Privacy Policy

privacy policy

Information on the Processing of Personal Data

Who is responsible for processing your data?

Gaman Portugal, Lda  (“NORAIRLABS”), VAT PT 516493019, is responsible for processing the personal data collected and processed on our platforms (platforms being understood as the use of the norairlbs.com website, app , as well as those derived from your relationship with NORAIRLABS). You can contact NORAIRLABS by the following means:

Postal address: Gaman Portugal, Av. do Imigrante 1717, 4770-316 Bente, Portugal
E-mail: team@norairlabs.com

We would also like to inform you that NORAIRLABS has appointed a data protection officer whom you can contact and/or ask any questions regarding the processing of your personal data by sending an e-mail to team@norairlabs.com or a letter to the following postal address: Gaman Portugal – DPO, Av. do Imigrante 1717, 4770-316 Bente,  Portugal

What kind of personal information does NORAIRLABS collect and process?

NORAIRLABS may collect information directly from your relationship and use of our services, mainly the following data and/or categories of data: i) identification and contact data; ii) personal characteristics data; iii) economic data, such as credit card (PAN+CVV2), in accordance with PCI DSS standards, which will be used for payment processing, whenever you buy any of our items, or, in cases of returns, for transfers, where we will need the account number in which we will have to process the return of your purchase; iv) data observed in the purchase of our products, as well as in the consumption habits and preferences of our customers; v) data on the use of NORAIRLABS platforms and browsing.

For what purpose do we process your personal data and what is the legal basis?

In order to ensure that personal data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed, NORAIRLABS will store your personal data only for the period of time necessary to fulfill the purpose for which it was collected, taking into account the needs to respond to questions that arise or to solve problems, make improvements, activate services, and comply with the requirements demanded by applicable legislation. This means that your personal data may be kept…

Who do we share your personal data with?

Your personal data may be shared with Gaman Group companies for internal administrative purposes based on legitimate interest. Your personal data will be communicated to third parties in compliance with legal obligations that in each case correspond, for example to Public Administrations and/or Entities when required by tax, labor, Social Security, or any other applicable issues. In the event that you make a purchase or sale through our platforms, your data may be communicated where appropriate to finan…

The purposes for which NORAIRLABS may process your personal data are as follows:

CREATION OF USER ACCOUNT
Manage your registration, which will involve the creation of an account as a NORAIRLABS user. This account will allow you to centralize any matters related to your status as a user, as well as provide access to certain functionalities available and reserved for users with this status. For example, with a user account, you will be able to save certain information that can be used in future purchases and/or interactions with NORAIRLABS.


PURCHASE OF NORAIRLABS PRODUCTS
Processing the purchase of items made through the different purchasing channels provided by NORAIRLABS. This management consists of carrying out all the appropriate actions in order to manage your purchase and, where appropriate, guarantee the correct delivery of your order, as well as carrying out any management related to the sale of the item such as, for example, managing and issuing documents accrediting the purchase and sale, such as the simplified electronic invoice, the sales invoice or Tax Free and, where appropriate, processing the return of items.

To this end, we may send you information on the status of the purchase either by e-mail or SMS and/or through any other channel available at any given time.

The legal basis that legitimizes the processing of your data for this purpose is the performance of a contract, understood as the Conditions of Sale accepted at the time of purchase of the items. The processing of your data is necessary to guarantee compliance with the obligations and rights provided for in the Conditions of Sale.


MANAGEMENT OF THE NORAIRLABS GIFT CARD
The legal basis that legitimizes the processing of your data for this purpose is the execution of a contract, understood as the Conditions of Use accepted at the time of purchase of the card. The processing of your data is necessary to ensure compliance with the obligations and rights set out in the Conditions of Use.


ONLINE PURCHASES
With regard to the processing of online purchases, NORAIRLABS, as the controller, will carry out the corresponding actions for the prevention, detection and control of abuse and fraud in the use of our services, and automated decisions may be taken in this regard.

