This Privacy Policy establishes the processing of personal data provided by users of this website to Fab Duo Education, the entity responsible for its collection and processing.

By providing your personal data, you expressly declare that you accept the terms of this Privacy Policy, which is supplemented by the Terms and Conditions of Use, available here.

In accordance with the General Data Protection Regulation (Regulation (EU) 2016/679), hereinafter “GDPR”, and other applicable legislation, this Privacy Policy also establishes the rights of the data subjects whose personal data is collected, as set out below.

1. WHO ARE WE?

Fab Duo Education is a brand operating this online store, managed by Fab-Duo Education Lda., corporate entity with Portuguese tax number 518547795, with based at Rua Amália Rodrigues, no 100, 4820-410 Fafe, Portugal.

2. PURPOSE OF THIS POLICY

The purpose of this policy is to inform Clients of the general rules regarding the processing of personal data, which are collected and processed in strict compliance with the provisions of the data protection legislation in force, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and any other applicable or future legislation.

Fab Duo Education is committed to protecting and maintaining the confidentiality of personal data, having adopted measures it considers appropriate to ensure the accuracy, integrity, and confidentiality of such data, as well as all other rights of the respective data subjects.

Fab Duo Education honors the best practices in data security and personal data protection and has adopted the technical and organizational measures necessary to comply with the GDPR and ensure that the processing of personal data is lawful, fair, transparent, and limited to the authorized purposes under the GDPR and applicable legislation.

This Privacy and Data Protection Policy also aims to complement the provisions on data protection and processing included in contracts concluded or to be concluded by Clients/Users with Fab Duo Education, as well as the rules established in the terms and conditions governing the provision of various services, as published on our website.

3. PERSONAL DATA SECURITY MEASURES

Fab Duo Education has always been committed to ensuring the protection and security of the personal data provided to it. To this end, Fab Duo Education has implemented an internal security policy, and compliance with these rules is mandatory for all those who legally access the data, namely its employees. These security rules and measures are of a technical and organizational nature and aim to protect personal data against dissemination, loss, misuse, alteration, unauthorized processing or access, as well as any other form of unlawful processing.

Furthermore, third-party entities that, in the context of service provision, process Clients’ personal data on behalf of Fab Duo Education are contractually obliged to implement adequate technical and security measures that comply with the requirements set out in the GDPR and other applicable legislation, with the aim of safeguarding the rights of data subjects.

Within the scope of Fab Duo Education’s internal security policy, all methods of online personal data collection are encrypted and securely stored, and physical and logistical security measures have also been implemented.

However, Fab Duo Education’s actions do not exempt Clients from adopting their own security measures, particularly regarding the use of personal online protection systems (firewalls, antivirus, anti-spyware, tools to verify website credibility, etc.).

4. WHAT IS PERSONAL DATA

For the purposes of Article 4(1) of the GDPR, “Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

5. PROCESSING OF PERSONAL DATA

For the purposes of Article 4(2) of the GDPR, “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal data collected is processed in strict compliance with all applicable legal provisions. This means that all data will be stored in accordance with the respective purposes and in compliance with applicable legal deadlines. Therefore, unless a specific

legal requirement exists, data will be retained only for the appropriate period and to the extent necessary for the purposes for which they were collected, unless the right to object, right to erasure, or withdrawal of consent is exercised within legal limits.

6. WHO IS THE DATA CONTROLLER

Fab Duo Education, through its legal owner, is the data controller responsible for the processing of personal data in accordance with the purposes and means of processing at any given time.

For the purposes established in this policy or within the scope of the GDPR, if the data subject needs to contact Fab Duo Education, they may do so via email at info@fab-duo- education.com or by written communication sent to our professional address at: Rua Amália Rodrigues, n.o 100, 4820-410 Fafe, Portugal.

