I. WHAT DATA ARE PROCESSED AND HOW ARE THEY COLLECTED?
CONSULYACHTS, UNIPESSOAL LDA. (hereinafter CONSULYACHTS) only collects personal data that is adequate, relevant and limited to what is strictly necessary for the purposes for which they are processed.
Regarding clients, clients' employees, suppliers, partners, employees and collaborators, CONSULYACHTS collects the following personal data: identification data, professional data, professional activity or accounting data, of the individuals themselves, in the case of natural persons, or of their representatives, in the case of legal persons, such as name, nationality, contact, citizen card data, position, functions, professional contacts and any personal data whose processing is strictly necessary for the execution of a contract or for compliance with legal obligations.
Regarding contact requests CONSULYACHTS collects the following personal data: identification data such as name, address, e-mail address, telephone number or mobile phone.
On newsletter subscription CONSULYACHTS collects the following personal data: identification data such as name, address, e-mail address, telephone or mobile phone number.
On applications CONSULYACHTS collects the following personal data: identification data such as name, address, e-mail address, telephone or mobile phone number and any data contained in a curriculum vitae.
Personal data is collected by various means, namely by filling in the forms on the CONSULYACHTS website, by sending e-mails, by telephone contact, by handing in a personal card, by requesting offers, by sending professional applications, by contracting the services of or by CONSULYACHTS.
II. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
Tiago Bacelar is the person within CONSULYACHTS who centralises and is responsible for data protection matters, whose contact is email@example.com.
III. WHAT IS THE LEGAL BASIS AND FOR WHAT PURPOSES ARE PERSONAL DATA PROCESSED?
The legal grounds for the processing of personal data of customers, customers' employees, suppliers, partners, employees and collaborators are the performance of contracts and the fulfilment of legal obligations, as provided for in Article 6(1)(b) and (c) of the GDPR.
The processing of personal data of customers, customers' employees, suppliers, partners, workers and employees is intended for any purposes directly related to the performance of the respective contracts or the fulfilment of legal obligations, namely, recruitment, contractual management, work management, accounting, commercial activity, customer management, communication, presentation of proposals and provision of services.
The processing of personal data for purposes other than the above, namely personal data collected through the website of CONSULYACHTS or following the sending of emails with contact requests, depends on the consent of the data subjects, as provided for in Article 6(a) of the RGPD.
The processing of personal data collected through the website or e-mail address of CONSULYACHTS is intended to respond to contact requests, including sending proposals / quotes and other information on services, sending marketing communications such as newsletters, commercial information, new services, technical articles, information on events or other related activities and recruitment.
IV. RETENTION OF PERSONAL DATA
CONSULYACHTS only retains personal data in a form that allows the identification of the data subjects for the period strictly necessary to carry out the purposes for which they are processed, without prejudice to the need to retain for longer periods for the purposes of compliance with legal obligations.
Thus, it is important to clarify that the personal data relating to the recruitment and selection of candidates may be retained for the period necessary to fulfil the purpose (for example, if a candidate is part of CONSULYACHTS, his personal data will be processed in accordance with the purpose of human resources management; if not part of CONSULYACHTS, they may be kept in reserve for future recruitment processes during 1 (one) year, without prejudice to the right of the holder to request deletion of his data at any time).
In the case of contact requests, the personal data are deleted after 6 months from the submission of the request, without there having been any subsequent contact.
In the case of personal data collected from newsletter subscriptions personal data is deleted after 2 years from the date of obtaining consent.
However, in order to comply with legal obligations regarding the keeping of books, accounting records and respective supporting documents, personal data may be kept for archiving purposes for a period of 10 years.
V. RIGHTS OF THE HOLDER OF PERSONAL DATA
CONSULYACHTS guarantees, at any time, the right of access to your personal data, as well as their rectification, elimination, portability, limitation and/or opposition to processing.
To this end, you may exercise any of these rights by addressing, in writing, to CONSULYACHTS through the address of the headquarters or through the following email firstname.lastname@example.org
Additionally, you may always lodge complaints as deemed necessary with the competent authority for that purpose.
VI. RIGHT TO FORGETTING
The holder of the personal data has the right to obtain, from the person responsible for processing them, the erasure of their personal data, who shall, in turn, be obliged to erase them, where one of the following grounds applies
(i) the data are no longer necessary for the purpose for which they were collected or processed;
(ii) the data subject withdraws consent, where consent is the legal basis or the data subject opposes the processing and there are no overriding legitimate interests justifying their maintenance.
VII. SECURITY IN THE PROCESSING OF PERSONAL DATA
CONSULYACHTS strives to implement all necessary precautions to preserve the confidentiality and security of personal data collected and processed. To this extent, technical and organisational security measures have been developed, especially with regard to information systems.
CONSULYACHTS hereby informs you that these security measures are reviewed and updated as required and necessary.
Should there be, for any reason, a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, CONSULYACHTS undertakes, in accordance with the applicable legislation, to report to the National Data Protection Commission, without justified delay and, where possible, within 72 hours of becoming aware of such occurrence. CONSULYACHTS further undertakes to communicate the breach of personal data to the respective data subject, in accordance with applicable law.
Additionally, notwithstanding the security measures adopted by CONSULYACHTS, it should be noted and alerted that users should also adopt additional security measures, namely, ensure the existence of an active firewall, antivirus and anti-spyware updated.
VIII. TRANSMISSION AND COMMUNICATION OF PERSONAL DATA TO THIRD PARTIES
CONSULYACHTS only transmits personal data to third parties where this is necessary for the provision of its services or for compliance with legal obligations to which CONSULYACHTS is subject, namely, judicial authorities, regulatory and other public entities, service providers of CONSULYACHTS, such as information technology, chosen upon compliance with high requirements and who are bound to comply with the applicable legal standards on the protection of personal data.
The transmission, when due for the performance of its services or fulfilment of legal obligations to which CONSULYACHTS is subject or as a consequence of the consent of the data subject, is made with the limitation of the data transmitted to what is strictly necessary for the fulfilment of such obligations and by means of adequate security measures. No personal data shall be transmitted in any other case without the consent of the data subject.
Within the scope of its business, CONSULYACHTS may rely on third parties for the provision of certain services (located within or outside the European Union), which may involve, in some situations, access by such entities to the personal data of users.
Thus, CONSULYACHTS undertakes to adopt the necessary and appropriate measures, in order to ensure that the entities that have access to such personal data, are reputable and offer high guarantees at this level, which will be duly enshrined and safeguarded in contract to be concluded in writing between CONSULYACHTS and the third entity(ies).
Consequently, any entity subcontracted by CONSULYACHTS shall treat the personal data of the users, in its name and on its behalf in the commitment to adopt the necessary technical and organisational measures in order to protect the personal data against destruction, accidental or unlawful, accidental loss, alteration, unauthorised disclosure or access and against any other form of unlawful treatment.
Nevertheless, CONSULYACHTS shall remain responsible for the processing of the personal data.
Where necessary and in connection with the engagement of third parties by CONSULYACHTS, personal data may be transferred outside the European Union under the terms and conditions permitted by applicable law.
IX. ACCESS TO THIRD PARTY WEBSITES
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