These automated decisions will consist of the analysis of behaviors in the payment process, for which, in general terms, the data of the purchase process and the history of purchases made will be used, in order to be able to verify whether it is a fraudulent transaction. This information will allow us to detect and try to prevent fraudulent behavior in payment transactions, so that a purchase can be denied and thus guarantee your protection, that of the interested party (in the event of identity theft) or that of NORAIRLABS as a service provider and responsible party.

  • The processing of your data for this purpose is legitimized by NORAIRLABS’s legitimate interest in analyzing all the operations that take place in the payment process for the products it sells to ensure that there is no economic fraud and consequent negative effects on itself or its customers. In this sense, we consider that there is also a general interest, as the processing helps to generate, improve and maintain public confidence in the economic relationships that are carried out through the means of payment that NORAIRLABS makes available in its online commerce to prevent distrust from being generated due to fraud or fraudulent activities that could occur in them.
  • Please note that, in this case, NORAIRLABS has compelling legitimate reasons to process your data for this purpose and cannot respond to your right to object in accordance with Article 21.1 of the General Data Protection Regulation.
  • You can find out more about this assessment by contacting our data protection officer directly.

 

If you are registered as a user and purchase one of our items through our platforms, we may carry out the following processing:

Save your credit card details so that they can be used for future purchases.
The legal basis that legitimizes the processing of your data is the express consent given by you for us to store this information so that it can be used for future purchases, without prejudice to the fact that the use of your credit card data itself is legitimized within the framework of the execution of a contract in accordance with what is stated in the previous section. Such consent may be withdrawn at any time without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

 

Configure Your Relationship With Norairlabs As A Brand

Newsletter: managing and sending commercial information on exclusive promotions and news tailored to your profile, sending audiences via digital platforms, as well as communications related to products stored in your shopping basket, via email, SMS or any other communication channel and/or digital platform. This includes promotional actions, such as the management of contests or sweepstakes organized by NORAIRLABS.
 If you have agreed to receive commercial communications through different channels, certain personal information may be used to personalize communications in digital media.

  • The legal basis that legitimizes the processing of your data is the express consent given by you, although you may withdraw your consent at any time, without the lawfulness of processing based on consent prior to its withdrawal being affected.

 

To manage the service of alerts on the availability of products through email, SMS or any other communication channel and/or digital platform.

  • The legal basis that legitimizes the processing of your data for this purpose is express consent, which may be withdrawn at any time without affecting the lawfulness of the processing based on consent prior to its withdrawal.
 
 

To respond to the exercise of rights recognized in the personal data protection regulation.
The legal basis that legitimizes the processing of your data is the fulfillment of a legal obligation relating to the management of the exercise of rights in accordance with the obligation provided for in the General Data Protection Regulation.

 

Respond to queries, requests and possible complaints that you make through the contact channels provided by Customer Service, such as post, telephone, email, Social Media, forms on the NORAIRLABS Web, virtual assistant on the Web with AI capability and any other channel enabled for this purpose. Depending on the reason for contacting NORAIRLABS, the basis for processing your data may be different. In this sense:

  • We consider the existence of a legitimate interest on the part of NORAIRLABS to resolve and respond correctly to suggestions, queries or requests that you may make through the channels made available by Customer Service, on the understanding that, in no case, are your rights and/or freedoms affected or prejudiced by the fact that the request initiated by you is being attended to.
  • In the event that we are dealing with issues related to an order and whose attention is necessary for the formalization of the purchase, the processing of your data is legitimized by the execution of a contract, understood as such in the Conditions of Sale.
  • In the event that your data is processed in order to respond to a complaint or claim submitted through the channels made available by the customer service department, your data will be processed in order to comply with a legal obligation laid down in the Consumers and Users Act.

After providing any of our services, we send you quality surveys in order to find out your opinion and level of satisfaction regarding your relationship with NORAIRLABS. The information collected as a result of the survey will allow us to create and improve our services and procedures, which is essential for us to have.

  • The legal basis for processing your data is legitimate interest. Our legitimate interest is to be able to guarantee that our platforms continue to be secure, as well as to help NORAIRLABS respond to your needs, expectations and level of satisfaction with the brand and, therefore, improve our services at every stage. All these actions are carried out in order to improve your level of satisfaction and guarantee a unique browsing and shopping experience, carrying out the aforementioned analysis in aggregate form.

