Privacy Policy

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last update: 13.09.2022

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CUSTOMERS AND USERS

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1. Who are we?

Anturio Corporation Lda — Computer Consultancy.

The company is committed to protecting the privacy of its customers, suppliers, users of its services and third parties, as well as the contractual information it has, in which context, it adopts the “Privacy Policy” reflected in this document, in order to demonstrate its commitment and respect for the rules of privacy and data protection personal data in compliance with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

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2. Why this privacy policy? Brief legal framework.

The adoption of a privacy policy arises from the need to make known to all people who contact the company, what are the principles and general rules for the treatment of their personal data that are collected and processed in strict compliance with the General Data Protection Regulation.

The company, in the treatment of the data of its customers and other contacts, takes care to respect the best security practices, having approved for this purpose an internal policy capable of safeguarding the protection of personal data that is provided to us by all those who relate to the company, in particular, in the scope of the provision of services in the market.

In this context and with the aim of promoting a policy of loyalty and transparency in the treatment of the data of our customers and users, the company has a responsible for the protection of personal data whose function and responsibility will be the implementation of this privacy policy and the verification of its compliance, ensuring your knowledge to ours to all concerned with the company, as well as users of the procedures used in the processing of their data.

This privacy policy will be supplemented, from case to case, by the provisions of the contracts to which the company is a party, to the extent justified.By reading and agreeing to our privacy policy you are accepting the conditions contained herein, so we ask our customers and users to pay special attention to all the content of this document.

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3. What is covered by our privacy policy?

The privacy policy applies solely and exclusively to the collection and processing of personal data carried out by the company for the continuation of its activity and provision of services to its customers.

In the execution of the provision of services to our customers, the company will proceed, from time to time and to the extent strictly necessary, to the copy of the database of our customers. To this extent, the company already guarantees and ensures the total confidentiality of the copied data, in compliance with the GDPR, committing and deleting them as soon as the assumption that led to its copy is extinguished.

The company also undertakes not to process the data of third parties without your consent to do so. It is also reported that the company undertakes to check at the time before the transfer of data whether its customers are in full compliance with the GDPR.

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4. What is personal data?

The protection of data of natural persons with regard to the processing of personal data is a fundamental right.

Personal data means information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as, for example, the name, identification number or specific elements of physical identity

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5. Our data officer.

Our data officer can be contacted at:

Name: Anturio Corporation Lda — Consultadoria Informática
Address: Rua Regimento Infantaria 11, nº30, 2ºA 2900-584 Setúbal
Phone: 707 454 000
E-mail: rgpd@anturio.com

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6. What types of personal data do we collect?

Within the scope of its activity and through the contracting of the specialized services of the company, the data necessary for the provision of services or the provision of contracted products will be collected. In this context, data such as name, address, telephone will be treated.

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7. How do we collect your data?

Your data may be collected, with your consent, by phone/in writing.

The personal data collected will be processed electronically, in compliance with the data protection legislation in force, being stored in the company's cloud database.

At no time will the data provided and processed be used for purposes other than those consented to or contracted.

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8. Purpose of the processing and collection of personal data.

The personal data provided by our customers and users are essentially intended for contractual management, adaptation of services to contracted needs, information.

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9. Data retention time.

Your personal data will be kept for the period of time necessary to achieve the purpose for which they are intended or, if there are legal requirements that require their conservation, for a certain minimum period of time.

The conservation will always be maintained during the period of validity of the contractual relationship with the client.

Whenever there is no legal requirement or any compelling reason justifying the maintenance of the data, they will be stored only for the minimum period necessary to fulfill the purposes for which they were collected.

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10. Rights of data subjects.

In accordance with the Legal Regime for the Protection of Personal Data, the data subject is guaranteed the right to access, update, rectify or delete their personal data, which may take place through the various contacts made available.

If you wish, you can choose not to receive any emails and/or SMS messages. You may also choose to unsubscribe from our website, delete or modify your personal information.

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11. How can you object to contact for marketing purposes?

If you do not wish to be contacted for marketing and advertising purposes, you may object at any time to the use of your data for these purposes.

To object just contact: Contact information.

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12. Security measures adopted to protect your data.

The company is committed to ensuring the protection and security of your personal data.

Thus and in compliance with the General Data Protection Regulation, it approved and implemented strict rules in this matter. Compliance with these rules is an unwavering obligation of all those who legally access them and who relate to us.

