Privacy Policy and Cookies

1. Hexagon Intelligence Commitment

Hexagon Intelligence, enrolled with the Identification number 516621904, registered at Lisbon, Portugal, with a share capital of € 5.000,00 (five thousand euros), headquartered at Zona Industrial da Zicofa, Lote 4, Cova das Faias, 2415-314 Leiria, within the business, proceeds to the processing of personal data, intending to assure with rigor, effectiveness and security the protection of all the data that daily collects and processes.

Hexagon Intelligence is committed to:

• Process your personal data in a lawful and fair manner, collecting only the information necessary and relevant to the purpose for which it is intended;
• Allow you, as the holder of the data, access and correction of the information that concerns you, transmitting them in a language clearly and accurately corresponding to the contents of the register;
• Not use collected data for purposes incompatible with collection;
• Keep the data accurate and, if necessary, current;
• Ensure the consent of the data subject in accordance with the legislation in force;
• Guarantee the right to delete the data in accordance with the legislation in force;
• Respect professional secrecy with regard to the data processed;
• Limit interconnections of personal data to the minimum necessary;
• Have adequate protection and security measures in place that prevent the unauthorized person from consulting, modifying, destroying or adding data.

2. The data processing and the Data Protection Officer

Under the General Data Protection Regulations, Hexagon Intelligence does not have a Data Protection Officer appointed. Nevertheless, in order to facilitate the contact of the personal data holders with Hexagon Intelligence or any of its subsidiaries, we have created an email to which all messages related to matters that fall within the scope of our privacy policy and the General Regulation on Data Protection in particular: privacy@hexaintel.com. Hexagon Intelligence will provide an adequate response to any questions that may arise in this area. We ensure, among other aspects, the processing of data in accordance with current legislation, by verifying compliance with this Privacy Policy.

3. Personal Data, owners of personal data and categories of personal data

What is personal data?

Personal data is any information of any nature, collected on any type of medium, relating to a natural person, identified or identifiable. The set of information that may lead to the identification of a particular person, namely by reference to an identifier (such as an identification number or a location data), is identifiable.

Whom do we collect personal data from?

In the face of the business object of Hexagon Intelligence, most are processed data of individual and collective persons (companies and associations). However, for the performance of their duties, data of the following types of natural persons may be collected and processed (non-exhaustive list):

• Clients / investors and their collaborators;
• Service providers and their collaborators;
• Collaborators from any of the companies in the universe Hexagon Intelligence;
• Candidates and trainees;
• Recruitment processes;
• Prospects;
• Candidates and program clients promoted by Hexagon Intelligence Participants in events promoted by Hexagon Intelligence;
• Subscribers to newsletters developed by Hexagon Intelligence, or any of its subsidiaries and development programs;
• Visitors to the Hexagon Intelligence facilities.

What personal data do we process and how do we collect them?

Hexagon Intelligence only collects data that is appropriate, relevant and limited to what is necessary in relation to the purposes for which it is addressed. The collection of your data can be done orally, in writing (in particular through forms and contracts), as well as through the Hexagon Intelligence website. As a general rule, we collect your data directly from the project site with customers or from business interactions. Personal data may also be collected from public sources (such as internet sites and official public lists). For different purposes, we may collect the following types of personal data:

• Identification data (such as name, citizenship, citizen’s card or date of birth);
• Contact information (such as mobile phone, address or e-mail); qualification data and professional status (such as level of education and CV);
• Data on jobs or positions held;
• Bank or financial data in case of economic transactions (such as IBAN or tax identification number);
• Location data (such as IP address);
• Images of recording of events or of videoconferences;

As a rule, Hexagon Intelligence does not collect any special data, such as health data or criminal misconduct data.

4. Fundamentals and Purposes of the treatment of Personal Data

Why and on what grounds do we use your personal data?

All data collected and processed by Hexagon Intelligence are based on one of the following conditions of legitimacy

Consent: When the collection is preceded by your express, specific and informed consent, through written or web support. We collect your consent, for example, for purposes relating to enrollment in the activities and initiatives of Hexagon Intelligence and its subsidiaries, for subscribing to newsletters or for enrollment in shares promoted by Hexagon Intelligence.

For the execution of professional and commercial relations, as a project activity and training programs and others.

Contract execution or pre-contractual procedures: Where the processing is necessary for the performance of a contract to which it is party or for pre-contractual procedures.

This condition will be fulfilled when we treat your data for the purposes of managing programs and protocols for financing and cooperation or for supply and service contracts.

The fulfillment of legal obligations: When the treatment is necessary for the fulfillment of a legal obligation. This includes, for example, reporting to the public (national and Community), tax or judicial bodies.

The public interest: When the treatment is necessary for the exercise of functions of public interest.

The legitimate interest: Where the treatment proves necessary to pursue the legitimate interests of the treating entity or third parties, without prejudice to the rights and freedoms of its customers and/or users. This includes all treatments that result from attributions conferred by law, namely commercial disclosure to the representatives of the client companies or partners of Hexagon Intelligence or any of its subsidiaries or the processing of data to improve quality of service and when our reasons for using it should prevail over data protection rights.

What are the purposes for which we collect your data?

Personal data collected by Hexagon Intelligence is only processed for specific, explicit and legitimate purposes. Whenever personal data are collected, they are intended exclusively for the purposes expressly identified at the time of collection. We have here the main purposes that justify the collection of personal data by Hexagon Intelligence:

• Project contracting and management with clients;
• Recruitment;
• Management of events, programs and offers promoted by Hexagon Intelligence;
• Contracting of supply and service contracts;
• Disclosure of newsletters/publications;
• Improved offerings and experiences;
• Physical Security of Facilities and People.

