2. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?Europalco, Lda., registered with the Commercial Registry of Sintra, under the single registration and incorporation number 503825280, is the entity responsible for processing the personal data of its customers and/or potential customers.
For questions related to the processing of your personal data, you should contact us through the following means:
Address: Estrada da Ericeira, 112 e 112A - Ral, 2710-453 Sintra
Telephone: +351 219 605 520
E-mail address: firstname.lastname@example.org
3. WHAT ARE PERSONAL DATA?The General Data Protection Regulation (hereinafter referred to as “GDPR”) defines "personal data" as "any information relating to an identified or identifiable natural person". Thus, any information that can be used, directly or indirectly, regardless of its support (including sound and image), to identify an individual, alone or in conjunction with other information, is considered as "personal data".
5. HOW DO WE COLLECT YOUR DATA?Your personal data is collected and processed in the following situations:
- subscription to our newsletter;
- contact with the sales department;
- automated means, such as cookies;
- interest in Europalco adds on third-party websites;
- filling in forms;
informationyou provided to us at events, conferences or fairs.
6. WHICH PERSONAL DATA IS COLLECTED?We may collect all data required for the formalization, execution, and management of contracted services, including, but not limited to:
- Contact details: name; address; e-mail; telephone/mobile phone;
- Personal information: date of birth; citizen card/identity card number; taxpayer number; bank account details; marital status; profession; employer;
- Identification data: customer number; contract number;
- Customer history: customer satisfaction ratio; services provided; place(s) where services were provided;
- Other: details about devices; IP address.
7. FOR WHAT PURPOSES AND WHAT BASIS CAN YOUR PERSONAL DATA BE USED?Generally, collected personal data is intended for the management of the contractual relationship, the provision of contracted services, the adequacy of our services to your needs and interests, and so that we can inform you about our events and our services/products.
Under the data protection legislation in force in the European Union (the GDPR), personal data processing must have a legal basis to justify such processing. In this context, the processing of personal data by Europalco shall always be based on one or more of the following legal bases:
- Consent of the data subject: Whenever consent is given to the processing of personal data for specific purposes, processing will be carried out under strictly agreed terms. The data subject may withdraw consent at any time, without such revocation affecting the processing performed while such consent was in force.
- Performance and/or management of the contract of other pre-contractual arrangements: Whenever the processing of personal data is carried out with the purpose of maintaining a contractual relationship between Europalco and customers or potential customers holding the data, in order to allow Europalco to provide services, namely for the performance of contracts and processing of requests (including contact requests, for example), as well as all actions required in the scope of conducting and managing Europalco’s business.
- Compliance with a legal obligation: Whenever the processing is necessary to comply with the legal obligations to which Europalco is subject.
- In the context of a legitimate interest: Whenever the processing of personal data is required to safeguard the legitimate interests of both Europalco and third parties, in particular in the context of maintaining the security of the network, infrastructure and technological systems, as well as their IT management, or whenever the processing is necessary for us to declare, exercise or defend a right in legal proceedings against you, us or a third party.
Europalco prevents unauthorized access or disclosure by using a variety of security measures for that purpose, including encryption and authentication tools to help protect and maintain the security, integrity
8. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
- Physical security measures:
- Facilities Security: entry into the facilities (including by subcontractors) is restricted to employees and, in exceptional cases, to individuals who are duly authorized by Europalco.
- CCTV cameras to ensure the physical security of employees and documents;
- There is a data protection policy, enshrined in the Europalco Code of Conduct, which applies to all its employees.
- Logical security measures:
- Access to computer systems is protected by login and password, with different levels of security, and it must be periodically changed;
- The whole Europalco IT network is protected by antivirus, firewalls
andmonitoring of the software installed;
- Use of SSL in the domain;
- Use of encryption technology in the collection or transfer of confidential data.
9. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?We process and store your personal data to the extent necessary to comply with the applicable contractual and legal provisions. There are cases in which the law requires the processing and storage of data for a minimum period, namely for 10 years, in the event data, are required to inform the Tax Authority, for accounting, tax or commercial bookkeeping purposes.
In other cases, we retain your data only for the period necessary for the purpose for which it was collected or, if any, for the period authorized by law. Once the maximum period of retention has been reached, your personal data will be irrevocably anonymized (anonymized data may be stored) or destroyed in a secure manner.
10. WHO DO WE SHARE YOUR DATA WITH?Within Europalco, the employees who need to access your data comply with contractual / pre-contractual and legal procedures have access to them.
Your data may be transferred to suppliers or service providers (Subprocessors
Your data may also be transferred to third parties – entities other than Europalco or Subprocessors - in case the holder has consented or entities to whom the data must be communicated as required by law, such as the Tax Authority.
In any case, Europalco ensures that these Subprocessors protect the security and privacy of your data, by means of a careful selection thereof and by entering into contracts that force them to adopt the technical and organizational measures required to protect your data, in accordance with the data protection framework in force.
11. WHICH RIGHTS DO YOU HAVE AND HOW CAN YOU ENFORCE THEM?Europalco guarantees all rights regarding the processing of your data, according to the GDPR, namely:
Rightof Access: right to obtain information about which of your personal data are processed, what are the purposes of the processing, what are the deadlines for storage, among others. Rightof Rectification: rightto request the rectification of your personal data that is inaccurate or request incomplete personal data to be completed, such as address, taxpayer number, e-mail address, telephone contacts or other.
- Right to Be Forgotten: right to have your personal data erased, as long as there is no valid basis for their maintenance, such as cases where Europalco is obliged to keep the data to comply with a legal obligation or because judicial proceedings are ongoing.
- Right to Portability:
rightto receive the data you provided us in digital format of current use and automatic reading.
- Right to Limitation:
rightto request the limitation of the processing of your personal data, in the form of:(i) suspension of processing or (ii) limitation of the scope of processing to certain categories of data or purposes of processing.
- Right to Withdraw Consent: right to withdraw your consent at any time to data processing that is based solely on said consent, for example in the case of data processing for marketing purposes.
Rightof Opposition: right to oppose to data processing, provided that no legitimate interests prevailing over your interests, rights andfreedoms exists, such as defense in judicial proceedings.
- Right to
complain: rightto file a complaint with the national supervisory authority, the CNPD.
August 28, 2018