Privacy Policy

1. IDENTIFICATION OF THE DATA CONTROLLER

Entity: TOPICS CHAT PORTUGAL, LDA (hereinafter, "TOPICS")

NIPC: 518288714

Headquarters: Rua Dr. Joaquim Pires de Lima, n.º 271, 4200 - 350 Porto, Portugal

Telephone contact: +351938369617

Email: info@topicschat.com

2. WHAT IS THIS POLICY ABOUT?

This Privacy Policy explains how we collect and process personal data that is necessary for the provision of services that are available through the Application and describes the practices adopted for that purpose.

3. WHAT ARE PERSONAL DATA?

Personal data shall mean all information relating to an identified or identifiable individual, whatever the nature and support of the information, including sound and image of the individual.

An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to other factors specific to his physical, physiological, mental, economic, cultural or social identity.

4. HOW DO WE USE YOUR PERSONAL DATA?

The personal data processing operations that we carry out are an essential tool for your satisfaction and for the activity of TOPICS and are performed in accordance with applicable law and best practices.

Your personal data will not be reused for other purposes that are not previously identified or that have no connection with those purposes for which they were initially collected.

5. WHAT ARE THE PURPOSES, LEGAL BASIS AND RETENTION PERIODS FOR THE DATA COLLECTED?

The personal data we process has specific bases, depending on the purposes for which they are intended, and will be kept for the time necessary for the respective purposes, as listed in this Privacy Policy.

The Application may request users to provide their gender for specific features that require enhanced identity matching, or verification purposes. This data is required for core usage and is collected only where strictly necessary.

The personal data collected are only those necessary and appropriate for the purposes indicated.

The following table shows the purposes of processing and data collected for these purposes, the respective grounds and the periods or criteria for storing data:

PURPOSELEGAL BASISCOLLECTED DATARETENTION PERIODTo follow up your user registration in the Application and allow you to use its features.Need to take steps at the request of the data subject prior to entering into a contract.Name, date of birth, phone number, email, password.For as long as you are registered as a user and still wish to use the respective services of the Application and up to 1 year after the last access.To store your account details in the reserved area.Need to take steps at the request of the data subject prior to entering into a contract.Name, date of birth, phone number, email, user code.For as long as you are registered as a user and still wish to use the respective services of the Application and up to 1 year after the last access.To analyze and respond to your messages, user support and requests for information.Consent for this specific purpose.Name, date of birth, phone number, email.1 yearTo keep track of your contact details.Consent for this specific purpose.Name, phone number, email1 yearTo follow up on your online purchase.Need to take steps at the request of the data subject prior to entering into a contract and performance of a contract.Name, date of birth, phone number, email, location, NIF, Banking details.For the period necessary for the performance of the contract.For Application management operations.Consent for this specific purpose (cookies); Legitimate interests pursued by TOPICS.IP address, Cookies.Cookie retention period.For commercial purposes, such as data analysis, audits.Consent for this specific purpose (cookies); Legitimate interests pursued by TOPICS.IP address, Cookies.Cookie retention period.For fraud prevention and information systems security.Legitimate interests pursued by TOPICS.IP address, Cookies.Cookie retention period.To adapt, improve and modify services, in particular by identifying usage trends, or to determine the effectiveness of promotional campaigns.Consent for this specific purpose (cookies); Legitimate interests pursued by TOPICS.IP address, Cookies.Cookie retention period.To communicate the expansion of TOPICS' commercial activities, excluding direct marketing.Legitimate interests pursued by TOPICS.Name, phone number, email.2 years.

If the law provides for a specific or mandatory period, the data will be kept for that period. In all other cases, personal data will be kept for a maximum of the times indicated above, periods that the TOPICS considers sufficient to fulfil the purposes.

At the end of the conservation period, all personal data collected will be deleted.

6. HOW DO WE COLLECT YOUR PERSONAL DATA?

We will collect your personal data through the forms on the Application, but also through the Application and the communication that it makes with your device and email messages that you send us.

Your personal data is collected through your equipment as follows:

• (a) Through your browser

• (b) Through cookies

• (c) Through pixel tags and other similar technologies

• (d) IP Address

• (e) Through your User details

TOPICS is committed to process your data lawfully and legally.

TOPICS will not sell, rent or share your personal data with third parties, except as clearly identified in this Privacy Policy (see Section 11 to understand how).

TOPICS' services are not aimed at minors and no personal data of minors will be processed intentionally.

7. WHAT ARE COOKIES?

Cookies are small information files that help you identify your browser and can store information, for example, User settings and preferences.

TOPICS will store cookies on your device to personalize and facilitate browsing as well as troubleshooting, statistics, quality assurance, and to monitor system security.

With the exception of cookies specifically required for the performance of the Application, the storage of other cookies will always depend on the acceptance and consent of the User, and this consent may be withdrawn at any time through specific browser tools.

To know more about the cookies we use please refer to our Cookies Policy.

8. HOW DO WE PROTECT YOUR PERSONAL DATA?

Your personal data is kept secure by adopting a variety of technical and organizational security measures to ensure that only those employees who are required to access the personal data in accordance with the access requirements and rules created for this purpose have access to it.

