In terms of general principles regarding the processing of personal data, Sixfold studio ensures that the Personal Data it processes is:

• a) Object to illicit, loyal, and transparent processing regarding the Holder;
• b) Collected for specific purposes, explicit and legitimate, not being processed later in an incompatible way for those purposes;
• c) Suitable, relevant, and limited to the required, relatively to the purposes to which they are processed for;
• d) Exact and updated when needed, adopting appropriate measures so that the inaccurate data is deleted or rectified immediately, considering the purposes, which they are processed for;
• e) Preserved in a way that allows identifying the Holder, only during the required period for the purposes which they are processed for;
• f) Processed in a manner that ensures its security, including protection against unauthorized or illicit processing and against loss, destruction, or accidental damage, taking appropriate technical and organizational measures.

Data processing by Sixfold studio is lawful when at least one of the following situations applies:

• a) The Holder has given his explicit consent to the processing of Personal Data for one or more specific purposes;
• b) The processing is necessary for the execution of a contract to which the Holder is a party, or for pre-contractual steps at the request of the Holder;
• c) The processing is necessary for compliance with a legal obligation to which Sixfold studio is subject;
• d) The processing is necessary in order to protect the Holder’s vital interests or of another natural person;
• e) Processing is required for the purposes of the legitimate interests pursued by Sixfold studio or a third party (except where the interests or fundamental rights and freedom of the Holder require protection of personal data).

Sixfold studio commits itself to ensure that Personal Data is processed only under the conditions listed above and with respect for the principles mentioned above. When Sixfold studio carries out the processing of Personal Data, based on the Holder's consent, he has the right to withdraw his consent at any time, without compromising the lawfulness of the processing conducted by Sixfold studio based on the consent previously given by the Holder.

Sixfold studio collects and processes Personal Data with the following aims:

• a) Management of the recruitment and selection process;
• b) Management of the Contractual Relation with the Holder;
• c) Use of the Holder’s image within the scope of marketing activities, and corporate events, through any media;
• d) Security of Sixfold studio’s Facilities/Systems.

Under applicable legal terms, Sixfold studio may transmit or communicate the Personal Data to other entities where such transmission or communication is necessary for the execution of the contract between the Holder and Sixfold studio or for pre-contractual diligences, where it is necessary for compliance with a legal obligation to which Sixfold studio is subject or where it is necessary for the purposes of pursuing the legitimate interests of Sixfold studio or a third party (for example, in the event of the sale or transfer of all or part of Sixfold studio or its assets between entities owned by or related to Sixfold studio). In the event that we transfer Personal Data to a third party, we will use reasonable efforts to ensure that the transferor uses the transferred Personal Data in accordance with the Privacy Policy.

Sixfold studio may collect data directly from the Holder or through partner entities or third parties.

The Personal Data processed may vary according to the reason that originates its processing as well as its preservation periods, which will be identified according to the specific purpose. In each case, Sixfold studio will inform the Holders of the purposes for which the collected data is intended, being as such the Entity responsible for the processing of Personal Data as well as for the compliance with this Privacy Policy.

In the context of the processing of Personal Data, Sixfold studio may use third parties, subcontracted by itself, to process Personal Data, on its behalf and according to its instructions, in strict compliance with the provisions of the law and this Privacy Policy.

These subcontracted entities may not transmit personal data to other entities without prior written authorization from Sixfold studio and are also prevented from contracting other entities unless previously authorized by Sixfold studio.

Sixfold studio undertakes to subcontract only entities that provide sufficient guarantees for the implementation of appropriate technical and organizational measures in order to ensure the protection of the Holder’s Rights.

On the other hand, Sixfold studio uses the services of subcontractors in the development of some specific projects assuming the commitment to regulate and communicate to such persons, the subject matter and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties.

