Privacy Policy


Effective date: March 30, 2023

ZUVI NOVA SA, its affiliates and subsidiaries (“ZUVI NOVA Group”, "us", "we", or "our") is incorporated in Portugal with company number PT508993970.

ZUVI NOVA Group operates the websites www.ttrdata.com, www.ericapro.com, and www.sustanya.com (the "Service" or “Sites”).

This privacy policy is applicable to ZUVI NOVA Group.


Your privacy is very important to us, and we are firmly committed to protecting the privacy of personal information that you provide to us when using our Service. We act in accordance with the provisions of the General Data Protection Regulation (“GDPR”) and other applicable legislation, and we are registered with the Portuguese Data Protection Authority’s Office under number 784/2010.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

By using the Service, you agree to the collection and use of information in accordance with this policy. Please do not use the Service or provide your personal information if you do not agree.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions available on our Sites.


Definitions

  • Data Controller

    Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

  • Data Processors (or Service Providers)

    Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

  • Data Subject (or User)

    Data Subject is any individual who is using our Service and is the subject of Personal Data.


Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.


Types of Data Collected

  • Personal Data

    While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you as well as to register or subscribe you to our services ("Personal Data"). Personally identifiable information may include, but is not limited to:

    • Name, gender, email, job title and phone number;
    • Address, State, Province, ZIP/Postal code, City and Country; and
    • Cookies, Usage Data including transactions you carry out through our Service.

  • Usage Data

    We may also collect information on how the Service is accessed and used ("Usage Data"), whether this is required for system administration, of for our own billing purposes or otherwise. This Usage Data may include, but not limited to, information such as your computer's Internet Protocol address (e.g., IP address), operating system, location data, browser type, browser version, search criteria used, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. In addition, when you receive newsletters, promotional or other e-mails from us, we may use customized links or similar technologies to determine whether the e-mail has been opened and which links you click in order to provide you with e-mail communications or other information that are more targeted to your needs.

  • Financial Data

    In case you decide to purchase any services that we offer, ZUVI NOVA will need to collect financial information necessary to conduct such a transaction ("Financial Information"). Financial Information that is collected may be used to bill you for products and services, or other purposes. We do not share financial information with outside parties except to the extent necessary to provide you with any product or service that you may have purchased.

  • Candidates

    If you are accessing any of our Sites to inquire about employment with any service part of the ZUVI NOVA Group, the information we gather may include, but is not limited to: your name, physical and email addresses, and phone number(s). If you are submitting an employment application and related information through the Site, your username/password and any additional employment-related information that you choose to provide. We use this information to process and manage your application for employment with any Service part of ZUVI NOVA Group and to improve our Sites and our services.

  • People We Work With

    For business reasons, we partner and work with many organizations. We retain contact details of people we speak to in those organizations as a legitimate interest. We will delete or restrict the use of those details if requested, or if we believe the contact details are no longer of use.

  • Business professionals

    We may collect business professional´s name, physical and email addresses, phone number(s), current and previous employers, current and former job titles, investment details, biographical information, gender, and educational history, as well as photos. We use this information to provide to other business professionals.


Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Cookies help us to improve our site and to deliver a better and more personalized service by enabling us to store information about your preferences and various settings that allow us to customize our site according to your individual interest. It also enables us to speed up your searches and to recognize when you return to our site.

Please note that our advertisers may also use cookies, over which we have no control. You can find more about cookies at www.allaboutcookies.org.


Use of Data

We use the collected data for various purposes:

  • To provide and maintain our Service;

  • To notify you about changes to our Service;

  • To verify whether you are entitled to access our Service;

  • To allow you to participate in interactive features of our Service when you choose to do so;

  • To carry out our obligations arising from any contracts entered into between you and us;

  • To provide customer support and to respond to your queries when you provide feedback;

  • To gather analysis or valuable information so that we can improve our Service and ensure that content form our Service is presented in the most effective manner for you and for your computer;

  • To complete surveys that we use for research purposes, although you do not have to respond to them;

  • To monitor the usage of our Service;

  • To detect, prevent and address technical issues;

  • To send you email notifications, news feeds and newsletters;

  • To send you certain mandatory service communications such as welcome letters, billings reminders, information on security announcements and periodic member letters letter that are considered part of the Service;

  • To display content and advertising that are customized to your interests and preferences;

  • To provide you with news, special offers and information about other products, services and events which we offer that you enquired about or which we fell may interest you unless you have opted not to receive such information; and

  • To report to our advertisers on aggregate information about our user’s browsing actions and patterns.

