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Privacy and Data Protection Policy

Effective Date: January 2025

Who we are
Nature Returns Unipessoal, Lda (“NATURE RETURNS“) is a private law company with registered office at Avenida Dom Sebastião 101, 2825-408 Costa da Caparica, Portugal, registered at the competent Commercial Registry Office under the main registration and taxpayer number PT 517487250.

The present privacy and data protection policy (“Privacy Policy”) relates to the processing of personal data carried out by NATURE RETURNS and collected through the website: www.nature-returns.eu

1. Introduction
Nature Returns (“we,” “our,” “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and share your information when you visit our website www.nature-returns.eu or contact us.

2. Information We Collect
We collect the following personal data:
• Names
• Email address
• Messages: Any message you choose to send us through our contact form.

In the event that any additional category of personal data is required, a specific additional consent shall be sent to you by NATURE RETURNS.

3. How We Use Your Data
We use your personal data for the following purposes:
• Replying to enquiries and messages sent to our email address (info@nature-returns.eu).
• Improving user experience on our website through analytics.
• Sending newsletters if you subscribe to them.

4. Data Retention
We retain and process your personal data for as long as necessary to fulfil the purposes outlined in this policy, unless otherwise required by law. The period of time during which Personal Data are stored and retained varies according to the purpose for which they are used, the rule being that they are retained only for the period necessary for each purpose. There are, however, legal obligations (e.g., tax) that may require the retention of Personal Data for a longer period of time and, in this case, the data will be retained only for the period necessary to comply with the legal obligation imposed.

The Personal Data collected is processed in strict compliance with the applicable legislation and is stored in specific databases created for this purpose. Such data shall be kept in a format that permits identification of the Holders of the Personal Data.

If Processing is based on Consent, NATURE RETURNS keeps the User’s Personal Data in accordance with the Consent given and/or until such Consent is revoked.
Personal data related to newsletter subscriptions will be kept until you express your will to unsubscribe (please see 15. below).

5. Third-Party Sharing
We may share your personal data with the following third parties:
• Google Analytics: For analysing website traffic and improving user experience.
• Mailchimp: For managing our newsletter subscriptions and communications.

We have Data Processing Agreements in place with these third-party service providers to ensure that they comply with applicable EU and national data protection legislation.

6. Cookies and Tracking Technologies
In addition to cookies, we use the following tracking technologies to improve your browsing experience and gather information about how you use our website:
• Session Storage: Temporary storage of data for the duration of your session. Once you close
your browser, this data is deleted.
• Device Fingerprinting: Collects information about your device (e.g., browser type, operating
system, etc.) to identify users based on their device setup.
• ETags (Entity Tags): Used to manage and validate cache, which may also track user behavior
by storing unique identifiers in your browser.
• Server Logs: Our servers automatically log information such as IP addresses, browser type,
and the pages you access, used for analytics and security purposes.
• Tracking Scripts (JavaScript Trackers): JavaScript code embedded on our website captures
user interactions such as clicks and scrolls for analytics and user behaviour analysis.

When you first visit our website, you will be asked to consent to the use of cookies and tracking technologies through a cookie consent banner. You can manage your cookie preferences at any time through your browser settings or our cookie management tool.

7. Links to Other Websites Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no liability for the content, privacy policies, or practices of any third-party sites or services.

8. Your Rights Under Personal Data Legislation in force (GDPR and national law)
As a data subject located in the EU, generically you have the following rights regarding your personal data:
• Access: You can request a copy of your personal data which we collect.
• Rectification: You can ask us to correct any inaccurate or incomplete information regarding
your personal data.
• Deletion: You can request the deletion of your personal data.

Specifically with regard to this right, the User may request that Personal Data be erased when one of the following situations occurs:

(i) the Personal Data is no longer necessary for the purpose for which it was collected or processed;
(ii) when the Consent on which the Treatment is based is withdrawn and there is no other legal basis for the Treatment;
(iii) where an objection to the Processing is lodged and there are no overriding legitimate interests justifying the Treatment;
(iv) where the Personal Data have been unlawfully processed; and
(v) where the Personal Data must be erased pursuant to a legal obligation.

