Data Protection Policy

Introduction
For Aqua Towel the privacy and protection of your Personal Data is very relevant. Aqua Towel expresses its commitment to comply with the legislation in force at all times and to treat your personal data in accordance with this privacy policy.
Aqua Towel reserves the right to modify the Privacy Policy in accordance with new legal and / or regulatory requirements, for security reasons or for the purpose of adapting the said Policy to the instructions of the control authorities regarding data protection.
 
Who is responsible for the treatment of your data?
The responsible for processing Personal Data is Aqua Towel, whose head office is in the Rua do Paque Industrial de S. João de Ponte, Fase 1, Lote D10, 4805-298 Ponte, Guimarães, holder of the identification number of corporate entity 513203885. The data subject may contact Aqua Towel through the following means:
- Tel .: +351 253 479 260
- E-mail address: protecaodedados@aquatowel.pt
 
What data do we collect, how do we use them, on what grounds and where do we store them?
1. Aqua Towel collects various types of Personal Data for different purposes, collecting in particular the following:
Full name / Date of birth / E-mail address / Telephone number / Address / Citizen's card number / NIF / NIB / NIB / Biometric data of workers.
 
The purposes of the treatment of Personal Data are as follows:
  1. Execution of the Work Contract: Aqua Towel uses your personal data in order to draw up the employment contract and to communicate the employment relationship, namely, to the Social Security, the Tax Authority, the company that Aqua Towel has selected to proceed hygiene and safety at work; to the financial institution selected to proceed with the transfer of salaries and other remunerations; to the insurer selected for compulsory and / or optional insurance (occupational accidents and illness).
  2. Communication: Aqua Towel may use your address, e-mail address or telephone number to communicate with you, in particular, for the dissemination of a Newsletter about the activities developed by Aqua Towel, as well as for the dissemination of products sold by Aqua Towel and promotions or discounts associated with them.
  3. Access Control and Attendance: Aqua Towel collects and use the biometric data of its employees for the purpose of access control and assiduity.
  4. Video Surveillance: some spaces of Aqua Towel, in particular the charges and discharges entrance, have a Video Surveillance system properly signalized. The capture of images aims at the safety of people and goods.
  5. Recruitment: Aqua Towel, during the recruitment and selection 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 any personal data that you spontaneously decide to transmit, including without limitation, the name, age, sex, photograph, contact details (e-mail address and phone number), education information, employment history, immigration status (if you need a work permit).
 
You may cancel the receipt of the Newsletter as well as any other communications identified above at any time using the above email address.
With the exception of treatment for the purpose of providing products and services (processing necessary for the execution of a contract), biometric data collection, image capture through the video surveillance system and treatment in recruitment processes, in which the treatment is based on the legitimate interest of Aqua Towel, the legal basis of the data processing is the consent of the holders.
Personal Data collected when a work contract or order processing is carried out by Aqua Towel are necessary for the execution of the respective contract, so that if the data subject in any way opposes their treatment, Aqua Towel will not be able to fulfil the contract.
 
Who are the recipients of your data?
Aqua Towel may subcontract other companies to provide certain services, such as fiscal, accounting and legal accessory services, insurance, training, informatics and communication, or website maintenance. In these cases, these third-party companies may need to access certain information and data of the data owners. Aqua Towel guarantees that, in such cases, these third parties will have limited access to the information of the data holders, restricted only to those data necessary for the execution of the contracted tasks. It further guarantees that a contract has been awarded between the parties in which the protection of Personal Data is regulated and where these third parties undertake not to disclose Personal Data in any way or to use them for different purposes than the provision of services contractors.
Likewise, Aqua Towel may communicate yours Personal Data, when it is determined by the law, in the context of a judicial process or in context of investigations of suspicious activity.
 