7. IS THERE A DATA PROTECTION OFFICER?

You may contact Fab Duo Education’s Data Protection Officer via the following email address: info@fab-duo-education.com

8. TYPES OF DATA SUBJECT TO PROCESSING

Considering the activities carried out by Fab Duo Education, this entity processes the personal data necessary for service provision, goods supply, or within its social responsibility activities, processing personal data such as name, address, telephone number, and email address. The amount of information collected may vary depending on what the Client provides.

Except where required by legal obligation, all data will be exclusively processed by Fab Duo Education only to the extent necessary for the development of its activity, also allowing the Client to access, for example, specific functionalities of the services.

If prior consent from the Client exists, it may be withdrawn and removed at any time without affecting the lawfulness of processing based on previously given consent. To revoke consent, you may use the email address info@fab-duo-education.com.

9. PURPOSES AND LEGAL BASIS FOR DATA COLLECTION AND PROCESSING

Fab Duo Education may process personal data for the following purposes:

a) Provision of commercial services (client file creation, proposal and order registration, communications with clients, and archiving);

The legal basis, in this case, is the performance of the contract, specifically Fab Duo Education’s interest in processing its clients’ information effectively and efficiently to ensure the quality of its services.

b) For statistical analysis purposes using Google Analytics, without collecting specific personal data (such as names, addresses, IPs);

c) For billing and accounting management;

To maintain efficient management control, ensure timely invoicing, and comply with applicable legal obligations;

d) For judicial and extrajudicial collection and claims, including the collection and recovery of amounts owed by clients;

The legal basis is Fab Duo Education’s legitimate and legal interest in satisfying its claims and defending its rights.

Google’s privacy policy can be consulted here.

10. PROCESSING BY SUBCONTRACTORS

As part of its activities, Fab Duo Education engages third parties to provide certain services, which may involve access to Clients’ personal data. When this occurs, Fab Duo Education ensures that subcontractors comply with the GDPR and other applicable legislation, as well as with security standards similar to our internal policy.

In cases where personal data is communicated to other subcontracted entities, Fab Duo Education remains responsible for that personal data.

11. COLLECTION OF PERSONAL DATA

Fab Duo Education collects personal data by phone, contractually, or through its website, always ensuring the prior consent of data subjects.

Please note that certain personal data is essential for the performance of executed contracts and, in cases of missing or insufficient data, service provision by Fab Duo Education may be compromised.

The rules of this policy apply to personal data subjects who are not Clients of Fab Duo Education.

Personal data collected may be processed by automated or non-automated means. Fab Duo Education ensures compliance with the GDPR and other applicable legislation. Personal data is stored in specific databases created for this purpose. Such data will never

be used for any purpose other than that for which it was collected or for which the data subject gave consent.

12. RETENTION OF PERSONAL DATA

The retention and storage of personal data is necessarily linked to the purpose for which the information was collected and processed.

Unless there is a legal obligation to retain the data, such personal data will only be stored and retained for the minimum period necessary for the purpose for which it was collected.

13. TRANSFER OF PERSONAL DATA

Fab Duo Education does not transfer personal data. If this eventually occurs, it will be done in accordance with the GDPR and other applicable legislation. However, this does not affect the data subject’s right to data portability.

14. YOUR RIGHTS AND HOW TO EXERCISE THEM

As a personal data subject, Fab Duo Education guarantees you the right, at any time, to access, rectify, update, restrict, and erase your personal data (except for data essential for service provision or where a contractual relationship persists), to object to its use for commercial purposes by Fab Duo Education, to withdraw consent, and to exercise the right to data portability.

To exercise these rights, you may contact us via email at info@fab-duo-education.com or by written communication sent to our professional address: Rua Amália Rodrigues, n.o 100, 4820-410 Fafe, Portugal.

15. COMPLAINTS

Although you may submit any complaints directly to Fab Duo Education as described above, you may also file a complaint directly with the Supervisory Authority, which in Portugal is the National Data Protection Commission (CNPD).

16. AMENDMENTS TO THE PRIVACY AND DATA PROTECTION POLICY

Fab Duo Education reserves the right, at any time and whenever deemed necessary, to make any necessary amendments, which will be publicly disclosed through the channels used by Fab Duo Education.