To protect your personal data, we only use data center providers that offer adequate and documented security measures, including guarantees that your personal data is stored on servers that are maintained in controlled environments with limited access.

Personal data is retained on secure servers at Amazon Web Services EMEA SARL (hereinafter, "AMAZON") with NIPC 352 2789 0057 and registered office at 38 Avenue John F. Kennedy, L-1855 Luxembourg, which provides us with adequate security guarantees to protect personal data against unauthorized disclosure, loss, misuse, alteration, processing or access, as well as against any other form of unlawful processing.

Likewise, when you browse the application, we protect your data with encryption, such as Transport Layer Security (TLS, is a security protocol that protects telecommunications via the Internet) and your password is stored using a one-way hash, i.e. it cannot be recovered (or disclosed) by anyone, including TOPICS, and can only be reset.

Although we take the care and precautions, we deem appropriate to protect the personal data you provide and we collect, you should be aware that no security system is impenetrable.

You should therefore take certain precautions, such as keeping your password secret and not disclosing it to anyone else; if you believe that your password has been misused, you should notify us immediately; you should also take care to log in and log out every time you close your browser.

9. WHICH ARE YOUR RIGHTS

Before we explain how you can exercise your rights, we inform you which they are:

(a) Access: the right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, the right to access your personal data(b) Rectification: the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed(c) Erasure: the right to obtain the erasure of your personal data when one of the grounds listed in the legislation appliesi. The personal data is no longer needed in relation to the purposes for which they were collectedii. The data subjects withdraws consent on which the processing is based and there is no longer other legal ground for the processingiii. The data subjects objects to the processing and there are no overriding legitimate grounds for the processingiv. The personal data have been unlawfully processedv. The personal data have to be erased for compliance with legal obligationsvi. The personal data have been collected in relation to the offer of information society services(d) Restriction of processing: the right to obtain limitation of processing if one of the situations listed in the legislation appliesi. The accuracy of the personal data is contested by the data subjectii. The processing is unlawful and the data subject opposes the erasure of the personal data requesting the restriction of their use insteadiii. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claimsiv. The data subject has objected to processing related with automated individual decision-making(e) Objection: the right to object on grounds relating to data subject's particular situation, at any time of the processing of personal data concerning him or her which is based on public interest or legitimate interests(f) Data portability: the right to receive personal data concerning him/her in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the controller to which the data have been provided where the processing is based on consent or on a contract or where the processing is carried out by automated means

You also have the right to lodge a complaint with a supervisory authority (National Data Protection Commission at www.cnpd.pt).

10. HOW CAN YOU EXERCISE YOUR RIGHTS?

By writing to the following addresses:

(a) Via email: support@topicschat.com

(b) Via post: Rua Dr. Joaquim Pires de Lima, n.º 271, 4200 - 350 Porto, Portugal

Through the form in the application, via "Settings" or "Definitions".

If you request us to delete some or all of your personal data, some of the services you have requested may not be provided to you and TOPICS will retain only the personal data necessary to comply with its legal obligations.

11. WHEN DO WE COMMUNICATE DATA TO THIRD PARTIES?

TOPICS may use third parties to provide certain services, such as maintenance, technical support and marketing, which may have access to some personal data, in particular, data required for contractual purposes.

TOPICS ensures that the entities that have access to the data are credible and offer high guarantees of protection, and that that data will never be transmitted beyond what is necessary to provide for the contracted service, nevertheless TOPICS remains responsible for the personal data made available.

For example, for data center management purposes, TOPICS uses the services of AMAZON.

TOPICS may also communicate your data to other partners, only with your prior authorization.

TOPICS may also transmit data to third parties in the context of investigations, inquiries and judicial and / or administrative proceedings or of similar nature, provided that it is duly ordered by a court.

12. THIRD PARTY APPS OR WEBSITES

The APPLICATION may contain links to other Apps/Websites which may collect and process your personal data, and this processing is the sole responsibility of the owners of these Apps/Websites, and TOPICS does not take any responsibility for its policies and / or practices.

Examples of such third parties are Uber, Google Maps, Apple Maps or Waze through the buttons that are present on the APPLICATION.

13. DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

Your data will be processed by us within the European Economic Area.

In the event that data transfers may occur to third countries outside the European Union or the European Economic Area, TOPICS will make the necessary efforts to adopt the appropriate guarantees so that these are realized in accordance with the applicable legislation.

14. MINORS

The Application can be used by anyone over the age of 13, so we ask that other minors do not provide us with personal data through the website, application, social networks and social media or emails.

Age will be verified by registering the full date of birth (day, month and year).

Regarding payments, minors under the age of 18 will be subject to the general rules of the Portuguese Civil Code, and should consult the Terms and Conditions of the Application.

15. SENSITIVE PERSONAL DATA

TOPICS requests you not to send or disclose to us any sensitive personal data, i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health data or data concerning a natural person's sex life or sexual orientation.

If you nevertheless send or make known such categories of personal data to us, it will be deleted immediately.

16. CHANGES TO THE PRIVACY POLICY

TOPICS reserves the right to readjust or change this Privacy Policy at any time. These changes will promptly be made public.

17. CONTACT DETAILS

If you have any questions about this Privacy Policy, please email us at info@topicschat.com.