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Privacy Policy

This privacy policy contains all the information applicable to the treatment of personal data collected on the website or through other alternative means used to contact LUGGit.


This Privacy Policy does not apply to third-party products and services or third-party websites that can be accessed through the links on our website for the user's convenience and/or information. Regarding access to third party links, you should consult our Terms and Conditions in advance.



1. Responsible for the Treatment of Personal Data


Bus Terrace Technologies, SA., collective person No. 515274003, with headquarters in Via do Conhecimento, Edifício Central, Parque da Ciência e Inovação, 3830-352 Ílhavo, Aveiro, Portugal, represented by Ricardo Figueiredo and Diogo Correia as administrators.


E-mail: [email protected]


Within our organisation, the contact person with whom you can clarify your doubts in this field and, as well, exercise the rights that are recognised to you, whenever you feel this need, is João Pedro Pedrosa through the following email contact: [email protected] or postal mail to the address of our headquarters under the care of João Pedro Pedrosa.


2. Principles followed by the Responsible, Security and Protection of Personal Data


According to the law, the processing of personal data is done based on the lawfulness, loyalty, justice, transparency, limitation of purposes, minimisation of data, and accuracy. Thus, to protect your data against unauthorised use and disclosure, LUGGit has implemented several security measures.


As Responsible for Processing, LUGGit processes your personal data lawfully, always collecting your free, specific, informed and explicit consent whenever required under the law. LUGGit does not use/transmit your data for purposes incompatible with the Principles set out above. The purpose(s) for which your data is collected is(are) solely, and exclusively the one(s) described here. To that extent, your data will not be treated for any other purpose unless such treatment has previously been consented to by you.


The collection of personal data is carried out based on the Principle of Minimization. LUGGit only collects data considered essential for the pursuit of the purpose in question.


As soon as the data collected is no longer necessary for the purpose for which it was collected, LUGGit will refrain from continuing to process it and will take all measures required for its destruction.


3. Information and consent


Law No. 58/2019, of August 8, 2019 (which ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 of the Parliament and of the Council, of April 27, 2016) and Regulation General Data Protection Act (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27 2016, from now on “GDPR”) ensure the protection of natural persons concerning the processing of personal data and the free circulation of that data.


Under the legal terms, "personal data" means any information of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person, so the protection does not cover the data of legal persons.


Upon acceptance of this Privacy Policy, the User gives his/her informed, express, free and unambiguous consent so that the personal data provided through the website are included in a file under the responsibility of LUGGit, whose treatment complies with the technical and organisational security measures appropriate.


LUGGit maintains a database with the registration of its Users. The data present in this database are only the data provided by them at the time of registration (as a Client, Keeper or Partner), being collected and processed automatically, under the terms approved by the National Data Protection Commission by LUGGit, the entity responsible for the corresponding file.


In any case, will be requested information about philosophical or political beliefs, party or union affiliation, religious faith, private life and racial or ethnic origin, and health and sexual life data, including genetic data.


In no case will any of the following activities be carried out with the personal data provided through this page:

  1. Handing over the data to other persons or other entities, without the prior consent of the data subject;
  2. Transfer data outside the European Economic Area (EEA) without the prior consent of the data subject.

4. Personal data collected and Purposes


The personal data collected on the web page depends on the interaction that the User had on it. Suppose the customer wants to schedule a LUGGit service or collaborate with LUGGit, as a Keeper or Partner. In that case, the personal data collected are those requested in the forms in question, and where it is understood:

  1. Identification Data: Name (first and last);
  2. Contact Details (email and phone number).

Subsequently, depending on the type of interaction, the LUGGit team may request other data to formalise the process and conclusion of the respective contract or partnership agreement.


The personal data processed through this page will only be used for the following purposes:

  1. Service scheduled by Clients;
  2. Pre-registration on the page and expression of interest in collaborating with LUGGit, as Keeper or Partner;
  3. Analysis of the application with a view to the collaboration of the User as Keeper or Partner of LUGGit, if they fulfil the required requirements;
  4. Communication with Users and clarification of doubts;
  5. Processing of information requests;
  6. Complaints processing;
  7. Statistical analysis activities;
  8. Monitor, maintain and develop systems and statistical analysis;
  9. Direct marketing communications, namely the newsletter (if the User has consented to the processing of their data);
  10. Request for comments on services provided by LUGGit;
  11. Conducting satisfaction surveys.

