Privacy Policy

Latest updated: dezembro 4th, 2019

Portobello America values our relationship with you and takes your privacy seriously. The purpose of this Notice is to clarify what information is collected from users of our website (, our Customer Portal and our Sales Portal (collectively, our “Sites”), and each of their services – and how this data is collected, used and disclosed. This Privacy Notice also identifies your rights with respect to your personal information, all as described in more detail below.

Your acceptance of our collection and use of information as described in this Notice will be made when you register, use or access any of our Sites or otherwise use our services, even if for free. This will indicate that you are aware and in agreement with how we will use your information and your data.

We may update or modify this Privacy Notice at any time by posting the amended version, which will include the effective date of the updated version. By accessing and/or using any of our Sites, you accept and agree to the terms of this Privacy Notice and the use of your data and personal information as described in this Privacy Notice.

If you do not agree to be bound by this Privacy Notice or any subsequent modifications, you should not access or use, or disclose any personal information on, any of our Sites. However, we would appreciate you informing us of your disagreement so that we are aware of your concerns.

For questions regarding our Privacy Notice, please email us:

This Notice is divided as follows to facilitate its understanding:

  1. Collection of data;
  2. Use and access of your personal information;
  3. How we safeguard your information;
  4. How long we store your personal information;
  5. Unsubscribing and changing/deleting personal information;
  6. Links to other sites and services;
  7. Children;
  8. Special notice to non-U.S. users regarding data transfers;
  9. Governing law and jurisdiction.

1. Collection of data

We collect information from you both when you provide it voluntarily and also automatically when you use our Sites. The information we collect can include (1) personal information (as described below), or (2) non-personal (or anonymized/aggregate) information, which is information that does not identify or relate to an individual.

Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect information through any correspondence that you provide to us whether through email, mail, phone calls, or through our Sites.

We do not consider personal information to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise. For example, we collect anonymized and aggregated information through Google Analytics that may be created or derived from your usage of our Sites for purposes that include data analysis and improving our Sites. For more information about Google Analytics, please visit

We collect the following information from you when you provide information to us or whenever you interact with us via the Sites:

  • Information provided by you – When you browse our Sites, download applications, sign up to receive communications, or request and/or use the services of Portobello America, you expressly consent to the collection and processing of personal information required to provide you with the information you requested and/or the services;
  • Site navigation information – When you visit any of our Sites, a cookie is placed on your browser through the Google Analytics software to identify how many times you return to our address. Information such as IP address, geographic location, reference source, type of browser, duration of the visit and pages visited are collected. We automatically collect your device type when you use our Sites in order to optimize the display of the Sites on your device.
  • Contact history – We store information about all contacts already made with our users, such as content downloaded from our pages and interactions via email.
  • Data generated during the use of our services – If you use any of our Sites or services (including services through our Sales Portal or Customer Portal), we will collect additional information from, such as contact name, email, phone number, location data (such as country, city and state where the access is taking place), professional profile information (including position, name and segment of the company where you work, number of employees in that company), your marketing preferences, and information about your browser.

2. Use and access of your personal information

Data we collect is used for the provision of our services. Our legal basis for using your information as described above is a legitimate basis. In relying on legitimate interests as the reason for processing your information, we carry out a balancing exercise to make sure your rights as an individual are not impacted unnecessarily.

All data and information about you are treated as confidential, and we will only use them for the purposes described and authorized by you. In particular, our use of the data allow you to fully use our services, always aiming to improve your experience as a user. They also allow us to customize the service so that it is increasingly adapted to your tastes and interests. In addition, your personal information also may be used to help us create new services, products and features.

We may use and share your personal information with the following types of recipients and for the following reasons:

  • Your email may be used for sending material or information requested by you when completing the form on our Sites;
  • Communicate with you about products, services, promotions, news, updates, events and other matters that may be of your interest;
  • Operate our software and infrastructure; in particular, we use service providers to host, store, manage, and maintain our Sites, content and the data we process, such as our hosting and information security service providers;
  • Employees of Portobello America may contact you via email or telephone to conduct surveys or present products and services;
  • Send you messages about support or service, such as alerts, notifications, and updates;
  • perform targeted advertising according to your tastes, interests and other information we collect;
  • customize the service so that it is increasingly adapted to your tastes and interests;
  • for any purpose you authorize at the time of data collection; and
  • to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using user purchases in the aggregate, including revenues generated in connection with our regulatory tax requirements) or when required by law (including to respond to valid legal process such as a search warrant or a court order).