The right to erasure shall not apply where Processing is necessary for the following purposes:

(i) exercise of freedom of expression and information;
(ii) compliance with a legal obligation requiring the Treatment;
(iii) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes to the extent that exercising the right to erasure would seriously prejudice the achievement of the purposes of such Processing; or
(iv) establishment, exercise or defence of legal claims.

• Restriction of Processing: You can request a limitation on the processing of your personal data, according to certain contexts. Restriction of processing allows the User to request to restrict access to certain Personal Data or to suspend certain activities of Nature Returns, acting as Data Controller. In particular, the User may request the limitation of the Processing of Personal Data in the following cases:

(i) if you contest the accuracy of the Personal Data, for a period of time that allows NATURE RETURNS to verify such accuracy;
(ii) if NATURE RETURNS no longer needs the Personal Data for a particular Processing purpose;
(iii) if you have objected to the processing, unless it is established that NATURE RETURNS legitimate interests prevail over your interests.

• Data Portability: You can request a copy of your personal data in a structured, machine-readable format.
• Objection: You can object to the processing of your data in certain circumstances.

To exercise any of these rights, please contact us at info@nature-returns.eu.

9. Legal Basis for Processing
We process your data on the following legal bases:
• Consent: When you subscribe to our newsletter or contact us via email, you give us your
consent to process your personal data. In this context, “Consent” means the free, specific, informed and explicit expression of will, by which you, as data subject, accept, through a declaration or unequivocal positive act, that your Personal Data may be processed for a specific purpose.
• Legitimate Interest: We process your data to improve user experience on our website.

10. International Transfers
Since our users may be located outside the European Economic Area (EEA), personal data collected on our website may be transferred to, and processed in, countries outside of the EEA. We take appropriate safeguards to ensure that these transfers comply with GDPR and that your data is protected according to the same standards.
When processing data outside the EEA, in each and every case we rely on one of the following mechanisms:
• Adequacy decisions by the European Commission for countries deemed to provide an
adequate level of data protection.
• Standard Contractual Clauses or similar contractual protections to safeguard data when
transferred to countries without an adequacy decision.

11. Compliance with Global Privacy Laws
In addition to GDPR, we strive to comply with other privacy regulations that apply to our users worldwide. These may include:
• California Consumer Privacy Act (CCPA) for users in California.
• Personal Information Protection and Electronic Documents Act (PIPEDA) for users in Canada. • Other relevant local data protection laws based on the user’s location.
Regardless of your location, you may exercise your rights as outlined in this Privacy Policy, and we will process your data in compliance with the applicable laws.

12. Data Security
We are committed to ensuring the protection of the security of Personal Data that is made available on the Portal to keeping your personal data secure. Demonstrating NATURE RETURNS great concern and commitment to privacy issues, several technical and organisational security measures have been adopted in order to protect the Personal Data provided on the Portal against diffusion, loss, misuse, alteration, unauthorized processing or access, as well as against any other form of unlawful processing (e.g., use of https).

Notwithstanding the security measures adopted by NATURE RETURNS, users browsing the Portal should adopt additional security measures, namely by ensuring that they use an up-to-date browser in terms of security patches, properly configured (e.g., active firewall, antivirus and antispyware). Finally, Users should ensure the authenticity of the platforms they visit on the Internet, and should avoid websites with an unreliable reputation.

13. Data Breach Notification
In the event of a data breach that affects your personal data, we will notify the relevant supervisory authority – in our particular case, CNPD – Comissão Nacional de Proteção de Dados, the Portuguese Data Controller Authority – and, where necessary, inform you without undue delay, in compliance with applicable data protection laws.

14. Automated Decision-Making and Profiling
We do not engage in automated decision-making or profiling using your personal data. If this changes in the future, we will update this policy and inform you accordingly.

15. Opt-Out for Marketing Communications
You can unsubscribe from our newsletter and other marketing communications at any time by following the unsubscribe link in the email or contacting us directly at info@nature-returns.eu.

16. Complaints
If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant data protection authority – CNPD – Comissão Nacional de Proteção de Dados, the Portuguese Data Controller Authority.

17. Children’s Privacy
We do not knowingly collect personal data from children under the age of 16.

18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Please review this page regularly for any changes. By continuing to use our website, you agree to the updated Privacy Policy.

19. Contact Us
If you have any questions about this Privacy Policy or your personal data, please contact us at info@nature-returns.eu.