LUGGit guarantees the confidentiality of all data provided by Users at any time and regardless of the means used for that purpose. Nevertheless, LUGGit proceeds to the collection and processing of data in a safe way and that prevents its loss or manipulation; using the most improved techniques for this purpose, it is informed that the collection in an open network allows the circulation of personal data without security conditions, at the risk of being seen and used by unauthorised third parties.


The website has a chat available 24 hours a day, in which Users can ask the questions they want if they do not find the answers on our page. However, if the Users provide personal data to LUGGit through chat or even through other forms of contact, they will not be used for any purpose other than what is requested by the User.


Thus, if the User, after any clarification, wants to become a Customer of the service or collaborate as a Partner or Keeper, for example, he will have to fill out the forms available on the website for that purpose, and any personal data that another way may have provided will be disregarded.


When collecting personal data, except in fields where otherwise indicated, the User may voluntarily make personal data available, without the lack of response implying a decrease in the quality or quantity of the corresponding services (unless it is otherwise indicated). However, the absence of response to the data, considered mandatory, will imply the impossibility of accessing the service for which the data was requested.


If you disagree with the conditions mentioned above, LUGGit will not contact the User through its website.


If you come to interact with LUGGit social networks in particular, please be aware that we collect personally identifiable data and any other information that you provide when interacting with us. Each of the aforementioned social networks has its privacy policies, which LUGGit is unrelated to. For this reason, the User, from the moment he decides to interact through these channels, is the only and exclusively responsible for what the prior consultation is advisable for such documents.


5. Period of retention of personal data


The period of retention of data varies according to the purpose for which the information is processed.


Personal data collected based on consent are kept for five years from the last date on which your permission was obtained unless previously requested by the respective holder to be deleted.


The data collected based on pre-contractual diligence and execution of the service provision contract will be kept until the contract is in force. Due to legal imposition or compliance with a legal obligation, the processing is necessary for a legal obligation time more extended.


At any time, you may cancel periodic direct communications previously consented to by LUGGit and stop receiving them. To do so, just in the communications you receive, click on the option “unsubscribe”, as a rule, available in them.


6. Treatment of Minors' Personal Data


As a rule, data is not collected or processed, by any means, under the age of 18. If, for any circumstance, this occurs, know that the treatment is only lawful if and to the extent that consent is given or authorised by the holders of parental responsibilities.


In that case, LUGGit will make every effort to verify that consent has been given or authorised by the holder of parental responsibility, taking into account the available technology.


7. Transmission of Data to Third Parties


Personal data collected from your interaction will not be transmitted to third parties other than LUGGit unless legally imposed or by an investigation by the competent authorities.


Concerning the data of the Users, considered as Client, Keepers or Partners, these, for the execution of the respective contract, may be transmitted to third parties subcontracted by LUGGit, which will, in due course, be known by the respective owners.


Please note that LUGGit may also, anonymously, transmit the personal data of its Users to:

  1. Payment and billing processors and facilitators;
  2. Security verification service providers;
  3. Cloud Storage providers;
  4. Google and/or AWS servers;
  5. Data analysis providers;
  6. Encrypted communication service providers, to be used during the provision of services;
  7. Partners that help LUGGit improve the security of our website.

8. Confidentiality


The confidentiality of all information that the User transmits is guaranteed.


LUGGit undertakes to protect the information disclosed with great care and, to that end, has adopted the necessary measures to prevent the use and dissemination of the data by any person other than itself, unless it consents in writing to such disclosure, which will be done on the agreed terms.


About the data provided by the Users, who intend to collaborate as Keepers or Partners, know that the fulfilment of the minimum requirements is assessed by a LUGGit team whose elements are recognised as having high technical and professional competence for the purpose and who are attached to confidentiality obligations in compliance with the rules imposed in the scope of the protection of personal data.


The information disclosed on the website is the sole and exclusive property of the disclosing entity or the property of those who have authorised such disclosure. LUGGit does not have any right over any type of information that may be transmitted to it to which it had access.


9. Security of Personal Data


LUGGit uses several technical and organisational measures to protect the personal data of data subjects, depending on what is appropriate for the specific case:

  1. Pseudonymization and encryption of personal data;
  2. Ability to ensure the confidentiality, integrity, availability and permanent resilience of treatment systems and services;
  3. Ability to restore availability and access to personal data promptly in the event of a physical or technical incident;
  4. Implementation of a process to test, assess and regularly evaluate the effectiveness of technical and organisational measures to ensure treatment safety, among other actions considered appropriate and relevant on a case-by-case basis.

