Privacy Policy

We take data privacy seriously and endorse the new General Data Protection Regulations (GDPR) or other applicable legislation which is built around the principles of transparency and control. Our operations are based in Portugal and Spain, and we have introduced a consistent approach to each office so that you can have the peace of mind of working with us wherever that may be in the world. This notice contains information about your privacy rights and how the law protects you.
This privacy notice will inform you as to how we look after your personal data when you visit our website or social media pages (regardless of where you visit it from) or when you provide personal data to us via alternative channels whether Telephone, Email, WhatsApp, etc).

Please refer to the Glossary that we have set out at the end of the Policy if there is any terminology used that you are unfamiliar with or don’t fully understand.

1. PURPOSE OF THIS POLICY AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. HOW WE DISCLOSE YOUR PERSONAL DATA
6. WHEN WE TRANSER YOUR DATA
7. HOW WE SECURE YOUR DATA
8. HOW LONG WE KEEP YOUR DATA FOR
9. YOUR LEGAL RIGHTS
10. GLOSSARY

/ Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide through this website or via any other means (such as over the telephone or email) when we provide services whether to you or for your benefit, when you sign up to our services.
This website is not intended for children, and we do not collect data in relation to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

/ Data Controller

Participant Experience is the data controller and responsible for your personal data (collectively referred to as “VOQIN’, Participant Experience, VOQIN Viagens e Turismo LTDA, Ole Special Events, Go Biz Viagens e Turismo SA, Seven Events USA LLC or Go Biz Eventos e Comunicação LTDA” “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

/ Contact details

Full name of legal entity: Participant Experience SA
Name or title of data privacy manager: Alexandra Pires
Email address: alexandra.pires@voqin.com
Head office address: Rua Circular Norte do Parque Industrial, 7005-841 Évora, Portugal.
Notwithstanding your legal rights to make a complaint to the Comissão Nacional de Proteção de Dados (National Data Protection Committee), we believe in a collaborative approach to concerns and would appreciate the opportunity to deal with any concerns directly with you first.

/ Changes to the privacy notice and your duty to inform us of changes

This is version One, dated 25th May 2018 and historic versions can be obtained by contacting us.
We want to ensure the data we hold about you is accurate and current and we ask you that keep us informed of changes during the course of your professional relationship with us by contacting.

/ Third-party links

This website may include links to plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

/ Identity Data

This includes data relating specifically to your identity, such as your first name, last name, username or similar identifier, and data that enables us to perform event services with suppliers such as hotels, where passport details of gender is required.

/ Contact Data

This includes data relating to how you may be contacted, such as your postal address, email address, telephone numbers and Skype.

/ Financial Data

This includes data relating to your means and methods of payment, such as your bank account and payment card details.

/ Transactional Data

This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of services you have purchased from us.

/ Technical Data

This includes additional technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, time
zone setting and location, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

/ Usage Data

This includes information about how you use our website and services.

/ Marketing and Communications Data

This includes your preferences in relation to whether you want to receive marketing from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. This may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

/ Special Categories of Personal Data

You may provide us with the following special categories of personal data about you.
Details about your:

/ dietary requirements which may disclose your religious or philosophical beliefs
/ health
/ passport or ID details for travel bookings or certain entrance passes and/or visa
/ issuance support
/ genetic and biometric data

We collect and process the above data only where it is strictly necessary to do so in order to fulfil the terms of a contract we have with you.
Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so (to enable attendance at an event, conference or incentive travel programs).

You are not under any obligation to consent to us processing your sensitive personal data. However, without your permission, we may not be able to fulfil the terms of a contract we have with you. If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time.

/ If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract, we have with you and you fail to provide that data when requested, we may not be able to fulfil the contract we have or are trying to enter into with you.

We use different methods to collect data from and about you including through:

(A) Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, by completing online registration forms or otherwise. This includes personal data you provide when you:

/ request that we provide services or information to you
/ register on our website
/ complete online job applications, including registering as a freelance specialist
/ provide us with feedback

(B) Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details:
https://www.voqin.com/cookies-policy

(C) Third parties

We may receive personal data about you from various third parties as set out below:

Identity Contact and Financial Data from publicly availably sources such as Registro Comercial and the Comissão Nacional de Eleições based inside the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

/ Where we need to fulfil the contract, we are about to enter into or have entered into with you.
/ Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
/ Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

/ Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at data.protection@voqin.com . If you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

/ Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing communications.

/ Promotions offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and services may be relevant for you (we call this marketing).
You will receive email marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

/ Third-party marketing

We do not share personal data with any company outside Participant Experience for marketing purposes.

/ Opting out 

You can ask us to stop sending you marketing messages at any time by contacting us at any time either through the unsubscribe button on our email or via email to: data.protection@voqin.com. Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of provision of services to you or other such transactions.

/ Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by email: data.protection@voqin.com
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

/ Internal Third Parties as set out in the Glossary.

/ External Third Parties as set out in the Glossary.

/ Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Most of our third parties are based within Portugal and Spain, however occasionally we may have to transfer your data outside of these countries. These suppliers assist us in providing services to you. We therefore operate within the framework of GDPR or equivalent applicable legislation and we rely on the derogation under Article 49 of the GDPR to transfer data to those countries outside the EAA (as the transfer relates to the services provided to you in the contract for your benefit) and hereby you give your permission for the same. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.

For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

/ We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

/ Where we use certain service providers, we may use specific contracts approved the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

/ Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us by email at: data.protection@voqin.com. if you require further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality through Non-Disclosure Agreements (NDA) with us.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal and any other data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers for legal and tax purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
After an appropriate period, all such data is destroyed.

Under certain circumstances, you have rights under data protection laws in relation to
your personal data summarized as:

/ Request access to your personal data.

/ Request correction of your personal data.

/ Request erasure of your personal data.

/ Object to processing of your personal data.

/ Request restriction of processing your personal data.

/ Request transfer of your personal data.

/ Right to withdraw consent.

/ If you wish to exercise any of the rights set out above, please contact us by email to: data.protection@voqin.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

/ What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

/ Time limit to respond

We try to respond to all legitimate requests within 4 weeks. Occasionally it may take us longer than that if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

/ Lawful Basis

/ Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us by email to: data.protection@gmail.com

/ Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

/ Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

/ Third Parties

Internal Third Parties

/ Other companies in Participant Experience acting as joint controllers or processors and who are based in Portugal and Spain.

External Third Parties

/ Service providers acting as processors based in Portugal or Spain who provide an event registration service, assist with group travel bookings and recruitment services.
/ Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Europe who provide consultancy, banking, legal, insurance and accounting services.
/ Local Revenue & Customs authorities, regulators and other authorities acting as processors or joint controllers based in Portugal, Spain, Brazil or Florida (USA) who require reporting of processing activities in certain circumstances.

/ Your Legal Rights

You have the right to:

/ Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

/ Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

/ Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing
(see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

/ Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

/ Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

/ if you want us to establish the data’s accuracy;

/ where our use of the data is unlawful, but you do not want us to erase it;

/ where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;

/ you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

/ Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

/ Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

This privacy policy is agreed and forms the basis of our working practices and environment.