Privacy Policy | Pharoll

1. About

CORDOUAN, UNIPESSOAL LDA, a company domiciled in Portugal with corporate taxpayer number 514.111.941, is the controller of personal data processed in relation to platform users. In exceptional circumstances, certain independent parties may act as separate controllers or processors.

This Privacy Policy explains how the company uses personal data relating to users, partners and collaborators of the digital platform. It applies to use of the platform in all its services, regardless of device, and to all infrastructure needed to provide Pharoll services or whenever a Pharoll account is connected to another application.

This Privacy Policy forms part of, but is separate from, Pharoll's Terms and Conditions, and does not apply where a special privacy policy applies and is expressly read and accepted by the user.

The purpose of this Privacy Policy is to provide information about users' rights under the General Data Protection Regulation and Portuguese data-protection law.

The platform undertakes to comply with Regulation (EU) 2016/679 of 27 April, the GDPR, and Law no. 58/2019 of 8 August, the Portuguese Data Protection Act.

Any question or request relating to personal data and privacy should be sent to privacy@pharoll.com.

2. Necessary and up-to-date information

All rules set out in this Privacy Policy are mandatory. Failure to comply with them may make access to and participation in the platform impossible.

Users undertake to provide truthful data and information to CORDOUAN, UNIPESSOAL LDA and to promptly communicate any changes or corrections to their personal data by written communication to privacy@pharoll.com.

By accepting this policy, the user declares that the information and data provided are accurate and truthful and, to the extent permitted by applicable law, accepts responsibility for any harm or non-compliance caused by false information.

3. General information covered by this policy

This Privacy Policy identifies, for each type of data processing carried out by Pharoll:

The purposes of personal data processing, or the reason why the data is processed;
The legal basis for each processing purpose;
Any potential disclosure of information to third parties and the reason for it. Pharoll undertakes not to disclose user data to partners or other parties without prior written consent, except where access by information-technology and service providers is indispensable to the proper operation of the platform and its ecosystem, subject to confidentiality and applicable personal-data rules;
The retention period for data covered by this policy. Data may remain blocked and available for judicial, administrative or tax claims for the period expressly required by law.

Further information about recipients of protected data may be requested in writing at privacy@pharoll.com. The request should identify the processing activity for which recipient information is required.

4. Detailed information about processing

Data processing under this policy is carried out to manage enquiries, based on the legitimate interests of Pharoll and its management in responding to information requests.

Pharoll will disclose data to third parties only where this is indispensable and necessary for regular platform activity or use, for compliance with legal obligations, or where disclosure is required by applicable law, court order or competent authority.

Pharoll uses personal data to configure and personalise user accounts and provide platform access, based on performance of a contract that the user acknowledges and expressly accepts.

Pharoll uses personal data where necessary to provide other Pharoll services, based on the platform's legitimate interests in keeping the service functional and available to users.

Pharoll uses personal data to provide voluntary platform features whenever the user's consent has been expressly given.

Pharoll uses personal data for diagnosis, correction or improvement of the service and platform, and to process payments, based on the Terms and Conditions. This use may also rely on consent where payment information is retained for future purchases.

Pharoll uses personal data to test and launch new functions and service improvements, including algorithmic and machine-learning models, where the platform has legitimate interests in developing and improving its services, economic wellbeing, business planning, reporting and forecasting.

Pharoll uses personal data for marketing and advertising where the user consents. This processing should be read together with the Cookie Policy. Data may also be used for promotion and advertising where applicable law does not require consent, based on Pharoll's legitimate interests in financing its services and offering a better quality service at lower cost.

Pharoll uses personal data where necessary to comply with legal obligations under the law of the user's country, Portuguese law, the law of the European Union, or to comply with contractual obligations to third parties.

Pharoll uses personal data where necessary to establish, exercise or defend legal claims, based on legitimate interests in obtaining informed legal advice and protecting the platform, partners, users or third parties.

Finally, Pharoll uses personal data to prevent and combat fraudulent use of the platform, clickbait, and to conduct research and surveys where its legitimate interests justify this, namely maintaining lawful platform use, protecting users, partners and third parties, and collecting user feedback.

5. Sharing personal data

Because Pharoll is a platform connecting businesses and creators, certain data must remain public and accessible between users who establish business relationships through the platform.

Pharoll may expose the following data from registered businesses and creators:

Profile name;
Profile picture; and
Public campaigns.

The platform may develop features allowing users to share information on third-party channels, including social and distribution channels. In such cases, users will be informed of changes to this Privacy Policy where necessary. Third-party platforms may store copies or records of shared content.

Pharoll may share personal data with service providers and partners so they can provide services to Pharoll, including customer support, infrastructure operation, security, campaign and event promotion, payment processing, potential fraud detection, and Pharoll promotion with partners.

