Privacy Policy

legal notice

This website was designed to make known the services offered by Reflexo Sustentável Lda and commercial contacts.

The website is managed by:
Company Name: Reflexo Sustentável Lda
NIF: 516356739
Registered office: Rua Coteães de Cima, nº252, 4765-478 Guardizela, Guimarães
E-mail: Cell phone number: 916459510

RETRY - Privacy Statement

We care about your privacy and are committed to protecting your personal data. This privacy statement will inform you about how we use your personal data, your privacy rights and how the law protects you. Please read this privacy statement carefully before using our Services.


  1. Who we are?
  2. What data do we collect about you?
  3. Do we collect data from minors?
  4. Why do we process your personal information?
  5. How will we inform you about changes to our privacy statement?
  6. your rights
  7. Communication and marketing
  8. Who do we share your data with?
  9. international transfers
  10. Where do we store your data and for how long?
  11. Technical and organizational measures and security processing
  12. Contacts
  13. controlling entities

In this privacy statement:

Services refers to any products, services, content, features, technologies or functions and all related websites, applications and services offered to you by us.

Platform refers to the websites, mobile applications, mobile websites or any other online properties through which we offer our Services to you.

1. Who are we?

The main person responsible for processing your data for the purposes of our services is Reflexo Sustentável Lda , a limited liability company based in Guardizela, Guimarães.

The person responsible for processing data is Reflexo Sustentável., with NIF 516356739, headquartered at Rua Coteães de Cima, Nº252 4765-478 Guardizela, Guimarães.

2. What data do we collect about you?

2.1.1 Data provided by direct interaction

Registration and other account information

When you register to use our Services, we may collect the following information:

  • If you want to register on the Platform, you will only be asked for your email address;
  • If you register using a Google account: name, surname and email address;
  • If you register using a Facebook account: we collect your name and surname as it appears on your Facebook account and your Facebook profile. If you have given permission to Facebook through the privacy option in the application (option that will appear immediately before registering on the Platform), we may collect your gender, age or email address, depending on the permissions you have given; It is
  • If you register using your mobile phone number, we collect your mobile phone number.

Depending on the choices you make when logging into our Services or during the process of using our Services, you may choose to additionally provide the following personal data:

  • your name;
  • residence address;
  • Tax Identification Number;
  • mobile number;

Communication through the chat feature on our Platform

When you use our chat feature to communicate with other users, we collect information that you choose to provide to other users through this feature.

Telephone conversations with our Customer Support team

When you contact us by phone or choose to be contacted by phone by one of our Customer Service representatives, we occasionally record the conversation, subject to your express consent, for the purpose of improving our customer interaction practice.

Recordings in video or audio format for specific customer interaction studies

When you expressly agree to participate in interaction studies organized by Reflexo Sustentável Lda with customers, we will record your interaction with our team. For each customer study organized by Reflexo Sustentável Lda, we will provide the necessary information about how we process your personal data and why we are doing so.

2.1.2 Data we collect automatically when you use our Services

When you interact with our Platform or use our Services, we automatically collect the following information about you:

Device Information

  • We collect device-specific information, such as operating system version or unique identifiers. For example, the name of the mobile network you are using. We associate that device with your RETRY account device identifiers.

Location Information

  • Depending on the permissions on your device, if you post an article on our Platform, we will automatically collect and process information about your current location. We use various technologies to determine location, including IP address, GPS, Wi-Fi hotspots and mobile data towers.

Customer and Registration Data

  • Technical details including your device's Internet Protocol (IP), time zone and operating system. We will also store your login information (date of registration, date of last password change, date of last successful login), your browser type and version.

clickstream data

  • We collect information about your activity on our Platform, including the websites you used to access our Platform, the date and time stamp of each visit, searches performed, listings or advertising banners you accessed, your interaction with these advertisements advertising or listings, length of your visit and the order in which you accessed content on our Platform.

Cookies and Similar Technologies

  • We use cookies to manage our users' sessions, to store your language preferences and to provide you with relevant advertisements. “ Cookies ” are small text files transferred by a web server to your device's hard drive. Cookies can be used to collect the date and time of your visit, your browsing history, your preferences and your username. You can set your browser to refuse some or all cookies, or to alert you whenever a website installs or accesses cookies. If you disable or refuse cookies, please be aware that some parts of our Services/Platform may become inaccessible or not function properly. For more information about the cookies we use, please consult our Cookie and Similar Technologies Policy .

2.1.3 Third Party Data or Publicly Available Sources.

We receive personal data about you from various third parties [and publicly available sources] as described below:

  1. certain technical and usage information from analytics providers such as Google;
  2. Contact data for business operations on advertising networks, such as data providers related to operations and service partners (Example: business activity data); It is

Services usage data on the Platform related to the Services or transactions. (Example: data directly related to advertisements published on the Platform to prevent fraud situations and report such cases to the respective entities).

3. Do we collect data from minors?

Our Services are not intended for anyone under the age of 16 and we do not knowingly collect data from anyone under the age of 16. If we become aware that a minor under 16 has given us his data, we will immediately delete such data.