Creation of profiles based on behavioral and consumption data, collected through your browsing, your interactions with the brand and those derived from your purchase history in order to show you, in a prioritized manner, recommendations or content on our platform, according to your tastes, as well as to send you commercial communications adapted to your profile, provided that you have given us your consent for this purpose.

  • Taking into account the characteristics of the person whose profile has been created and after the corresponding weighing of their interests as the affected subject, as well as NORAIRLABS as the responsible party, it has been determined that the legal basis that legitimizes the processing of their data is legitimate interest, as it is considered to be in the interest of all parties involved that those items that may be of interest to the consumer are shown as a priority. In this way, by prioritizing items that may reflect the priorities of the user in question, NORAIRLABS will be able to offer them a higher quality service and ensure that the user experience is much more positive and, at the same time, bring a reputational benefit to NORAIRLABS in the fact that users have a good experience while browsing and buying on our platforms.
  • Taking into account the characteristics of the person whose profile has been created and after the corresponding weighing of their interests as the affected subject, as well as NORAIRLABS as the responsible party, it has been determined that the legal basis that legitimizes the processing of their data is legitimate interest, since it is considered to be in the interest of all parties involved that personalized communications be sent. In this way, the fact that it is possible to tailor commercial communications to the user’s profile will allow NORAIRLABS to offer them a higher quality service, since they will only receive communications whose content may be of interest to them, and avoid sending generic communications that may be excessive or unattractive to the interested parties. This will increase your level of satisfaction and, at the same time, will benefit NORAIRLABS, allowing it to carry out more effective commercial communications to attract new customers and retain those it already has, as well as improving its corporate image.
  • The algorithm envisaged for profiling does not make recommendations on actions to be taken (neither at segment level nor at individual level), nor does it apply decisions in an automated way, but merely analyzes data on the behaviour and consumption of customers and potential customers to find out their interests, tastes and preferences, inferring the behavior of the interested party in the future. Based on this information, the person responsible for marketing will decide on the best strategy for that segment, customer or potential customer.
  • You can obtain more information on this assessment of legitimate interest by requesting it directly from our data protection officer.

How long will we keep your personal data?

In order to ensure that personal data is adequate, relevant and limited to what is necessary for the purposes for which it is processed, NORAIRLABS will store your personal data only for the period of time necessary to fulfill the purpose for which it was collected, taking into account the needs to respond to questions that arise or to solve problems, make improvements, activate services and comply with the requirements demanded by applicable legislation. This means that your personal data may be kept for a reasonable period of time, even after you have stopped using NORAIRLABS’s services and/or stopped using the website. After this period, your personal data will be blocked from all NORAIRLABS systems for the sole purpose of making it available to the competent authorities to fulfill any administrative or judicial responsibilities and for the exercise or defense of claims. Once the personal data has been blocked, it will be permanently deleted.

Who do we share your personal data with?

Your personal data may be shared with Gaman Group companies for internal administrative purposes based on legitimate interest.

Your personal data will be communicated to third parties in compliance with legal obligations that, in each case, correspond, for example, to Public Administrations and/or Entities when required by tax, labor, Social Security or any other applicable issues.

In the event that you make a purchase or sale through our platforms, your data may be communicated, where appropriate, to financial entities and payment service providers, fraud detection and prevention entities, such as Stripe, logistics providers, transportation and delivery of goods. These communications are strictly necessary to guarantee the delivery of your order.

On the other hand, please note that NORAIRLABS may contract third parties who have access to your data derived from the provision of services, after having regulated this relationship. These third parties may provide us with technological services, customer service or marketing and advertising, among others, and in any case, they will process your data following NORAIRLABS’s instructions and never for their own purposes.

Under no circumstances will NORAIRLABS sell your personal data to third parties.

International transfers

International data transfers may take place if the companies with which NORAIRLABS shares your data are located outside the European Economic Area, which will be lawful given that adequate guarantees are established to protect personal data. In cases where the country receiving the data is not considered to be of an adequate standard, NORAIRLABS will regularize the relationship with the third party receiving the data by signing the corresponding Standard Contractual Clauses adapted by the European Commission, the content of which can be consulted at the following link.