In the case of subcontracting service providers, they will have to guarantee the same level of protection.


The violation, or attempted breach, of the personal data for which LUGGit is responsible will be reported to the judicial authorities, as well as to control and supervision. If the breach involves a high risk for the holders of personal data, they will be informed of the incident.


10. Cookies Policy


LUGGit uses cookies and other identification technologies on the website for the following purposes:

  1. Authenticate Users;
  2. Remember Users' preferences and settings;
  3. Discover the popularity of a content;
  4. Disseminate and measure the effectiveness of marketing campaigns;
  5. Analyse trends and traffic to understand online behaviours and the interests of people who interact with services. It may also allow other entities to provide measurement and analysis services to LUGGit, showing advertisements on the Internet on behalf of the brand and monitoring the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify their device when they visit the website and use the LUGGit services and when they visit different websites and online services.

Cookies are files with a small amount of data that are usually used as unique anonymous identifiers. These are sent to your browser from the user visits and stored in your device's internal memory.


This service does not use "cookies" explicitly. However, the page may use third party code and libraries that use "cookies" to collect information and improve its services. The User can accept or refuse these cookies and know when a cookie is being sent to his device. If you choose to decline LUGGit cookies, you may not be able to use some parts of the proposed service. This Cookie Policy is periodically reviewed, so its content may be updated.


11. Exercise of rights


Following the provisions of Law No. 58/2019 and the GDPR, the User can exercise his rights of access, rectification, deletion, limitation, opposition and portability at all times by requesting any of the following means:


Mail: Personal Data / Via do Conhecimento, Edifício Central, Parque da Ciência e Inovação, 3830-352 Ílhavo, Aveiro, Portugal

E-mail: [email protected]



If the User wishes, at any time, to stop being part of the LUGGit database, he can exercise this right through these contacts, providing the respective identification for this purpose.


12. Changes to the Privacy Policy and applicable legislation


This privacy policy can be frequently updated whenever it is justified by LUGGit and without prior notice, informing you of the date of the last update, so it is advisable to read it periodically.


The use of the site assumes that you know and accept this Privacy Policy and the Terms and Conditions of Use of the same.

This privacy policy contains all the information applicable to the treatment of personal data collected on the website or through other alternative means used to contact LUGGit.


This Privacy Policy does not apply to third-party products and services or third-party websites that can be accessed through the links on our website for the user's convenience and/or information. Regarding access to third party links, you should consult our Terms and Conditions in advance.



1. Responsible for the Treatment of Personal Data


Bus Terrace Technologies, SA., collective person No. 515274003, with headquarters in Via do Conhecimento, Edifício Central, Parque da Ciência e Inovação, 3830-352 Ílhavo, Aveiro, Portugal, represented by Ricardo Figueiredo and Diogo Correia as administrators.


E-mail: [email protected]


Within our organisation, the contact person with whom you can clarify your doubts in this field and, as well, exercise the rights that are recognised to you, whenever you feel this need, is João Pedro Pedrosa through the following email contact: [email protected] or postal mail to the address of our headquarters under the care of João Pedro Pedrosa.


2. Principles followed by the Responsible, Security and Protection of Personal Data


According to the law, the processing of personal data is done based on the lawfulness, loyalty, justice, transparency, limitation of purposes, minimisation of data, and accuracy. Thus, to protect your data against unauthorised use and disclosure, LUGGit has implemented several security measures.


As Responsible for Processing, LUGGit processes your personal data lawfully, always collecting your free, specific, informed and explicit consent whenever required under the law. LUGGit does not use/transmit your data for purposes incompatible with the Principles set out above. The purpose(s) for which your data is collected is(are) solely, and exclusively the one(s) described here. To that extent, your data will not be treated for any other purpose unless such treatment has previously been consented to by you.


The collection of personal data is carried out based on the Principle of Minimization. LUGGit only collects data considered essential for the pursuit of the purpose in question.


As soon as the data collected is no longer necessary for the purpose for which it was collected, LUGGit will refrain from continuing to process it and will take all measures required for its destruction.


3. Information and consent


Law No. 58/2019, of August 8, 2019 (which ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 of the Parliament and of the Council, of April 27, 2016) and Regulation General Data Protection Act (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27 2016, from now on “GDPR”) ensure the protection of natural persons concerning the processing of personal data and the free circulation of that data.


