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PRIVACY NOTICE
Privacy Notice

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

Accordingly, EGF has drawn up this Privacy Notice in order to disclose 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 27 April 2016 (hereinafter GDPR), Law No. 58/2019 of 8 August, which ensures the implementation, in the national legal system, of Regulation (EU) 2016/679 of 27 April.

The processing of personal data described in this Notice concerns the personal data of citizens who are related to EGF (all those who interact with us in any way).

This document describes the conditions under which EGF processes your personal data, hereinafter referred to as (‘Data Subjects’). EGF respects the right to privacy of Data Subjects and declares that it complies with the applicable legal and regulatory provisions on privacy and personal data protection, taking appropriate measures to ensure the privacy and confidentiality of personal data transmitted by 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 read this Privacy Notice periodically.

 

Who is responsible for processing your personal data?

ERSUC is the entity responsible for data processing under the terms of the GDPR and can be contacted via email at geral@ersuc.pt or by telephone on +351 239 851 910 (call to the national landline network) or by visiting our facilities at the ERSUC Integrated Centre for the Treatment and Recovery of MSW - Vil de Matos, 3025-607, Vil de Matos - Coimbra.


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 compliance with its legal obligations.

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

Any information provided by the data subject 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 it was collected, or for purposes compatible with the initial purpose for which it was collected. In addition, we process your personal data for legally established purposes.

 

Customer support services

EGF uses customer Personal Data for customer support purposes, including to respond to customer enquiries. This typically requires the use of certain personal contact information and information about the reason for the customer's enquiry (e.g., requests for information, service requests, complaints about a product or service, general questions, suggestions, compliments, environmental communication programmes, 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 the performance of pre-contractual steps at your request. If you do not provide your data, we will not be able to provide you with the requested or contracted services. Your data will be kept for this purpose for the duration of the contract(s), plus 10 years after termination. The data of potential customers will be kept for 2 years. Customers' personal data 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 necessary), uses the customer's Personal Data to provide them 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 mail, 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 may object or withdraw their consent whenever they wish. Your data will be kept for this purpose until the data subject exercises their 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 analyse and resolve the situation underlying your request/complaint, and will be processed based on the legitimate interests of EGF.

 


Events

 

At events promoted by EGF, the processing of your personal data is necessary to ensure the management of your registration and participation in the event. Images may also be collected, based on your consent. In specific situations where it is not possible to obtain consent in advance, processing may be carried out based on EGF's legitimate interest, always safeguarding your right to withdraw consent or object to processing.
Your data will be kept for this purpose until you exercise your right to withdraw consent or object to processing.

 

Supplier Management

 

The processing of your data is necessary for the performance of the contract to be concluded between you and EGF, or for the performance of pre-contractual steps at your request. If you do not provide your data, we will not be able to fulfil our contractual obligations. Your data will be kept for this purpose for the duration of the contracts plus 10 years after termination. The data of potential customers will be kept for 2 years. The 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. The data of EGF suppliers, in particular employees, may be communicated to EGF customers in order to comply with legal or contractual obligations.

 

Recruitment

 

Following an open recruitment process or a spontaneous application, EGF will process your data for the purposes of selecting and recruiting candidates, as necessary for the performance 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 longer than 2 years if you wish your data to be considered for a suitable future vacancy.

 

Video Surveillance System

 

EGF has a video surveillance system in place at its premises for the purpose of ensuring the safety of people and property. Based on EGF's legitimate interest, we collect your image simply by virtue of your accessing our premises - however, no sound is collected. This data may be communicated to criminal police or judicial authorities upon request. The images collected are kept for a maximum period of 30 days from the moment they are captured (unless otherwise required by applicable legislation).

 

Recording of telephone calls

 

As a result of your telephone contact and within the scope of EGF's activity, we may record calls, subject to prior notification and based on your consent, for the management of the pre-contractual and contractual relationship, as well as to improve our services and to control their quality, 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.

