1. About this privacy policy

This privacy policy explains how we collect, use, share, and transfer your data when you use the services provided on our sites or interact with us; and your personal data privacy rights.

We define your data as any information about you by which you can be identified or be identifiable. This can include information such as:

• your name, email address, company, phone number, job function or geographical location
• information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based)
• information relating to how you use and interact with our sites, communications and services

When we refer to “personal data” in this policy, we are also referencing “personal information,” as it is defined under California law and as it is defined under Australian law.

Our Services and our Business-Client relationship have their own, individually defined, set of privacy rules.

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2. Who we are and how to contact us

4TUNE ENGINEERING, Limited, Av. António Augusto Aguiar N. 108 - 4, 1050-019 Lisbon, Portugal is the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “How to contact us” section below.

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3. The types of personal data we collect from you

We collect your personal data when you visit our websites, subscribe our newsletters, use our resources or when you interact with us. We will only collect your personal data in line with applicable laws. We collect your personal data in various ways:

• directly from you, when you sign up to access or download our content
• personal data we generate about you, e.g. personal data we use to authenticate you, or personal data in the form of your IP address or your preferences
• personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts

More details about these three categories of personal data are provided below.

3.1 Personal data collected directly from you

When you access or download content on our sites in 4tuneengineering.com we collect:

• your name
• your email addresses
• your geographical location
• your job positions
• your company

3.2 Personal data we generate about you

When you use our sites, we may also use cookies or similar technology to collect data, including:

• your IP address - a numerical code to identify your device, together with the country, region or city where you are based
• your geolocation data - your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment
• information on how you interact with our services
• your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites and the communications you have opened
• details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content

We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health or sexual orientation.

3.3 Personal data we collect from third parties

If you have mentioned 4TE in posts on social media sites, then we may collect your social media handles. For example, when you mention the 4TE in a LinkedIn post, we may collect your LinkedIn handle.

When you post on a discussion board or comment publicly on an article on one of our sites, the personal data you post, including your username and other information about yourself, are publicly accessible. This personal data can be viewed online and collected by other people. We are not responsible for the way these other people use this personal data.

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4. How we collect personal data

We collect personal data when you:

• access our content or download our articles
• attend our events
• enter our surveys
• post in our online communities
• sign up for marketing communications
• use mobile devices to access our content
• access and interact with any of our sites
• through cookies and other similar technology
• when you contact us via email, social media or similar technologies or when you mention us on social media

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5. How we use your personal data

We use personal data collected through our sites only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.

The legal ground may be one of the following:

• Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email.
• Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
• Our legitimate interests: Where it is necessary for us to understand our clients, promote our services and operate our sites efficiently for the creation, publication and distribution of services and content both online and in print form, globally. Examples of when we rely on our legitimate interests to use your personal data include:
• when we analyse what content has been viewed on our sites, so that we can understand how they are used and improve our content
• o carry out marketing analyses to better understand your interests and preferences so that we can make our marketing more relevant to your interests and preferences. This includes when we promote our own products and services. For example, we look at what you have viewed on our sites.
• to show you personalised advertising by identifying your interests and to create “segments” of particular types of audiences that we may show you advertisements that may be more relevant to your interests and the ‘’segments’’ you may be in. These ‘’segments’’ are also used to inform the building of custom audiences so that we can identify our audience across third party websites, such as social media platforms like LinkedIn.
• for internal administrative purposes related to when you use our services - such as our accounting and records - and to make you aware of any changes to our services
• to collect and log IP addresses to improve the website and monitor website usage
• enabling you to share our content with others using social media or email
• when responding to your queries and to resolve complaints
• for security and fraud prevention, and to ensure that our sites and are safe and secure and used in line with our terms of use

Where we rely on cookies to collect any personal data please see our cookie policy for more information and how to manage your cookie choices.

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6. International Data Transfers

We may transfer your personal information to countries other than the country in which the data was originally collected, including Brazil. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the personal information.

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7. Using children’s personal data

We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13. Some of our services may have a higher age restriction and this will be shown at the point of registration.

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8. Security of your personal data

We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.

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9. When we share your personal data

We may share your data for administrative purposes, or when we have a legitimate interest in doing so. For example:

• If you are going to one of our events hosted by an event partner, we may share your personal data with that partner for event administration purposes.
• We may share your data to understand how you interact across our group products or to tailor and offer relevant advertising to you.
• We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:
• internet and cloud hosting services providers, such as Microsoft Azure
• software service providers such as Hubspot that assist us with our customer relationship management
• other platforms that we may use for our services and content.

We may share your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer ever takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy.

Any organisations which access your data in the course of providing services on our behalf will be governed by contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply.

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10. How long we keep your personal data

We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you.

If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.

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11. How we may contact you

If we have your permission, we may send you materials we think may interest you, such as new contente or information.

You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email.

Sometimes we may contact you for market research purposes, for example about a survey.

If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

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12. Cookies and similar technologies

When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technologies. A cookie is a small file that can be placed on your device that allows us to recognize and remember you. It is sent to your browser and stored on your computer’s hard drive or tablet or mobile device. When you visit our sites, we may collect information from you automatically through cookies or similar technology, such as a tag, pixel, or other web beacon.

This privacy policy includes our cookie policy, where you can find details of our key advertising partners.

We use cookies in a range of ways to improve your experience on our site, including:

• Understanding how you use our site
• Showing you content that is relevant to you
• Showing you 4TE products and services that are relevant to you
• Working with partners to deliver to you relevant advertising

4TE only uses 3rd-party cookiers – cookiers used by our partners such as LinkedIn, Hubspot and Google. Because of how cookies work, our website cannot access third-party cookies; nor can other organisations access the data in the cookies we use on our website.

Cookies are a key part of how we deliver advertising on our sites. Among other uses, they allow us to show more relevant advertising to people who visit 4tuneengineering.com by showing you adverts that are based on your browsing patterns and the way you have interacted with our sites and apps. We can then show you adverts which we believe may interest you.

It is possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser.

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13. Your privacy and data protection rights with regard to the personal data that we hold about you

You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:

• You have the right to receive a copy of the personal data we hold about you
• You have the right to correct the personal data we hold about you
• Where applicable, you may also have a right to receive a machine-readable copy of your personal data
• You also have the right to ask us to delete your personal data or restrict how it is used, consistent with the GDPR. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request
• Where applicable, you have the right to object to processing of your personal data for certain purposes
• Where you have provided us with consent to use your personal data, you can withdraw this at any time
• If you do not want us to use your personal data for marketing analysis, you can unsubscribe

If you would like to exercise any of your rights specified above, please email qms@4TuneEngineering.com or write to the Data Protection Officer at 4TUNE ENGINEERING, Limited, Av. António Augusto Aguiar N. 108 - 4, 1050-019 Lisbon, Portugal. We will deal with requests within one month.

CWe may need to request specific information from you to help us confirm your identity. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

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14. Contact us for information about how we use your personal data

If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please email qms@4TuneEngineering.com or write to the Data Protection Officer at 4TUNE ENGINEERING, Limited, Av. António Augusto Aguiar N. 108 - 4, 1050-019 Lisbon, Portugal.

Complaints will be dealt with by the Data Protection Team and will be responded to within 30 days.

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15. Changes to this privacy policy

If we decide to change our privacy policy, we will post the changes here. If the changes are significant, we may also choose to email all our registered users with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.