Personal Data Protection Policy 

1. Entity Identification and Contacts

Who we are? 

WISDOM SELECT – CONSULTORIA DE GESTÃO, LDA (henceforth, Fullback), is a Sports Management and Technology Consulting company.

Address: Rua Doutor Manuel Carvalho, nº 6, R/C, 2500-328 Caldas da Rainha

Contact: 

Email: geral@fullback.pt 

This Policy is made available to Customers/Users of our products and services, both in Portugal and abroad.

2. Objectives and Scope of the Policy

Purpose of the document

This Personal Data Protection Policy aims to:

• Informing data subjects of the general rules governing the collection, processing and storage of their personal data.
• Ensure that data processing is carried out in accordance with Regulation (EU) 2016/679 (GDPR) and Law No. 58/2019 of August 8, 2019.
• To demonstrate Fullback’s commitment to the security, confidentiality and protection of the personal data of its Customers/Users.

Scope

It applies to the collection and processing of personal data carried out by Fullback within the scope of the services and products provided, covering all situations in which data is collected, whether through face-to-face meetings, telephone, written form or through the website.

3. Personal Data – Definition and Categories Processed

What is Personal Data?

Personal data is any information, regardless of the medium, which makes it possible to identify or make identifiable a natural person, directly or indirectly, through elements such as name, identification, location data, electronic identifiers, among others.

Categories of Data Processed

Fullback processes the following types of personal data in an appropriate and proportionate manner:

• Identification data: Name, address, telephone number, e-mail address, VAT number, etc.
• Data of a Contractual Nature: Information necessary for the execution of services and products.
• Traffic and Usage Data: Information relating to access, use of services and, where applicable, geographical location, profile and consumption habits.
• Data for Marketing and Dissemination: Personal data collected for the promotion of products and services, with the prior consent of the data subject.
• Other Data: Data that may be collected for social intervention, recruitment, market research or surveys.

4. Purposes of Porcessing and Legal Basis

Purposes of processing

The personal data collected will be used for the following purposes:

• Contractual Relationship Management: Execution and management of contracted services and products.
• Compliance with Legal Obligations: Storage and transmission of data for legal and investigative purposes, where necessary.
• Marketing and Promotion: Sending information, newsletters, campaigns and promotions, provided that the holder has previously consented.
• Improving Services: Adapting and personalizing the services provided, suggesting specific content and functionalities.
• Other Purposes: For recruitment actions, social intervention or market studies, always with due information and, if necessary, consent.

Legal bases (according to article 6 of the GDPR)

• Execution of a Contract: When the data is indispensable for the provision of the contracted services.
• Legal Obligation: To comply with legal obligations imposed on Fullback.
• Consent: When processing data for marketing and promotional purposes or other optional activities, with the express acceptance of the data subject.
• Legitimate Interests: To the extent necessary for the internal management and security of the services provided, always safeguarding the rights of the holders.

5. Collection and Storage of Personal Data

How and When Do We Collect Data?

• Data is collected directly from data subjects, either in person, by telephone, in writing or via the website.
• Processing can be automated or not, and is stored in specific and secure databases.

Conservation Criteria

• The data will be kept for the period strictly necessary to achieve the purposes for which it was collected, respecting the minimum legal storage periods.
• In the event of specific legal obligations, the data will be kept for the time required by law.

6. Recipients of Personal Data

Personal data may be communicated to:

• Police, judicial, tax and regulatory bodies, when necessary to comply with legal obligations.
• Third-party entities that carry out processing on behalf of Fullback, provided that they undertake to adopt appropriate technical and organizational measures.
• Under no circumstances will data be transferred outside the European Economic Area, unless adequate protection mechanisms are guaranteed (e.g. standard contractual clauses).

7. Data subjects’ rights

As data subjects, Customers/Users may exercise the following rights at any time:

• Right of Access: Request information about your personal data.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Restriction of Processing: Request the restriction of data processing.
• Right to Portability: Request that your data be transferred to another controller, in accordance with the law.
• Right to Object: To object to the processing of data, especially for marketing purposes.
• Right to Erasure: Request the erasure of your data, except when the processing is indispensable for the provision of the service or for compliance with legal obligations.
• Right to Withdraw Consent: Withdraw the consent previously granted, without compromising the lawfulness of the processing carried out up to that point.

How to exercise your rights

Holders can exercise their rights through the following channels:

• Email: geral@fullback.pt 
• Mail: Send a written communication to the address above.

8. International Data Transfers

Fullback does not currently transfer personal data outside the European Economic Area.

In the event of a transfer to third countries, we will ensure appropriate legal mechanisms (such as standard contractual clauses approved by the European Commission or other safeguards to ensure a level of protection equivalent to that required by the GDPR.

9. Automated Decisions and Profiling

Fullback does not make automated decisions that produce legal or significantly similar effects for data subjects.

Should any form of automated decision-making be implemented, data subjects will be duly informed and given the opportunity to express their consent or opposition, as required by the GDPR.

10. Data Processing of Minors

If, for any reason, Fullback’s services or products are directed at minors, personal data will only be processed with the express consent or authorization of their legal guardians.

In particular, in the case of minors under the age of 13, processing will be subject to the authorization of the holders of parental responsibility.

11. Security measures

Fullback adopts strict technical and organizational measures to protect personal data against unauthorized access, loss, disclosure, alteration or any form of unlawful processing.

These measures include, but are not limited to:

• Adoption of firewalls, antivirus and encryption systems.
• Access control and user authentication policies.
• Written contracts and commitments with third parties who process data on behalf of Fullback, ensuring that they comply with legal data protection requirements.

Despite the efforts and measures taken, it is recommended that owners also use up-to-date equipment and software and take additional measures to protect their own online security.

12. Policy updates and validity

This policy comes into effect from April 2025 and may be reviewed and updated periodically in the light of legislative or operational changes. We recommend that you consult this policy regularly to stay informed of any changes.

13. Complaints and Contacting the Control Authority 

If the data subject believes that their rights have been violated, they may:

• Contact Fullback directly through the channels indicated to resolve the issue.
• File a complaint with the National Data Protection Commission (CNPD).

For further clarification or complaints, please send an email to geral@fullback.pt or go to the address above.