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.
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:
- 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 relationship it establishes with you at the time of creation of said account.
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, email and password. To complete your personal account, the Foundation may collect additional data, which may be, depending on the personal account created, mandatory or optional (such as birthdate, gender, additional contact details, nationality and address).
- 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.
- 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.
- 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, address, as well as the amount of the purchase, payment method and associated data, identification of the establishment and products/services purchased.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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 purpose at stake, of mandatory or optional completion (such as birth date, gender, education level, profession or nationality), may be processed for statistical purposes. Statistical treatment of the data collected is done aggregately, not individual, and does not allow identifying the User.
- 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.
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.
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:
The Foundation may change this Policy at any time. These changes will be duly publicised in the pages of the Websites.