This Privacy and Cookies Policy (“Policy”) governs the processing of users’ (hereinafter “User” or “Users”) personal data collected, within the scope of the use of the websites of the Calouste Gulbenkian Foundation (hereinafter “websites”), by the Calouste Gulbenkian Foundation (“Foundation”), reflecting the institutional concerns of the Foundation in matters of privacy and processing of personal data in these contexts.

Providing personal data in the context of browsing the websites implies knowledge and express acceptance of the conditions contained in this Policy.

1. Controller of Users’s Personal Data

The Foundation is the controller of the processing of Users’ personal data and may process such data directly and/or through entities subcontracted for that purpose.

2. Collection and Processing of Personal Data

Access and browsing in general on the websites do not necessarily entail provision of personal data. Any User can (i) freely browse the websites and view the available content, and can even purchase tickets without having to register (in which case only the data necessary for processing payment is requested); and (ii) freely subscribe to the Foundation’s newsletters through the websites, in which case they will be asked for their email address.

However, the use of certain features of the websites requires creating an account and/or providing a set of personal data. In these cases, it will only be possible to enjoy the features, products and services in question if you provide the personal data requested.

The Foundation processes Users’ personal data in the following terms and for the following purposes:

1. 2.1. Registration on websites

As part of the creation of personal accounts on the websites, including the MyGulbenkian Account, the Foundation collects a set of personal data, which will be processed for the purposes of creating and managing your personal account, on the grounds of the performance of the contract executed with you at the time of creation of said account, by accepting the Terms and Conditions.

For this purpose, you are requested to provide personal data, which is mandatory, under penalty of not being able to complete the registration process, namely name, date of birth, email and password. To complete your personal account, the Foundation may collect optional additional data (such as VAT number, gender, additional contact details, nationality and address), which will be processed for statistical purposes in accordance with paragraph 2.11

2. 2.2. Submission of applications for scholarships and support and monitoring of scholarships and support granted

To be able to process applications for scholarships and support, the Foundation will necessarily process the personal data requested from Users at the time of application, as well as during the monitoring, by the Foundation, of a scholarship or support granted by it. Collection of this data is necessary for the Foundation to be able to review your application and award the scholarship or support. The Foundation processes this data for purposes of pre-contractual diligence and subsequent contractual execution. For the purposes of submitting the application, it will be necessary to create an account as described in the preceding point.

3. 2.3. Submission of applications for awards

Personal data requested of applicants and/or proponents, or made available by them, shall be processed by the Foundation for the purpose of managing the granting of awards. Collecting such data is required to enable the Foundation to review applications, grant the award(s) and disclose the awardee(s), and also for precontractual diligence and subsequent contract execution.

4. 2.4. Purchase of Foundation products (ticket office and online store)

The Foundation will process the personal data needed to manage purchases, and correspondingly associated transactions, that you carry out from the websites, on the grounds of the execution of the purchase and sale contract entered into, and to fulfil the legal obligations applicable to the Foundation. This personal data refer essentially to your name, email, telephone number, VAT number and address (when applicable), payment method and associated data, identification of the establishment and products/services purchased.

5. 2.5. Customer service

To be able to respond to your requests, the Foundation will process your personal data, namely identification and contact details, as well as data that you share with the Foundation within the scope of your request. This data will be processed on the grounds of the Foundation’s legitimate interest in responding to questions/requests that any User submits through the websites.

6. 2.6. Registration and participation in events held at and/or by the Foundation

The Foundation also processes your personal data for purposes of processing applications and participating in events held at and/or by the Foundation (for example, Conferences, Educational Activities, among others), namely identification and contact details. This data will be processed on the grounds of the relationship established through your registration at the event or of the Foundation’s legitimate interest in processing your registration, as applicable.

The Foundation may collect images, sound and voice recordings of participants at events held at and/or by the Foundation, and these recordings may contain personal data and be publicised by the Foundation by any technical means of broadcast, distribution or communication.

7. 2.7. Managing users and services provided by the Art Library and Archives

To allow access to the Art Library and its services, the Foundation collects, on the grounds of consent, a set of personal data required for purposes of establishing a record of readers and managing the relationship between the Foundation and the reader. To that end, providing personal data is requested and mandatory, under penalty of making it impossible to verify fulfilment of the eligibility requirements to be a user of the Art Library or completing registration as a reader, namely, name, civil identification number, email, birth date, qualification and professional activity.

