Privacy Policy

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

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

The processing of personal data described in this Notice relates to the personal data of individuals who have dealings with EGF (all those who, in any way, interact with us).

This document sets out the conditions under which EGF processes your personal data; you are hereinafter referred to as the “Data Subjects”. EGF respects the Data Subjects’ right to privacy and undertakes to comply with the applicable legal and regulatory provisions regarding privacy and the protection of personal data, taking appropriate measures to ensure the privacy and confidentiality of the personal data provided by the Data Subjects.

In order to clarify how data is processed, as well as the purpose of such processing and the rights of data subjects, you are advised to read this Privacy Notice from time to time.

 

Who is responsible for processing your personal data?

Amarsul and Valorsul are the entities responsible for processing your personal data under the UK GDPR/GDPR and can be contacted through:

Amarsul: email address geral@amarsul.pt, telephone +351 212 139 600 (call to the Portuguese national landline network), or by visiting our premises at Estrada Luís de Camões, Apartado 117, 2861-909 Moita, Portugal.

Valorsul: email address valorsul@valorsul.pt, telephone +351 219 535 900 (call to the Portuguese national landline network), or by visiting our premises at Plataforma Ribeirinha da CP, Estação de Mercadorias da Bobadela, 2696-801 São João da Talha, Portugal.

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 activities and in fulfilment of the responsibilities legally assigned to it.

EGF collects and processes personal data voluntarily provided by data subjects through the various channels of communication established with us, whether in person, via our website, by telephone, post or email.

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

 

What are the purposes for collecting your personal data and what is the legal basis for processing it?

EGF ensures that your personal data is processed solely for the purposes for which it was collected, or for purposes compatible with the original purpose of collection. In addition, we process your personal data for purposes required by law.

Customer Support Services

EGF uses customers’ Personal Data for customer support purposes, including responding to enquiries. This normally requires the use of certain contact details and information regarding the reason for the enquiry (e.g. information requests, service requests, complaints regarding a product or service, general enquiries, suggestions, compliments, environmental communication programmes, etc.).

In these situations, processing your data is necessary for the performance of a contract to be entered into between you and EGF, or for taking steps at your request prior to entering into a contract. If you do not provide your data, we may be unable to deliver the requested or contracted services.

Your data will be retained for this purpose throughout the duration of the contract(s), plus 10 years following termination. Data relating to prospective customers will be retained for 2 years.

Customers’ personal data may also be processed by EGF for the purpose of handling disputes and litigation. The legal basis for such processing is EGF’s legitimate interest, and the data will be retained for the period necessary to exercise the relevant rights.

Marketing Communications

With the customer’s consent (where required), EGF uses customers’ Personal Data to provide information about new goods, products or services (e.g. marketing communications, campaigns and promotions).

This may be carried out via email, advertisements, SMS, telephone calls and postal correspondence, to the extent permitted by applicable legislation. Some EGF campaigns and promotions are conducted through third-party websites and/or social media platforms.

The use of customers’ Personal Data for these purposes is voluntary, meaning that you may object to, or withdraw your consent for, such processing at any time.

Your data will be retained for this purpose until you exercise your right to withdraw consent.

Management of Complaints and Enquiries

In your relationship with EGF, you may submit suggestions or complaints relating to the services provided by EGF. In these situations, your data will be collected in order to analyse and resolve the matter underlying your request or complaint and will be processed on the basis of EGF’s legitimate interests.

Events

At events organised by EGF, the processing of your personal data is necessary to manage 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 prior consent, processing may be carried out on the basis of EGF’s legitimate interest, while always safeguarding your right to withdraw consent or object to processing.

Your data will be retained 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 a contract to be entered into between you and EGF, or for taking steps at your request prior to entering into a contract. If you do not provide your data, we may be unable to fulfil our contractual obligations.

Your data will be retained for this purpose for the duration of the contracts, plus 10 years following termination. Data relating to prospective suppliers will be retained for 2 years.

Suppliers’ personal data may also be processed by EGF for dispute and litigation management purposes. The legal basis is EGF’s legitimate interest, and the data will be retained for the period necessary to exercise the relevant rights.

Data relating to EGF suppliers, particularly employees, may be disclosed to EGF customers in order to comply with legal or contractual obligations.

Recruitment

Following an open vacancy or a speculative application, EGF will process your data for candidate selection and recruitment purposes, as such processing is necessary in order to take steps prior to entering into a contract.

The personal data collected will be retained for up to 2 years where your application has not been considered for any vacancy.

With your consent, we may retain your data for a period exceeding 2 years should you wish your details to be considered for future opportunities that match your profile.

CCTV Surveillance System

EGF operates CCTV systems at its facilities to ensure the security of people and property. On the basis of EGF’s legitimate interest, your image may be collected simply by accessing our premises; however, no audio is recorded.

