The Navigator Company, S.A., as data controller, is committed to respecting the privacy of personal data subjects, adhering to the general principles of the General Data Protection Regulation (“GDPR”) and other applicable legislation.
In this regard, the data subject is informed about how their personal data is processed and protected.
1 – INTRODUCTION
The Navigator Company, S.A., with the Portuguese legal person identification number (NIPC) 503025798, registered under the same number at the Commercial Registry Office of Setúbal, with headquarters at Península da Mitrena 2910-738 Setúbal, with share capital of €500,000,000.00 (henceforth referred to as “Navigator”) is the entity responsible for the processing and protection of the personal data of the Data Subject collected through the website https://biodiversidade.com.pt/.
2 – PURPOSES OF THE PROCESSING AND LEGAL BASIS
The Data Controller will process personal data manually and/or automatically, only for the purposes defined and communicated below, in accordance with Article 5(1)(b) of the GDPR, namely:
Sending communications
- Personal Data – identification data (name) and contact data (email, telephone and address);
- Purpose of Processing – responding to contact requests submitted through the website https://biodiversidade.com.pt/, clarifying doubts and sending information related to content, initiatives, projects or activities disclosed on the website;
- Legal Basis – the processing of personal data is carried out based on the legitimate interest of the Data Controller, pursuant to Article 6(1)(f) of the GDPR, or with the free, specific, informed and unambiguous consent of the Data Subject, as provided for in Article 6(1)(a) of the same legislation.
- Data Retention Period – Personal data will be processed while the consent provided by the Data Subject remains valid, for the time strictly necessary to respond to the contact request and, subsequently, for an additional period of up to two years after the last contact, for the purpose of sending communications considered relevant, without prejudice to the exercise of the right to object to processing, under Article 21 of the GDPR.
Publishing Institutional Content
- Personal Data – image (photographs and/or videos), name (when applicable), other identifying elements contained in the published content;
- Purpose of Processing – Purpose of Processing – institutional dissemination of activities, initiatives, events and projects promoted by the Data Controller, through the publication of content on the website https://biodiversidade.com.pt/ and, when applicable, on other institutional channels;
- Legal Basis – processing is based on the consent of the Data Subject, pursuant to Article 6(1)(a) of the GDPR, whenever required. In certain institutional contexts or public events, it may also be based on the legitimate interest of the Data Controller, pursuant to Article 6(1)(f) of the GDPR, taking into account the rights and freedoms of the Data Subjects;
- Data Retention Period – the data will be kept as long as the purpose of institutional dissemination remains, without prejudice to the right of objection or withdrawal of consent by the Data Subject, when applicable.
Website usage management
- Personal Data – IP address, online identifiers, cookies and similar technologies;
- Purpose of Processing – to guarantee access to and correct functionality of the website https://biodiversidade.com.pt/; to ensure the security of systems and prevent unauthorized access; to carry out aggregated statistical analyses on browsing patterns and website usage; to manage consent regarding the use of non-essential cookies;
- Legal Basis – the processing of IP addresses and strictly necessary cookies is based on the legitimate interest of the Controller, pursuant to Article 6(1)(f) of the GDPR, namely, to enable connection to and use of the websites. The processing of optional or personalization cookies depends on the free, specific and informed consent of the Data Subject, pursuant to Article 6(1)(a) of the GDPR;
- Data Retention Period – the data will be kept for the period defined in the Cookie Policy, depending on the nature and purpose of each cookie or similar technology used.
Under certain circumstances, the Data Controller may determine different purposes, with other companies in the Navigator Group. In such cases, this Policy will be adjusted accordingly.
3 – DATA COMMUNICATION
We hereby inform that personal data may be communicated to Navigator Group entities which, in some cases, may act as co-responsible parties. These entities pledge to process personal data solely and exclusively for the fulfilment of the purposes identified above.
Navigator may also communicate the personal data to third parties as long as it has obtained consent or when:
- (I) The transmission is made in compliance with legal obligations or court order; and
- (II) The communication is made to protect vital interests or any other legitimate purpose foreseen by law.
4 – PROCESSORS
Navigator may hire external service providers, acting as processors, to provide services in different areas (e.g., communications services, IT consultancy).
In this regard, Navigator follows strict criteria when selecting service providers in order to comply with its data protection obligations, pledging to subscribe a data processing agreement with them which includes, among other things, the following obligations:
- Apply appropriate technical and organizational measures;
- Process personal data for the agreed purposes and respond exclusively to Navigator’s documented instructions;
- Delete or return the personal data to Navigator’s upon completion of services.
5 – INTERNATIONAL DATA TRANSFERS
Navigator will process personal data within the European Economic Area. However, in certain cases, it may carry out international transfers in order to comply with legal obligations, or in cases where it proves necessary to contract a service, as long as the third country ensures an adequate level of protection of personal data in accordance with the directives and agreements celebrated with the European Union.
