In the context of its activities and the contractual relations established, EFACEC collects personal data of its clients’ representatives, suppliers, job applicants, partners and any other natural person. Additionally, the interaction with user of EFACEC website http://www.efacec.pt/ (from now on “website”) also requires, in some cases, (i) collection of personal information through the contact form and the campus for subscribing our newsletter, as well as (iii) collection of data through your device (through cookies files), in accordance with our Privacy and Cookies Policy.
These data could be considered personal, being personal data any information, of any nature and of any format, including, but not limited to sound and image, relating to an identified or identifiable natural person (data subject).
PERSONAL DATA PROCESSING
EFACEC collects and processes your personal data in order to provide EFACEC services, to comply with legal obligations (including tax and regulatory obligations) and to manage EFACEC contractual relationship with its clients, suppliers and partners.
The personal data of representatives, contacts and employees of EFACEC clients and suppliers (companies) are generally processed within the supply of products and the provision and management of the services contracted, in order to allow EFACEC to comply with contractual obligations and clients’ instructions, if applicable. In these cases, data subjects shall address their employer and/or responsible entity (if they are not clients and/or suppliers employees) any question and/or exercise their legal rights, without prejudice of the terms herein.
Suppliers’ personal data (natural person), i.e. natural persons who represent or collaborate with suppliers and services providers of EFACEC, in which EFACEC has access in the supplier and the provision of services context, are processed for client management purposes. This personal data processing is lawful since it is necessary for the performance of the contract established between EFACEC and the supplier and, in certain cases, for the compliance of a legal obligation to which EFACEC is subject. In relating to partners, i.e. natural persons and their collaborators with whom EFACEC establishes partnerships, and relating to personal data necessary for managing the partnership, the processing activities are lawful because of the performance of the contract celebrated with the partner and, in certain cases, of the compliance of a legal obligation to which EFACEC is subject.
In this sense, EFACEC uses the following personal data of data subjects for the following purposes:
- Personal data of clients’ representatives (name, competences and role, email address, telephone number, professional address): the personal data are processed for suppling EFACEC products and execute EFACEC services. EFACEC uses this information to supply its products, to provide its services and to manage contacts with clients, within the performance of the contractual relationship established, as well as to comply with legal obligations to which EFACEC is subject;
- Personal data of individuals acting as suppliers and suppliers’ representatives (companies) (name, competences within the company, email address, telephone number, professional address): the personal data are processed for suppling EFACEC products and execute EFACEC service, within the performance of the contractual relationship established with the natural person/entity and to comply with legal obligations to which EFACEC is subject;
- Personal data with suppliers and representatives of clients, suppliers and partners (companies): to send newsletter and invitations for conferences, product launches, events and publications of EFACEC. EFACEC may send to its contacts promotional communications in order to disclose its products and services targeted for clients, though sent for individual email addresses of the client – these communications are sent via email and/or via telephone and are not based on automated profiling.
- Personal data of partners (natural persons) and their collaborators: performance of the contract and management of the partnership.
EFACEC’s communications regarding newsletters and invitations for events are made strictly for disclosure, to its clients, partners and other entities (through the individual contacts available), the activities and relevant initiatives of EFACEC and entities with which EFACEC engages. These communications are not based on automated profiling activities, instead they are made exclusively for management purposes of the contractual relation between EFACEC and the entities which whom EFACEC engages.
Every recipient who does not to want to receive any more marketing communications from EFACEC may send a request via email to email@example.com.
In addition to the mentioned purposes, EFACEC may process personal data for complying with legal obligations to which EFACEC is subject. In this sense, EFACEC may have to communicate personal data to judicial authorities, tax authorities, Instituto dos Mercados Públicos do Imobiliário e Construção and any other regulatory entities.
PERIOD OF STORAGE
The personal data which are collected will be stored by EFACEC for the duration period of the relation with the client, supplier or partner in which the data subject is involved. However, the personal data can be stored for a longer period, as provided in law for the defence of rights and interests in a judicial proceeding or for the execution of the mentioned purposes.
