Data Protection and Privacy Policy Nãm Mushroom

NÃMFUNGI LDA., with registered office at Rua Amorim, nº11, 1950-022 Lisbon, NIPC 515050334, (“NÃM MUSHROOM”), in carrying out its commercial activities on the website www.nammushroom.com (“ Website ” or “ Online Store ” ), processes Personal Data, that is, information relating to an identified or identifiable natural person (“ Data Holder(s) ”), considering an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, electronic identifiers or to one or more elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (“ Personal Data ”).

The use of the Website by any user will be governed by the Terms and Conditions of use (“ Terms and Conditions ”), its use implying acceptance thereof by the user. If the user rejects the Terms and Conditions, they must immediately cease using the Website.

The General Conditions of Purchase and Sale (“ Conditions ”) constitute an integral part of the Terms and Conditions and establish the Conditions for purchasing products sold by NÃM MUSHROOM in the Online Store.

NÃM MUSHROOM determines the purposes and means of processing Personal Data as Responsible for the processing of Personal Data, ensuring compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, and other applicable legislation and matters of data protection and privacy (“Data Protection Legislation”)

Under the terms of Data Protection Legislation, NÃM MUSHROOM strives for the processing of Personal Data in accordance with all applicable principles, namely: i) Principle of Lawfulness, Loyalty and Transparency; ii) Purpose Limitation Principle; iii) Principle of Data Minimization; iv) Principle of Accuracy; v) Principle of Conservation; vi) and, Principle of Integrity and Confidentiality.

In light of the foregoing, this Data Protection and Privacy Policy (“Privacy Policy”) is established, with NÃM MUSHROOM committing to carry out any and all Personal Data processing operations in accordance with the provisions of the following points:

1. BASIS OF LAWSUIT AND PURPOSES OF DATA PROCESSING

The Personal Data of Data Subjects will be processed by NÃM MUSHROOM on the following legal basis:

Fundamentals of Lawfulness	What do they consist of?
Consent i	The Data Holder may consent to the respective Processing through a free, specific, informed and explicit expression of will, by which he or she accepts, through a declaration (written or oral) or unequivocal positive act (by filling in an option), that your Personal Data is subject to processing.
Pre-contractual diligence or the execution of a contract i	Personal Data may be processed if necessary, without limitation, for the execution of a contract for the provision of services and/or supply of products to which you are a party as an Employee, Customer and/or Supplier, or to carry out pre-contractual measures to your request.
Compliance with a legal obligation i	Personal Data may be processed to ensure and guarantee compliance with legal obligations to which it is subject under the legislation of a Member State and/or the European Union.
Defense of the Data Subject’s vital interests i	Personal Data may be processed to ensure the protection of your vital interests, particularly when the same Processing is essential to your life.
Legitimate Interests i	NÃM MUSHROOM, other Responsible Persons or Third Parties may process Personal Data as long as such Processing does not prevail over your interests or fundamental rights and freedoms.

Taking into account the aforementioned, the collection of Personal Data based on the exposed legal grounds will be essentially for purposes related to the development of NÃM MUSHROOM's corporate purpose and, as well, for the execution of its contracts and legal obligations, therefore Failure to collect Personal Data will result in the impossibility of carrying out the purposes for which Personal Data is processed.

2. PROCESSING OF PERSONAL DATA ON THE WEBSITE

NÃM MUSHROOM processes the Data Holder’s Personal Data as follows:

Purpose i	Treatment Activities i	Foundation of Lawfulness i	Conservation Period i
i Website Management	Analysis and processing of Web Browsing Data	i Execution of the contract, the terms of which are governed by the Terms and Conditions of the Website (“Agreement”)	Up to 3 months after the last visit to the Website
i Customer Management	Analysis and execution of orders	i Pre-contractual due diligence or execution of the Contract	For the period necessary to comply with the Contract and/or legal obligations
i Making Contacts	B2B contact form	i Consent	For a period of 1 year
iCommercial and marketing activities	Direct marketing communications	i Consent	Up to 1 year after last contact
		i Legitimate Interest for communications under the Contract	Up to 1 year after termination of the Contract