6 – RETENTION PERIODS
The period for which we store personal data may vary depending on the purpose for which they were processed. In the event that the personal data is used for several purposes, which require Navigator to keep it for different periods, the longest retention period will apply.
7 – RIGHTS OF THE DATA SUBJECT
It is possible, at any time and free of charge, to exercise the rights of access, rectification or elimination, opposition, limitation and portability of personal data, through written communication sent to dpo_nvg@thenavigatorcompanhy.com or DPO/Ethics & Compliance – Av. Fontes Pereira de Melo, 27, 1050-117 Lisboa, Portugal.
Under the terms established in the applicable legislation:
- Access – You can obtain information on whether we are processing your personal data, as well as consult your personal data included in the Navigator archives;
- Rectification – You can change your personal data when they are incorrect or complete those which are incomplete;
- Erasure – You can request the elimination of your personal data when, among other reasons, the personal data is no longer necessary for the purposes for which they were collected;
- Objection – In certain situations, you may request that for your personal data to cease being processed. Navigator will cease the processing of personal data, except if there are legitimate grounds or for the declaration, exercise, or defense of rights in an administrative, judicial or extrajudicial proceeding;
- Restriction of processing – You may request the restriction of the processing of your personal data in the following situations: (a) during the dispute of the accuracy of your personal data; (b) when the processing is illicit and you have opposed to it and requested the restriction of the use of the personal data; (c) when Navigator no longer needs to process your personal data, but needs it for the exercise or defense of rights in an administrative, judicial or extrajudicial proceeding; (d) when you have opposed to the processing of your personal data for the fulfillment of an obligation of public interest or for the satisfaction of a legitimate interest, for as long as such legitimate grounds for processing prevail over those reasons;
- Portability – Em determinadas situações terá direito a receber, num formato estruturado, de uso corrente e leitura automática, os dados pessoais que tenha disponibilizado e aqueles que se tenham obtido a partir da sua relação com a Responsável pelo Tratamento, assim como a transmiti-los a outra entidade.
In certain situations, you will have the right to receive, in a structured, commonly used and automatically readable format, the personal data you have made available to us and those obtained from your relationship with Navigator, as well as to transmit them to another entity.
To exercise your rights, if necessary, you must provide proof of identity. You must also indicate the right you wish to exercise. The exercise of rights is free of charge, except in the case of a manifestly unfounded, excessive or repeated request.
In any case, we inform that if you consider that Navigator has violated, or may violate, your rights under the legislation regarding the protection of personal data, you may file a complaint with the Portuguese Supervisory Authority – Comissão Nacional de Proteção de Dados (cnpd.pt) – through the forms provided at https://www.cnpd.pt/cidadaos/participacoes/.
8 – WITHDRAWAL OF CONSENT
The acceptance that personal data may be processed or transferred will always be revocable, without retroactive effect.
To revoke consent, you can contact Navigator by writing to dpo_nvg@thenavigatorcompanhy.com.
9 – REQUIRED NATURE OF THE SOLICITED DATA
The data that is marked with an asterisk (*) in the forms provided by Navigator via its platforms will be required in order to fulfil the established purpose. Therefore, if they are not provided, Navigator will not be able to fulfil the request in question.
10 – AUTOMATED DECISIONS
The Controller may create profiles of the Data Subject, which will allow for automated decisions based on personal characteristics, preferences, behavioral history, and location. In these cases, the Data Subject will have the right to obtain human intervention in the decision, express their opinion, and contest the decision made by the Controller.
11 – PERSONAL DATA PROTECTION MEASURES
Navigator implements appropriate technical and organizational measures to ensure the protection of personal data, as well as to prevent unauthorized access to data, improper use, disclosure, loss or destruction.
Navigator makes every effort to protect personal data from unauthorized access via the Internet. To this end, it uses security systems, rules and other procedures to ensure the protection of personal data and to prevent unauthorized access to data, improper use, disclosure, loss or destruction.
It is, however, the responsibility of the data subject to guarantee and ensure that the computer it uses is adequately protected against harmful software, computer viruses and worms. Additionally, the data subject should be aware that without the adoption of appropriate security measures (e.g., secure browser configuration, updated antivirus software, security barrier software and the non-use of software of doubtful origin), the risk of personal data and passwords being accessed by unauthorized third parties is aggravated.
It should be noted that whenever data is collected on open networks, such as the Internet, personal data may circulate without security conditions and there is a risk that it may be seen and used by unauthorized third parties.
12 – CHANGES TO THE PRIVACY POLICY
Navigator reserves the right, at any time, without notice and with immediate effect, to amend, add to or revoke, in whole or in part, this Privacy Policy. Any changes will be immediately disclosed on this same online page; therefore we recommend its regular consultation for periodic review.
This policy is subject to regular review to verify that it complies with the applicable legal requirements and best practices in terms of personal data protection.
Last update: May 20th 2026