5. Period of retention of personal data

Hexagon Intelligence treats and holds your data only for as long as is necessary to continue or complete the purposes of the processing for which they are intended, in compliance with the maximum periods required to comply with contractual, legal or regulatory obligations. As a general rule, and when there is a contract that legitimizes the processing of your data, Hexagon Intelligence will maintain such data for as long as this contractual relationship is maintained. Other circumstances exist, such as compliance with legal or regulatory obligations (for example, for the purposes of complying with tax obligations, personal data relating to invoicing must be kept for a maximum period of ten years from the date of the act) and pending a judicial proceeding, which may justify keeping their data for a longer period of time. After the retention period, Hexagon Intelligence will proceed to the elimination of such data.

On a regular basis, every 5 years, Hexagon Intelligence will contact the owners of personal data to renew their consent or, if it is their preference, to exclude them from our databases. However, if you wish to change your preferences, you can do so at any time by sending an email to privacy@hexaintel.com.

6. Rights of data subjects

Under current legislation, as soon as we collect and process your data, there is a set of rights that you can exercise at any time with Hexagon Intelligence.

What are your rights?

Right of access: Right to obtain information on the processing of your data and its characteristics (in particular the type of data, the purpose of the processing, to whom your data may be communicated, storage periods and what data you need to know compulsory or optional).

Right of rectification: Right that allows you to request the rectification of your data, requiring that these are accurate and current, such as when you consider that they are incomplete or outdated.

Right to be deleted or “Right to be forgotten”:Right that allows you to request the deletion of your data, when you consider that there are no valid grounds for data retention and provided there is no other valid basis for such treatment. the performance of a contract or the fulfillment of a legal or regulatory obligation).

Right to limitation: Right allowing the suspension of treatment or limitation of treatment to certain categories of data or purposes.

Right to portability: Right through which you can request the sending of your data, in digital format and in current use, that allows the re-use of such data. Alternatively, you may request the transmission of your data to another entity that becomes responsible for the processing of your data.

Right of opposition: Right which allows it to oppose certain purposes and provided that there are no legitimate interests prevailing over its interests. One of the examples of this right concerns opposition to direct marketing (marketing) purposes

Right to Withdraw Consent: Right that allows you to withdraw your consent, but which can only be exercised when your consent is the only condition of legitimacy.

How can you exercise your rights?

All rights described above may be exercised, subject to the limitations set forth in applicable law, upon written request, to be sent by privacy@hexaintel.com.

7. Data transmission

With whom do we share your personal data?

Subject to the responsibilities of Hexagon Intelligence, and depending on its purpose, your data may be shared with third parties, which include national and international public bodies and private entities for the purpose of fulfilling legal, regulatory, contractual or functions obligations of public interest.

Your data may also be accessed by service providers of Hexagon Intelligence, deemed necessary for the purposes described above, in particular as regards information security and archiving services. Hexagon Intelligence guarantees that it only resorts to service providers that present the guarantees of execution of technical and organizational measures necessary and adequate to protect their personal data.

Hexagon Intelligence does not commercialize data of natural or legal persons.

Transfers of personal data from outside the EEA

Since it operates in different geographies, Hexagon Intelligence may, exceptionally, transfer your personal data to third countries (outside the EEA – European Economic Area).

In such cases, Hexagon Intelligence will ensure that data transfers are carried out in strict compliance with applicable legal standards.

8. Cookies

What are Cookies:

Cookies are small text files with relevant information that is downloaded by your access device (computer, mobile phone / smartphone or tablet), through the browser, when a site is visited by the user, and used to store information about user visits.

Cookies, depending on how long the user stays on the page, can be classified as session or permanent cookies. The first type of cookies expires when the user closes the browser. The second type of cookies expires when your goal is completed or when they are manually turned off.

The cookies used by the sites of Hexagon Intelligence do not collect personal information to identify the user.

The cookies used on our sites are:

• Analytical – collects information about users’ browsing experience on the web page, anonymously, although sometimes they also allow a user to be identified, uniquely and unambiguously to obtain information about the user’s interests in the services provided by the web page.
• Advertising – persistently active but for a limited period of time, in order to collect user information on Internet browsing habits so that the advertisement displayed by the user matches their needs and interests.
• Third-party – allow the site to remember browsing preferences, language, region, and collect information from users to target advertising to their interests.

We use cookies to collect statistical information in order to analyze the functioning of the site and the users’ browsing experience and to evaluate the effectiveness of advertising and promotional campaigns.

Disable the use of cookies

All browsers allow the user to accept, reject or delete cookies by selecting the appropriate settings in their browser. This way, users can at any time disable the use of cookies on the websites of the Hexagon Intelligence universe by modifying browser settings.

However, it is important to note that disabling cookies may prevent some web services from functioning properly, affecting, in whole or in part, navigation.

9. Legislation

The processing of personal data of users and clients carried out by Hexagon Intelligence, as well as the sending of commercial communications carried out by electronic means are in compliance with the national and community legislation in force, namely by the General Regulation of Protection of Data.

Hexagon Intelligence reserves the right to revise and change this policy from time to time. The date of the last modification is indicated at the end of this document. Any changes to this policy and to the way we use the personal data of the data subject will imply the publication of an updated version on our website.

Last update: January 2th, 2024