3. PERSONAL DATA PROCESSED ON THE WEBSITE

For the purposes stated, NÃM MUSHROOM processes the following Personal Data:

Purpose i	Personal Data i
i Website Management	Personal Identification Data, Contact Data, Authentication and Access Data and/or Web Browsing Data (such as name, email, user account, username , password, creation date, access validity, registration of entries and exits, electronic identifier (Mac, IP), connection start date/time, connection end date/time, web browsing origin location, URL visited, social network address, interaction history on social networks or host name )
i Customer Management	Personal Identification Data, Contact Data, Data Related to Payment Methods and Transactions.
i Making Contacts	Personally Identifiable Data and Contact Data.
i Commercial and marketing activities	Personal Identification Data, Contact Data, Data Related to Payment Methods and Transactions.

4. TREATMENT METHODS

The processing of Personal Data will be carried out automatically and manually using IT tools, applying logic strictly related to the purposes and, in any case, promoting the security and confidentiality of Personal Data.

5. DISCLOSURE AND TRANSMISSION OF PERSONAL DATA

NÃM MUSHROOM employees will process the Personal Data of Data Subjects to perform their work functions and will process Personal Data exclusively under the terms specified in this Privacy Policy.

Personal Data may be made available to third parties responsible for providing services to NÃM MUSHROOM (“Subcontractors”), bound by a written contract and processing the data in accordance with this Privacy Policy, and may not process it, directly or indirectly, for any other purpose, for your own benefit or that of a third party.

Data Holders have the right to obtain a complete and updated list of Subcontractors (if any) hired by NÃM MUSHROOM, and for this purpose they must send a specific request to NÃM MUSHROOM under the terms specified in Point 10 of this Privacy Policy.

In compliance with legal obligations, the Personal Data of Data Subjects may be transmitted to third parties, for the pursuit of their own purposes, namely banks and insurance companies, judicial, administrative, supervisory or regulatory authorities and also entities that lawfully carry out compilation actions of data, prevention actions and combating fraud.

Your Personal Data may also be processed by the entities managing social networks or the functionalities available on the Website , such as for the purposes of sharing content or creating an account, in accordance with their respective privacy policies, which we recommend reading before browsing. on the Website .

6. INTERNATIONAL TRANSFERS

NÃM MUSHROOM may transfer the Data Subject's Personal Data outside the European Economic Area (“EEA”), to locations that may not guarantee the same level of protection.

However, if applicable, NÃM MUSHROOM will only transfer Personal Data outside the EEA, in accordance with the following measures:

• When the transfer is carried out to a location or through a method or in circumstances that the European Commission considers to guarantee adequate protection of Personal Data;
• When you have implemented standard data protection contractual clauses approved by the European Commission or a competent supervisory authority; or,
• When none of the previous options apply, but the law still authorizes this transfer, for example, if it is necessary for the declaration, exercise or defense of a right in legal proceedings.

You can request detailed information about the security measures that NÃM MUSHROOM has implemented regarding transfers of Personal Data outside the EEA and, when applicable, a copy of the standard data protection contractual clauses in force at NÃM MUSHROOM through the contact details provided in Point 9.

7. RIGHTS OF DATA SUBJECTS

Under current or future Data Protection Legislation, NÃM MUSHROOM informs that Data Holders have the right to access, rectification, limitation, portability, erasure and the right to object to the processing of Personal Data, in certain circumstances, which may be exercised under the terms of this chapter of the Privacy Policy.