In any case, third parties with whom certain personal data is shared will have accredited, in advance, the adoption of appropriate technical and organizational measures that guarantee the correct protection of said data.

Data from the interested party not collected directly

In some of the services offered through our platforms, such as Gift Cards, a user may provide personal information about the recipient. In this case, NORAIRLABS will also comply with its obligations in accordance with data protection regulations, and the data will therefore be processed exclusively to fulfill the purpose for which it was provided.

How does NORAIRLABS protect your personal data?

Our platforms use information security techniques such as network and application firewalls, automated anti-attack systems, access control procedures and cryptographic mechanisms, all with the aim of preventing unauthorized access to data and guaranteeing its confidentiality. Periodic security audits are also carried out to assess risks, in addition to frequent checks. In order to achieve these purposes, you agree to NORAIRLABS obtaining data for the purposes of the corresponding authentication of access controls.

Any transaction made through our platforms will be carried out using secure payment systems. Confidential payment data is transmitted directly and in encrypted form to the corresponding entity.

NORAIRLABS declares that it has adopted all the technical and organizational measures necessary to guarantee the security and integrity of the personal data it processes, as well as to prevent its loss, alteration and/or access by unauthorized third parties.

What are your rights in relation to your personal data?

You have the following rights. You can exercise these rights by emailing team@norairlabs.com. In order to process your request to exercise your rights, we may ask you to confirm your identity.

Right of access
You have the right to know whether or not NORAIRLABS is processing personal data concerning you, as well as to access personal data that NORAIRLABS may hold about you.

Right to rectification
You have the right to request that NORAIRLABS rectify your personal data when it is incorrect or complete it when it is incomplete. If you have a user account, you can correct your data directly by accessing the “My Account” section of your profile.

Right of deletion
You can ask us to delete personal data when, among other reasons, it is no longer necessary for the purposes for which it was collected.

Right to restriction
You have the right to request that the processing of your data be restricted, in which case it will only be kept for the exercise or defense of claims.

Right to portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format and to have us transmit it to another controller when the processing of your data is legitimized by your consent or derives from the performance of a contract, provided that it is carried out by automated means.

Right to object
You can object to personal data being processed on the basis of the public or legitimate interest pursued by NORAIRLABS, including profiling. In this case, NORAIRLABS will stop processing the data, unless there are compelling legitimate reasons or it is necessary to exercise or defend any claims. You also have the right to object to the processing of data for direct marketing purposes.

Automated individual decisions
Where applicable, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or affects you in an equally significant way. However, it will not be possible to exercise this right: if the decision is necessary for the conclusion or performance of a contract between you and NORAIRLABS; if it is authorized by the law applicable to NORAIRLABS, provided that NORAIRLABS establishes appropriate measures to safeguard your rights, freedoms and legitimate interests; or if it is based on your explicit consent.

Right to lodge a complaint
You have the right to lodge a complaint with the competent local Supervisory Authority, which in Portugal is the Comissão Nacional de Proteção de Dados.

Changes to the privacy policy?

This privacy policy will always be available. However, in the event that we make substantial and significant changes to its content, we will send you a notification, either through our platforms or to your email address, thus complying with the duty to inform provided for in the GDPR, so that, if you so consider, you can exercise your rights as an interested party.

Cookie Policy

What are cookies and how are they used?

Cookies are files installed on the User’s computer, phone, tablet, or any other device with the purpose of recording activities during the user’s browsing time on the website. By using cookies, the server where the Web/App is located recognizes the browser used by the user, which allows, for example, registered users to access areas and services without having to register on each visit, as well as remembering their language preferences, country, etc., on future visits. Cookies are also used to measure audience and traffic parameters.

In relation to the concept of “cookie,” we also refer to other technologies similar to cookies that similarly allow storing or retrieving certain information from a device, such as flash cookies, web beacons or bugs, pixels, HTML5 (local storage), and SDK technology for App formats, as well as the use of fingerprinting techniques to identify the user’s device.