Under the legal terms, "personal data" means any information of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person, so the protection does not cover the data of legal persons.


Upon acceptance of this Privacy Policy, the User gives his/her informed, express, free and unambiguous consent so that the personal data provided through the website are included in a file under the responsibility of LUGGit, whose treatment complies with the technical and organisational security measures appropriate.


LUGGit maintains a database with the registration of its Users. The data present in this database are only the data provided by them at the time of registration (as a Client, Keeper or Partner), being collected and processed automatically, under the terms approved by the National Data Protection Commission by LUGGit, the entity responsible for the corresponding file.


In any case, will be requested information about philosophical or political beliefs, party or union affiliation, religious faith, private life and racial or ethnic origin, and health and sexual life data, including genetic data.


In no case will any of the following activities be carried out with the personal data provided through this page:

  1. Handing over the data to other persons or other entities, without the prior consent of the data subject;
  2. Transfer data outside the European Economic Area (EEA) without the prior consent of the data subject.

4. Personal data collected and Purposes


The personal data collected on the web page depends on the interaction that the User had on it. Suppose the customer wants to schedule a LUGGit service or collaborate with LUGGit, as a Keeper or Partner. In that case, the personal data collected are those requested in the forms in question, and where it is understood:

  1. Identification Data: Name (first and last);
  2. Contact Details (email and phone number).

Subsequently, depending on the type of interaction, the LUGGit team may request other data to formalise the process and conclusion of the respective contract or partnership agreement.


The personal data processed through this page will only be used for the following purposes:

  1. Service scheduled by Clients;
  2. Pre-registration on the page and expression of interest in collaborating with LUGGit, as Keeper or Partner;
  3. Analysis of the application with a view to the collaboration of the User as Keeper or Partner of LUGGit, if they fulfil the required requirements;
  4. Communication with Users and clarification of doubts;
  5. Processing of information requests;
  6. Complaints processing;
  7. Statistical analysis activities;
  8. Monitor, maintain and develop systems and statistical analysis;
  9. Direct marketing communications, namely the newsletter (if the User has consented to the processing of their data);
  10. Request for comments on services provided by LUGGit;
  11. Conducting satisfaction surveys.

LUGGit guarantees the confidentiality of all data provided by Users at any time and regardless of the means used for that purpose. Nevertheless, LUGGit proceeds to the collection and processing of data in a safe way and that prevents its loss or manipulation; using the most improved techniques for this purpose, it is informed that the collection in an open network allows the circulation of personal data without security conditions, at the risk of being seen and used by unauthorised third parties.


The website has a chat available 24 hours a day, in which Users can ask the questions they want if they do not find the answers on our page. However, if the Users provide personal data to LUGGit through chat or even through other forms of contact, they will not be used for any purpose other than what is requested by the User.


Thus, if the User, after any clarification, wants to become a Customer of the service or collaborate as a Partner or Keeper, for example, he will have to fill out the forms available on the website for that purpose, and any personal data that another way may have provided will be disregarded.


When collecting personal data, except in fields where otherwise indicated, the User may voluntarily make personal data available, without the lack of response implying a decrease in the quality or quantity of the corresponding services (unless it is otherwise indicated). However, the absence of response to the data, considered mandatory, will imply the impossibility of accessing the service for which the data was requested.


If you disagree with the conditions mentioned above, LUGGit will not contact the User through its website.


If you come to interact with LUGGit social networks in particular, please be aware that we collect personally identifiable data and any other information that you provide when interacting with us. Each of the aforementioned social networks has its privacy policies, which LUGGit is unrelated to. For this reason, the User, from the moment he decides to interact through these channels, is the only and exclusively responsible for what the prior consultation is advisable for such documents.


5. Period of retention of personal data


The period of retention of data varies according to the purpose for which the information is processed.


Personal data collected based on consent are kept for five years from the last date on which your permission was obtained unless previously requested by the respective holder to be deleted.


The data collected based on pre-contractual diligence and execution of the service provision contract will be kept until the contract is in force. Due to legal imposition or compliance with a legal obligation, the processing is necessary for a legal obligation time more extended.


At any time, you may cancel periodic direct communications previously consented to by LUGGit and stop receiving them. To do so, just in the communications you receive, click on the option “unsubscribe”, as a rule, available in them.


6. Treatment of Minors' Personal Data


As a rule, data is not collected or processed, by any means, under the age of 18. If, for any circumstance, this occurs, know that the treatment is only lawful if and to the extent that consent is given or authorised by the holders of parental responsibilities.