Rights	What do they consist of?
Right to provide information i	The Data Subject has the right to obtain clear, transparent and easily understandable information about how NÃM MUSHROOM uses their Personal Data and what their rights are. It is for this reason that NÃM MUSHROOM makes all this information available in this Privacy Policy.
Right of access i	The Data Subject has the right to obtain information about what Personal Data NÃM MUSHROOM processes (if it is processing them) and certain information (similar to that provided in this Privacy Policy) about the way in which such Data is processed. This right allows you to know and confirm that we use your Data in accordance with Data Protection Legislation. NÃM MUSHROOM may refuse to provide the requested information whenever, in order to do so, NÃM MUSHROOM has to reveal Personal Data of another person or the information negatively impacts the rights of another person.
Right to rectification i	If the Data Subject's Personal Data is incorrect or incomplete (for example, if your name or address is wrong), a request may be made to NÃM MUSHROOM to take reasonable steps to correct it.
Right to erasure of Personal Data i	This right is also known as the “right to be forgotten” and, in simple terms, allows the Data Holder to request the erasure or elimination of their data, as long as there are no valid grounds for NÃM MUSHROOM to continue using it or its use is illicit. This is not a generic right to erasure, as exceptions are permitted (for example, whenever this data is necessary to defend a right in legal proceedings).
Right to limitation of treatment i	The Data Holder has the right to “block” or prevent future use of their Data while NÃM MUSHROOM evaluates a request for rectification or as an alternative to erasure. Whenever the Processing is limited, NÃM MUSHROOM will continue to be able to store your data, but will not be able to use it later. NÃM MUSHROOM maintains a list of holders who have requested the “blocking” of future use of their data to ensure that this limitation is respected.
Right to portability of Personal Data i	The Data Subject has the right to obtain and reuse certain Personal Data for its own purposes across various organizations. This right only applies to personal data provided to NÃM MUSHROOM and which NÃM MUSHROOM processes with consent and which is processed by automated means.
Right to opposition i	The Data Holder has the right to object to certain types of processing, for reasons related to their particular situation, at any time that processing takes place, for the purposes of the legitimate interests of NÃM MUSHROOM or third parties. NÃM MUSHROOM may continue to process this Data if it can prove “preponderant legitimate reasons for the processing that override your interests, rights and freedoms” or if this Data is necessary for the establishment, exercise or defense of a right in a judicial proceeding.
Right to file a complaint i	The Data Holder has the right to lodge a complaint with the competent supervisory authority, the National Data Protection Commission – CNPD, if he considers that the Processing carried out on Personal Data violates his rights and/or Data Protection Legislation.

If the legal basis for the processing of your personal data is consent or legitimate interest, you may withdraw your consent or oppose the processing, respectively, at any time, without any consequences resulting from this, but without this compromising the legality of the treatments carried out in the meantime. If consent is withdrawn or your express opposition is verified, NÃM MUSHROOM will immediately cease processing your personal data for the purpose in question, unless there is a need to process the data to comply with legal and/or contractual obligations.

You may at any time, in writing, exercise the rights enshrined in Data Protection Legislation and other applicable legislation through the means described in Point 9 of this Privacy Policy.

8. SECURITY AND CONFIDENTIALITY

To guarantee the security and confidentiality of Personal Data, protected databases are used, among others, appropriate firewalls and passwords, in accordance with the provisions of Data Protection Legislation. Access to Personal Data is only possible to authorized employees who have an effective need to use Personal Data, in accordance with the principles of security and confidentiality. Violations of this Privacy Policy by NÃM MUSHROOM employees may give rise to disciplinary action. Compliance with NÃM MUSHROOM standards and procedures is monitored and verified periodically.

9. COOKIES

With regard to the processing of Personal Data that NÃM MUSHROOM carries out through the use of cookies, please consult the NÃM MUSHROOM Cookies Policy and customize your settings, according to your preferences.

10. HOW TO CONTACT NÃM MUSHROOM ON PRIVACY AND DATA PROTECTION MATTERS

Data Holders may exercise their rights by contacting NÃ M MUSHROOM by sending an email to the Privacy@gruponabeiro.com mailbox.

Data Holders may also contact NÃ M ’s Personal Data Protection Officer MUSHROOM by sending an email to the mailbox at DPO@gruponabeiro.com .

Revised version and in force since June 25, 2021