Privacy Policy and Cookies Policy

6. How We Collect, Use, Share and Store Personal Data

a) Collection of personal data

1. For situations that don’t involve web tools

Personal data is collected directly in the following ways:

• • Spontaneous applications or response to job offers with Curriculum Vitae sharing;
  • Filling out paper forms;
  • Capture of images and videos during rowing tours;
  • E-mail;
  • Telephone.

Personal data may be collected indirectly in the following ways:

• • Import of the content of the Curriculum Vitae for the human resources registration record;
  • Data import with shared responsibility with contracted business partners;
  • Marketing outlets, catering services, or the like;
  • Job Seeker Screening Companies;
  • Medical service companies;
  • Life Insurance Service Companies.

The collection of sensitive personal data will only be carried out in cases that are strictly necessary and justifiable by the activity carried out by Row For Fun and in accordance with the legislation in force.

2. For situations involving web tools

Personal data may be collected directly through the organization’s official digital platforms, or indirectly through marketing automation systems and online advertising tools operated by duly authorized subcontracted partners, in full compliance with our Personal Data Privacy Management Policy.

Indirect collection may also occur through authorized partners involved in order processing, such as the purchase of tickets or access to exhibitions and company services.

The Cookie Management Policy complements this section by detailing the available “opt-in” and “opt-out” mechanisms related to cookies and similar technologies on our websites.

Data subjects may also “opt out” of targeted advertising through social media and online advertising platforms, including Facebook, Google Ads, Instagram, and LinkedIn.

Row For Fun ensures that no manual or digital form includes pre-selected options, guaranteeing that all choices are made consciously and explicitly by the data subject.

All personal data are collected based on the legal grounds established in this policy and in strict adherence to the principle of data minimization.

b) Sharing of personal data

1. For situations that don’t involve web tools

In addition to the sharing purposes described below, no other purposes may be carried out, unless previously and expressly authorized by the Data Protection Officer.

Purposes arising from the activity of Row For Fun, Lda., inter alia:

• • Social security;
  • Communication with Tax Authority, Customs or other legal entities;
  • Communication of complaints or privacy violations;
  • Port security and immigration control;
  • Labour registration & payroll;
  • Issuance of the medical certificate for maritime or similar purposes;
  • Compliance with registration and union obligations;
  • Creation and registration of insurance policy;
  • Compliance with tax and customs obligations.

Personal data may be shared with subcontracted entities for the purposes referred to above, under the terms of the contracts entered into with them. Row For Fun only uses processors that ensure, in accordance with the law, the implementation of appropriate technical and organizational measures for the protection of your data through subcontractor agreements, thus ensuring the defense of your rights under the applicable data protection law.
The sharing of data classified as sensitive will only be carried out with legal entities, partners, medical service providers and the like.

2. For situations involving web tools

In addition to the sharing purposes described below, no other purposes may be carried out, unless previously and expressly authorized by the Data Protection Officer.

Purposes arising from marketing, electronic payments and other services involving the use of electronic tools:

• • Conducting advertising campaigns;
  • Advertising in virtual places such as Google Ads, Facebook, Instagram and Linkedin;
  • Operational needs in the interconnection with HiPay and Paypal and other electronic payment gateways using credit cards;
  • Sending news, campaigns and personalized offers to the customer.

Data is shared with formally authorized subcontractors for digital marketing purposes, and the personal data involved in these shares are subject to the consent of the respective owner, with the possibility of opt-out at any time.

These shares may give rise to data transfers outside the European area, in the case of segmentation of digital marketing campaigns with intercontinental subcontracting partners. In these cases, the organization will take care to implement security controls appropriate to each risk situation identified, as well as to ensure the guarantee of the unconditional execution of their rights and all the requirements of the General Data Protection Regulation.

c) Retention of personal data

Retention is understood as the secure storage of data, in digital or paper format, ensuring the conditions of access management to guarantee confidentiality, integrity, availability of information and non-repudiation, as well as its preservation in the appropriate conditions of use according to the defined time.
Legal requirements requiring the retention of personal data for a minimum period for each purpose will be complied with. In particular, when data retention is mandatory for the purposes of fulfilling our tax documentation obligations, in which case we will retain the data for 10 years after the end of the relevant tax period.
Where such a minimum period is not imposed, personal data will be kept only for the period strictly necessary for the pursuit of the purposes for which the data were collected or are subsequently processed or, if and when applicable, for the period determined by the competent data protection authority, after which the data will be permanently deleted in secure mode.

d) Use of personal data for promotional communications

Row For Fun may use the contact details provided by customers and partners to send information about activities, special offers or promotional campaigns related to its services.

Such communications will always be carried out in accordance with applicable data protection regulations and based on the data subject’s consent, which may be withdrawn at any time.

Row For Fun guarantees that personal data used for these communications will never be shared, sold, or made available to third parties for independent marketing purposes.

All promotional messages will include clear and accessible mechanisms allowing recipients to unsubscribe (“opt-out”) from future communications, in accordance with the principles of transparency and lawful processing.