We may also collect public and non-public information from you or third parties and combine it with information collected at the Service. For the purpose of providing the Service, it is possible that we may already have information about you before you used the Service. ZUVI NOVA accepts no liability for public information or information provided by third parties and in case you would like to rectify or delete your information, please see "Your Data Protection Rights" below and contact us at our registered address as given below to assist you.

We may use your Personal Data to contact you with marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.


Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), ZUVI NOVA legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

ZUVI NOVA may process your Personal Data because:

  • We need to perform a contract with you;

  • You have given us permission to do so;

  • The processing is in our legitimate interests, and it's not overridden by your rights;

  • For payment processing purposes; and

  • To comply with the law.


Storage and Retention of your Personal Data

The personal information that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area ("EEA"), including any member of ZUVI NOVA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. If this happens, we will take steps to ensure that your data is safe and treated securely and in accordance with this Privacy Policy.

ZUVI NOVA will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

ZUVI NOVA will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.


Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. ZUVI NOVA will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


Disclosure of Data

  • ZUVI NOVA Group

    We may disclose your Personal Data to any member of our group, including ZUVI NOVA’s subsidiaries and affiliates.

  • Business Transaction

    Your Personal Data may be disclosed in case ZUVI NOVA is involved in a merger, acquisition, change of control, consolidation, dissolution, corporate divestiture, or asset sale. If we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about its customers may be one of the transferred assets.

  • Disclosure for Law Enforcement

    Under certain circumstances, ZUVI NOVA may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

  • Legal Requirements

    ZUVI NOVA may disclose your Personal Data in the good faith belief that such action is necessary to:

    • To comply with legal obligations;

    • To protect and defend the rights or property of ZUVI NOVA;

    • To prevent or investigate possible wrongdoing in connection with the Service;

    • To protect the personal safety of users of the Service or the public;

    • To protect against legal liability;

    • To exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; and

    • To enforce or apply our terms of use and other agreements.


Security of Data

The security of your data is extremely important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. If we or one of our service providers is required to disclose or provide notice to you of unauthorized access to or other invasions of certain security systems, you agree that we may provide you notice by either posting notice on our Service or sending notice to any e-mail address we have for you.


Your Data Protection Rights

ZUVI NOVA aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

In certain circumstances, you have the following data protection rights:

  • The right to access the information we have on you. Whenever made possible, you can access your Personal Data directly within our Service. If you are unable to perform these actions yourself, please contact us at our registered address as given below to assist you. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

  • The right of rectification. You have the right to have your information rectified if you believe that any information we hold about you is inaccurate or incomplete.

  • The right to object. You have the right to object to our processing of your Personal Data.

  • The right to delete. You have the right to request to delete the information we have on you (subject to certain limitations).

  • The right of restriction. You have the right to request that we restrict the processing of your personal information (subject to certain limitations).

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format (subject to certain limitations).

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where ZUVI NOVA relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).


Service Providers

We may employ third party companies and individuals to provide services ("Service Providers") on our behalf. These Service Providers provide a variety of services to us, including without limitation customer support, host websites, process transactions, assist us in analyzing how our Service is used, processing transactions, security, fraud prevention, providing systems and software for administrative functions, such as sales processing, accounting and finance management, and procurement. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We may use third-party industry conference organizers to also provide conference management tools to facilitate viewing of other attendees, scheduling of meetings and general conference information. While you’re using these tools, we may collect conference related information about your activities including pages viewed, meetings scheduled, messages sent and other actions. This information may also be shared with our third-party industry conference organizers to help them deliver a better service and provide a better conference to our attendees.


Links to Other Sites

Our Service may, from time to time, contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and do not accept any responsibility or liability for the content, privacy policies or practices of any third party sites or services.


Children's Privacy

Our Service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


Changes To This Privacy Policy

We may update our Privacy Policy from time to time and will post the changes on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


Contact Us

If you have any suggestions, questions, or request about this Privacy Policy, you are welcome to contact us:

  • Postal mail to this address: Rua Luz Soriano 67 - 1 Andar Posterior - Sala 30 1200-246, Lisboa, Portugal

  • Email: privacy@ttrdata.com