RIGHTS OF THE DATA SUBJECTS
In accordance with the applicable legislation, every data subject may at all time access to his/her rights relating to data protection (in some cases and depending in the contractual terms, those data protection rights can be exercised through the client, supplier or partner in which the data subject is involved):
- Rectification – the data subject has the right to obtain the rectification of inaccurate personal data concerning him or her, as well as the right to have incomplete personal data completed;
- Erasure of his/her personal data – the data subject has the right to ask for the erasure of personal data concerning him or her if, for example, the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, the data subject withdraws consent;
- Portability of personal data – in some cases the data subject may have the right to receive the personal data concerning him or her, which he or she has provided to EFACEC, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller;
- Restriction of processing – the data subject has the right to ask the restriction of processing in some cases, namely, if the processing is unlawful and the data subject opposes the erasure of personal data, EFACEC no longer needs the personal data for the purposes of the processing but they are required by the data subject for the establishment, exercise or defence of legal claims, among others;
- Object – the data subject may object to processing, on grounds relating to his or her particular situation, and if the processing is made on the following cases: (i) pursuant to legitimated grounds of EFACEC or third parties, or are being processed for different purposes of those for what they were being collected for and are being processed without the data subject’s consent or based on European Union Law or national law, or (ii) personal data are being processed for direct marketing purposes, or (iii) personal data are being processed for scientific or historical research purposes or statistical purposes.
The data subject may exercise the mentioned rights by sending a request to EFACEC via email to firstname.lastname@example.org
According to the applicable law, EFACEC guarantees to the data subject the possibility of withdrawing the consent given for processing his or her personal data, through the mechanism referred above, whenever the processing is based on consent. For this purpose, the data subject has the right to withdraw his or her consent at any time, which shall not affect the lawfulness of the processing based on consent previously given and before its withdraw.
SECURITY MEASURES IMPLEMENTED BY EFACEC
EFACEC develops its best efforts to protect personal data of its clients against any unauthorised access through its network. For that purpose, EFACEC keeps in place all technical mechanisms to prevent loss, misuse, modification, unauthorised access, disclose, loss or destruction and illegitimate appropriation of personal data given or transmitted, and undertakes to comply with data protection legislation applicable as well as to process those personal data only for the defined purposes, and declares that such personal data are processed in accordance with the adequate safety and confidentiality level.
TRANSFER OF PERSONAL DATA TO OTHER ENTITIES
EFACEC contracts other entities for providing certain services. Eventually that provision of services may imply the access, by those entities, to personal data of their clients, suppliers and partners.
Therefore, any processor contracted by EFACEC will process data subject’s personal data on behalf of EFACEC and in strict compliance with its instructions. EFACEC guarantees that those processors give and execute sufficient and adequate technical and operational measures in order to comply with the applicable law and assure that security and protection of personal data are guarantee according to the terms of data processing agreement signed between EFACEC and processors.
In some cases, data subject’s personal data may be transferred to third parties, whenever those personal data transfers are necessary or adequate (i) to the applicable law, (ii) in order to comply with legal obligation/judicial orders, (iii) or orders directed by the Portuguese Data Protection Authority or any other competent supervisory authority, or (iv) for answering state or governmental authorities’ requests.
In any case, EFACEC undertakes to implement all reasonable measures to guarantee full and effective protection of the processed data.
INTERNATIONAL TRANSFER OF PERSONAL DATA
The supply of products and the provision of services by EFACEC may require the transfer of personal data to other countries (which do not belong to the European Union or the European Economic Area). In these cases, EFACEC implements the necessary and adequate measures in light of the applicable law in order to protect the personal data subject to the said transfer, and in strict compliance with the legal requirements applicable to that transfer, namely, informing the data subject.
The data subject may contact EFACEC in order to obtain more information about the processing of his or her personal data, as well as any question regrading the exercise of his or her legal rights, via the following email address (without prejudice of, in certain cases and as a result of the contractual terms expressly agreed, those rights can be exercised before EFACEC clients, suppliers or partners):
Email address: email@example.com