4. Why do we process your personal information?

We only use your personal data when permitted by law. Most of the time, we will use your personal data in the following circumstances:

  • When we need to fulfill the contract that we are about to enter into or that we have entered into with you.
  • Whenever it is necessary for our legitimate interests to improve our Services and provide you with a secure Platform.
  • Whenever we have to comply with legal or regulatory obligations.
  • When you give us your express consent (for example, for recordings in audio or video format).

In certain circumstances we may also process your personal data based on your consent. If we do, we will inform you of the reason and category of personal data to be processed at the time we request your consent.

We set out below a description of how we use your personal data and what legal bases we rely on to do so. We also identify what our legitimate interests are, where necessary.

4.1. For the purposes of providing access and providing the Services through our Platform

  1. If you log in to the Platform using your phone number or email ID, we will use your first and last name, phone number and/or email address to identify you as a user and allow you to access our Platform.
  2. If you log in through your Facebook account, we will use your Facebook profile name and surname and your Facebook email address to identify you as a user on our Platform and allow you to access our Platform.
  1. the above login information is also used by us to provide our Services to you in accordance with our Terms and Conditions .
  2. We use your email address and mobile phone number to make suggestions and recommendations about our Services that may be of interest to you.

We process the information described above for the proper performance of the contract concluded with you and on the basis of our legitimate interest in carrying out marketing activities to offer you Services that may be of interest to you.

4.2. To improve your experience on the Platform

  1. We use clickstream data to:
  • provide targeted content, for example, providing you with more relevant search results whenever you use our Services.
  • to determine how much time you spend on our Platform and how you navigate through our Platform, so that we can understand your interests and improve our Services based on this data. For example, we may provide you with suggestions about content you might visit based on the content you have accessed.
  • to monitor and report the effectiveness of targeted advertising campaigns to our business partners and for internal business analytics.
  1. We use your location data for the following purposes:
  • to compile anonymous and aggregated information about the characteristics and behavior of users of Reflexo Sustentável Lda including for the purpose of business analysis, segmentation and development of anonymous profiles.
  • to improve the performance of our Services and personalize the content we direct to you.
  • to measure and monitor your interaction with third-party advertising banners that we place on our Platform.
  1. With the help of your login information, which includes your email ID and phone number, we map the different devices (such as computers, mobile phones, tablets) used by you to access our Platform. This allows us to link your activity on our Platform across devices and helps us to give you a seamlessly integrated experience no matter what device you are using.

We process the information described above based on our legitimate interest in improving your experience on our Platform and to ensure proper performance of the contract we enter into with you.

4.3 To provide you with a secure Platform

  1. We use your phone number, login details and unique device identifiers to manage and secure our Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, communication and data storage). data).
  2. We analyze your communications through our chat feature to prevent fraud and to promote security by blocking spam or abusive messages that may have been sent to you by another user.

We process the information described above for the proper performance of our contract with you, to improve our services and on the basis of our legitimate interests in terms of fraud prevention.

4.4 To provide you with top-notch customer support

  1. We record your conversations with members of our Customer Support Team, subject only to your express agreement;
  1. We process the personal data identified above for further analysis of your interaction with members of our Customer Support Team and sales team (as applicable) and to improve the way our team members provide services to Reflexo Sustentável's customers.
  2. You may withdraw your consent at any time without any charge through a request to be sent to Reflexo Sustentável using the contact details identified in Section 13. All processing activities carried out up to the withdrawal of consent will be valid.

5. How will we inform you about changes to our privacy statement?

We may change this privacy statement from time to time. We will post changes on this page and let you know of such changes by email or through our Platform. If you do not agree with these changes, you can close your account by accessing your account settings and accessing the delete account option.

6. Your rights

Under certain circumstances, and under data protection laws, you have rights relating to your personal data.

If you wish to use any of the rights described below, please access our account/privacy settings or contact us via our Help Center :

  • Right to request access to your personal data (known as a “data subject access request”). This allows you to receive a copy of the personal data we hold about you and to check that we are processing it in accordance with the law.
  • Right to request corrections to any data we hold about you. This allows you to correct any incomplete or incorrect data we hold about you, although we are obliged to verify the accuracy of the new data you provide to us.
  • Right to request limitation of processing of your personal data. This allows you to request the suspension of the processing of your personal data in the following circumstances: (a) if you want us to determine the accuracy of the data; (b) whenever our use of the data does not comply with the law; (c) whenever you need us to store your data, even if you do not need them, in case you need to establish, exercise or defend against legal claims; or (d) if you object to our use of your personal data, although we are required to check that there are overriding legitimate interests for us to continue to use it.
  • Right to request the deletion of your personal data. This allows you to request that we erase or remove your personal data whenever there is no good reason for us to continue processing it. You also have the right to ask us to erase or remove your personal data where you have successfully exercised your right to refuse processing (see below), where we have processed your information unlawfully or where we are required to delete your personal data for the purposes of compliance with local law. Please note that, for certain purposes, we may be legally obliged to retain your data. Please also refer to section 10 .
  • right to object to the processing of your personal data whenever we have recourse to a legitimate interest (or the legitimate interest of a third party) and whenever there is something related to your personal situation that leads you to object to its processing in these terms, as you consider that this may have a fundamental impact on their fundamental rights and guarantees. You also have the right to object whenever we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have legitimate and compelling reasons that override your rights and guarantees to process your information.
  • Right to request the portability of your personal data for yourself or a third party. We will provide you, or provide a third party of your choice, with your personal data in a structured, commonly used, and electronically readable format. Please note that this right only applies to automated information for which you initially gave us your consent for use or in situations where we have used the information for the purposes of fulfilling the contract we have entered into with you.
  • Right to withdraw consent, at any time, for the processing of your personal data . This does not affect the legality of any processing that we have already carried out based on the previously given consent.

