This Privacy Policy sets out the general terms and conditions under which the AGA KHAN FOUNDATION PORTUGAL (hereinafter "AKF Prt”), a private law entity of public utility, with statutes approved by Decree-Law No. 27/96 of 30 March and subsequent amendments, corporate identification number 503841560, with registered office at Centro Ismaili, Av. Lusíada no. 1, 1500-650 Lisbon, processes the personal data of visitors and users (hereinafter "Users”) of this website located at "https://moodle.akfportugal.com/”, as well as the rights that data subjects may exercise, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation (GDPR) and applicable national legislation, namely Law No. 58/2019 of 8 August (hereinafter "Privacy Policy”).

This Privacy Policy aims to communicate transparently to the Users of the website managed by AKF Prt how the information provided will be processed by AKF Prt, as the data controller.

AKF Prt undertakes to comply with current legislation at all times and to process personal data in accordance with this Privacy Policy.

Whenever personal data is provided to AKF Prt through registration on the website, the personal data transmitted will be processed in accordance with the legal requirements defined for each specific situation. For AKF Prt, the privacy and protection of Users’ personal data on this website are of utmost importance, ensuring compliance with all GDPR requirements.

AKF Prt’s Privacy Policy should be read beforehand to understand and become aware of how the information provided to us will be processed.

"Personal data”: any information relating to an identified or identifiable natural person ("data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, psychological, economic, cultural or social identity.

"Processing of personal data”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Personal data filing system”: any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.

"Data controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

"Consent of the data subject”: any specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

"Supervisory authority”: an independent public authority which is responsible for monitoring compliance with the GDPR and relevant national legislation on personal data protection. In Portugal, the supervisory authority is the National Data Protection Commission (CNPD).

The data controller is AKF Prt, a private law entity of public utility, with registered office at Avenida Lusíada, no. 1, Lisbon, corporate identification number 503841560.

As the entity responsible for the website, AKF Prt undertakes to guarantee the privacy of the personal data provided by Users electronically when interacting with the website.

When a visitor registers on the AKF Prt website, it may collect the IP address for statistical purposes. Email, name, gender, date of birth, location, qualifications or other personal data may be collected, subject to the User’s prior consent.

At any time, the User may withdraw consent by contacting AKF Prt at the email address rgpd.akfportugal@akdn.org or by post to FUNDAÇÃO AGA KHAN PORTUGAL, Centro Ismaili, Av. Lusíada, No. 1, 1500-650 Lisbon.

The personal data collected through the website is intended for the following purposes:

a. Communication of information about ongoing activities and projects or subscription to AKF Prt newsletters, as defined by the data subject, through their express, free and informed consent.

b. Preparation of website access statistics to understand the profile of website Users. However, statistical information does not include details that could be used to identify those Users.

c. Increasing the level of personalisation of the website to suit, as far as possible, Users’ tastes and preferences based on the data collected.

The data collected is processed exclusively by AKF Prt.

Under no circumstances will AKF Prt make international transfers of personal data to third countries or international organisations outside the European Union.

AKF Prt adopts the necessary and appropriate technical and organisational measures to ensure the security of personal data and to prevent unauthorised and unlawful processing, accidental loss, misuse or unauthorised access, destruction or damage, including in the case of subcontracting data processing operations.

AKF Prt emphasises that personal data will only be processed for the purposes for which it was collected, as provided for in this Privacy Policy.

AKF Prt regularly reviews its data collection, storage and processing policies to ensure that only adequate, relevant and limited data is processed in relation to the purposes of processing.

AKF Prt adopts appropriate procedures to ensure that information is accurate, complete and up to date, but relies on data subjects to update or correct their personal information when necessary.

Notwithstanding all security mechanisms adopted and compliance with all personal data protection rules, Users should be aware that, for example, when browsing the Internet, if their access does not have the necessary protection barriers (antivirus, firewall, antispyware, etc.), their personal data may be viewed and used by unauthorised third parties.

In this context, AKF Prt is obliged to warn Users to take appropriate precautions to ensure greater security when using the Internet, namely by ensuring that they use a browser that allows secure communication.

AKF Prt takes all necessary and legally required precautions to ensure, taking into account available technology, an adequate level of protection of the information collected from website Users, namely through the implementation of necessary technical and organisational measures to protect their personal data against accidental destruction, loss or alteration, as well as against unauthorised access and other unauthorised processing, namely: (i) password protection, (ii) physical access restrictions to locations where servers storing personal data are located; (iii) firewalls, (iv) secure communication via https protocol, using digital certificates.

