PRIVACY POLICY

1. Identification of the Controller

WHYSTAR DELTA PT, LDA. (hereinafter referred to as “BRIDGEWHAT”) is the Controller of the processing of your personal data in order to provide you the services identified in this website (the “Website”). WHYSTAR DELTA PT, LDA., is a Portuguese company with Tax ID number is 516 059416, with registered office at Rua Ernesto da Silva, 52, 4B, 1500-269 Lisbon.

You can contact BRIDGEWHAT via the following email-address:

bridgewhat@bridgewhat.com

BRIDGEWHAT is committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights.

2. Information and consent

The Portuguese Data Protection Law, “Lei da Proteção de Dados Pessoais” (hereinafter, “LPDP”) and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th of April 2016, hereinafter “GDPR”) shall ensure the protection of natural persons with regard to the processing of personal data and the free movement of such data.

According to the Law, personal data refers to any “information relating to an identified or identifiable natural person, “the data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that natural person.”

By accepting this Privacy Policy, the user gives their express, free and unequivocal consent to the personal data provided through the website https://bridgewhat.com/ to be included in a file belonging to BRIDGEWHAT, whose protection of personal data complies with the appropriate technical and organizational security measures.

BRIDGEWHAT maintains a database with the registration of its clients composed only of the personal data provided by the data subjects at the time of registration, which are collected and processed automatically by BRIDGEWHAT, the entity responsible for the processing of the personal data (“Controller”).

In no case shall personal data on racial or ethnic origin, political opinions, religious or philosophical beliefs, political opinions, trade union membership, data on health, genetic data, biometrics or data relating to sexual life or sexual orientation be solicited.

In no case shall BRIDGEWHAT carry out any of the following activities with the personal data provided through this site, without the express prior consent of the data subject:

• Provide the data to other people or other entities;

• Transfer the data outside the European Economic Area (EEA).

3. What information will we collect from you?

You should be aware that there are different ways to collect personal data:

We collect information about you when you use the Platform and website in the following way:

• When you enter the website, we may collect personal data through cookies, for more information please consult the Cookies Policy.

• When you browse, different cookies and other tracking devices may be installed on your device, as explained in our Cookies Policy.

• When you register in the Platform, we may collect your name, surname, email address and company job function, and other data about your professional profile and academic background, especially in case you are applying to work with us.

• When you purchase one of our subscription packages, we will also collect the financial information required for payment and billing of these services.

It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect, you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.

In order to ensure that the information provided is always up to date and free of errors, you must keep your personal data updated through the options enabled in the "my account" section.

BRIDGEWHAT will assume your data are correct unless you proceed to change them in the mentioned section.

Likewise, by clicking on the “I accept” (or equivalent) button incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.

4. What is the source of your data?

We will process personal data that we receive when you visit our websites, use our service or contact us.

In the event that the personal data provided is from a third person, you guarantee that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to BRIDGEWHAT for the purposes indicated above. You also guarantee that the information provided is accurate and up to date, and you are responsible for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.

5. How will we use your personal information and what services will we provide you?

BRIDGEWHAT acts as the controller of the personal data for the following purposes:

• Based on the management of the contractual or pre contractual relationship:

a) To manage your registration as a user on our Platform, as well as allow your access to the free services included in our platform and all landing pages.

b) To manage the acquisition of the subscription package you had chosen, allow your access to the services included in our platform and which must be accessible according to the contracted package, to attend to any type of incident or request derived from the same, and carry out any management related to the package contracted or after-sales service.

c) To provide you with the services you have requested and to attend to your requests for information, as well as to facilitate the exercise of your rights.

d) Analyze the data provided in order to offer you suggestions of services (or services requests) that may be of interest to you provided by other individuals or companies.

e) To evaluate the CVs received and manage the selection processes. Surveys may also be conducted on own or by third party services, that you have used on the platform, although these surveys will not be associated with personal data of any kind.

• Based on the existence of a legitimate interest of BRIDGEWHAT:

 a) To keep you informed about the products and services of BRIDGEWHAT, as well as to send you news, events and other activities that we carry out in BRIDGEWHAT, by conventional and/or electronic means (e-mails, SMS, …), related to the products or services that we carry out and that may be of your interest.

b) To carry out periodic reviews of our services and carry out satisfaction surveys in order to evaluate and improve the quality of the service we provide;

c) To carry out internal reviews and, if necessary, contact the client in the event that a possible fraud or identity theft is detected or there are well-founded suspicions.

On the basis of the explicit, free and unequivocal consent that you give us at the time of collecting your data:

a) If applicable, to keep you informed about products and services of third parties, always sent through BRIDGEWHAT, and provided that you have given us your explicit consent to do so, by conventional and/or electronic means (emails, SMS, …).

b) Conduct non-anonymous surveys in which the user wants to participate on a voluntary basis.

However, if you do not wish your data to be processed for these purposes, you may object at any time by contacting us at bridgewhat@bridgewhat.com as indicated in the Rights Management section of this Privacy Policy.

