1. Scope and Legal Framework
This policy explains how the Arquivo.pt service, operated by Fundação para a Ciência e a Tecnologia (FCT) through its FCCN unit, collects, uses and preserves personal data. It covers not only the institutional website, but the entire activity of Arquivo.pt, including the automated collection of web content and the preservation and public availability of archived pages.
As a national public infrastructure, Arquivo.pt reflects FCT’s commitment to the protection of personal data, in accordance with Article 35 of the Constitution of the Portuguese Republic, Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR), and Law No. 58/2019 of 8 August, which ensures its implementation in the Portuguese legal order.
Based on this legal framework, this Privacy Policy applies to the management and operation of Arquivo.pt, ensuring that personal data collected are processed lawfully, fairly and transparently. This document clearly sets out:
- what personal data may be collected in the context of Arquivo.pt;
- the purposes for which such data are processed, and the legal bases relied upon;
- how the data are used, shared, preserved or erased;
- the rights of data subjects and how those rights may be exercised; and
- how data protection interacts with the platform’s other governing instruments, namely the Terms and Conditions, the Cookies Policy and any other specific applicable policies.
2. Controller of Personal Data
Arquivo.pt is managed by Fundação para a Ciência e a Tecnologia, I.P. (FCT), through its FCCN unit, which acts as controller of the personal data processed in the context of the technical and organizational management of the Arquivo.pt digital infrastructure.
FCT acts as controller only in relation to the operations necessary for the functioning, maintenance and development of the platform, including the automated collection, preservation and making available of web content.
FCT does not validate the content of the websites collected, nor does it verify the lawfulness, accuracy or compliance of any personal data that may be contained therein.
Responsibility for the initial publication of such content on the public web, as well as for its lawfulness and compliance with the GDPR, lies with the entities or people that published it.
Arquivo.pt is limited to the collection, preservation and making available of publicly accessible content within the scope of its mission carried out in the public interest.
3. Data Protection Officer
For the exercise of rights or for clarification concerning privacy and data protection, FCT has appointed a Data Protection Officer (DPO), who may be contacted directly at: dpo@fct.pt.
4. Purpose of the Processing of Personal Data
The personal data processed within the scope of Arquivo.pt is used exclusively for the management, operation and development of digital infrastructures serving science, technology, research and knowledge, including the collection, preservation and making available web content for archiving purposes in the public interest.
Within this primary purpose, FCT carries out various processing operations, namely:
- the automated collection of publicly accessible web content;
- the preservation and making available such content for scientific, historical and cultural purposes;
- the technical and operational management of the platform; and
- the management of interactions with users, such as forms, communications, applications and newsletters.
Such processing operations are regarded as compatible with the original purpose, pursuant to Article 5(1)(b) and Article 89 of the GDPR, and appropriate safeguards are ensured to protect the rights and freedoms of data subjects.
5. Collection and Processing of Personal Data
The collection and use of personal data within the scope of Arquivo.pt take place at different stages of interaction with the platform and correspond to distinct processing operations, namely:
- Management of applications to the Arquivo.pt Prize
For the purposes of submission, assessment and communication with applicants, the following data are processed through a form:
Email address;
Secondary email address;
Telephone number;
Name of the applicant (or of the person responsible for the team);
Title of the work;
Indication of application for honorable mentions;
Summary description (including document upload);
Video file;
Additional comments; and
Optional information on how the applicant became aware of the Prize.
- Preservation and making web content available
Within the scope of Arquivo.pt’s core activity, publicly accessible web content is collected and processed. Such content may include personal data, such as:
Identification data (e.g. name);
Photographs;
Contact details;
Biographical profiles; and
Texts and other content published online.
- Sending communications (newsletter)
For the purpose of sending informational communications, the following data are processed on the basis of consent:
Name;
Email address; and
Website address(es), where provided.
- Management of communications (contact)
For the purpose of responding to contact requests, the following data are processed through a form:
Email address;
Subject; and
Message content.
- Management of site suggestions and “Citation Saver”
For the purpose of collecting suggestions of content to be archived, the following data are processed:
Email address (optional); and
URLs or content indicated for collection.
- Technical activity logs
For platform operation, security and technical audit purposes, the following data are collected automatically:
IP addresses;
Access logs (timestamps, sessions and technical preferences); and
Cookies strictly necessary for the operation of the platform.
For further information regarding the use of cookies, the applicable Cookies Policy should be consulted.
6. Categories of Data Subjects
Within the scope of the processing operations described above, personal data may relate to the following categories of data subjects:
a) Users of the website;
b) Newsletter subscribers;
c) Persons who complete contact forms, site suggestion forms, prize application forms or removal requests;
d) Administrators of websites whose pages are collected; and
e) Natural persons whose data appear in publicly archived web content.
7. Lawfulness of Processing
The processing of personal data carried out within the scope of Arquivo.pt complies with the lawfulness requirements laid down in Article 6 of the GDPR.
