LEGAL INFORMATION ABOUT DATA PROTECTION

In our company we recognize that the collection and usage of your personal data involves the establishment of a relationship based in trust and confidence. We are fully committed to meeting the highest privacy and compliance standards of the General Data Protection Regulation, ensuring that your personal data will receive a legal, loyal and seamless treatment. These data collection will only be used for the mentioned, explicit and legitimate purposes, limited to what is necessary and updated where appropriate. It will be stored ensuring the identification of the recipients only during the compliance of the mentioned purposes, managed in a way that guarantees the privacy, through the implementation of technical and organizational measures.

We consider that the responsibility, privacy and integrity of your personal data is one of our main concerns.

1. DATA USAGE – PURPOSES AND REASONS

   Your personal data will be collected and used for the following purposes, under the strict terms you have consented:

   • Provision of Services – As and where required, to provide you our services and products;
   • Marketing Campaigns – Your data will be used for marketing purposes or products advertising, company services and activities;
   • Customer service – Your data will be also processed in order to guarantee the excellence in the quality and efficiency of our customer service.

   Lawful basis for data processing

   • Data processing consent;
   • Conclude and apply a contract;
   • Comply the legal obligations;
   • Achieve a legitimate interest, whose usage does not prevail over data protection rights;
   • Declare, execute or support a right in a legal action against you, our company or a third party.

2. DEFINING THE PERSONAL DATA THAT CAN BE COLLECTED

   Under the new GDPR, personal data includes:

   • Contact information
     Name; Address; Email.
     
   • Personal information
     Date of birth; Marital Status; Job Occupation.
     
   • Identification data
     Client number; contract number.

3. DATA PROCESSING – RESPONSIBILITY

   Our company is entirely responsible for the processing of our clients’ or potential clients’ personal data that fill in their data and submit the Declaration of Consent.

4. DATA PRIVACY MECHANISMS

   We will use a variety of security measures, including encryption and authentication tools, in order to help protecting your data privacy, integrity and availability.Despite the data transmission through the internet or website not assuring a complete privacy against intrusions, our company, service providers and business partners are committed to implement and keep physical, electronic and procedural privacy measures, meant to protect your data according to this regulation. We have implemented the following measures:

   • Restrict and personal data access, based on a “need to know” basis and the purposes previously announced;
   • Data transfer collected only through encryption;
   • Highly confidential data storage only through encryption;
   • Information technology system protection, in order to block the non-authorized access to your personal data;
   • Information technology system access being constantly monitored, in order to prevent, detect and avoid the misuse of your personal data.

5. DATA STORAGE PERIOD

   We storage your data only during the necessary period of the purposes mentioned above.

   Once the storage maximum deadline is reached, your data will be anonymized in an irreversible way (the anonymised data can be stored) or erased in a safe way.

6. DATA SHARING

   Our company is a global company that works on every continent. Therefore, your data can be accessed by our suppliers or service providers located in several countries outside the European Economic Area, even if this usage is for certain purposes previously mentioned in this Privacy Policy and according to the defined rules in the General Data Protection Regulation.At a national level, your data will only be shared with third parties for tax (accountancy – invoice issuance by the accountancy external services) and legal (law firms – data transfer for legal effects and rights exercise) obligations compliance.

   In any case, we assure you these transmissions will be held according to appropriate privacy measures and rules from the General Data Protection Regulation.

7. CHANGE OR REVOKE YOUR CONSENT

   At any moment, you are able to change or revoke your consent.To revoke your declaration of consent, you would have to present to our company, by any means, a written communication specifically informing such decision.

8. DATA PROTECTION, ACTION AND COMPLAINT RIGHTS BEFORE THE NATIONAL SUPERVISORY AUTHORITY

   If you have further queries you should, first of all, contact our customer service.
   Subject to certain conditions, you may have the right to request our company the following actions:

   • Additional information provision about data usage;
   • Request a copy of the data provided;
   • Request the data provided to be followed to a different processing responsible;
   • Update of any mistake of the stored information;
   • Data erasure whose usage is no longer legitimate;
   • Limit the data usage until the presented complaint is clarified.

   The exercise of these rights may be subjected to certain exceptions related to the public interest (crime prevention or detection) or our own interest (maintain the professional secrecy) safeguard.
   
   If any of these rights are applied, we will proceed their analysis and reply within a period maximum of 1 (one) month.
   
   If your are not pleased with the usage of your data or with the reply upon these rights’ exercise, you have the right to claim before your supervisory authority
   Comissão Nacional de Proteção de Dados – CNPD
   Rua de São Bento, n.º 148, 3º, 1200-821 Lisboa
   Tel: 351 213928400
   Fax: +351 213976832
   e-mail: geral@cnpd.pt