Those data could be defined as personal data, considering personal data any information, of any nature and of any format, including, but not limited sound and image, relating to an identified or identifiable natural person (“data subject”)
PERSONAL DATA PROCESSING
In general, EFACEC collects and processes your personal data for executing of its commercial activities, namely, to provide its services, to manage EFACEC contractual relationship with its clients, suppliers and partners, since the prior contractual steps until the execution of the contract, as well as to comply with legal obligations (including tax and regulatory obligations).
In order to achieve the specific purposes of the correspondent processing activity, EFACEC collects and processes, depending on the context and on the contractual relationship, personal data from the following data subjects: (i) clients’ representatives, (ii) individual suppliers and suppliers’ representatives, and (iii) other individual third parties and third parties’ representatives.
Therefore, the personal data which are collected by EFACEC through the website, signed contract or any other mechanism of personal data collection mentioned above, may include: name, competences and role within the company, email address, telephone number for professional purposes, professional address.
The collection and processing activities of personal data carried out by EFACEC, either manually or automated, as mentioned above, aim exclusively to accomplish the following specified purposes: (i) the supply of EFACEC’s goods and provision of the contracted services; (ii) compliance with clients’ instructions; (iii) management of the agreement with companies which are EFACEC’s clients; (iv) newsletters sending and invitations for conferences, launches, events and publications done or powered by EFACEC; (v) marketing communications regarding EFACEC’s products and services focused on clients albeit sent to individual contacts of the said clients; (vi) to comply with legal obligations, in which cases EFACEC may transfer personal data to public and regulatory authorities whenever legally mandatory.
NEWSLETTERS SENDING AND OTHER COMMUNICATIONS
EFACEC’s communications regarding newsletters and invitations for events are made strictly for promoting, to its clients, suppliers, third parties and other entities (through the individual contacts available), the activities and relevant initiatives of EFACEC and entities which whom 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 want to receive any more marketing communications from EFACEC may send a request via email to firstname.lastname@example.org or select the Unsubscribe Newsletter option, whenever applicable.
PERIOD OF STORAGE
The personal data which are collected by EFACEC will be stored for the duration period of the commercial relation with the client, supplier or third party 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 third party 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 email@example.com
According to the applicable law, and whenever the processing activity is based on the data subject’s consent, 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. 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 to provide certain services. Eventually that provision of services may imply the access, for those entities, to personal data of their clients, suppliers and third parties.
Therefore, any processor contracted by EFACEC will process data subject’s personal data on behalf of EFACEC and in strict compliance with its documented 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 data protection processed.
INTERNATIONAL TRANSFER OF PERSONAL DATA
The supply of products and the provision of services by EFACEC may require the transfer of personal data to third 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 to obtain more information about the processing of his or her personal data, as well as any question regarding 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: firstname.lastname@example.org