Privacy Policy

1. Introduction and Data Controller

Global Memorandum ("we", "us", "our") operates the website GlobalMemorandum.info and provides career transition programmes in Portugal. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation — GDPR) and applicable Portuguese data protection legislation, including Law No. 58/2019 of 8 August 2019.

The data controller responsible for your personal data is:

Global Memorandum
Edifício, R. Soeiro Pereira Gomes, Andar 11
1600-024 Lisboa, Portugal
Email: [email protected]
Phone: +351 910 409 560

2. Personal Data We Collect

We collect personal data in the following circumstances:

2.1 Contact Form Submissions

When you submit our contact form, we collect: your full name, email address, telephone number, and the content of your message. You may also voluntarily provide information about your current or previous industry.

2.2 Programme Participation

When you participate in our career transition programmes, we collect additional information necessary to deliver the programme, including professional background information you provide during the programme process.

2.3 Website Usage Data

If you consent to analytics cookies, we collect anonymised information about how you use our website, including pages visited, time spent on pages, and general geographic location (country/city level). This data does not identify you personally.

2.4 Cookie Data

We use cookies as described in our Cookie Policy. Essential cookies are used without consent; other cookies require your explicit consent.

3. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 GDPR:

• Consent (Article 6(1)(a)): When you submit our contact form and tick the privacy consent checkbox; when you accept non-essential cookies.
• Legitimate Interests (Article 6(1)(f)): For essential website functionality and security; for responding to enquiries where you have initiated contact.
• Contract Performance (Article 6(1)(b)): When processing data necessary to deliver programme services you have engaged with.
• Legal Obligation (Article 6(1)(c)): Where processing is required to comply with applicable legal obligations.

4. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To respond to your enquiries and provide information about our programmes
• To assess whether our programme is appropriate for your situation
• To deliver career transition programme services to participants
• To maintain records of our business activities as required by law
• To improve our website and services (where you have consented to analytics)
• To comply with our legal obligations

We do not use your personal data for automated decision-making or profiling in ways that produce legal or similarly significant effects.

5. Data Sharing and Third Parties

We do not sell your personal data to third parties. We do not share your data with recruitment agencies or employers. We may share data with:

• Service providers: Third-party providers who assist with website hosting, email services, and similar operational functions, acting as data processors under appropriate agreements.
• Legal authorities: Where required by law, court order, or regulatory authority.

Any third-party service providers are required to process your data only on our instructions and in accordance with GDPR.

6. International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). Where any transfer outside the EEA is necessary, we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR, including Standard Contractual Clauses where applicable.

7. Data Retention

We retain personal data for the following periods:

• Contact form enquiries: Two years from the date of submission, unless you become a programme participant.
• Programme participant data: Five years from the completion of the programme, to fulfil legitimate business and legal record-keeping requirements.
• Analytics data: Anonymised analytics data may be retained for up to twenty-six months.
• Cookie consent records: Twelve months from the date consent was given or withdrawn.

After the applicable retention period, personal data is securely deleted or anonymised.

8. Your Rights Under GDPR

You have the following rights in relation to your personal data:

• Right of access (Article 15): You may request a copy of the personal data we hold about you.
• Right to rectification (Article 16): You may request correction of inaccurate or incomplete personal data.
• Right to erasure (Article 17): You may request deletion of your personal data in certain circumstances.
• Right to restriction of processing (Article 18): You may request that we restrict processing of your data in certain circumstances.
• Right to data portability (Article 20): You may request your data in a structured, machine-readable format where processing is based on consent or contract.
• Right to object (Article 21): You may object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within one month of receiving your request.

9. Right to Lodge a Complaint

If you believe we have processed your personal data in breach of applicable data protection law, you have the right to lodge a complaint with the Portuguese supervisory authority:

Comissão Nacional de Proteção de Dados (CNPD)
Rua de São Bento, 148-3.º
1200-821 Lisboa
Website: www.cnpd.pt

We encourage you to contact us first at [email protected] so we can address your concern directly.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage. These measures are reviewed and updated regularly. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of our website after any changes constitutes acceptance of the updated policy.

12. Contact

For any questions about this Privacy Policy or our data processing practices, please contact us:

Email: [email protected]
Phone: +351 910 409 560
Post: Global Memorandum, Edifício, R. Soeiro Pereira Gomes, Andar 11, 1600-024 Lisboa, Portugal