The Foundation also processes your personal data on the grounds of your consent for purposes of managing requests to consult, use and reproduce the documents that are part of the acquis of the Art Library and Archives.

8. 2.8. Publicising Foundation activities

Upon your consent, the Foundation will send newsletters and/or process the User’s personal data for the purpose of profiling and sending promotional communications, disclosure of events and campaigns, as well as promotional coupons adjusted to your interests and preferences related to the Foundation’s products and services, by automated means such as text messaging, email and telephone.

Your profile will be created based on your activity on the websites, stores and ticket offices of the Foundation, and on other databases that the Foundation has access to, for the purposes of publicising, sending institutional information and presenting new products and services.

In addition, the Foundation sends communications to its institutional contacts for the purpose of publicising its institutional activity to relevant entities and persons, and to send invitations, institutional communication and other relevant news. In this context, the Foundation processes the following personal data: name, email, telephone, institution that you work for and position held. These communications are sent by the Foundation on the grounds of its legitimate interest in keeping in touch and publicising its activities with its institutional contacts.

9. 2.9. Processing spontaneous applications and recruiting processes

The Foundation also processes your personal data for the purpose of processing applications, both spontaneous and within recruiting processes, submitted using the form available on the websites for that purpose. This personal data refers essentially to your name, email, telephone number, Citizen Card number, birthdate, academic qualifications and professional career and other data contained in your CV, such as your image, if it contains your photo. Your personal data will be processed to manage the Foundation’s recruitment processes, on the grounds of the Foundation’s legitimate interest in processing your application, and to fulfil the competent legal obligations of the Foundation.

10. 2.10. Managing Reports

or the purpose of managing reports submitted using the whistleblowing channel, the Foundation processes your personal data (name, email and telephone number), as a whistleblower, on the grounds of fulfilling legal obligations, namely, arising from the General Scheme for Protecting Whistleblowers of Infringements, and on the legitimate interest of the Foundation in pursuing reports concerning its activity. If a report is submitted anonymously, the Foundation does not collect any data or information that allows identifying the whistleblower.

11. 2.11. Statistical Analysis

In the context of the abovementioned purposes, and with your consent or on the grounds of the legitimate interest of the Foundation in managing and assessing its activities, the data collected, which may be, depending on the initial purpose at stake, of mandatory or optional completion (such as birth date, gender, education level, profession, address or nationality), may be processed for statistical purposes. After collection, tatistical processing of the data collected is done aggregately, not individual, and does not allow identifying the User.

12. 2.12. Conducting functionality reviews and monitoring quality

Without prejudice to the information provided in point 5 below regarding the use of cookies by the Foundation, and, if applicable, with the User’s consent, the Foundation may carry out sporadic surveys to measure the quality of the websites’ features, and to monitor their qualities and level of User satisfaction with the websites.

3. Communication of Personal Data

1. 3.1. The Foundation may transfer your data to partner entities and subcontracted entities for the purposes mentioned above, under the terms of the contracts entered into with them in accordance with the applicable legislation.

2. 3.2. The processing of data by the Foundation, and the aforementioned service providers, may involve transfer of personal data to third countries (that do not belong to the European Economic Area), namely, those included in the following list. In such cases, the Foundation guarantees the technical and organisational measures appropriate to the security and protection of personal data and access to copies thereof, informing the data subjects about the locations and entities to which they have been transferred.

3. 3.3. The Foundation may also, to fulfil legal obligations, conclude the operations carried out through the website, or on the grounds of the consent you provide for this purpose, communicate your data to third parties, whether these are (i) other entities in the universe of the Foundation, (ii) partners, sponsors or other entities with whom the Foundation establishes comparable relationships, (iii) financial/payment institutions; (iv) competent entities, under the terms of the law.

4. 3.4. Some of the personal data collected at events carried out at and/or by the Foundation, and in the scope of the granting of scholarships, may be kept for the time required to manage the Foundation’s cultural, intellectual and artistic acquis.

4. Retention of Personal Data

1. 4.1. The personal data needed for purposes of signing up and managing your My Gulbenkian Account will be kept as long as you are interested in maintaining it.

2. 4.2. Personal data processed for the purpose of processing spontaneous applications will be kept for a period of one year after submission.

3. 4.3. When processing is carried out based on your consent, the data will be kept for that purpose until you withdraw it.