Bearing in mind the great concern and commitment that the company imposes to the defense of privacy issues, several security measures have been adopted, of a technical and organizational nature, in order to protect the personal data that are made available to us against its dissemination, loss, misuse, alteration, treatment or unauthorized access as well as, against any other form of treatment unlawful conduct.

In this sense, all personal data that are transferred to us, are stored securely in the company's systems (describe how data is stored and protected).

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13. Data communication to subcontracted third parties - How and when?

Within the scope of its activity, the company uses third parties for the provision of certain services.

Sometimes, the provision of these services implies access, by these entities, to the personal data of our customers. When this happens, the company takes the appropriate measures, in order to ensure that the entities that have access to the data, are reputable and offer the highest guarantees at this level, which will be duly enshrined and protected in the contracts.

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14. Transfer of personal data.

In the provision of certain services by the company and in the fulfillment of contractual relations with its customers, your data may be transferred outside Portugal, to a subsidiary of the company, namely in the use of services in international institutions.

In this case, the applicable legal provisions shall be scrupulously complied with, in particular, with regard to the determination of the adequacy of the country concerned with regard to the protection of personal data.

Such data transfers will always be communicated to the data subject.

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15. Obligations relating to data processing.

Obligations of the Subjects In the processing of data, and in accordance with point 3 of our privacy policy, the company informs that all its employees in the exercise of their functions are subject to this privacy policy and must comply with it.

The Data Subjects must, in particular in the exercise of their functions and when they have access to personal data:

Process personal data in accordance with both the purpose for which said personal data are intended, as well as with the instructions of the company;
Ensure that access to personal data is limited in accordance with their need to know, in accordance with the confidentiality obligations to which they are contractually bound;
not to use the personal data to which they have access for purposes other than those clearly and explicitly necessary for the performance of their functions;
not to communicate personal data to third parties, even for the purposes of their storage, in addition to that necessary for the fulfillment and execution of their contractual obligations and the instructions of the company;
Inform the company immediately and in writing of the existence of any irregularity relating to personal data that they detect or become aware of in the exercise of their functions;
Inform the company of the existence of any request for the exercise of rights and/or complaints regarding the personal data that they are aware of in the exercise of their functions;
Keep documented the operations they carry out in accordance with the instructions of the company;
comply with the obligation of secrecy with regard to the content of the personal data to which they have access in the exercise of their functions;
Respect the technical and organizational measures implemented to protect personal data;
Collaborate with the company and provide it with all documentation and information that is necessary to demonstrate compliance with the obligations established in this Policy and in the legislation.

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16. Contacts

In case of questions or comments regarding our privacy policy, write to us at the following address: Rua Regimento Infantaria 11, nº30, 2ºA 2900-584 Setubal

‍Or by e-mail: rgpd@anturio.com

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COLLABORATORS

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1. Purpose - What is covered by this privacy policy.

The data collected or processed by our company are intended for the full execution of the employment contract, namely, for the purposes of salary processing, human resources management, recording working hours and attendance, to comply with the rights of workers provided for in the law, to ensure the fulfillment of the duties of the workers and the exercise of the rights of the employer, as in the case of the possible instruction of disciplinary procedures to the worker and also, for other purposes permitted by law.

In addition, personal data may also be processed for the purpose of fulfilling legal obligations, namely, to present information to judicial, police or other tax entities, when in the meantime our company is notified in accordance with the law.

The data shall be collected and processed in accordance with Article 6 (1) (b) insofar as they are necessary for the performance of the employment contract and, on the basis of paragraph a) of the same Article in cases where the worker has consented to its collection and processing for certain purposes and is still necessary for the fulfilment of a legal obligation of the employer entity, which is justified in point c) of the identified article 6 always of the RGPD

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2. Foundations.

The processing of employees' personal data is based on:

in its need for the performance of a contract to which the employee is a party;
in its need to comply with the legal obligations to which the company is subject;
where necessary for the purposes of the legitimate interests pursued by the company or by third parties.

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3. Data collection.

Personal data, and others that are processed by the company, are obtained through the employment contract, as well as through other documents that are requested during the performance of the employee's duties and during the validity of the employment relationship.

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4. Legitimacy for data collection.