 

How long do we keep your personal data?

The personal data collected and processed is kept, in accordance with its purpose, in compliance with the applicable legal deadlines.

In cases where no legal time limit applies to the retention and storage of personal data, such data will only be stored and retained for the appropriate period and to the extent necessary, taking into account the purposes for which it was collected, unless, at any time, the data subject, within the legal limits, exercises their rights of opposition or erasure, or withdraws their consent.

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

For marketing and contact purposes, your personal data will be retained from the moment your consent is obtained and if, within this period, you have not withdrawn your consent.

 

What are the rights of personal data subjects?

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 it. In this case, EGF reserves the right to charge a reasonable fee, taking into account administrative costs;
- Right of Rectification: to obtain the rectification of inaccurate personal data concerning you and to request that your incomplete personal data be completed;
- Right to Erasure: to obtain the erasure of your personal data, except in cases where there are grounds for validating its retention;
- Right to Restriction of Processing: to obtain restriction of the processing of your personal data when it concerns certain categories of data or processing purposes;
- Right to Data Portability: to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, as well as to request the transfer 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, for example, in the case of processing personal data for direct marketing purposes;

- Right Not to be Subject to Automated Individual Decisions, including Profiling: not to be subject to any decision made solely on the basis of automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

In order to exercise your rights, you should contact us using the contact details mentioned in the section below, ‘Contact Details of the Data Controller’.

You are also guaranteed the right to withdraw your consent whenever you have given it, using the means indicated above. However, the withdrawal of consent does not invalidate the processing carried out up to the date of withdrawal.

The data subject also has the right to lodge a complaint with the CNPD, or another competent supervisory authority, as well as to seek any other judicial remedy, if they consider that their personal data is not being processed lawfully by EGF, in accordance with the legislation in force and this notice.

 

Contact details of the Data Controller

EGF is not required to appoint a Data Protection Officer (DPO) under current legislation. However, in order to maintain contact with data subjects, you can use the following contact details to clarify any questions you may have regarding the processing of your personal data and the exercise of your rights: privacy@egf.pt

 

What security measures are in place?

EGF is committed to implementing appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorised access. An appropriate level of security is considered to be in place in relation to the risks presented by the processing, given the nature of the data to be protected.

To this end, 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 unauthorised access, accidental loss and/or destruction of your personal data, committing itself to respect and comply with legislation on 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 activities, 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 of the implementation of appropriate technical and organisational measures, so that the processing meets the requirements of the GDPR and other applicable legislation, as well as ensuring the protection of the rights of personal data subjects.

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 subject, to respond to requests from public authorities, in the event that the vital interests of the personal data subject or a third party are at stake, for the protection of EGF's rights and property, or when you have given us your prior consent.

 

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

The activity conducted by EGF may involve the transfer of your personal data to third countries – located outside the European Union or not belonging to the European Economic Area – even if this occurs occasionally and always in relation to other services used by EGF.

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

One such situation arises in the context of EGF's presence on social media, where it has limited influence over the data processing carried out by the operators of these networks (e.g. member management and general information management). In situations where we have no influence, we try to ensure, as far as possible, that social media operators 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 operators and we do not have clear knowledge of the data being processed on certain occasions.

Social network operators 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 they are registered users of the social network). Furthermore, operators are fully responsible for all matters relating to user profile data to which EGF has no access.

 

 

For more information on data processing carried out by social media operators, please refer to their respective Privacy Policies:

- Facebook: https://www.facebook.com/privacy/policy/
- Instagram: https://privacycenter.instagram.com/policy
- YouTube: https://policies.google.com/privacy
- LinkedIn: https://www.linkedin.com/legal/privacy-policy

 


How do we use cookies?

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

 


Changes to the Privacy Notice

All updates to the Privacy Notice will be communicated via 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 change to the Privacy Notice that has been communicated in this manner, it will be assumed that the user has read and accepted its terms.