of the Sites by minors and notice to parents

(a) The Sites are directed at natural persons aged 14 or over, with parental consent up to the age of 16. We ask that other natural persons under 14 years of age do not provide Personal Data through the Sites. We reserve the right to require, at any time, proof of parental consent, in order to permit the processing of Personal Data relating to minors.

(b) On some Sites, there may be age restrictions, based on what is appropriate for certain ages or what is legally permitted. Where specific age restrictions apply, this will be unequivocally marked on the Site in question, and we may ask you to confirm your age before proceeding with the processing.

11. What transfers of Personal Data do we carry out outside the European Economic Area?

In order to pursue the purposes described in this Privacy Policy, we may transfer your Personal Data to Third Countries which do not guarantee an adequate level of protection, such as, for example, the United States. In this case, our data transfers are subject to the following appropriate safeguards, in accordance with the provisions of the GDPR, in order to ensure that your Personal Data is adequately protected:

• Standard data protection clauses adopted by the EU Commission, under Article 46, paragraph 2, of the GDPR (click here to access the EU Commission decision on standard contractual clauses, for transfers to data processors established in Third Countries); and
• EU-United States Privacy Shield, for transfers to entities located in the United States (click here to access the EU Commission decision in relation to the EU-United States Privacy Shield).

To obtain any relevant information relating to any transfers of your Personal Data to Third Countries (including the relevant transfer mechanisms), please contact us at this address [email protected].

12. Applicable law

This Privacy Policy is governed by and shall be interpreted in accordance with Portuguese law and any other mandatory provisions of the law applicable in the European Union.

13. Updates to this Privacy Policy

(a) You can find out when this Privacy Policy was changed by consulting the "LAST REVISED" notice at the top of this page.

(b) All contemplated changes to this Privacy Policy will be communicated to you well in advance of their entry into force.

You may print, download or otherwise retain a copy of this Privacy Policy (and of any revised version) for your records.