Response Time: We try to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your order is particularly complex or if you have placed multiple orders. In that case, we will notify you and keep you informed.

Furthermore, you have the right to make a complaint at any time to the responsible data protection authority pursuant to section 14.

However, before filing a complaint with the data protection authority, we would appreciate the opportunity to deal with your concerns in the first instance, so we would appreciate it if you could use our CONTACT FORM.

7. Communication and marketing

We will communicate with you by email, SMS or notification through the application associated with our Services/Platform to confirm your registration.

You may receive marketing communications from us if:

  • you have requested such information;
  • use our Platform or Services;
  • you have provided us with your details when participating in a competition; or
  • if you have registered for a promotion.

8. With whom do we share your data?

We may need to share your personal data with the parties listed below for the purposes of Section 4 above.

Affiliated companies : We may share your data with other Collaborating companies of Reflexo Sustentável Lda, which are located inside or outside the EEA and which help us to provide commercial operations services, such as product improvement, customer support and detection mechanisms of fraud. Any sharing of personal data located outside the European Economic Area (“ EEA ”) will always be subject to safeguards, as described in section 9 , or to a data transfer agreement that clearly defines the obligations of the parties and ensures measures appropriate techniques and organization to protect your data.

Advertising and Analytics and Data Providers: In order to improve our Services, we will sometimes need to share your information with analytics providers who will help us analyze how people use our Platform/Service. For the most part, we share your information with these data providers in non-identifiable form to monitor and report on the effectiveness of the campaigns we run, aimed at our business partners, and for internal business analysis. This information usually includes a cookie ID, an IP address (abbreviated), the referring URL, as well as browser and device information.

Law enforcement authorities, regulators and others: We may disclose your personal data to law enforcement authorities, regulators, government or public entities and other third parties to comply with any legal or regulatory requirements.

We may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. If there is any change to our business, the new owners may use your personal data as described in this privacy statement.

Publicly available information : Whenever you publish an item for sale using our Services, you may choose to make some of your personal information visible to other users of Reflexo Sustentável. This information may include your first name, last name, your email address, your location and your contact number. Please note that any information you provide to other users may be shared by them with third parties, so you should exercise discretion in this regard.

9. International transfers

Whenever we transfer your personal data outside the EEA, we guarantee a similar degree of protection by ensuring that at least one of the following safeguards is implemented:

You may receive a copy of the relevant safeguards in place by contacting us via our Contact Form.

10. Where do we store your data and for how long?

The data we collect about you will be stored and processed both inside and outside the EEA on secure servers in order to provide the best possible user experience. For example: for quick links to the website or mobile application.

We will only retain your personal data for as long as necessary to serve the purposes for which we collected it, including for the purposes of complying with any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized disclosure or use of your personal data, the reasons why we process your data and whether we are able to fulfill those reasons by other means, and applicable legal requirements.

If there is no activity on your account for more than 24 months, we reserve the right to delete your account, which means you will not be able to use it again. However, we will not delete your account when you have open transactions or are entitled to a refund or credit refund from us. Before your account is deleted, we will contact you to verify that you wish to continue using your account.

If you have questions regarding the retention period of your personal data, please contact us using our Contact Form.

11. Technical and organizational measures and security processing

All the information we receive about you is stored on secure servers, and we have implemented technical and organizational measures that are adequate and necessary to protect your personal data. Reflexo Sustentável Lda continually assesses the security of its network and the adequacy of its internal security information program which is designed to (a) help protect your data against accidental or unlawful loss, access or disclosure, (b) identify risks reasonable foreseeable measures for the security of the Reflexo Sustentável Lda network, and (c) minimize security risks, including through risk assessments and regular testing. Furthermore, we ensure that all payment data is encrypted using SSL technology.

Please note that, despite the measures we have implemented to protect your data, data transfer over the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.

12. Contacts

For any additional information, or to exercise your rights, please check your account/privacy settings or contact our Privacy Office via our Contact Form or via the Help Center on our Platform. If you want to contact us to request information regarding the processing of your personal information, you can send us a letter to: Reflexo Sustentável Lda, Rua Coteães de Cima, nº252 4765-478 Guardizela, Guimarães.

13. Control entities

Our Main Controlling Entity is:

For local matters relating to data protection to your local authority:

CNPD – National Commission for Data Protection, headquartered at Rua de São Bento, n.º 148 – 3rd

1200-821 Lisbon

Telephone +351 213928400; Fax: +351 213976832