VALORSUL - Privacy Notice

EGF - Empresa Geral do Fomento, SA (hereinafter, EGF), and its 11 companies are committed to ensuring the security of personal data.

Subsequently, EGF has prepared this Privacy Notice, in order to make known the terms under which it collects and processes personal data, in accordance with Regulation (EU) 2016/769 of the European Parliament and of the Council, of April 27, 2016, (hereinafter GDPR), Law No. 58/2019, of August 8, which ensures the implementation, in the national legal system, of Regulation (EU) 2016/679, of April 27.

The processing of personal data described in this Notice concerns the personal data of citizens who interact with EGF (all those who, in some way, interact with us).

This document describes the conditions under which EGF processes your personal data, hereinafter referred to as (“Data Subjects”). EGF respects the Data Subjects’ right to privacy and declares that it complies with the applicable legal and regulatory provisions on privacy and personal data protection, adopting appropriate measures to guarantee the privacy and confidentiality of the personal data transmitted by the Data Subjects.

In order to clarify the processing of data, as well as its purpose and the rights of data subjects, it is advisable to periodically read this Privacy Notice.

 

Who is responsible for processing your personal data?

Valorsul is the entity responsible for data processing, under the terms of the GDPR and can be contacted via the email address,  Valoresul@valorsul.pt  or by telephone +351 219 535 900 (call to the national landline network) or by going to our facilities at Plataforma Ribeirinha da CP, Estação de Mercadorias da Bobadela, 2696-801 São João da Talha. 

 

What personal data do we collect?

The personal data we collect depends on the context of your interactions with EGF, within the scope of its commercial activity and in the fulfillment of the duties legally assigned to it.

EGF collects and processes personal data that is voluntarily provided by the data subject through the various contacts that are established, both in person and via the website, by telephone, by post or email.

Any information provided by the holder will only be used for the purpose described and in strict compliance with data protection legislation.

 

What are the purposes that precede the collection of your personal data and what is the basis for its processing?

EGF ensures that the processing of your personal data is carried out within the scope of the purpose for which they were collected, or for purposes compatible with the initial purpose for which they were collected. In addition, we process your personal data for legally foreseen purposes.

 

Customer support services

EGF uses your Personal Data for customer support purposes, including to respond to your queries. This typically requires the use of certain personal contact information and information about the reason for your query (e.g. requests for information, service requests, complaints regarding a product or service, general questions, suggestions, compliments, environmental communication programs, etc.). In these situations, the processing of your data is necessary for the performance of the contract to be concluded between you and EGF, or for carrying out pre-contractual steps at your request. If you do not provide your data, we will not be able to provide you with the services requested or contracted. Your data will be retained for this purpose for the duration of the contract(s), plus 10 years after termination. Data of potential customers will be retained for 2 years. Personal data of customers may be processed by EGF for the purpose of litigation management. The legal basis is the existence of a legitimate interest on the part of EGF and the data will be kept for the period necessary to exercise the respective rights.

 

Marketing Communications

EGF, with the customer’s consent (where required), uses the customer’s Personal Data to provide the customer with information about new goods, products or services (e.g. marketing communications or campaigns and promotions). This may be done via email, advertisements, SMS, telephone calls and postal correspondence, to the extent permitted by applicable law. Some of EGF’s campaigns and promotions are conducted on third party websites and/or social networks. This use of the customer’s Personal Data is voluntary, which means that the customer can object or withdraw his/her consent at any time. Your data will be retained for this purpose until the data subject exercises his/her right to withdraw consent.

 

Management of Complaints and Contacts Received

In your relationship with EGF, you may send us suggestions or complaints regarding the services provided by EGF. In these situations, your data will be collected to analyze and resolve the situation underlying your request/complaint, and will be processed based on EGF's legitimate interests.

 

Events

At events promoted by EGF, the processing of your personal data is necessary to ensure the management of your registration and respective participation in the aforementioned event, and images may also be collected, based on your consent. This use of your personal data is voluntary, which means that you can object or withdraw your consent whenever you wish. Your data will be kept for this purpose until the holder exercises his/her right to withdraw consent.

 

Supplier Management

The processing of your data is necessary for the execution of the contract to be concluded between you and EGF, or for carrying out pre-contractual due diligence at your request. If you do not provide your data, we will not be able to fulfil the contractual obligations assumed. Your data will be kept for this purpose for the duration of the contracts plus 10 years after termination. Data of potential customers will be kept for 2 years. Personal data of suppliers may be processed by EGF for the purpose of litigation management. The legal basis is the existence of a legitimate interest on the part of EGF and the data will be kept for the period necessary to exercise the respective rights. Data of EGF suppliers, in particular employees, may be communicated to EGF customers for the fulfilment of legal or contractual obligations.

 

Recruitment

EGF, following an open recruitment vacancy or a spontaneous application, will process your data for the purposes of selecting and recruiting candidates, if necessary for the execution of pre-contractual procedures. The personal data collected will be kept for a maximum of 2 years in cases where your application has not been considered for any vacancy. Based on your consent, we will keep your data for a period of more than 2 years if you wish your data to be considered for a future vacancy suitable for your profile.

 

Video Surveillance System

EGF has a video surveillance system in its facilities to ensure the security of people and property. Based on EGF's legitimate interest, we collect your image simply by accessing our facilities - however, no sound is collected. This data may be communicated to criminal police bodies or judicial authorities, upon request. The images collected will be kept for a maximum period of 30 days from the moment they were captured (except if other legislation applies).