4. 4.4. Other personal data collected through the websites will be kept for the time needed to achieve the purpose for which they were collected, under the terms of this Policy.

5. 4.5. Some of the personal data collected in events carried out at and/or by the Foundation, and within the granting of scholarships, aid and awards, may be retained for the period required to manage the cultural, intellectual and artistic acquis of the Foundation.

5. Cookies

1. 5.1. To be able to provide a more customised service to the satisfaction of Users, meeting their expectations, the Foundation uses own and third-party cookies to collect and store information.

2. 5.2. A cookie is a text file automatically stored in Users’ internet browsers when they access certain websites. The cookie allows the Foundation and third parties to identify the web browser on the server, enabling storage of information, to improve the users’ experience, and to analyse and review website performances.

3. 5.3. Cookies can be classed as session cookies or persistent cookies. Session cookies expire automatically when you close your internet browser. Persistent cookies remain in your internet browser until their expiration date, or until they are deleted. Expiration dates vary by cookie, some expiring after a few minutes, others only after several years.

4. 5.4. Within the websites, the Foundation uses the cookies included in the following list.

5. 5.5. Cookies and other immediate tracking technologies do not collect personal data about you, except in cases where you voluntarily provide this type of information, by registering on the website or sending communications; these technologies may be used to obtain more information regarding your use of the website.

6. 5.6. Each User corresponds to an individual cookie, thus securing data privacy and security. The presentation of statistical data is done in aggregate and not individually, thus not allowing identification of the User. In this way, it is possible to assess the website’s performance, in view of constant updating and improvement, to meet the user’s tastes and needs.

7. 5.7. To set your cookies, you must access “Cookie Settings”, at the bottom of the homepage of the Foundation’s websites. Additionally, web browsers allow users to manage their cookies. They can set their devices to accept all cookies, know when a cookie is set, or never receive cookies. You can at any time disable the cookies feature through the web browser, usually in the “Preferences” or “Tools” menu. For more details regarding the configuration in your browser, see the “Help” menu of the browser.

8. 5.8. Note that, by disabling cookies completely, some/all of the websites’ features may cease to be available.

6. Security

1. 6.1. The Foundation guarantees privacy and security in the transmission of Users’ data using SSL (Secure Sockets Layer) encryption of all information exchanged with the Foundation, via the internet.

2. 6.2. In addition, the Foundation represents, for this purpose, that it has and will keep in operation all technical means available to it to prevent loss, misuse, alteration, unauthorised access and improper appropriation of personal data provided or transmitted. In any case, note that, by circulating the data on an open internet network, it is not possible to completely remove the risk of unauthorised access and use, so the User must implement appropriate security measures when browsing the websites.

3. 6.3. Where payments are made through the website’s servers, the information sent will be encrypted and additional security measures, appropriate to the state of the art and good market practice, will be employed.

7. User’s Rights

1. 7.1. Under the terms of the applicable legislation, the User may request, at any time, access to personal data concerning them, as well as rectification, deletion or limitation of processing, portability of their data, or object to processing (and may, in the specific case of profiling and as applicable, request clarification about the criteria used and/or object to profiling).

2. 7.2. The User may also obtain confirmation that the personal data concerning them is subject to processing and access them. If required, a copy of the data processed may be made available to you.

3. 7.3. Under the terms of the law, the User also has the right to withdraw consent at any time to the processing of their data based on their consent, without prejudice to the fact that processing carried out until that date, based on consent previously given, remains entirely valid.

4. 7.4. The User also has, under the terms of the law, the right to request limitation of the processing or portability of their data, subject to the legally applicable conditions.

5. 7.5. The rights of Users mentioned above may be exercised using the contact details provided in point 9.

8. Complaints

Without prejudice to any other administrative or judicial remedy, the User is entitled to submit a complaint to the National Data Protection Commission or other competent supervisory authority under the law, if they believe that the processing of their data by the Foundation violates the legal scheme in force from time to time.

9. Questions

If you have any questions related to the processing of your personal data and the exercise of the rights conferred on you by the applicable legislation and, in particular, mentioned in this Policy, you can use the following contacts:

Form
Address: Av. de Berna, 45 A, 1067 – 001, Lisboa
Telephone: +351 217823000

10. Changes to the Personal Data Processing Terms

The Foundation may change this Policy at any time. These changes will be duly publicised in the pages of the Websites.

 

Last updated on: 16 may 2024
Implementation date: 9 may 2024