Privacy Policy of Companhia das Soluções – Treasurecode, Lda

This Privacy Policy describes how Treasurecode Lda., owner of the Companhia das Soluções brand, hereinafter referred to as Companhia das Soluções, processes Personal Data entrusted to it by its partners and clients.

Before supplying Personal Data to Companhia das Soluções, we recommend you read this Privacy Policy, since your Personal Data may be subject to a number of processes. By supplying your Personal Data, you accept and give permission for the collection, use and disclosure of your Personal Data (information likely to identify you), as set out in this Privacy Policy.


Treasurecode, Lda, a corporate body registered at the Vila Nova de Gaia Commercial Registry, under number 510450202, having its registered office at Rua 28 de Janeiro, nº350, Candal Parque E2, is the Controller Responsible for Processing the Personal Data provided by Data Subjects by telephone, e-mail or any other means.

Before providing Personal Data to Companhia das Soluções you should read this Privacy Policy and give your consent in the field set aside for that purpose.

Processing of Personal Data

Right to Process

In order to pursue its business Companhia das Soluções needs to collect and process data of a personal nature, which are essential to its business, and which are only collected with the consent of the Data Subjects.

With the Data Subjects’ consent their data are:

      a) used to send information about the products/brands that Companhia das Soluções represents, as well as information about advertising campaigns, partnerships, actions, etc.

      b) uploaded to a database owned by Companhia das Soluções so that the data may be segmented for the media, influencers, bloggers, fashion producers, etc.

In order to receive information about the products/brands and/or be contacted by Companhia das Soluções, Data Subjects have to agree to supply their Personal Data and give permission for their data to be stored in our database for future contacts.

The data processed

Companhia das Soluções shall collect the following Personal Data: NAME, SEX, EMAIL ADDRESS, TELEPHONE NUMBER, ADDRESS, although other data may be requested later for the purposes described in this Privacy Policy.

Companhia das Soluções shall use this database to enter into regular contact with Data Subjects in the course of its business to regularly disseminate information on products/brands, and it may divide the database into segments based on the nature of each brand/product/client.

Processing purposes

The aforesaid Personal Data supplied by the Data Subjects to Companhia das Soluções shall be processed by the latter for the following purposes:

      a. Sending of Information on the products/brands/clients it represents;
Sending of products via shippers;
      c. Media investment proposals;
      d. Partnership proposals;
      e. Technical management and maintenance of the information systems.

Under no circumstances will Users’ Personal Data be used by Companhia das Soluções for purposes other than those described above.

Processors and disclosure of data to third parties

The Personal Data supplied to Companhia das Soluções shall be processed by its employees and staff who are duly authorised to undertake said processing under their job description, and are bound to process the Personal Data in accordance with the law and this Privacy Policy.

However, the Personal Data may also be processed by Companhia das Soluções’processors, which will process the data in line with instructions from and on behalf of Companhia das Soluções, for example in regard to the technical management and maintenance of the computer systems and management of the information systems, the sending of products via shippers or others.

Companhia das Soluções requires its processors to comply with a series of duties, which include providing the Personal Data with suitable protection, employing technical and organisational measures that guarantee their integrity and confidentiality, as well as forbidding the data’s use for any purpose other than those referred to herein and for which the Data Subjects have given their consent.

Depending on the purposes of a specific process, on its legitimacy and on the specific consent given by the Data Subjects, Personal Data may be communicated to end clients, state bodies and processors.

In exceptional circumstances and under certain conditions, Companhia das Soluções may transfer the Data Subjects’ Personal Data to a foreign country pursuant to the applicable laws, including countries outside the European Union, for data housing or storing purposes, technical processing by processors, back-up and data storage recovery, service development. Companhia das Soluções shall not transfer their data to countries that do not guarantee an adequate level of protection as prescribed by the applicable legislation.

In addition to the aforementioned entities, Personal Data may also be disclosed, when so required under the legal provisions, to the courts, the police or any other authority legally entitled to receive them.

Processing conditions

Companhia das Soluções, as Controller of the Personal Data provided to it, abides by all the applicable legal provisions covering the processing of the data it collects. Companhia das Soluções ensures the quality, accuracy,  integrity and confidentiality of the data entrusted to it, as well as the legitimacy of its processing, such as the lawfulness, security and confidentiality of the processing, no subsequent use of the Personal Data for purposes other than those stated at the time of collection, except with the subsequent express consent of the Data Subject, and the storing of the data solely for the length of time needed to pursue the purposes for which they were collected/processed.

Companhia das Soluções has appropriate technical and organisational measures to protect the Data Subjects’ Personal Data against accidental or unlawful destruction, accidental loss, alteration, disclosure and/or unauthorised access.

Companhia das Soluções uses suitable systems and procedures to protect and safeguard the integrity of the Personal Data provided, such as restriction on organisational, technical and physical security, the forbidding of unauthorised access, clean desk policies, functional data separation, user network login and password access policies, controlled access to premises, which means only staff authorised to access Personal Data in the performance of their duties and for the aforementioned purposes may do so. Nonetheless, and within the maximum scope of the law, Companhia das Soluções shall not be liable for any attacks or unlawful acts perpetrated by third parties.

Data storage

Pursuant to the law, Companhia das Soluções shall only process Personal Data whilst there is a commercial relationship between itself and the Data Subjects. At the end of that period the data shall be eliminated, so as not to allow the Data Subjects to be identified.

Data Subject’s rights

Companhia das Soluções protects all the Data Subjects’ legal rights, such as the right to confirm that their data are being processed, as well as all information relating to that processing, to know the source of the data, the recipients or categories of recipient to whom the Personal Data has been or will be disclosed, and the period of time for which their Personal Data will be held. Companhia das Soluções also guarantees to the Data Subjects their right to access, contest and/or restrict processing, withdraw consent, portability, as well as the possibility of updating, correcting or erasing their Personal Data.;

Companhia das Soluções shall allow its Data Subjects to exercise, at any time, their rights under the applicable legislation, by contacting Companhia das Soluções in writing to that end.

The Data Subjects’ legitimate requests shall be met by Companhia das Soluções within thirty days. This period may be extended for another thirty days if absolutely necessary and by way of sending prior justification.

Companhia das Soluções processes Data Subjects’ Personal Data in accordance with the requirements of the legislation in force. However, if any user believes that Companhia das Soluções is not complying with the law or is not respecting their rights, they may lodge an appeal with the National Data Protection Committee.

Privacy Policy Consent

Companhia das Soluções is governed by the legislation in force and pledges it will comply with this Privacy Policy.

Nonetheless, Companhia das Soluções reserves the right to make changes to this Privacy Policy without prior warning. Any change to this Privacy Policy will be published on its website in the coming days so regular consultation of this document is recommended. The version published on the website shall be deemed the current policy.

If you disagree with this Privacy Policy, please do not provide us with your Personal Data. However, we draw attention to the fact that the use of information on products/brands/clients provided by Companhia das Soluções is dependent upon the provision of your personal registration and other data, without which you will be unable to benefit fully from the services provided by us.

More detailed information on the protection of Personal Data may be obtained by consulting the applicable legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the relevant national legislation.


Last updated: May 2018