This data may be disclosed to criminal investigation authorities or judicial authorities where requested. Recorded images are retained for a maximum period of 30 days from the date of capture (unless otherwise required by applicable legislation).

Recording of Telephone Calls

As part of your telephone contact with EGF and within the scope of our activities, calls may be recorded, subject to prior notice and your consent, for the management of pre-contractual and contractual relationships.

Recordings may also be used to improve the services we provide and for quality control purposes, on the basis of EGF’s legitimate interest.

Call recordings will be retained for the period stipulated in the decisions of the Portuguese Data Protection Authority (CNPD), namely Decision No. 1039/2017, which regulates this processing activity.

For how long do we retain your personal data?

The personal data collected and processed is retained according to its purpose and in compliance with the applicable legal retention periods.

Where no legal retention period applies, personal data will only be stored and retained for an appropriate period and only insofar as necessary to fulfil the purposes for which it was collected, unless the data subject exercises their rights of objection or erasure, or withdraws their consent, within the limits established by law.

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

For marketing and contact purposes, your personal data will be retained from the date consent is provided and provided that such consent has not been withdrawn during that period.

What are the rights of data subjects?

Under applicable legislation, you may exercise the following rights:

Right of Access: obtain confirmation as to whether your personal data is being processed and, where that is the case, access that data. EGF reserves the right to charge a reasonable fee reflecting administrative costs;
Right to Rectification: obtain the correction of inaccurate personal data concerning you and request the completion of incomplete personal data;
Right to Erasure: obtain the deletion of your personal data, except where there are legitimate grounds for its retention;
Right to Restriction of Processing: obtain the restriction of processing of your personal data where it concerns specific categories of data or purposes of processing;
Right to Data Portability: receive the personal data you have provided to us in a structured, commonly used and machine-readable format and request its transmission to another controller;
Right to Object: object at any time to certain processing activities, such as processing for direct marketing purposes;
Right Not to Be Subject to Automated Individual Decision-Making, Including Profiling: not be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

To exercise your rights, please contact us using the details provided in the section below, “Contact Details of the Data Controller”.

You are also entitled to withdraw your consent at any time using the contact methods indicated above. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.

You also have the right to lodge a complaint with the CNPD or another competent supervisory authority, and to pursue any judicial remedy available, if you consider that your personal data is not being processed lawfully by EGF in accordance with applicable legislation and this Notice.

Contact Details of the Data Controller

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

What security measures are adopted?

EGF is committed to implementing appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access.

An appropriate level of security is maintained in relation to the risks presented by the processing, taking into account the nature of the data being protected.

To this end, EGF carries out all of its activities using systems designed to ensure the security of your personal data through procedures that prevent unauthorised access, accidental loss and/or destruction of personal data, while remaining fully committed to compliance with data protection legislation.

Why do we share your personal data?

EGF may share your personal data with third parties that have access to such information. These third parties may include public authorities, partners, service providers and others.

As part of its activities, EGF may engage processors who will access and process your personal data in accordance with our instructions.

We ensure that such processors provide sufficient guarantees that they will implement appropriate technical and organisational measures so that processing complies with the GDPR and other applicable legislation, while safeguarding the rights of data subjects.

EGF may also share your personal data when such disclosure is necessary or appropriate under applicable law, for compliance with legal obligations, in response to requests from public authorities, where the vital interests of the data subject or another person are at stake, for the protection of EGF’s rights and property, or where you have provided prior consent.

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

The activities carried out by EGF may involve the transfer of your personal data to third countries outside the European Union or the European Economic Area, although such transfers occur only occasionally and always in connection with services used by EGF.

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

One such situation arises from EGF’s presence on social media platforms, where EGF has limited influence over the data processing carried out by the operators of those platforms (for example, member management and general information management).

Where we have no influence over such processing, we seek, to the extent possible, to ensure that social media operators comply with the privacy and data protection requirements established by the GDPR. However, in many cases, we have no influence over the data processing carried out by these operators and have no clear knowledge of the specific data processed on particular occasions.

Social media operators manage the entire IT infrastructure of the service, applying their own privacy and data protection policies and maintaining their own relationship with users (to the extent that such users are registered users of the platform).

Furthermore, the operators are solely responsible for all matters relating to users’ profile data to which EGF does not have access.

For further information regarding the processing carried out by social media operators, 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 refer to our Cookie Notice.

Changes to the Privacy Notice

Any updates to this Privacy Notice will be communicated through a notice displayed on the homepage of the website: https://www.egf.pt/pt/, so that such changes may be immediately brought to your attention.

By continuing to use this website following a modification to this Privacy Notice that has been communicated in this manner, users will be deemed to have been informed of, and to have accepted, its terms.

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