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Terms and conditions for using the STCP WhatsApp service

1. Object and scope
1.1 These Terms and Conditions govern the use of the official WhatsApp channel provided by Sociedade de Transportes Colectivos do Porto, EIM, SA (hereinafter "STCP"), intended for providing information to passengers about the STCP public transport network.
1.2 Use of this channel implies acceptance of these Terms and Conditions.
1.3 The channel is integrated into the WhatsApp platform, provided by Meta Platforms, and its use is also subject to the terms and policies applicable to the use of WhatsApp.

2. Purpose and scope of the service
2.1 The STCP WhatsApp channel is intended exclusively for providing general information related to the STCP transport network, specifically regarding:
a) lines and routes;
b) stops;
c) schedules and frequencies;
d) changes or restrictions on traffic flow;
e) titles and general conditions of use of transport services; and
f) other information related to network operation that falls within the functionalities provided on the channel.
2.2 The channel uses automated response systems, including artificial intelligence technologies, designed to interpret questions asked by users and provide answers based on information provided by STCP.
2.3 The answers provided by the channel are for informational purposes only and do not replace the information or decisions formally provided by STCP through its official channels.
2.4 The channel is not intended, in particular, for the presentation or processing of:
a) complaints;
b) requests relating to lost items;
c) requests that involve the identification or authentication of the passenger;
d) issues relating to individual cards, securities or accounts that require access to the respective holder's data; or
e) any other requests which, by their nature, require the processing of personal data or the intervention of specific STCP services.
2.5 Whenever a question cannot be addressed through this channel, the user should use the appropriate STCP channel or service for the situation.


3. Availability and operation
3.1. The channel is available 24 hours a day, 7 days a week.
3.2. The availability of the channel does not mean that the information provided is necessarily updated in real time in all circumstances.
3.3. STCP may, particularly for technical, maintenance, security or system upgrade reasons, temporarily interrupt the operation of the channel, without this resulting in any right to compensation.
3.4. The use of the channel also depends on the availability of the communications network and the services provided by WhatsApp, and STCP is not responsible for failures or interruptions originating from these services or from equipment, networks or connections that are not under its control.

4. Nature of the information provided
4.1. STCP seeks to ensure that the information made available through the channel is current and appropriate for its intended purpose.
4.2. Nevertheless, the information provided may present discrepancies in relation to the situation actually verified on the ground, particularly in situations of traffic, breakdowns, accidents, works, temporary changes in circulation, unforeseen restrictions or other occurrences that may affect the operation of the network.
4.3. Automatically generated responses, including those produced by artificial intelligence systems, may contain inaccuracies, omissions, or misinterpretations of the question asked.
4.4. The user should therefore confirm the information provided through STCP's official channels whenever the nature of the situation warrants it.
4.5. The provision of a response through the channel does not, in itself, constitute a binding statement by STCP nor does it alter the rights and obligations arising from applicable legislation, transport conditions or any other instruments or procedures in force.

5. Proper use of the channel
5.1. The user undertakes to use the channel responsibly, appropriately and exclusively for the purposes for which it was made available.
5.2. The use of the channel is prohibited for:
a) sending messages of an unlawful, offensive, discriminatory or defamatory nature;
b) sending content that may harm, interrupt or compromise the operation of the channel or STCP systems;
c) sending spam messages or unsolicited commercial communications;
d) use of automated systems, bots or other mechanisms designed to generate an abnormal or abusive volume of messages;
e) sending content that infringes the rights of third parties; or
f) any other use contrary to applicable law or these Terms and Conditions.
5.3. STCP may limit, suspend or block a particular user's access to the channel when necessary to ensure its operation, security or proper use, particularly in the face of abusive behavior or behavior that repeatedly violates these Terms and Conditions.