Depending on the specific circumstances, processing may be based on the following grounds:
- Pre-contractual measures and performance of a contract — in connection with the acceptance and performance of the Terms and Conditions and applications to the Arquivo.pt 2026 Prize;
- Compliance with a legal obligation — whenever necessary to satisfy legal obligations applicable to FCT;
- Consent — for the sending of newsletters, the use of non-essential cookies and other specific processing operations where requested from the user; and
- Task carried out in the public interest — the performance of functions in the public interest, applied to the collection, preservation, indexing and making available of archived content (for archiving purposes in the public interest and for scientific or historical purposes), pursuant to Article 6(1)(e) and Article 89 of the GDPR.
8. Rights of Data Subjects
Under the applicable legislation, data subjects whose personal data are processed within the scope of Arquivo.pt may exercise the following rights:
- Access;
- Rectification;
- Restriction of processing;
- Objection;
- Erasure;
- Portability, where applicable;
- Withdrawal of consent, where consent constitutes the legal basis for processing; and
- Lodging a complaint with the Portuguese Data Protection Authority (www.cnpd.pt).
The exercise of certain rights, in particular the right to erasure, may be restricted where the processing is necessary for compliance with legal obligations, for the performance of tasks carried out in the public interest, or for archiving purposes in the public interest, scientific research or historical research. Such limitations are described in Section 8 of this Policy.
8.1 Exercise of rights
Rights may be exercised by means of a request addressed to FCT, preferably by email to dpo@fct.pt.
FCT shall respond within a maximum period of one month, which may be extended in accordance with the GDPR. Where necessary, additional information may be requested to confirm the identity of the applicant, in compliance with the principle of data minimization.
9. Limitations to the Right to Erasure
The right to erasure is not absolute (Article 17(3) GDPR). Personal data may not be erased where the processing is necessary, in particular:
- for compliance with legal obligations;
- for the performance of tasks carried out in the public interest;
- for archiving purposes in public interest, scientific research or historical research (Article 89 GDPR); or
- for the establishment, exercise or defense of legal claims in judicial proceedings.
In the context of Arquivo.pt, the preservation of web content may justify the retention of data. In such cases, alternative measures may be adopted, such as restriction of access or de-indexing.
Requests for removal of content do not necessarily correspond to the exercise of the right to erasure and are handled independently through the specific mechanisms made available on the website.
10. Data Sharing
Personal data may be shared in the following circumstances, according to the nature of the processing operations carried out within the scope of Arquivo.pt:
a) Processors and Third Parties
FCT may engage service providers for hosting, technical support or marketing. Such partners have access only to the data necessary for the relevant purpose and are contractually bound to guarantee confidentiality and security. In such cases, FCT ensures that contracts are entered into providing for appropriate technical and organizational measures, in accordance with Article 28 of the GDPR.
FCT may also share data with entities within its sphere or with other institutional partners, always providing prior information and ensuring the data subject’s consent where applicable. Personal data may also be disclosed in compliance with legal obligations or court orders.
Personal data may likewise be disclosed for compliance with legal obligations or in response to judicial orders.
b) Transfers of Data to Third Countries
Within the scope of Arquivo.pt, no transfer of personal data takes place outside the European Economic Area (EEA). All data are stored and processed in infrastructures located in Portugal or elsewhere in Europe, ensuring the application of GDPR standards.
11. Retention Periods
Personal data are retained only for the period necessary for the purposes that justified their processing, in accordance with the principle of storage limitation.
As regards archived content and having regard to the nature of Arquivo.pt as an infrastructure for archiving in the public interest, personal data may be retained for extended periods, for so long as the relevant public archival interest subsists, pursuant to Article 89 of the GDPR.
In such cases, retention is accompanied by appropriate safeguards, namely restriction of access, de-indexing or other proportionate measures intended to protect the rights and freedoms of data subjects.
With regard to the other processing operations (namely management of applications, communications, newsletters or forms), data are retained for the period necessary to pursue those purposes or until the applicable rights are exercised, where relevant.
12. Security Measures
FCT implements appropriate technical and organizational measures to ensure the confidentiality, integrity and availability of personal data, including:
- Encryption and, where appropriate, anonymization;
- Role-based access controls;
- Continuous security monitoring; and
- Regular updating of systems and protection policies.
Security is a shared responsibility, and users are advised to adopt good digital protection practices.
13. Notification and Complaints
For matters relating to this Privacy Policy or to the processing of personal data carried out within the scope of Arquivo.pt, you may contact Fundação para a Ciência e a Tecnologia, I.P. (FCT), through the Data Protection Officer, by email at dpo@fct.pt, or by post at Av. D. Carlos I, 126, 1249-074 Lisbon, Portugal.
Without prejudice to Section 7 above, if you consider that the processing of your personal data does not comply with the applicable legislation, you may lodge a complaint with the Portuguese Data Protection Authority (www.cnpd.pt).
14. Third-Party Websites
The website contains links to third-party services, such as social networks (for example, Facebook and Twitter). FCT is not responsible for the privacy practices of such websites/platforms. You are advised to consult their respective privacy policies.
15. Changes to this Policy
This Policy may be updated because of legislative changes, technological developments or improvements in organizational practices.
The most recent version will always be made available on the platform, indicating the date of the latest update.
Last update: 29th april, 2026, Lisbon, Portugal.