We also use information provided by you or about you:

  • to send important information about our relationship with you or our Sites, changes in our terms, conditions and policies and/or other administrative information; and
  • for our business purposes, such as data analysis, audits, development of new products, improvement of our Sites, improvement of our products and services, identification of trends in the use of the Sites and services, customization of your experience on the Website with the presentation of products and offers appropriate to you and determining the effectiveness of our promotional campaigns.

We also may disclose information collected through the Sites and our applications:

  • to our third-party providers with whom we offer a promotion through co-branding or co-marketing;
  • to our third-party service providers who provide services such as web hosting and moderation, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provisioning, IT services, customer service, email and email marketing, credit card processing, auditing services and other services with the purpose of enabling the provision of services; and
  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, dissolution, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Most, if not all, of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States.

Portobello America also reserves the right to monitor the entire platform, including to ensure that there is no violation of our Terms of Use or applicable laws.

3. How we safeguard your personal information

We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. While we are committed to protecting your personal information, please note that information communicated over the Internet is never 100% secure. Any transmission of personal information is at your own risk.

4. How long we store your personal information

We may store your personal information as long as you use our Sites and for legitimate business purposes. We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements. Additionally, we may continue to store your personal information contained in our standard back-ups.

Upon your request, we will delete or de-identify your personal information unless we are legally required or allowed to maintain such personal information.

5. About unsubscribing and changing/deleting personal information

You have choices about how we use your personal information to communicate with you. You can opt out from receiving future marketing communications from us at any time by clicking the unsubscribe link in emails you receive from Portobello America. (Please note completing any form will again characterize the reinsertion of your email to the list. Therefore, the cancellation request must be made again if you wish.)

The request to exclude data from the Sales Portal and Customer Portal tools automatically implies the suspension of the use of these services, as they require the user’s data to operate.

You may request the review and correction of your data at no cost and at any time. To do this, please contact us.

Please remember that, in order to comply with legal obligations, Portobello American may retain and store certain data as necessary to comply with those legal obligations and in accordance with the applicable legislation.

6. Links to other sites and services

Our Sites may provide links to third-party websites that we do not control. We cannot be held responsible for third parties’ privacy practices or content provided on these websites. If you click on one of these links, please understand that you are leaving our Sites and any information you provide will not be covered by this Privacy Notice. Please read that website’s privacy policy before providing any information.

7. Children

None of our Sites are directed to children under the age of fourteen (14) years. By using our Sites, you represent that you are at least fourteen (14) years old. If you do not meet this age requirement, then you must not access or use our Sites.

We do not knowingly collect information from children under the age of thirteen (13) years old. If you are under the age of thirteen (13) years old, please do not use our Sites and do not provide any information to us. For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website

If you think we have collected information from a child under the age of thirteen (13) through one of our Sites or applications, please contact us at If we learn that we have collected the information of a child under the age of thirteen (13) years old, we will take reasonable steps to delete such information.

8. Special notice to non-U.S. users regarding data transfers

We store your personal information in the United States or other locations outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

If you are located in a country outside the U.S. and submit personal information to us, you consent to the general use and disclosure of such information as provided in this Privacy Notice and to the transfer and/or storage of that information to the U.S. and other countries outside your home country.

9. Governing law and jurisdiction

This Privacy Notice shall be construed and governed under the laws of the United States and State of Tennessee (without regard to rules governing conflicts of laws provisions). You agree that venue for all actions, arising out of or relating in any way to your use of our Sites, shall be in federal or state court of competent jurisdiction located in Nashville, Tennessee, within one (1) year after the claim arises. Each party waives any objections based on forum non conveniens and waives any objection to venue of any action instituted hereunder to the extent that an action is brought in the courts identified above.