Effective Date: 09/11/2025

At PUGNA, we are committed to protecting your personal data and privacy. This Privacy Policy outlines how we collect, use, and safeguard your personal information when you use our website, make purchases, or interact with our services. This policy complies with the General Data Protection Regulation (GDPR), Portuguese law, and other applicable regulations.

DATA CONTROLLER

The data controller responsible for your personal data is:

Company name: PUGNA

Email: pugna.designs.official@gmail.com

Responsible for the processing of Personal Data

The Personal Data Controller is the PUGNA brand, which provides products, determining for this purpose and without limiting:

• Personal Data that must be processed in the context of the supply of products;
• The Purposes for which Personal Data are processed;
• The means to be applied for the processing of Personal Data.

Principles applicable to the processing of Personal Data

The Processing of Personal Data is carried out in accordance with the general principles set out in the General Data Protection Regulation and other legislation relating to data protection, namely:

• In the context of the relationship with the Data Subject, we ensure that Personal Data will be processed in a lawful, fair and transparent manner (“Principle of lawfulness, fairness and transparency”);
• We collect Personal Data for specified, explicit and legitimate purposes and do not further process the same Data in a manner incompatible with those purposes (“Purpose Limitation Principle”);
• We ensure that only Personal Data that is adequate, relevant and limited to what is strictly necessary for the purposes for which it is processed (“Principle of data minimization”) is processed;
• We take appropriate measures to ensure that Personal Data deemed inaccurate, taking into account the purposes of processing, are erased or rectified without delay (“Principle of accuracy”);
• We retain Personal Data in a manner that allows its identification only for the period necessary for the purposes for which it is processed (“Principle of retention”);
• We ensure that Personal Data is processed in a manner that guarantees its security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by adopting appropriate technical or organizational measures (“Principle of integrity and confidentiality”).

Data we collect

The types of data we may collect about you, depending on your use of our Website, include:

• name;
• email address;
• Telephone contact;
• Country;
• Other information you choose to provide to us when contacting us on our Website.

Fundamentals of Legality

By reference to the “Principle of Lawfulness” enshrined in current data protection laws, in the development and performance of its activities, PUGNA only processes Personal Data when there is a lawful basis that legitimizes the processing.

The following are the grounds for lawfulness:

• Consent: When the Data Subject has given his/her consent, through a free, specific, informed and explicit expression of will, by which he/she accepts, by means of a declaration (written or oral) or unequivocal positive act (by completing an option), that the Personal Data be subject to Processing.
• Pre-contractual steps or the performance of a contract: When processing is necessary for the performance of a contract to which the Data Subject is a party or for pre-contractual steps at his request.
• Compliance with a legal obligation: When the processing of Personal Data is necessary to ensure and guarantee compliance with legal obligations to which the Controller is subject under the legislation of a Member State and/or the European Union.
• Defense of vital interests of the Data Subject: When data processing is necessary to ensure the defense of vital interests of the Data Subject or another natural person.
• Legitimate Interests: When processing is necessary for the purposes of legitimate interests pursued by the Controller, other Responsible Parties or Third Parties, provided that the interests or fundamental rights and freedoms of the data subject do not prevail over such processing.

Sharing of Personal Data

PUGNA, within the scope of its activity, may share data with third parties, however, it will only do so under the terms set out in this section of the Data Protection and Privacy Policy.

• Subcontractors: Your Personal Data may be shared with service providers. Service providers are bound to PUGNA by written contract and may only process Personal Data for the specifically established purposes. They are not authorized to process Personal Data, directly or indirectly, for any other purpose, for their own benefit or that of a third party.
• Other Responsible Parties and/or Third Parties: Personal Data may be shared internally with other entities associated with PUGNA, which will comply with the applicable data protection rules depending on the purposes associated with the processing carried out.
• Upon request and/or with your consent, your Personal Data may be shared with other entities.
• In compliance with legal and/or contractual obligations, your Personal Data may also be transmitted to judicial, administrative, supervisory or regulatory authorities and also to entities that lawfully carry out data compilation actions, fraud prevention and combat actions, market or statistical studies.

Your Rights

Holder's Right Description

1. Right to be informed. You have the right to obtain clear, transparent, and easily understandable information about how we use your data and what your rights are. That's why we've made all this information available to you in this Privacy Policy.
2. Right to access. You have the right to obtain a copy of your data and certain information about how it is processed. This right allows you to know and confirm that we use your data in compliance with data protection laws. We may refuse to provide the requested information whenever doing so would reveal another person's Personal Data or negatively impact another person's rights.
3. Right to rectification. If your data is incorrect or incomplete, you can ask us to make the corresponding rectification/correction.
4. Right to erasure. This allows you to request the deletion or deletion of your data, provided there are no valid grounds for us to continue using it or its use is unlawful. This is not a generic right to erasure, as exceptions are permitted (for example, whenever such data is necessary to defend a right in a legal proceeding).
5. Right to restrict processing. You have the right to block or prevent future use of your data when we evaluate a request for rectification or as an alternative to erasure. Whenever processing is restricted, we may still store your data, but we will not be able to use it further. We maintain lists of people who have requested to block future use of their data to ensure this restriction is respected in the future.
6. Right to data portability. You have the right to obtain and reuse certain Personal Data for your own purposes across multiple organizations. This right only applies to data you provided to us and that we process with your consent, which is processed by automated means.
7. Right to object. You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time when such processing is carried out for the legitimate interests of PUGNA or third parties. We may continue to process this data if we can demonstrate “overriding legitimate grounds for the processing that override your interests, rights, and freedoms,” or if such data is necessary for the establishment, exercise, or defense of legal claims.

You may, at any time, in writing, exercise the rights enshrined in the Personal Data Protection Law and other applicable legislation via email at pugna.designs.official@gmail.com

Personal Data Retention Period

We retain Personal Data only for the period necessary to fulfill the specific purposes for which it was collected. However, we may be required to retain some Personal Data for a longer period, taking into account factors such as:

• legal obligations, under applicable laws, to retain Personal Data for a certain period;
• prescription/statute of limitations, under applicable laws;
• litigation;
• guidelines issued by the appropriate data protection authorities. While we process your Personal Data, we ensure that it is treated in accordance with this Privacy Policy. Once the Data is no longer needed, we will securely delete it.

Security

Personal Data will be processed only for the purposes identified in this Policy, in accordance with PUGNA's internal policies, and using technical and organizational measures designed to reflect the risks associated with the specific processing of Personal Data. We use appropriate security measures to ensure the protection of your Personal Data and prevent access by unauthorized persons. We periodically review our security policies and procedures to ensure our systems are safe and secure. However, given that the transmission of information over the Internet is not completely secure, we cannot guarantee the security of your data transmitted to our Website.

Confidentiality

We recognize that the information you provide may be confidential. As part of its business, PUGNA does not sell, rent, distribute, or otherwise make Personal Data available commercially or in any other way to any third party, except in cases where it needs to share information with Service Providers for the purposes set forth in this Policy or with Third Parties to comply with its legal obligations. We will maintain the confidentiality of your data and protect it in accordance with our Privacy Policy and all applicable laws.

Cookies

Whenever you use our website, we will process your Personal Data collected through the use of cookies in accordance with our cookie policy. Click here to learn more about our cookie policy.

Changes to this Privacy Policy

PUGNA will update this Privacy Policy from time to time. Whenever it does, the new version will be published on the website and will be effective immediately. Therefore, we recommend that you consult it regularly.