Terms and Conditions and GDPR Privacy Policy



These Website Standard Terms and Conditions written on this webpage shall manage your use of our website, Lugna accessible at www.lugna.pt.

These Terms will be applied fully and affect to your use of this Website. By using this Website, you agreed to accept all terms and conditions written in here. You must not use this Website if you disagree with any of these Website Standard Terms and Conditions.

Intellectual Property Rights

Other than the content you own, under these Terms, Lugna and/or its licensors own all the intellectual property rights and materials contained in this Website.

You are granted limited license only for purposes of viewing the material contained on this Website.


You are specifically restricted from all of the following:

  • publishing any Website material in any other media;
  • selling, sublicensing and/or otherwise commercializing any Website material;
  • publicly performing and/or showing any Website material;
  • using this Website in any way that is or may be damaging to this Website;
  • using this Website in any way that impacts user access to this Website;
  • using this Website contrary to applicable laws and regulations, or in any way may cause harm to the Website, or to any person or business entity;
  • engaging in any data mining, data harvesting, data extracting or any other similar activity in relation to this Website;
  • using this Website to engage in any advertising or marketing.

Certain areas of this Website are restricted from being access by you and Lugna may further restrict access by you to any areas of this Website, at any time, in absolute discretion. Any user ID and password you may have for this Website are confidential and you must maintain confidentiality as well.

Your Content

In these Website Standard Terms and Conditions, “Your Content” shall mean any audio, video text, images or other material you choose to display on this Website. By displaying Your Content, you grant Lugna a non-exclusive, worldwide irrevocable, sub licensable license to use, reproduce, adapt, publish, translate and distribute it in any and all media.

Your Content must be your own and must not be invading any third-party’s rights. Lugna reserves the right to remove any of Your Content from this Website at any time without notice.

No warranties

This Website is provided “as is,” with all faults, and Lugna express no representations or warranties, of any kind related to this Website or the materials contained on this Website. Also, nothing contained on this Website shall be interpreted as advising you.

Limitation of liability

In no event shall Lugna, nor any of its officers, directors and employees, shall be held liable for anything arising out of or in any way connected with your use of this Website whether such liability is under contract.  Lugna, including its officers, directors and employees shall not be held liable for any indirect, consequential or special liability arising out of or in any way related to your use of this Website.


You hereby indemnify to the fullest extent Lugna from and against any and/or all liabilities, costs, demands, causes of action, damages and expenses arising in any way related to your breach of any of the provisions of these Terms.


If any provision of these Terms is found to be invalid under any applicable law, such provisions shall be deleted without affecting the remaining provisions herein.

Variation of Terms

Lugna is permitted to revise these Terms at any time as it sees fit, and by using this Website you are expected to review these Terms on a regular basis.


The Lugna is allowed to assign, transfer, and subcontract its rights and/or obligations under these Terms without any notification. However, you are not allowed to assign, transfer, or subcontract any of your rights and/or obligations under these Terms.

Entire Agreement

These Terms constitute the entire agreement between Lugna and you in relation to your use of this Website, and supersede all prior agreements and understandings.

Governing Law & Jurisdiction

These Terms will be governed by and interpreted in accordance with the laws of the State of Portugal, and you submit to the non-exclusive jurisdiction of the state and federal courts located in Portugal for the resolution of any disputes.


Privacy Policy

Please read our Privacy and Data Protection Policy. It was designed to be compliant with the new General Data Protection Regulation.
Browsing or accessing our website will not necessarily imply cookies or the gathering of Personal Data – Please read our Cookie and Terms of Use disclaimer. This Statement describes what kind of personal information we may collect, how we collect it and why we collect it.
It is addressed to individuals with whom we interact, including individual clients, personnel of corporate clients, vendors and other recipients of our services. We recognize the importance of protecting your data and privacy.
We reserve the right to amend or change our Privacy and Data Protection Policy. The published version on the website is the one currently in force.

Our Privacy and Data Protection Policy is not applicable to third party websites.

Personal Data

Personal Data is any information that can be used to identify you or that we can link to you as an identified or identifiable natural person.
An identifiable natural person is someone who can be identified, directly or indirectly, by reference to an identifier such a number, location data, electronic identifiers or specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity.
We process Personal Data about different categories of people, including our clients, people involved in matters we act on for our clients, people we or our staff have relationships with, and other third parties who interact with us. Because of the nature of the services we provide, the types of data we process can be quite varied, but will usually include full names, nicknames, gender, date of birth, marital status, tax and social security numbers, other government issued numbers, nationality, signatures, photographs, contact details, and associated client information.
Depending on the nature of our relationship with you, we may also process information about your business and company affiliations; identification (including copies of your passport); financial affairs (including bank account details); family, lifestyle and social circumstances; education and employment background; the services we provide you or your company; and the goods or service you or your company provide us.
We may also collect other information that is relevant to our functions or activities, including usage details about how you use our website, our services and other information as collected by Google Analytics.

