Privacy Policy

By Article 13 of the European Data Protection Regulation EU Reg. 201/679

1. Responsible for Treatment

Wishes And Intuition Unipessoal Lda, with headquarters at Rua Senhora da Saúde, No. 14-A 7005-372 Évora, 7005 – 372 Évora, with NIF 514267470 is the Data Controller of the information collected on this website. You can contact us for general matters, in writing, through the email address info@cyango.com and for issues related to your personal data to info@cyango.com.

2.  Purposes of Processing and Legal Basis

2.1 In the table below, you will find the categories of personal data we process, for what purposes, and the legal basis on which we do so.

Please note that subject to the unique situations described below, we generally process your data to manage our contractual relationship with you and provide the services you have requested. To that extent, we may send you marketing communications about our services unless you refuse such communications by sending us an email to that effect or by changing your preferences in your area of our site.

2.2 The use of specific Wishes services such as participation in “Marketing Campaigns” or other activities Wishes may organize may determine the need to collect personal data other than those mentioned in the table below and may involve the performance of other personal data processing activities.

In such a case, we will provide you with additional information about data processing and registration conditions available on the website dedicated to these actions. These conditions shall be considered an integral part of this Privacy Policy and shall prevail in case of conflict.

2.3 It is likely that not all scenarios will apply to you because the data collected will depend on the services you choose to use. However, we provide you with information on all possible scenarios.

Please note that they are presented scenarios only in that condition and do not constitute an exhaustive description whenever you read examples.

2.4 The personal data collected in each case are those requested in the various registration forms and will be for the purpose inherent to each specific action or situation.


2.5 Following the provisions of article 13.º-A/3 of Law 41/2008 of August 18, Wishes may use your data to send communications relating to services similar to those you have contracted.

Data Category Purpose Legal Basis
   a) Identification Data: first name and last name, NIF; website username and password;    b) Contact data: email; mobile phone number; postal address;    c) Non-sensitive data necessary for campaign operation: Type of service contracted; (*)    f) Contractual Data: Products and services contracted to Wishes;    g) Browsing data: IP; User ID; browser used; Registration at www.cyango.com or related microsites; Execution of the Contract or steps before the conclusion of the contract: by registering on our site as a subscriber or as a Supporter, you accept our [ contractual conditions].
Managing your subscription (e.g., software updates, renewal, refunds, etc…) Contract execution / pre-contractual due diligence; Compliance with legal obligations;  
Claims management and fraud prevention against Wishes; The legitimate interest of the Responsible Party in preventing misuse; compliance with legal obligations (e.g., prevention of criminal charges)  
Webinar and workshop registration management (e.g., courses or similar); Consent (if applicable), contract execution (rules of participation in the events); the legitimate interest of the responsible (to contact participants); fulfillment of applicable legal obligation (e.g., access control for security reasons)  
Satisfaction surveys about our services; The legitimate interest of the Responsible Party (to evaluate the degree of satisfaction of its clients)  
Service satisfaction surveys to publish articles/conduct studies; The legitimate interest of the Responsible Party (studies and publication of articles on consumer protection)  
Statistics on your use of our products or services; Consent or legitimate interest when necessary
Sending direct marketing communications about our services; Legitimate Interest of the Responsible Party; consent if applicable (see 2.2)
Consumption profile/use of our products and services; aggregate analysis of site usage for sending personalized advertising communications; Consent
   h) Image and Audio: Photographs, Videos, and audio recordings Interviews and studies related to the services provided Consent
   i) Bank Details: IBAN; Credit Card; Information for internal validation of receipts and invoices Consent
   j) Complaint data: Entity and service complained about; client number; consumption; Information and support to consumers in consumer conflicts Art.9/2 d) of the RGPD + terms and conditions for accessing the information service.

You may always object to these messages in one of the following ways:


– at the time of sending each message, by selecting the unsubscribe link;

– by writing to info@cyango.com;

2.6 Following the provisions of article 6.1 f) of the RGPD in conjunction with recital 47, Wishes may use your data for sending direct marketing communications, regardless of your consent, based on its legitimate interest, which is to promote its activity and thus enable its action for the benefit of all clients.

Wishes will not fail to evaluate the possible prevalence of your rights and freedoms over Wishes’ legitimate interest in sending you marketing communications.

3. Category of data recipients

3.1 To be correctly processed for the purposes referred to in paragraph 2, Wishes will enable access to your data by the following entities:

  1. Third parties which carry out part of the data processing activity, on behalf and under the responsibility of Wishes, based on a subcontracting agreement (subcontractors) concluded under Article 28 of the RGPD; or who carry out data processing activities in co-responsibility with Wishes (where applicable and depending on the information provided in the specific case);
  2. Individuals, employees, and collaborators who have been designated to perform one or more of your data processing activities as “Authorized Persons” as provided in Article 29 of the RGPD;
  3. Your data may be communicated to public entities or judicial authorities if required by law or to prevent or punish the commission of crimes.