The personal data of the workers who hold the data are collected and processed within the scope of an employment contract relationship and also, based on the consent of the worker and also to comply with legal obligations inherent in the execution of the employment contract, namely for social security purposes, for tax purposes, for safety, hygiene and health at work, for the purposes of fulfillment of labor rights and duties, among others, which constitutes an obligation of the employee who owns the data.

The refusal to communicate and inform the data would make it impossible to conclude and execute the employment contract normally and in accordance with the law.

Thus, our company has the legitimacy to proceed with the processing of personal data, under the provisions of Article 6 (b), (a) and (c) of the GDPR

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5. Information to be provided.

In compliance with this privacy policy, the company undertakes to provide employees with the following information:

Your identity and contacts;
The contacts of the data protection officer;
the purposes of the processing for which the personal data are intended;
the legal basis for the processing for which the personal data are intended;
if any, the recipients or categories of recipients of the personal data;
the existence of transfers of personal data to a third country;
The period of retention of personal data and the criteria used to define this period;
the existence of the rights and the way in which they are exercised;
the right to lodge a complaint with the supervisory authority;
The fact that the communication of personal data constitutes a legal obligation and a necessary requirement to conclude a contract;
The possible consequences of not providing this data. This information must be presented to candidates at the time of data collection.

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6. Legal obligation.

The processing operations of employees' personal data are necessary both for the execution of the contract and for the fulfillment of the legal obligations to which the company is subject. In particular, issues imposed by labor, social security and tax legislation are foreseen here, so the communication of personal data constitutes a contractual and legal obligation.

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7. Special data categories.

The company carries out processing of special categories of personal data when

Necessary for the fulfilment of obligations and the exercise of specific rights of the undertaking in the field of labour law, social security and social protection; or,
Necessary for preventive or occupational medicine purposes, for the evaluation of the employee's working capacity.

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8. Term for conservation.

The company retains personal data only for the period necessary for the execution of the purposes for which they are intended, in particular, during the execution of the contract.

However, the company will also retain personal data for the period necessary to comply with the legal obligations to which it is subject, in particular, within the scope of labor, social security and tax legislation.

In the event of a dispute between the company and the employee, the data will be kept at least until the court decision is passed.

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9. Communication and transfers.

Within the scope of the activities related to the administration and management of the employment contract and the employment relationship, the company may communicate or transfer the personal data of the employees to the entities identified below, not excluding other entities not mentioned, but which have legal legitimacy to proceed with the processing of the data in question:

IGFSS — Institute of Financial Management of Social Security;
AT — Tax Authority;
Banking and Insurance Institutions;
INE — National Institute of Statistics;
ACT — Authority for Working Conditions.

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10. Subcontractors

The company may communicate employees' personal data to service providers, namely:

Entity responsible for the performance of duties relating to safety, hygiene and health at work;

• Data collection for preventive and occupational medicine purposes shall be carried out by the medical, health, hygiene and safety services at work and breath and urine tests by personnel duly qualified and accredited by those services;
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• Such services and entities are subject to the GDPR, so absolute confidentiality will be guaranteed in their treatment and cannot be assigned a different purpose than that for which they are intended;
any other entity to which payroll processing functions have been assigned;
Entity to which functions related to the management of human resources have been assigned. The purpose of the communications or transfers referred to in the previous paragraph is, in particular:
The calculation and payment of remuneration, ancillary benefits, other allowances and gratuities
the calculation, withholding and operations relating to remuneration discounts, mandatory or optional, arising from a legal provision;
The performance of non-nominative statistical operations related to the processing of wages within the scope of the processing entity;
Compliance with the obligations to which the company is subject, in particular, within the scope of labor, social security and tax legislation.

The company ensures that said service providers present sufficient guarantees of execution of appropriate technical and organizational measures in such a way that the processing meets its internal standards and requirements and the legislation, and the processing subcontracted by these service providers is regulated by written contract and in accordance with this privacy policy.

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11. Safety of treatment.

The company is committed to ensuring the protection and security of your personal data.

Thus and in compliance with the General Data Protection Regulation, it approved and implemented strict rules in this matter. Compliance with these rules is an obligation of all those who legally access them and who relate to us.

Bearing in mind the great concern and commitment that the company imposes in the defense of privacy issues, several security measures have been adopted, of a technical and organizational nature, in order to protect the personal data that are made available to us against its dissemination, loss, misuse, alteration, treatment or unauthorized access as well as, against any other form of unlawful treatment.

In this sense, all personal data of employees is stored securely in the company's systems on the company's cloud servers.