AKF Prt informs that the aforementioned security measures are reviewed and updated according to needs and state of the art.

If, for any reason, a security breach occurs that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorised access to personal data, AKF Prt will notify the competent
authorities without undue delay and, where possible, within 72 hours of becoming aware, in accordance with applicable legislation. Similarly, AKF Prt will notify the data subject of the breach, in accordance with applicable legislation.

In accordance with applicable legislation, AKF Prt undertakes to respect the confidentiality of data subjects’ personal information and to guarantee the exercise of the following rights:

a. Right to be informed: Users have the right to obtain clear, transparent and understandable information about how AKF Prt uses data subjects’ personal data.

b. Right of access: In addition to the right to information, Users may access their personal data that is processed and stored. In these cases, AKF Prt will provide access to a copy of the personal data being processed. In addition, when requested by electronic means, the information will be provided in a commonly used electronic format.

c. Right to rectification: Users have the right to rectify their personal data if it is incorrect, outdated or if they wish to complete it.

d. Right to erasure/right to be forgotten: Users may request AKF Prt to delete their data, however, they should bear in mind that this is not an absolute right, as AKF Prt may have legal grounds or other legitimate interests to retain the personal data.

e. Right to withdraw consent at any time: Users may withdraw consent to the processing of personal data when such processing is based on the data subject’s consent. However, withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

f. Right to data portability: Users have the right to move, copy or transfer data from AKF Prt’s database to another.

g. Right to restriction of processing: Users have the right to request restriction of processing of their personal data in the following situations: if they contest the accuracy of the data, if processing is unlawful and they do not wish to erase the data but only restrict it, if the data is no longer necessary for AKF Prt but necessary for the User, or if they have exercised the right of opposition referred to above, during the period in which AKF Prt assesses whether its legitimate interests for processing prevail over that right.

To exercise any of the aforementioned rights, in addition to the methods specifically referred to in the respective paragraphs, the User may do so by sending an email to rgpd.akfportugal@akdn.org or contacting AKF Prt in writing at Centro Ismaili, Av. Lusíada no. 1, 1500-650 Lisbon.

If the User considers that there has been an infringement of their rights, they may lodge a complaint with a supervisory authority. In Portugal, the supervisory authority is the CNPD. More information about the CNPD is available at www.cnpd.pt.

Personal data will be retained for different periods of time, depending on the purpose for which it is intended and taking into account legal, necessity and minimisation criteria.

Whenever there is no specific legal requirement, personal data will be stored and retained only for the minimum period necessary to pursue the purposes that led to its collection.

For example, for newsletters, the retention period begins upon obtaining consent through registration on the AKF Prt website and ends when the User cancels the subscription. Upon unsubscribing, the User will receive a notification email and their data will be removed from the newsletter distribution list.

The right of access, rectification, erasure and portability, as well as the right to object and the right to complain, may be exercised by the data subject by contacting AKF Prt at the following email address: rgpd.akfportugal@akdn.org or the following address: FUNDAÇÃO AGA KHAN, Centro Ismaili, Av. Lusíada no. 1, 1500-650 Lisbon.

In case of doubt about this Privacy Policy, the data subject may obtain additional information or clarify any doubt by sending their questions to the email address or address indicated above.

AKF Prt will respond to the data subject’s request within a maximum period of one month from receipt of the request, unless in cases of particular complexity, in which case this period may be extended to two months.

If requests made by the data subject are manifestly unfounded or excessive, particularly due to their repetitive character, AKF Prt reserves the right to charge administrative costs or refuse to act on the request.

See Cookies Policy

This website managed by AKF Prt may contain hyperlinks to other websites. AKF Prt is not responsible for the privacy policies of those websites. Users of the AKF Prt website are advised, when accessing other websites, to consult the pages within those websites that relate to their privacy policies. This information relates only to the privacy policy applicable to the AKF Prt website.

AKF Prt reserves the right, at any time, to amend its Privacy and Cookies Policy. Such amendments will be duly publicised on this website.

If Users have any questions about the security and privacy of this website, they should contact AKF Prt at rgpd.akfportugal@akdn.org or by post to Fundação Aga Khan Portugal, Centro Ismaili, Av. Lusíada, No. 1, 1500-650 Lisbon.

Published on: 30 September 2021