In that case, LUGGit will make every effort to verify that consent has been given or authorised by the holder of parental responsibility, taking into account the available technology.


7. Transmission of Data to Third Parties


Personal data collected from your interaction will not be transmitted to third parties other than LUGGit unless legally imposed or by an investigation by the competent authorities.


Concerning the data of the Users, considered as Client, Keepers or Partners, these, for the execution of the respective contract, may be transmitted to third parties subcontracted by LUGGit, which will, in due course, be known by the respective owners.


Please note that LUGGit may also, anonymously, transmit the personal data of its Users to:

  1. Payment and billing processors and facilitators;
  2. Security verification service providers;
  3. Cloud Storage providers;
  4. Google and/or AWS servers;
  5. Data analysis providers;
  6. Encrypted communication service providers, to be used during the provision of services;
  7. Partners that help LUGGit improve the security of our website.

8. Confidentiality


The confidentiality of all information that the User transmits is guaranteed.


LUGGit undertakes to protect the information disclosed with great care and, to that end, has adopted the necessary measures to prevent the use and dissemination of the data by any person other than itself, unless it consents in writing to such disclosure, which will be done on the agreed terms.


About the data provided by the Users, who intend to collaborate as Keepers or Partners, know that the fulfilment of the minimum requirements is assessed by a LUGGit team whose elements are recognised as having high technical and professional competence for the purpose and who are attached to confidentiality obligations in compliance with the rules imposed in the scope of the protection of personal data.


The information disclosed on the website is the sole and exclusive property of the disclosing entity or the property of those who have authorised such disclosure. LUGGit does not have any right over any type of information that may be transmitted to it to which it had access.


9. Security of Personal Data


LUGGit uses several technical and organisational measures to protect the personal data of data subjects, depending on what is appropriate for the specific case:

  1. Pseudonymization and encryption of personal data;
  2. Ability to ensure the confidentiality, integrity, availability and permanent resilience of treatment systems and services;
  3. Ability to restore availability and access to personal data promptly in the event of a physical or technical incident;
  4. Implementation of a process to test, assess and regularly evaluate the effectiveness of technical and organisational measures to ensure treatment safety, among other actions considered appropriate and relevant on a case-by-case basis.

In the case of subcontracting service providers, they will have to guarantee the same level of protection.


The violation, or attempted breach, of the personal data for which LUGGit is responsible will be reported to the judicial authorities, as well as to control and supervision. If the breach involves a high risk for the holders of personal data, they will be informed of the incident.


10. Cookies Policy


LUGGit uses cookies and other identification technologies on the website for the following purposes:

  1. Authenticate Users;
  2. Remember Users' preferences and settings;
  3. Discover the popularity of a content;
  4. Disseminate and measure the effectiveness of marketing campaigns;
  5. Analyse trends and traffic to understand online behaviours and the interests of people who interact with services. It may also allow other entities to provide measurement and analysis services to LUGGit, showing advertisements on the Internet on behalf of the brand and monitoring the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify their device when they visit the website and use the LUGGit services and when they visit different websites and online services.

Cookies are files with a small amount of data that are usually used as unique anonymous identifiers. These are sent to your browser from the user visits and stored in your device's internal memory.


This service does not use "cookies" explicitly. However, the page may use third party code and libraries that use "cookies" to collect information and improve its services. The User can accept or refuse these cookies and know when a cookie is being sent to his device. If you choose to decline LUGGit cookies, you may not be able to use some parts of the proposed service. This Cookie Policy is periodically reviewed, so its content may be updated.


11. Exercise of rights


Following the provisions of Law No. 58/2019 and the GDPR, the User can exercise his rights of access, rectification, deletion, limitation, opposition and portability at all times by requesting any of the following means:


Mail: Personal Data / Via do Conhecimento, Edifício Central, Parque da Ciência e Inovação, 3830-352 Ílhavo, Aveiro, Portugal

E-mail: [email protected]



If the User wishes, at any time, to stop being part of the LUGGit database, he can exercise this right through these contacts, providing the respective identification for this purpose.


12. Changes to the Privacy Policy and applicable legislation


This privacy policy can be frequently updated whenever it is justified by LUGGit and without prior notice, informing you of the date of the last update, so it is advisable to read it periodically.


The use of the site assumes that you know and accept this Privacy Policy and the Terms and Conditions of Use of the same.

Last Updated: May 25, 2021