In addition, BRIDGEWHAT guarantees the confidentiality of all data provided. Although BRIDGEWHAT collects and processes data in a secure manner and prevents its loss or manipulation using the most appropriate techniques, it should be borne in mind that the collection of data in open networks allows personal data to be circulated without safety conditions, with the risk of being seen and used by unauthorized third parties.

6. Failure to respond to data marked as mandatory, implies the inability to respond to the request of the data subject.

Data transfers and international transfers.

a) All transfers of personal data that we carry out are necessary for the fulfilment of the above-mentioned purposes, or are made in order to fulfil a legal obligation:

b) To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us.

c) To the courier companies we work with to deliver your orders.

d) Companies providing payment services (banks, payment gateways, etc.), in case the customer makes a payment through the service offered by one of these companies.

e) Companies providing IT services, tools or IT infrastructure on which the services provided by BRIDGEWHAT are based, such as hosting providers, CRMs, emailing service companies, event organizing companies, educational partners analytical companies, etc.

In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers as established by the regulations.

Furthermore, BRIDGEWHAT guarantees that the necessary safeguards are in place to ensure that the data can be transferred securely, either because the provider offers adequate guarantees, though, among others the signing of Standard Contractual Clauses of the European Commission, or any of the exceptions contained in the regulations.

In no case shall BRIDGEWHAT carry out any of the activities above mentioned with the personal data provided through this website, without the express prior consent of the data subject to transfer the data outside the European Economic Area (EEA).

7. Exercising your rights.

We inform you that you will be able to exercise the following rights:

1. Rights of access to your personal data to know which ones are being processed and the processing operations carried out with them.

2. Right to rectify any inaccurate personal data;

3. Right to delete your personal data, where possible;

4. Right to request limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may retain the data for exercise or defense of claims;

5. Right to object to the processing of your personal data when the legal basis that enables us to process them is the legitimate interest;

6. The right to the portability of your data, when the legal basis that enables us to process them is the existence of a contractual relationship or your consent;

Right to revoke the consent granted to BRIDGEWHAT. If you object, we will no longer process your personal data, unless we can show that there are compelling, protected reasons for processing your data that outweigh your interests, rights, and freedoms, and unless your data are processed to assert, exercise, or defend legal rights or claims. Objections may be made informally and should be addressed as shown above.

You can exercise your rights at any time and for free in the following ways:

1. By sending an e-mail to bridgewhat@bridgewhat.com indicating the right you wish to exercise and your identification data.

2. By sending a written request to the address Av. da Liberdade 110 – 1º, 1269-046 Lisboa, indicating the right you wish to exercise and your personal data.

3. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you can unsubscribe from all previously accepted commercial communications.

We also inform you that you have the right to file a complaint at the Portuguese Data Protection Authority (the National Data Protection Commission, CNPD), if you believe that we have breached the applicable data protection legislation regarding the processing of your personal data.

8. Retention periods and Cookies.

We will only keep your data for as long as necessary to provide you with these services.

Any of the data you provide us through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available if there is a legal obligation (derived from a request from the appropriate authorities) and when you exercise your rights.

Regarding the personal data obtained through the BRIDGEWHAT channels, BRIDGEWHAT uses cookies according to the Cookies Policy that you can consult here.

9. . Security and confidentiality.

BRIDGEWHAT states that it has implemented and will continue to implement the security measures of a technical and organizational nature necessary to guarantee the security of the personal data provided to it, in order to prevent its alteration, loss, unauthorized treatment and/or access, taking into account the current state of the technology, the nature of the data stored and the risks to which it is exposed.

BRIDGEWHAT guarantees the confidentiality of the data provided through this website. The collection and processing of data takes place safely and prevents its loss or manipulation.

The personal data is treated with the level of protection legally required to guarantee the security of the same, as well as prevent unauthorized alteration, loss, unauthorized processing, considering the state of the technology, being the user aware and accepting that the security measures of Internet are not impregnable.

Whenever BRIDGEWHAT accesses personal data, it undertakes to:

• Store the data by means of legally enforceable security measures of a technical and organizational nature that guarantee their security, thus avoiding unauthorized alteration, loss, processing or access, according to the current state of technology, the nature of the data and the possible risks to which they are exposed;

• Use the data exclusively for the purposes which were previously defined; and

• Make sure that the data is handled only by the employees whose intervention is necessary to satisfy the request of the data subject, being the same obliged to the duty of secrecy and confidentiality. Should the information be disclosed to third parties for said purposes, they should be required to keep the confidentiality in accordance with what is envisioned in this document.

10. Minors

Minors under 14 years of age may not use the services available through the Platform without the prior authorization of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the Platform by the minors in their care, including the filling of forms with the personal data of such minors and the marking, where appropriate, of the boxes accompanying them. In this regard, and to the extent that BRIDGEWHAT is not able to control whether or not users are minors, it shall be the parents and guardians who shall enable the necessary mechanisms to prevent minors from accessing the Platform and/or providing personal data without their supervision, and BRIDGEWHAT shall not accept any liability in this regard.

11. Update of the privacy policy

We do our best to keep our privacy policy fully updated on a monthly basis. If we make changes, they will be clearly identifiable in a conspicuous manner (for example: we may communicate changes to you by email).

This privacy policy has been reviewed and published as of March 25, 2024