Additional data may be shared with companies that may be acquired by Pharoll and with academic researchers for statistical analysis and optimisation.

Data may also be shared in the event of a sale or proposed sale of the platform to an actual or prospective buyer. As a result, a successor or affiliate may receive users' personal data.

The above also applies to courts and competent authorities for lawful legal processes, legal obligations, cooperation and transparency duties, requests from criminal, judicial or administrative authorities, and to protect the legitimate interests of Pharoll or good-faith third parties.

6. Personal data collected

This Privacy Policy is based on collecting and processing the following categories of data:

Registration data - Data needed to create a Pharoll account and use the service, including full name, profile name, tax or corporate taxpayer number, password, telephone contact, date of birth, country of domicile and confirmed age. This data is provided by the user when creating an account;
Usage and technical data - Data collected when the service is used, including information about campaigns in which creators or businesses participate, platform actions such as searches, campaign history, statistics, transcripts, questions or requests, account settings, campaign content, published content, access dates and times, URLs, online identifiers, device information, network type, provider, performance, browser, language, operating system and approximate location;
Additional data with user consent - Campaign data, age-verification data, payment and purchase data, and research or survey data; and
Data received from third parties - Data shared with the user's consent, including information from authentication partners such as Google, Apple or Meta, social network information related to campaigns, technical service partners, payment partners and merchants.

7. Personal data rights

As a person whose data is processed by Pharoll, you have the following rights:

To be informed - About the personal data processed and how it is processed. A person is considered informed by reading and accepting this policy and other policies or updates communicated when using Pharoll services.
To access - To request and access the personal data we process, including the rights set out in Article 15 of the GDPR.
To rectify - To request changes, updates or corrections to personal data stored and processed by Pharoll where it is incorrect, incomplete or outdated.
To erase - To request erasure where the data is no longer necessary, processing is based on consent and consent is withdrawn, or there is a justified objection. This right may not apply where legal retention obligations, court or administrative instructions, fraud-prevention, anti-money laundering, counter-terrorist financing, or legal-claim needs apply.
To restrict - To ask Pharoll to stop processing personal data in whole or in part where data is incorrect, processing is unlawful, the data is no longer necessary, or an objection request is under review.
To object - To object to processing where there is a legitimate, justified and legally grounded claim, or where data is used for personalised advertising.
To data portability - To request a digital copy of personal data and transmit it to another entity. Partners may request direct transmission between service providers where applicable.
Not to be subject to automated decisions - No user should be subject to decisions based solely on automated processing without human intervention.
To withdraw consent - To withdraw consent and request erasure or restriction where processing is based on consent.
To lodge a complaint with the Portuguese National Data Protection Commission, the CNPD.

To exercise these rights or ask questions about how Pharoll processes personal data, contact privacy@pharoll.com or use the contact form at https://pharoll.com/contact/. Additional data may be requested to verify the user's identity.

8. Retention of personal data

Pharoll retains personal data only to the extent and for the period strictly necessary to provide its services, pursue its business purposes, protect its legitimate interests, maintain service performance, make informed strategic decisions, comply with legal obligations and resolve disputes.

Some data will be retained until erasure or restriction is requested. Other data is retained until the Pharoll account is deleted, such as user profile information.

A third category of data remains stored until a specific period is reached. Another category may be retained for a longer period for restricted purposes, such as complying with legal or contractual obligations, helping ensure user safety, or protecting against harmful content affecting platform operation.

Age-verification data is deleted immediately after validation by the platform or its partners.

9. Security

Personal data of users and partners is kept secure through Pharoll's technical and organisational mechanisms for protection and privacy.

Additional safeguards are in place to protect users and the platform against unauthorised access, improper retention or unnecessary retention, including pseudonymisation, encryption and access procedures.

For better data security, users are advised to use a unique, personal and non-transferable password, used only on their personal devices, and to sign out when they have finished using or consulting the platform.

If the user shares access credentials or allows third parties to access the account, the user is responsible for all resulting activity on the profile.

10. Changes to this policy

Pharoll reserves the right to make changes, corrections or updates to this policy and to inform users and partners in writing.

11. Contact and support

For technical questions or doubts, contact us at privacy@pharoll.com or through the contact form available at https://pharoll.com/contact/.

By accessing and participating in Pharoll, you acknowledge that you have read, understood and agreed to this Privacy Policy.

12. Unforeseen situations

Any situation not covered by these Terms and Conditions may be analysed and handled case by case, in accordance with applicable law.

Any death, incapacity, force majeure or other exceptional circumstance that may affect the user's experience or interaction with the platform or another user should be communicated to the Pharoll team as soon as known and to the extent possible.

CORDOUAN, UNIPESSOAL LDA is the controller for personal data processed under this Privacy Policy.