A) Who is responsible for the treatment of your data;
B) What data we collect from our customers and purpose of them;
C) Who are the recipients of your data;
D) Where we store your data;
E) What are your rights when you give us your data;
F) How long we store your data;
A) WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR DATA? (Controller)
The person responsible for the processing of Personal Data is the commercial company, Wurllitzer, Limitada , with the unique registration number and corporate body number 508.582.679, headquartered at Rua Câmara Pestana 23, 1150-082 Lisboa, in the parish of Arroios, Lisbon municipality - Portugal.
In order to deal with issues / issues related to the processing of your personal data, you should contact us through the following means:
- Tel .: (+351) 218 290 810
- Email address: firstname.lastname@example.org
- Address: Rua Câmara Pestana 23, 1150-082 Lisbon, in the parish of Arroios, Lisbon municipality - Portugal.
B) WHAT DATA DO WE COLLECT FROM OUR CUSTOMERS, HOW DO WE USE IT, AND THE PURPOSE OF THEM?
Our company collects the following types of personal data from customers:
- Full name
- E-mail address
- Phone or mobile phone number
The purposes of the treatment of Personal Data are as follows:
a . Marketing : we will use your personal data to communicate with you, sending you information about your services, products and events, newsletter dissemination, promotions and invitations to the company activity.
B. Provision of products and services : we will use your personal data to fulfill and carry out a contract for the purchase and sale of our products / services or for a service agreement concluded with our company.
W. Communication : we may use your personal data to send you information / news related to services and / or products, or to send invitations, as well as to assist in matters relating to customer support;
d . Recruitment : Wurllitzer Lda during the personnel selection and recruitment process collects and processes the personal data of its candidates. The personal data processed will be those contained in the application form and the Curriculum Vitae, as well as all personal data that you spontaneously decide to transmit to Wurllitzer Lda, including but not limited to, name, age, sex, phone number), education information, employment history.
e ) Video surveillance of Wurllitzer establishments: The premises of our company have a video surveillance system. The image recordings obtained will be preserved, for a period of 30 days counted from the respective capture, at the end of this period the images will be eliminated, without prejudice to being kept for a longer period by judicial order.
We further inform that you may cancel the receipt of the Newsletter as well as any other communications identified above at any time, using the option that we make available in each communication.
With the exception of treatment for the purpose of supplying goods and services (treatment necessary for the performance of a contract), and treatment in connection with recruitment procedures, where treatment is based on the legitimate interest of the undertaking, the legal basis of the processing is the consent of the holders.
The Personal Data collected during the execution of an order or service request is necessary for the execution of the respective contract, so if the user in any way opposes the respective treatment, our company can not comply with performance of the contract.
C) WHO ARE THE RECIPIENTS OF YOUR DATA? WITH WHOM WILL WURLLITZER SHARE YOUR PERSONAL DATA?
Your personal data may be disclosed by our company within your business group, as well as, Wurllitzer may subcontract third parties for the provision of certain services, such as marketing services (including, sending of sms and emailing) or maintenance of the website and digital suppliers, digital marketing software in the cloud, online marketing platform company, therefore, your personal data, may be handled by companies subcontracted by our company, namely for hosting web pages, sending product information and services, special offers or invitations, email, response to customer inquiries about services. However, we would like to point out that only the personal data necessary for the provision of the service in question will be provided to these companies.
In these cases, these third-party companies may need to access certain information and data from the data holders. Wurllitzer Lda guarantees that, in such cases, these third parties will have limited access to the information of the data subjects, restricted only to those data necessary for the performance of the contracted tasks and that a contract has been awarded between the parties in which the protection of the data is regulated. Personal Data, these third parties undertake not to disclose, in any way, the Personal Data, or to use them for purposes other than the provision of contracted services.
Our company does not knowingly collect personal information from children under the age of 18.
D) WHERE DO WE STORE YOUR DATA?
Our company stores your personal data in a database on online marketing platforms, in data management software, and is protected from unauthorized access, use or disclosure of the Customer's Personal Data.
Our company follows technical, electronic and organizational procedures necessary and adequate to ensure the security of your Personal Data and to prevent its loss, misuse or improper access.
Our company adopts the appropriate procedures to ensure that your information is accurate, complete and current, but it is up to the customer to update or correct your personal information when necessary.
E) WHAT ARE YOUR RIGHTS WHEN USING YOUR DATA?
In accordance with applicable legislation, our company undertakes to respect the confidentiality of its personal information and ensure the exercise of its rights to:
a) Right to the protection of personal data (Article 1 RGPD-General Data Protection Regulation): that the regulation establishes the rules regarding the protection of individuals with regard to the processing of personal data and the free movement of such data.