For what purpose does NORAIRLABS use cookies?

During access and navigation on the website, NORAIRLABS may store or record IP addresses, user preferences, or the type of device used with the main purposes of: (i) preparing statistics related to the number of visits or traffic on the web pages; (ii) offering a more personalized browsing experience; (iii) remembering login details even on different devices; and (iv) presenting advertisements on this page or others based on browsing habits within our website.

Please note that we do not store sensitive personal identification information, such as your address, password, etc., in the cookies we use.

NORAIRLABS does not sell its customers’ data to third parties under any circumstances.

Who uses the information stored in the cookies?

What types of cookies does NORAIRLABS use?

The information stored in the Web/App cookies is used by Gaman Portugal Lda (“NORAIRLABS”) with VAT PT 516493019:

Postal address:
Gaman Portugal,
Av. do Imigrante 1717,
4770-316 Bente, Portugal
E-mail: team@norairlabs.com

Some cookies that are not owned by NORAIRLABS but by third parties may also be installed. You can consult the complete list of cookies used by NORAIRLABS in the configuration panel that you will find below.

Below are the types of cookies used on NORAIRLABS’s Web/App according to their purpose and the entity managing them (own and third-party).

Own management cookies
These are created or managed by NORAIRLABS as the entity responsible for the Web/App.

Third-party cookies
These are managed by external service providers to NORAIRLABS and are identified in the configuration panel which you can access through the “configure cookies” button found below.

PURPOSE/DESCRIPTION

Strictly necessary cookies

These cookies are essential for the website’s operation and cannot be disabled in our systems. They are usually set in response to actions made by the user to access services such as adjusting privacy preferences, logging into your account, or filling out forms. You can set your browser to block or alert you about these cookies, but some parts of the website may not work as a result. These cookies do not store any personally identifiable information.

Preferences or personalization cookies

These cookies allow you to access the service with predefined features based on a series of criteria, such as language, the type of browser through which you access the service, regional settings from which you access the service, etc. Not accepting these cookies may result in slower performance or poorly tailored recommendations.

Analytics cookies

These are cookies that, managed by us or by third parties, allow us to quantify the number of users and thus perform the measurement and statistical analysis of how users use the offered service. For this purpose, we analyze your navigation on our website to improve the range of products or services we offer.

Behavioral advertising cookies

These are cookies that, managed by us or by third parties, allow us to analyze your internet browsing habits so that we can show you advertising related to your browsing profile.

Social media cookies

These cookies are set by various social media services that we have added to the website to enable you to share our content with your friends and networks.

How to disable cookies in the main browsers

You can allow, block, or delete cookies installed on your device through the configuration of your internet browser options. If you block them, some services that require their use may no longer be available. Below we provide links where you will find information on how to enable your preferences in the main browsers:

  • Google Chrome
  • Mozilla Firefox
  • Internet Explorer
  • Safari
  • Opera

If you have accepted third-party cookies, you can delete them from the browser options or through the system provided by the third party itself.

Retention periods

NORAIRLABS will retain the personal data collected only for the determined, proportionate, and limited period necessary to fulfill the purpose for which they were collected, as well as to comply with the requirements of applicable legislation. Once the intended purpose is fulfilled, your data will be properly blocked for the period during which legal actions can be taken, and once the limitation period has expired, they will be properly deleted.

Similarly, data obtained through the use of cookies accepted by the user will be retained for a period of 12 months, and therefore, after this period, new consent will be requested when you visit our WEB/APP. Regarding third parties identified in the cookie configuration panel, you can consult their retention period in their respective privacy policies.

Data transfer to third countries

Data processing is generally carried out by service providers located within the European Economic Area or in countries that have been declared to have an adequate level of protection. In the event of international data transfers to countries that do not have a European Commission adequacy decision, NORAIRLABS will use the Standard Contractual Clauses adopted by the European Commission as a guarantee for such transfers and in accordance with Articles 44 to 49 of Regulation 2016/679 on Data Protection. In…

How to manage your consent preferences

You can configure the optional cookie categories by clicking on the cookie settings button below: Manage Consent