According to Article 4/9 of the GDPR, “public authorities that may receive personal data in the framework of a particular inquiry following Union or Member State law shall not be regarded as recipients.”

4. Retention Period

4.1 Wishes will retain your data for as long as you remain a registered user of our website (as a subscriber) for the purposes related to the provision of the services requested. Without prejudice to the exercise of its right of opposition when applicable.

4.2 In case you are a subscriber to our platform, after the termination of the subscription, we will keep your data only for compliance with legal obligations and for a period not exceeding ten years, counted from the date of termination of the contract under the conditions explained below.

After the contract termination (s) – “Subscriber – we may keep your data to prove compliance with legal obligations, including the RGPD, tax legislation, and distance selling legislation.

In this case, we will only keep the necessary data for this purpose, and such data will be kept duly blocked and pseudonymized. They will only be accessible to specially authorized persons and exclusively to fulfill the aforementioned purposes. Even then, they will only be kept for the duration of the limitation period for the obligation in question, which may vary depending on the applicable law.

5. Rights of Data Subjects

5.1 You may exercise the following rights, as provided by the RGPD, by emailing info@cyango.com:

Right of access to your personal information;

  • Right to rectification of your data;
  • Right to erasure of data;
  • Right to limitation of processing;
  • Right of portability
  • Right of opposition;
  • Right of opposition to sending marketing communications;
  • Directly file a complaint with the CNPD – National Commission for Data Protection (www.cnpd.pt); In this case, don’t hesitate to contact us before filing a complaint with the CNPD to resolve the reported problem quickly.

5.2 You may also contact the number 961 085 333 between 9 am and 6 pm on working days to request information on how to exercise your rights.

5.3  Where your Data is processed based on consent (see the table above), you may withdraw your consent without this affecting the lawfulness of the processing carried out based on the previously given consent.

5.4 To comply with your requests, we may request additional information to identify you as set out in art. 11 of the GDPR in conjunction with recital 67.

In the event of an unjustified refusal to identify you, if we cannot identify you in any other way, we reserve the right not to respond to your request.

6. Data Protection Officer

Wishes have appointed a Data Protection Officer who can be contacted via email at info@cyango.com.

7. Analytical Data

7.1. Analytics

The services in this section allow the owner to monitor and analyze web traffic and can be used to monitor user behavior. Google Analytics (Google Inc.) Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the data collected to monitor and review your use of this website, prepare reports about your activities, and share it with other Google services. Google may use the collected data to contextualize and personalize ads for its ad network. Personal Data Collected: Cookies and Usage Data. Processing: United States – Privacy Policy – Opt-out.

Conversion tracking for Facebook (Facebook, Inc.), LinkedIn, and GoogleAds ads.

Conversion tracking for Facebook ads is an analysis provided by Facebook, Inc. that connects data from the Facebook advertising network with actions taken on this website. Personal data collected: Cookies and Usage data. Processing: United States – Privacy Policy.

7.2 Conteúdo Comentado

Content commenting services allow Users to make and post their comments on the content of this website. Depending on the settings chosen by the owner, users can also leave anonymous comments. If there is an email address among the personal data provided by the user, we can use it to send comment notifications about the same content. Users are responsible for the content of their comments. If a content feedback service provided by a third party is installed, it may still collect web traffic data for the pages where the feedback service is installed, even when Users do not use the content feedback service.

7.3 Cookies

The user can manage cookie preferences directly in his browser and prevent – for example – third parties from installing Cookies. Through browser preferences, it is also possible to delete Cookies installed in the past, including cookies that may have saved the initial consent to install cookies through this site. Users can, for example, find information on how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Internet Explorer. Concerning cookies installed by third parties, Users can manage their preferences and withdraw their consent by clicking on the related disabling link (if provided), using the means provided in the third party’s privacy policy, or contacting the third party. Notwithstanding the above, the owner advises that Users may follow the instructions provided in the initiatives subsequently linked to by the EDAA (EU), the Network Advertising Initiative (USA) and the Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. These initiatives allow Users to select their tracking preferences for most advertising tools. The owner, therefore, recommends that Users make use of these features in addition to the information provided herein.

System logs and maintenance

For operation and maintenance purposes, this site and any third-party services may collect files that record interaction with this site (system logs) using other personal data (such as IP address).

8. Security

Wishes have implemented and maintained security measures and technical and organizational policies to ensure the security of the personal data we process.

These measures include, in particular, the execution of confidentiality agreements with our employees and suppliers; policies to restrict and control access to personal data; destruction or anonymization of personal data that is no longer necessary for the purposes for which it was collected;

Because information security depends partly on protecting the computer or electronic device you use to communicate with us and the protection you employ to save usernames and passwords, please take appropriate steps to protect this information.

9. Version and Changes

The latest version of this Privacy Policy is March 28, 2022. Wishes may make changes to the content of this Privacy Policy. Such changes will be legally communicated to you.