6. Personal data
6.1. The channel was designed to answer general questions about the STCP network, and user identification or the provision of personal data is not required to obtain the information provided.
6.2. The user must avoid sending, through this channel, personal data that is not necessary for the purpose of the communication, namely:
a) data relating to health or other special categories of personal data;
b) identification document numbers and copies thereof;
c) bank or payment details;
d) passwords or access codes;
e) data relating to individual accounts or securities, when not necessary for processing the request; or
f) any other personal data of third parties.
6.3. Whenever the question asked involves identifying the user or processing individualized information, STCP may request that the user use another channel or service specifically suited for that purpose.
6.4. If the user voluntarily submits unsolicited personal data, STCP will process this data only to the extent that it is necessary and appropriate for the legitimate purpose of the communication, and must delete it or cease storing it as soon as it is no longer necessary for that purpose, without prejudice to situations where retention is required by law or necessary for the exercise or defense of rights.
6.5. STCP is the entity responsible for processing personal data carried out within the scope of providing and operating the channel, determining the purposes and means of the processing carried out for this purpose.
6.6. STCP uses Geolink for the provision and maintenance of the technological solution that supports the channel, with this entity acting, within the scope of the processing of personal data carried out on behalf of STCP, as a subcontractor, in accordance with Article 28 of the General Data Protection Regulation.
6.7. Geolink may only process personal data in accordance with the documented instructions of STCP and for the purposes determined by it, and is subject to the obligations set out in the applicable legislation on the protection of personal data and in the contract entered into with STCP.
6.8. STCP does not request passwords, authentication codes, bank details or other access credentials through this channel.
6.9. The processing of personal data carried out by STCP within the scope of this channel is subject to the General Data Protection Regulation and applicable national legislation on the protection of personal data.
6.10. Detailed information on the processing of personal data, including purposes, legal basis, retention periods, recipients and rights of data subjects, is available in STCP's Privacy Policy, which should be consulted by the user, available at www.stcp.pt.

7. WhatsApp and Meta services
7.1. The channel is made available through the WhatsApp platform, which is not an application, system or technological infrastructure developed or controlled by STCP.
7.2. The use of WhatsApp is subject to the terms of use, privacy policies and other conditions defined by Meta and/or the entities responsible for providing the service.
7.3. STCP does not determine or control the operation of the WhatsApp platform or the processing of personal data that may be carried out by Meta in the context of making the platform available and using it for its own purposes.
7.4. The user should consult the terms and privacy policies applicable to WhatsApp to obtain information about the data processing carried out by Meta.
7.5. STCP is not responsible for the processing of personal data carried out by Meta for its own purposes, nor for the operation of WhatsApp platform functionalities that are not under STCP's control.

8. Preservation of communications
8.1. Communications made through the channel may be recorded and kept by STCP for the period necessary for the purposes that determined their collection, namely for:
a) to ensure the operation and safety of the service;
b) monitor and improve the quality of the responses provided;
c) identify and correct errors in automatic response systems;
d) produce statistical information on the use of the channel;
e) to ensure compliance with legal obligations.
8.2. Personal data contained in communications will be kept only for the period necessary for the purposes that determined its collection, without prejudice to the retention periods imposed by law or necessary for the exercise or defense of rights.
8.3. STCP may define different retention periods depending on the nature and purpose of the data or communications, which will be disclosed in the respective Privacy Policy, where applicable.
8.4. Geolink, as a subcontractor, will retain personal data only for the period and under the conditions determined by STCP, without prejudice to any legal obligations directly applicable to it.
8.5. The use of conversations or the personal data contained therein for the development, training or improvement of artificial intelligence systems or for any other purpose independent of Geolink is not permitted, except when such use has been expressly authorized by STCP and is legally permissible.
8.6. The automatic response or artificial intelligence functionalities used in the channel are intended exclusively for the provision of the information service offered by STCP and must operate in accordance with the instructions and parameters defined by STCP.

9. Limitation of liability
9.1. STCP does not guarantee that the responses provided through the channel will be permanently free from errors, omissions, or outdated information.
9.2. STCP cannot be held responsible for damages resulting from the use of information that, due to its characteristics, is subject to changes depending on the specific operating conditions of the network or unforeseen events.
9.3. STCP is not responsible for failures, unavailability or limitations arising from the operation of WhatsApp, telecommunications networks or equipment and services that are not under its control.
9.4. The use of the information made available through the channel is the user's responsibility, without prejudice to any rights legally recognized to them.

10. Intellectual property
10.1. The content, texts, graphic elements, information databases and other content made available by STCP through the channel are protected by applicable intellectual property rights.
10.2. The use of information made available through the channel for personal and informational purposes is permitted, but its reproduction, commercial exploitation or use for purposes incompatible with these Terms and Conditions is not authorized without prior authorization from STCP, when legally required.

11. Changes to the Terms and Conditions
11.1. STCP may amend these Terms and Conditions whenever necessary.
11.2. The updated version of the Terms and Conditions will be made available on STCP's official channels, indicating the respective update date.

12. Applicable law
These Terms and Conditions are governed by Portuguese law.

13. Contacts
13.1. For questions related to the operation of the WhatsApp channel, the user may contact STCP through the official channels provided for this purpose.
13.2. For questions related to the processing of personal data, the user may consult the STCP Privacy Policy and use the contacts indicated therein, including the contacts of the Data Protection Officer: epd@stcp.pt.