Where do we store your data?
Aqua Towel stores on servers that are in a secure environment, protected from unauthorized access, use or disclosure, the Personal Data that the holder of the data provides.
Aqua Towel adopts the 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.
Aqua Towel states that will only process your data for the purposes for which it was collected, under the terms provided in this Privacy Policy.
Aqua Towel frequently reviews its data collection, storage and processing policies to ensure that only collect, stores and processes information that is essential to the delivery or improvement of services.
Aqua Towel takes the appropriate procedures to ensure that your information is accurate, complete and current, but it depends to the data subject to update or correct your personal information when necessary.
Aqua Towel doesn’t make automated decisions.
What are your rights when you give us your data?
In accordance with the applicable legislation, Aqua Towel undertakes to respect the confidentiality of your personal information and guarantee the exercise of your rights, namely:
  1. Right to be informed: our workers / customers / suppliers have the right to obtain clear, transparent and understandable information about how Aqua Towel uses their Personal Data.
  2. Right of access: in addition to the right to be informed, you can access your personal data that we treat and store. In these cases, Aqua Towel will provide you a copy of the personal data that is being processed. In addition, when requested through electronic means, the information will be provided in an electronic format of common use.
  3. Right of rectification: you have the right to rectify your personal data if they are incorrect, outdated or if you wish to complete them. To do so, you can contact us at protecaodedados@aquatowel.pt.
  4. Right of erasure / right to be forgotten: you may request us to delete your data, however, please note that this is not an absolute right, as we may have legal grounds or other legitimate interests for the retention of your personal data.
  5. Opposition right, including to direct marketing: You can eliminate the Aqua Towel Newsletter subscription or choose to be removed from our direct disclosure communications at any time. For this purpose, you must communicate this intention to us at protecaodedados@aquatowel.pt.
  6. Right to, at any time, withdraw your consent for data processing: You may withdraw your consent to the processing data when such processing is based on your consent. Withdrawal of consent doesn’t affect the legality of consent-based treatment prior to withdrawal.
  7. Right to file a complaint at the CNPD: If you consider that the processing of your personal data by Aqua Towel violates the applicable data protection legislation, you may file a complaint with the National Data Protection Commission ("CNPD"). Don’t hesitate to contact us before filing any complaint with the CNPD.
  8. Right to data portability: you have the right to move, copy or transfer the data from our database to another.
  9. Right to limitation of treatment: You have the right to request the restriction of the processing of your data in the following situations: if you dispute the accuracy of the data, if the treatment is unlawful and don’t want to erase your data, but only limit them, if the data are no longer required by Aqua Towel, but necessary to the employee / customer / supplier or if you have exercised the right of objection referred above, during the period of time in which Aqua Towel analyses whether yours legitimate interests in treatment prevail or not over that right.
To request the exercise of any of the rights listed above, in addition to the forms specifically referred in the respective paragraphs, you may send a communication addressed to the abovementioned address or by sending an email to the email address also mentioned above, which you may also use if you have any questions regarding this Privacy Policy.
 
How long do we store your data?
We only store Personal Data for the time necessary 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 time 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.
  1. When entering into a work contract, we will keep your personal data during the term of our contractual relationship, as well as for a period of ten years after its termination, without prejudice to the fulfilment of legal obligations of the controller;
  2. When you have consented to the sending of our newsletter, we will keep your personal data until you cancel the subscription or ask us to delete it;
  3. Regarding to the collection of biometric data of the employees we will keep your personal data during the term of the contractual relationship;
  4. Relatively to the images captured by the video surveillance system, during a maximum period of 90 days;
  5. In the case of data collected during the recruitment procedure, for a maximum period of one year from the close of the procedure;
  6. The period of time provided in the applicable legislation; or
  7. 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 rendered.
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 judicial recourse.
Ended the storage periods mentioned above, the Personal Data will be eliminated and / or deleted in a secure way.
 
Warranties
The data holder guarantees that the Personal Data communicated to Aqua Towel are certain and accurate and undertakes to notify any change or modification to them and assumes sole responsibility for the losses and damages caused by the erroneous, inexact or incomplete communication of the data.
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