Privacy Policy

(Last updated: July 13, 2026)

By using this service, you are expressing your agreement with the following conditions.

In accordance with Regulation (EU) 2016/679 (on Data Protection), this privacy policy (the “Policy”) reflects the privacy practices of Alaya Foundation (“AF”), a Foundation incorporated under the laws of Portugal and filed with the corporations and foundations register, with the Portuguese tax number 514 934 409, regarding information about you or third parties provided directly by AF or through this website.

By accessing or using this site, you voluntarily and unconditionally agree to the use, disclosure, and procedures set out in this Privacy Policy.

AF reserves the right, at its sole discretion and without prior notice, to update and amend this Policy, with such updates and amendments taking effect immediately upon being published on this site.

Data Protection

AF has implemented various technical and organizational security procedures and measures to protect personal data from any disclosure, loss, misplacement, harmful use, modification, or unauthorized access, as well as from any other form of unlawful processing.

Despite adopting all these precautions and measures, AF cannot absolutely guarantee that unauthorized access, disclosure, modification, or deletion of data willnot occur, caused namely by hardware or software failures or any unauthorized use.

Any information you transmit to AF is done under your sole and exclusive responsibility.

How AF Uses and Shares Information

AF uses your personal information for the following main purposes:

  • For administrative purposes, such as supervising you whenever necessary, with a view to preventing any criminal activity, fraudulent action, or any act that may constitute money laundering or any other legal obligation;
  • To comply with legal obligations;
  • To record and archive all communications with you or to comply with legal duties;
  • For the management, dissemination, or publication of newsletters, marketing and/or institutional content from AF, including offers, advertising of products and services that AF (or a service provider acting on its behalf) may present to you on third‑party websites, platforms, and applications based on your usage information of the site.

AF reserves the right to share information withthird parties, such as:

  • Service providers: AF may share information with service providers that collaborate with AF in performing or executing certain tasks or functions;
  • ‍Educational partners, internship programs, higher education institutions;
  • ‍‍Whenever legally required: AF willshare information that is legally required or necessary to defend its rights;
  • ‍With third parties for research/investigation purposes.

Your data may be used for:

  • Account management and authentication;
  • Operational communications, such as notifications or updates;
  • Sending information about programs, training, or services;
  • Compliance with legal obligations;
  • Improvement of the Site and statistical analysis;
  • Security and fraud prevention.

Retention Period

Personal data provided will be stored and maintained for the period necessary for the purposes for which they were collected or for the number of years required to comply with legal obligations.

  • ‍Right to information: You have the right to request that AF inform you about the purposes of data processing, to whom the data may be transmitted, your rights, and under what conditions you may exercise them, and what details may be provided;
  • ‍Right of access: You have the right to request access to the information AF holds about you;
  • ‍Right to rectify your personal information: If you find that the information AF holds about you is incorrect or incomplete, you have the right to rectify that information or request that AF complete any information you consider incomplete;
  • ‍Right to erasure: Under certain conditions, you have the right to have information about you deleted;
  • ‍Right to restrict processing: In certain situations, you may have the right to restrict the processing of your personal information. You have the right to request that AF not use your information for marketing purposes. AF will request your authorization to use your information for these purposes when collecting it for such purposes;
  • ‍Right to object to processing: You may reasonably object to the processing of your personal information (including profiling). You may also object to the processing of your personal information for marketing purposes (including marketing‑related profiling) and for statistical analysis;
  • ‍Right to data portability: You have the right to move, copy, or transfer your personal information;
  • ‍Rights related to automated decision‑making, including profiling.

Your Rights

Yourpersonal information is protected by Data Protection Law, and AF recognizes thefollowing rights, which you may exercise free of charge:

If you wish to exercise your rights, have any questions about AF’s Policy, or have any comments, you may do so via the following email: dpo@alayafoundation.org.

Without prejudice to the rights described above, you also have the right to lodge a complaint with the Comissão Nacional de Protecção de Dados – https://www.cnpd.pt/

Personal Data

The personal data that AF may collect from you or about you, or when you voluntarily respond to a customer survey or respond through this site, include: name, email address, home address, telephone number, place of birth and nationality data, and identification document data.

Additionally, AF may automatically collect information from your device whenever you access this site, such as your IP address, browser type, and information through cookies (see the cookies section below).

The personal data collected are as follows:

Data provided directly by the user:

  • Name
  • Email

and excepcionally,

  • Phone number
  • Account registration data
  • Information submitted in forms
  • Messages sent through the Site

Automatically collected data:

  • IP address
  • Device and browser type
  • Cookie data
  • Usage and navigation data
  • Technical identifiers

AF may also collect and process your personal data for:

  • Processing and responding to your requests or contacting you to respond to your questions and/or requests;
  • Communicating any information of interest to you or sending you communications, as well as inviting you to events promoted by AF;
  • Managing AF’s operational needs related to your participation in conferences, debates, or promotional activities;
  • Authenticating the identity of individuals who contact AF;
  • Training and quality assurance purposes;
  • Understanding and evaluating consumer interests, desires, and changing needs, to improve the site, current products and services, and/or develop new products and services;
  • Providing you with personalized products and communications, as well as targeted advertising and product recommendations.

Your personal data are collected and processed within the scope of the services and products provided by AF on its website and commercial network.

There may also be cases where the legal basis for collecting and processing your personal data is AF’s legitimate interest — for example, to assist in the execution of a contract or to optimize a service — provided that your rights as an individual are not compromised. This legal basis will only be used when there is no less intrusive way to process your personal data.

AF also processes personal data to execute a contract in which the user is or may become a party, to comply with a legal or binding obligation, or to perform tasks in the public interest.

Cookies Policy

A cookie is a file downloaded to the user’s computer, smartphone, or tablet when accessing certain web pages, used to store and retrieve information about browsing activity.

Cookies necessary for the functioning of the site (and configured so as not to allow cross‑site tracking) do not require your consent.

For all other cookies, you must provide express consent, as indicated on the site upon your initial access.

To comply with our obligations regarding the cookies policy, and without prejudice to what is already stated in this privacy policy and in AF’s website terms and conditions, you are informed of the following:

  • The identity and contact details of the data controller;
  • The exhaustive list of cookies used (name, purpose, duration, issuer);
  • The purposes of each cookie, described clearly and understandably;
  • The legal basis for processing (consent for non‑essential cookies, legitimate interest for technical cookies);
  • The recipients of the collected data (advertising partners, analytics tools, etc.);
  • Cookie management methods (how to modify or withdraw consent).

International Transfers

If any data transfer outside the European Union occurs, AF ensures:

  • Standard contractual clauses approved by the European Commission;
  • Adequate technical and organizational measures.

Security

Aware that no system is completely immune to risks, AF implements adequate technical and organizational measures, including:

  • Encryption
  • Access control
  • Firewalls
  • Backups
  • Security monitoring

Changes to the Privacy Policy

AF may update this Policy at any time and without prior notice.

The updated version will be published on the Site with an indication of the revision date.

Contacts

For questions related to privacy or exercising rights: dpo@alayafoundation.org

This Privacy Policy is an integral part of the terms and conditions set by AF on its site, which prevail over these document.