1. What is our commitment:
This document reflects our commitment to (i) communicate transparently about the personal data we process and under what conditions; (ii) protect the security and privacy of personal data; (iii) provide the appropriate mechanisms for the exercise of the rights of personal data subjects; (iv) comply with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – General Data Protection Regulation (GDPR) – and other applicable legislation, including Portuguese legislation that complements the GDPR; If you are our Client, potential Client, or you have any relationship with José Borda & Cª, Lda (JBC), providing us your personal data, or are you a user of our websites or mobile applications (Client), we recommend reading this document. We are committed to safeguarding your privacy. Contact us if you have any questions or problems regarding the use of your Personal Data, as we want to help you.
2. Who we are:
José Borda & Cª, Lda (JBC) is responsible for the processing of the personal data of the respective Clients and Employees and who, in this context, taking into account the nature, scope, context, and purposes of the data processing, as well as the risks to the rights and freedoms of individuals whose likelihood and severity can be variable, (ii) apply appropriate technical and organizational measures as are appropriate to ensure and be able to prove that the treatment is carried out in accordance with the Regulation (RGPD). Data processor: José Borda & Cª, Lda (NIF: 502907100) Rua Serpa Pinto, 103 4490-680 Póvoa de Varzim Telephone: 252 248160 Email: firstname.lastname@example.org
3. What personal data we collect and process:
In essence, personal data is information related to an identified or identifiable particular person (“data subject”); an identifiable particular person is a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, identification number, location data, electronic identifiers or to one or more specific elements of physical, physiological, genetic, mental, economic, cultural or social identity of that particular person. Personal data category examples: Identification and contacts such as name, identification document number, tax identification number, signature, address, telephone number, or email address. Biographical data: Date of birth, sex, nationality, place of birth, marital status, household information, academic qualifications, or data about the profession. Financial data: Financial assets. Products and services: Account number and other information related to products and services purchased or subscribed by the Client and respective conditions. Use of websites and applications: Visited pages, or information about the used equipment (e.g. IP address, geographic location, used browser). JBC obtains this personal data through the following means of collection (or production): Data or content provided directly by the data subject (i) in the process of subscribing or purchasing products and services, (ii) in the letters or emails sent, (iii) participation in promotional actions, or (iv) the possibility of responding to satisfaction surveys. Cookies: Data related with the use of JBC websites and applications (e.g. pages visited; user preferences).
4. We commit to the following Data Protection Principles:
I. We always consider your rights before processing your Personal Data. II. We will provide information about the processing of your Personal Data, upon your request. III. The processing is limited to its purpose. In other words, the Personal Data collected is limited to serving the purpose of its collection. IV. The processing is done with minimal data. We only collect the minimum amount of Personal Data necessary for any purpose. V. The processing is limited to a period of time. We will not store your data any longer than the necessary. VI. We will do our best to ensure the accuracy of the data. VII. We will do our best to ensure the integrity and confidentiality of the data.
5. How we treat personal data:
6. What are the deadlines for the conservation and treatment of personal data:
JBC preserves and processes personal data for as long as necessary and as long as it remains legitimate purposes for which data is considered, to comply with contractual, legal and regulatory standards or to protect the legitimate interests of JBC or third parties. Reason for retention / Retention period: Contract Compliance / Contract Duration. JBC may keep personal data for periods longer than the duration of the contractual relationship, based on the Client’s consent, to ensure rights or duties related to the contract, or based on legitimate interests that underlie it, namely the defense of JBC in judicial lawsuits.
7. What are your rights as a data subject
JBC guarantees the exercise of the rights of data subjects in relation to the processing. Data subject rights Right to information: Clients have the right to know if their personal data is being processed; what data is collected, where it is obtained from and by whom and / or why it is processed. Access: Clients have the right to access the personal data they have provided to JBC or resulting from the use of JBC products and services and the respective treatment conditions. Rectification: Clients have the right to request the rectification of their personal data that are inaccurate or incomplete (e.g. address, e-mail address, telephone contacts). Opposition: Clients have the right to object to data processing based on JBC’s legitimate interest. Withdrawal of consent: Clients have the right to withdraw their consent of the data processing based on them. Forgetfulness: Clients have the right to request or delete their personal data held by JBC, as long as there are no valid grounds for their conservation (for example, compliance with a legal obligation, defense of JBC or legal process). Limitation: Clients have the right to request the limitation of a data processing when (i) they have disputed the accuracy of personal data and for a period that allows JBC to verify its accuracy, (ii) the processing is unlawful and opposes the erasure of personal data; (iii) JBC no longer needs personal data, but these data are required by Clients for the purpose of declaring, exercising or defending a right in a judicial process; (iv) were opposed to the treatment and during the period of evaluation of the request by JBC. Portability: Clients have the right to receive the personal data they have provided to JBC or resulting from the use of JBC products and services, and the respective treatment conditions, in a structured format, in current use and automatic reading, and the right to transmit that data to another data processor. Not to be subject to exclusively automated decisions: Clients have the right to request human intervention or to challenge decisions based on fully automated personal data processing that may have significant effects on their legal or private spheres, except in exceptional situations provided by law. JBC has mechanisms to guarantee human intervention in data processing based on automated decisions, allowing the data subject to express his / her point of view and challenge the automated decision. Complain to CNPD: Clients have the right to submit complaints to CNPD in relation to matters related to the exercise of their rights and to the protection of their personal data. You can exercise your data processing rights by letter or email to the contacts of JBC or to the data processor. JBC will respond to requests within a maximum of 30 days, except for particularly complex requests. In these cases, JBC will inform the data subject of the need to extend the response period for an additional maximum period of 30 days and the respective justification. Whenever JBC considers that it is not possible to respond to requests, data subjects will be informed of the reasons, within the deadlines set out above. The exercise of this rights is free of charge, except when situations are considered excessive, anomalous and / or in bad faith. In these situations, JBC will inform the data subject of the fees to be charged and the respective justification in advance. JBC has adequate mechanisms to verify and confirm the identity of the data subjects who intend to exercise their rights, being served exclusively those whose identity can be confirmed, and through a channel that allows to maintain evidence of the request and the respective response.
8. Cookies and other technologies we use
- Necessary cookies – necessary so that you can use some important features of our website, such as login for example.
- Functionality cookies – make our website as personalized and convenient as possible. For example, you can save your name and email in the comment forms, so you don’t have to fill in this information again.
- Analytical cookies – used to analyze the use and performance of our website and services.
- Advertising cookies – allow us to target advertising content according to your interests.