Collection of Personal Data

Collection and processing of Personal Data takes place when and if:

  • An individual or corporate entity requests our contact, a service and/or budget proposal.
  • An individual requests information on a particular topic or service.
  • An individual requests his/her registration for the purposes of receiving a newsletter.
  • An individual submits his/her application for a job position.

We will only collect and/or process Personal Data where we have a lawful basis for doing so, such as:

  • Consent – if we need and have obtained your consent to use your Personal Data.
  • Performance of a contract – we may need to collect and use your Personal Data for the performance of a contract to which you are party or in order to take steps at your request prior to entering a contract.
  • Legitimate interest – we may use your Personal Data is as necessary for the purposes of pursuing our legitimate interests.
  • Compliance with law or regulation – we may use your Personal Data as necessary to comply with applicable law/regulation.

In the event of non-transmission of required Personal Data, we may reserve the right to not consider a job application or respond to proposals and/or budgets requests or other requests, as applicable.
We collect Personal Data for several different purposes including (but not limited to):

  • To provide information or assistance that you request from us.
  • To provide you with the services requested.
  • To send updates, invitations to events and other information that may be of interest to you.
  • To comply with KYC (Know Your Client) policies and perform the on-boarding of new clients in compliance with our internal compliance requirements, policies and procedures.
  • To comply with legal and regulatory requirements.
  • To conduct verifications, monitoring and reporting in accordance with AML (anti-money laundering) and counter terrorist financing laws.
  • To notify you about changes to our services.
  • To monitor and improve the quality of our services.
  • Quality assurance and training purposes.
  • To establish, exercise or defend our legal rights or for the purpose of legal proceedings.
  • To analyze any complaints or queries you may have.
  • To prevent and respond to actual or potential fraudulent or illegal activities.

We may obtain such Personal Data from you directly, from our clients, from third parties involved in matters we act on for our clients, and from other third parties (including publicly available information). Where you are our client, it will sometimes be necessary for you to provide us with information directly, and in those cases, it is your responsibility to ensure that all such information is complete in all material respects and not misleading.
The accuracy and appropriateness of our services may be affected because of your failure to do so.
If any information changes, please let us know so that we can keep it updated on our systems. Please note that you are responsible for ensuring that any Personal Data that you send to us is sent securely.
We do not request or encourage the submission or transmission of Personal Data related to philosophical or political beliefs, party or trade union affiliation, religious faith, private life and racial or ethnical origin, as well as the processing of data related to health and sexual life, including genetic data. Therefore, and if this type of Personal Data is transmitted to us, we cannot be held liable for its processing under this Data Protection and Privacy Policy. We will take particular care to only process it in accordance with strict parameters.

Maintenance of Personal Data

Personal Data will be processed and stored in electronic and/or paper format.
The period of time during which Personal Data are stored and maintained will vary in accordance with the purposes of collecting the data. Laws or regulations may set a minimum period for which we have to keep your Personal Data.
We will ensure that the Personal Data that we hold is subject to appropriate technical and organizational security measures, including password protection, encryption, physical entry restrictions to the premises and firewalls where applicable.

Communication of Personal Data to Third Parties

In providing services to our clients and in complying with our legal obligations, we may share the Personal Data that we obtain about you, insofar as we are permitted by law to do so.
We do not provide your Personal Data to other companies or organizations, unless we are required to do so by law. We may disclose your personal information internally for legitimate business purposes (including providing services to you) and in accordance with applicable law.
Thus, we may disclose your personal information to our staff, third party service providers engaged for specific functions, regulators and other entities which we are legally required to disclose your Personal Data to. This list of possible disclosures is not intended to be exhaustive. There may be other legitimate purposes for holding, disclosing or otherwise processing your Personal Data.
Where the law so requires, you will be notified of any additional purposes and where required your consent will be sought.
We may use third parties to provide certain services (located in jurisdictions inside or outside the European Union), which may imply, in some cases, access by these entities to Personal Data.

Rights of user

You can always contact us if you have any questions regarding our Privacy and Data Protection Policy or wish to review, modify or delete your personal information.
You have the following rights:

  • Being informed on which Personal Data we have and what purposes we are using it for.
  • Inspection of the Personal Data that we keep from you.
  • Having incorrect data corrected.
  • Request to delete outdated Personal Data.
  • Revoke your consent.
  • Object to certain uses.

You have the right to obtain the deletion of your Personal Data when the data is no longer needed for the purpose for which it was collected or processed or, in the event of consent being the legal basis for data collection, you withdraw it and there are no prevailing legitimate interests justifying its maintenance.
You have the right to lodge a complaint in respect of our processing of your Personal Data. If you would like to raise your complaint with us in the first instance, please contact us.
Finally, you have the right to data portability, were applicable.
24th May 2018