 

Recording of telephone calls

As a result of your telephone contact and, within the scope of EGF’s activity, we may record calls, upon prior information and based on your consent, for the management of the pre-contractual and contractual relationship, as well as for the improvement of our services provided and, also, for quality control, based on EGF’s Legitimate Interest. These call recordings will be kept for the period indicated in the CNPD’s deliberations, which regulate this processing activity, namely Deliberation no. 1039/2017.

 

For how long do we keep your personal data?

The personal data collected and processed are kept, according to their purpose, in compliance with the applicable legal deadlines.

In cases where there is no legal term for the conservation and storage of personal data, such data will only be stored and retained for the appropriate period and to the extent necessary, in accordance with the purposes for which they were collected, unless, at any time, the holder of the personal data, within the legal limits, exercises his/her rights of opposition or erasure, or withdraws his/her consent.

Once the maximum retention period has been reached, personal data will be irreversibly anonymized (anonymized data may be retained) or securely destroyed.

For marketing and contact purposes, your personal data will be kept from the collection of your consent and if, within this period, you have not withdrawn it.

 

What are the rights of personal data holders?

Under applicable law, you may exercise the following rights:

  • Right of Access: obtain confirmation as to whether or not your personal data is being processed and, if so, access to it. In this case, EGF reserves the right to charge a reasonable fee, taking into account administrative costs;
  • Right to Rectification: obtain the rectification of inaccurate personal data concerning you and request that your incomplete personal data be completed;
  • Right to Erasure: obtain the erasure of your personal data, except in cases where there are grounds that validate its conservation;
  • Right to Limitation of Processing: obtain the limitation of the processing of your personal data when they relate to certain categories of data or processing purposes;
  • Right to Portability: to receive the personal data you have provided to us, in a structured format that is commonly used and can be read automatically, as well as to request the transmission of your personal data to another data controller;
  • Right to Object: to object, at any time, to certain processing of your personal data, such as in the case of the processing of personal data for direct marketing purposes;
  • Right not to be subject to automated individual decision-making, including profiling: not to be subject to any decision taken exclusively on the basis of automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar way.

In order to exercise your rights, you must contact us using the contact details mentioned in the chapter below, 'Contacts of the Data Controller'.

Furthermore, you are guaranteed the right to withdraw your consent whenever you have given it, through the means indicated above. The withdrawal of consent does not, however, invalidate the processing carried out up until the date of withdrawal.

The holder of personal data also has the right to lodge a complaint with the CNPD, or another competent supervisory authority, as well as to resort to any other judicial remedy, if he/she considers that his/her personal data is not subject to lawful processing by EGF, under the terms of the legislation in force and this notice.

 

Contacts of the Data Controller

EGF is not obliged to appoint a Data Protection Officer (DPO) in accordance with current legislation. However, in order to maintain a means of contact with data subjects, you can use the following contacts to clarify any questions you consider relevant related to the processing of your personal data and the exercise of your rights:  privacy@egf.pt

 

What security measures are adopted?

EGF is committed to implementing appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access. An adequate level of security is considered to be applied in relation to the risks that the processing presents, given the nature of the data to be protected.

In effect, EGF carries out all its activities using systems that aim to ensure the security of your personal data, through the creation of procedures that prevent unauthorized access, accidental loss and/or destruction of your personal data, committing to respect and compliance with the legislation regarding the protection of personal data.

 

Why do we share your personal data?

EGF may share your personal data with third parties, who will have access to it. Such third parties include public authorities, partners, service providers, among others. In the course of its activity, EGF may use subcontractors, who will access and process your personal data in accordance with our instructions.

To this end, we ensure that such subcontractors offer sufficient guarantees for the implementation of appropriate technical and organizational measures, so that the processing meets the requirements of the GDPR and other applicable legislation, as well as ensuring the defense of the rights of the holders of personal data.

Therefore, EGF may also share your personal data when such sharing is necessary or appropriate in light of applicable legislation, to comply with legal obligations to which it is bound, to respond to requests from public authorities, in the event that the vital interests of the holder of the personal data or of a third party are at stake, to protect the rights and property of EGF, or when you have given us your prior consent.

 

Under what circumstances do we transfer your personal data to third countries?

The activity carried out by EGF may involve the transfer of your personal data to third countries – located outside the European Union or that do not belong to the European Economic Area – even if this occurs occasionally and always in the relationship established with other services used by EGF.

In such situations, all necessary and appropriate measures will be adopted to ensure the protection of your personal data.

One such situation is in the context of EGF’s presence on social media, where we have limited influence over the data processing carried out by the operators of these networks (e.g. membership management and general information management). In situations where we do not have influence, we try to ensure, as far as possible, that the operators of the social media networks act in accordance with the privacy and data protection requirements of the GDPR. However, in many cases, we have no influence over this data processing carried out by the operators and we do not have clear knowledge of the data that is being processed on a given occasion.

The operators of the social networks manage the entire IT infrastructure of the service, applying their own privacy and data protection rules and, in addition, maintain their own relationships with users (insofar as these are registered users of the social network). Furthermore, the operators are fully responsible for all matters relating to user profile data to which EGF does not have access.

 

For more information on the data processing carried out by the social network operator, please consult their respective Privacy Policies:

 

How do we use “Cookies”?

For more information about cookies and how EGF uses them on its website, please see our Cookie Notice.

 

Changes to the Privacy Notice

Any updates to the 'Privacy Notice' will be communicated by means of a notice on the website's home page: https://www.egf.pt/pt/, so that such changes can be immediately understood. By continuing to use this website following a modification to the 'Privacy Notice' that has been communicated by this means, it will be assumed that the user has been aware of and accepts its terms.