To ensure personal data security and the maximum confidentiality, we process the information that is provided to us in an absolute confidential manner, in accordance with our policies, internal safety and confidentiality procedures, which are periodically updated according to the needs, as well as in accordance with the terms and conditions legally foreseen.

According to the nature, of the scope, the context, and its purposes in processing data, as well as the resulting risks for the Holder’s rights and freedom, Sixfold studio undertakes to apply, the necessary and adequate technical and organizational measures to protect personal data and fulfil the legal requirements.

Regarding general measures, Sixfold studio adopts the following:

• a) Awareness and training of personnel involved in the operations of data processing;
• b) Security protocol implementation (1 - Pseudonymization and personal data encryption, when necessary; 2 - Mechanisms capable of ensuring confidentiality, availability, and resiliency of information systems; 3 - Security procedures to ensure confidentiality and safety of the physical registers where is personal data);
• c) Mechanisms that ensure the re-establishment of information systems and access to personal data in a timely manner in case of a physical or technical incident – backups.

In certain types of processing, personal data, collected by Sixfold studio may be made available to third parties that can involve its transfer out of the European Union. In this case, Sixfold studio undertakes to guarantee that the transfer follows the applicable laws, namely in determining the adequacy of the country in relation to the protection of personal data and the applicable requirements of such transfers.

When visiting our Site/Application, you will be asked to give your consent to create and save a text file (Cookie) in your computer. This file will allow you to access the site/application more easily and quickly, as well as customize it according to your preferences. Most browsers accept these files (Cookies) but the Holder may delete them or automatically define its blocking. In the menu "Help" of the browser, you will find how to make the settings. However, if the use of cookies is not allowed, there may be some functionalities from the site/application that you cannot use.

What are cookies: Cookies are small text files that are stored by a website on the user's computer or mobile device when visited, through a browser. The storage of cookies will help the website to recognise your device on your next visit. Cookies also collect generic information, namely how users arrive and use the website or the part of the country/countries through which they access the website, etc. Cookies only store information related to your preferences. By refusing the use of cookies on the website, you may not be able to access some of its areas or receive personalised information.

What are cookies for: Cookies are used to help determine the usefulness, interest, and number of uses of the website, enable faster, more efficient browsing and avoid the need to enter the same information several times.

What type of cookies do we use:

• a) Essential cookies – these allow you to navigate around the website and use its applications, as well as access secure areas of the website. Without these cookies, the services you have requested may not be provided;
• b) Analytical cookies - These are used anonymously to create and analyse statistics to improve the functioning of the website. For example, we use performance cookies to learn which pages users visit most often, or which method of linking pages is most effective, without ever collecting personal information;
• c) Functionality cookies - These store the user's preferences regarding the use of the website, so that they do not need to reconfigure the website each time they visit;
• d) Third Party Cookies - We sometimes use external services on our website to display content on our web pages. For example, to provide images and videos. In these cases, we cannot prevent the collection of usage information from our visitors when they access this content embedded on our website.

Cookies can be:

• a) Permanent cookies - These are stored at the browser level on your access devices and are used every time the user visits the website;
• b) Session cookies - These are temporary, they remain in the browser cookies until you leave the website. The information obtained allows identifying problems and providing a better browsing experience All browsers allow you to accept, refuse or delete cookies, namely by selecting the settings in your browser.
• c) Functionality cookies - These store the user's preferences regarding the use of the website, so that they do not need to reconfigure the website each time they access the website

We remind you that deactivating cookies may prevent some web services from working correctly, affecting, partially or totally, navigation on the website.

In the applicable legal terms, Sixfold studio has the duty to ensure and promote the Personal Data Holders’ rights, which was collected and processed by Sixfold studio.

Personal data Holders have the right to be informed about the data collected, and the purposes and means for which they are processed.

The Holder has the right to request to see what Personal Data Sixfold studio holds about him or her, the purpose of the processing and the categories of data concerned.

Sixfold studio shall notify the Holder of the recipients with whom it will share his data, where this is not a result of a legal obligation, especially if the recipient is in another country or belongs to an international organization.