b) Right to Information: our customers have the right to obtain clear, transparent and understandable information on how our company uses their personal data (Article 13 RGPD - General Regulation on Data Protection);
c) Right of access to information we have about the client : in addition to the right to information, you can access your personal data that we treat and keep, so at any time you can ask our company to access the information we have about you ( Article 15 RGPD-General Regulation on Data Protection);
d) Right of Rectification: you have the right to rectify your personal data if they are incorrect, out of date or if you wish to complete them. To do so, you can contact us for the contacts mentioned above (Article 16 RGPD - General Regulation on Data Protection);
e) Right of erasure or right to be forgotten (Article 17 RGPD - General Regulation of Data Protection): you can ask us to delete your data. The right to delete the data is usually known as the "Right to be forgotten", therefore, the holder of the data is entitled to obtain from our company the erasure of his personal data without undue delay and the latter has an obligation to erase his data without undue delay, where one of the following grounds applies:
- (a) personal data are no longer necessary for the purpose for which they were collected or processed;
- (b) the holder withdraws the consent on which the processing of the data under Article 6 (1) (a) or 9 (2) (a) of the RGPD is based and there is no other legal basis for such treatment;
- (c) the holder opposes treatment under Article 21 (1) of the RGPD and there are no prevailing legitimate interests justifying the treatment, or the holder opposes the treatment under Article 21. (2) of the RGPD;
- d) The personal data have been treated illegally;
- (e) personal data must be deleted in order to comply with a legal obligation deriving from Union law or a Member State to which the controller is subject;
- (f) personal data have been collected in the context of the provision of information society services referred to in Article 8 (1) of the RGPD;
f) Opt-in right , including direct marketing: you can delete your company's Newsletter subscription or choose to be removed from our direct marketing communications at any time. (Article 21 RGPD - General Regulation on Data Protection);
g) Right to withdraw consent at any time for the processing of data: you may withdraw your consent to the processing of data when such treatment is based on your consent. Withdrawal of consent does not affect the legality of consent-based treatment prior to withdrawal.
h) Right to file a complaint with the CNPD: If you consider that the processing of your personal data carried out by our company violates the applicable data protection legislation, you may file a complaint with the National Data Protection Commission ("CNPD"). Do not hesitate to contact us before submitting any complaint to the CNPD.
i) Right to data portability: you have the right to move, copy or transfer the data from our database to another (Article 20 RGPD - General Regulation on Data Protection);
j) Right to limit treatment : you have the right to request the restriction of the treatment of your data in the following situations: if you dispute the accuracy of the data, if the treatment is illicit and you do not want to erase your data, but only limit it, if the data is no longer required by our company but required by the customer or if you have exercised the right of objection referred to above during the period of time in which our company examines whether or not its legitimate interests in the treatment prevail over that right . (Article 18 RGPD - General Regulation on Data Protection);
k) Right to notification (Article 19 of the RGPD): The data subject has the right to be notified of any rectification, erasure or limitation of the treatment to which the controller has acted as a result of a request for rectification, erasure or limitation of treatment.
l) Right not to be subject to autonomous decisions (Art.22 of the RGPD ): The data subject has the right not to be subject to any decision made exclusively on the basis of automated processing, including profiling, its legal sphere or significantly affect it in a similar way.
The provisions of the previous paragraph shall not apply if the decision:
- (a) necessary for the conclusion or execution of a contract between the data subject and a controller;
- (b) is authorized by the law of the Union or of the Member State to which the controller is subject, and in which appropriate measures are also provided for in order to safeguard the rights and freedoms and legitimate interests of the data subject;
- c) is based on the explicit consent of the data subject.
m) Right to be notified in case of violation of personal data (Article 34 of the RGPD): When the violation of personal data is likely to entail a high risk to the rights and freedoms of natural persons, our company will report the data breach the data subject without undue delay.
n) Rights related to the principles of the processing of personal data as enshrined in article 5 of the RGPD - General Regulation on Data Protection;
F) How long do we store your data?
We only store Personal Data for the time required to achieve the purpose for which it was collected, to respond to your needs or to comply with our legal obligations.
In order to determine the period for which we store your data, we use the criteria listed below. If multiple criteria are applied simultaneously, we will keep your personal data in accordance with the criterion that entails the preservation of your Personal Data for the longest period of time.
a) When purchasing products and / or services, we will keep your personal data for the duration of our business relationship, including any complaints that may arise, and for a period of two years after the termination of the same, without prejudice to compliance with legal obligations of the controller;
b) When you contact us to ask questions, we will keep your personal information for the period of time necessary to resolve your question;
c) When you make reservations online on our website, we will keep your data until you ask us to delete them or after a period of inactivity of two years;
d) When you consent to the sending of direct marketing, we will keep your personal data until you cancel the subscription or ask us to eliminate it;
(e) for data collected during the recruitment procedure, for a maximum period of one year from the close of the procedure;
f) The period of time provided in the applicable legislation; or
(g) until the specific purpose applicable to certain data ceases to exist.
In any of these situations, if there is pending legal or judicial proceedings, the data will be kept for the duration of the process and up to six months after a final decision is passed.
We may also retain some of your personal data to the extent necessary to comply with our legal obligations, as well as to manage or enforce our rights, including through recourse to the courts.
After the above mentioned periods of conservation, the Personal Data will be deleted and / or erased in a secure way.
The data owner guarantees that the Personal Data communicated to us is accurate and accurate and undertakes to notify any change or modification to them and assumes sole responsibility for the losses and damages caused by the wrong, inaccurate or incomplete communication of the data.
The owner of the data is expressly warned that when disclosing Personal Data in public means of our establishments (company) such as Facebook, and Instagram, this information may be seen and used by third parties. We do not read any personal communications published on the websites of your customers.