The Data Holder has the right to object to the processing and the right to rectification and erasure.

The Holder has the right to complain to the CNPD - Comissão Nacional de Proteção de Dados.

When data is collected through someone other than the Holder itself, it should be possible for Sixfold studio to communicate the source of that data to the Holder itself.

Sixfold studio guarantees to have in place measures and procedures to identify and respond to access queries by the Holder without undue delay and within one month at the latest.

Data Holders have the right to have inaccurate data rectified, and Sixfold studio will make every effort to do so immediately.

The holder has the right to obtain from the person responsible for processing the erasure of his or her data ("right to be forgotten"). It is Sixfold studio's responsibility to do its best to promptly delete the personal data it processes, except when there is a legal requirement for its retention.

All individuals, including children, are protected by the GDPR, so in the case of children, their Personal Data will be processed with the consent of the respective holders of parental responsibilities.

Personal Data is processed and used for other purposes only when consent exists. The Holder is entitled at any time to withdraw consent to the processing of his Personal Data. It should be noted, nevertheless, that such withdrawal of consent does not affect the lawfulness of the processing carried out based on the consent.

The Data Holder has the right to be informed of any violations to his rights, without undue delay. Such violations may consist, namely, of improper access to Personal Data, Personal Data processing for different purposes to which was given consent or that is legally admissible, safety breaches in the systems where the data is saved, or Personal Data deletion.

Note that, under legal terms, communication to the Holder is not required in the following cases:

• a) In the event of Sixfold studio having applied suitable protection measures, both technical and organizational, and those measures have been applied to Personal Data, which was affected by Personal Data’s violation, especially measures that make the data incomprehensible to any unauthorized person that accesses this data, such as encryption;
• b) If Sixfold studio has taken subsequent measures to ensure that the high risk to the Holder's rights and freedom is no longer likely to materialize;
• c) If communicating with the Holder implies a disproportionate effort on the part of Sixfold studio. Then, Sixfold studio will make a public communication or take a similar measure through which the Holder will be informed.

The Data Holder is entitled to lodge a complaint with the national supervisory authority CNPD - Comissão Nacional de Proteção de Dados, or possibly a judicial authority, if he/she considers that his/her rights as a Holder have been violated.

The Holder may exercise the right of access, the right of rectification, the right of erasure, the right of limitation, the right of portability and the right of opposition, by contacting Sixfold studio at: dpo@sixfoldstudio.com

Sixfold studio will respond in writing (including by electronic means) to the Holder's request within a maximum period of one month from receipt of the request, except in cases of special complexity, where this period may be extended up to two months.

If requests submitted by the Holder are manifestly unfounded or excessive, namely due to their repetitive nature, Sixfold studio reserves the right to charge administrative costs or refuse to act on the request.

In order to ensure the full enjoyment of the right to information, Sixfold studio has implemented the procedural mechanisms to provide information regarding the collection of personal data.

Sixfold studio processes its data only for the time required for the purposes for which they were collected and at the end of that period, the data are deleted or irrevocably anonymized.

Sixfold studio reserves the right to change the present Privacy Policy at any time. In case of any change in it, such information will be made available in an accessible manner to the Holder.

In case the Holder wishes to ask any questions or make complaints related to the Privacy Policy, he may do so through the email: dpo@sixfoldstudio.com

The Privacy Policy, as well as the collection, processing, or transmission of Personal Data, is governed by the European Parliament and of the Council Regulation (UE) 2016/679, of April 27, 2016 and by the Laws 58/2019 and 59/2019, both of August 8.

Any legal disputes arising from the validity, interpretation, or execution of the Privacy Policy, or that are related to the collection, processing or transmission of Personal Data, shall be submitted exclusively to the jurisdiction of the judicial courts of the district of Porto, without prejudice to the applicable mandatory legal regulations.