Privacy Management Policy

1. Objective

This policy presents WINPROVIT’s commitments regarding personal data privacy management of who interacts with it and demonstrates its accordance and conformity with the General Data Protection Regulation, identified as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

2. Scope

Regarding WINPROVIT’s personal data inventory, all data considered as private and/or sensitive are managed in accordance with the requirements of the above-cited regulation in order to ensure the fulfilment of the data subjects’ rights.

3. Personal Data Privacy

Personal and/or sensitive data placed under WINPROVIT’s control is only accessible by employees who are formally authorized to do such activities, and only used in accordance with GDPR’s principles relating to processing of personal data.

This means that within the framework of our commitment to guarantee the privacy of the personal data, will also be assured the respective confidentiality.

4. Personal Data Controller

It has been established through this policy that WINPROVIT – Soluções Inteligentes, S.A, with permanent representation in Portugal in the following address: n.º 163, Rua César das Neves, Porto and with corporate entity number 507 478 045, is responsible for collecting and treating the personal data.

5. Collecting, Processing, Transferring and storing Personal data

5.1. Collection of Personal data

Personal data can be collected directly through the following ways:

Form filling on WINPROVIT’s website
Responding to job offers by sharing the Curriculum Vitae
Filling in paper forms
Capturing of images and videos;
E-mail or Telephone.

The personal data can be also collected indirectly by the following method:

Importing the contents of the Curriculum Vitae to the internal portal for candidates’ management;
Sharing by partner entities, of personal data of candidates, in response to job opportunities managed by Winprovit.

It will not be executed any other indirect method of personal data collection.

Winprovit assures that, in no circumstances any manual or electronic form will have prefilled options and that all selected changes are made by the data subject.
The personal data collection will be always limited to the activities of the company which are strictly essential for the legitimate commercial interest.

The collection of sensitive personal data will only be performed for the strictly essential cases and justified by the applicable law, namely for the case of occupational health.

5.2. Processing of personal data

The personal data authorized by their holders will be utilized by WINPROVIT for the single purpose of maintaining its commercial activities and legal obligations.

Those activities include:

Reason	Processing Purposes	Legal Basis
Job Applicant Management	Curricular Analysis and Selection for Interview	Performance of a contract or pre-contractual actions and legitimate interest of Winprovit and its clients in hiring human resources.
	Exporting CV´s data to the internal candidates management portal.
	Contact with the candidate through the various phases of the recruitment process.
	Communication of personal data to the client in the case of candidate’s selection.
	Conserving the data for upcoming opportunities.
	Contact the candidate for new opportunities and for updating data.
	Background verification checks	Consent
Human Resources Management	Human Resources administrative management process. Salary and expenses payment process	Performance of a contract Legal obligations
Human Resources Management	Creation of the employee´s card and placing it in the company’s contact and access directory.	Performance of a contract Legal obligations
Physical security	Access control. Capturing surveillance images or video.	Controlling the physical Security of the company’s buildings.
Internal and External Communication	Publication of news, testimonials, Images and videos on the website, internal newsletter and on the social networks of the company	Consent
Commercial Management	Registration of customer contact in ERP. Registration and archiving of commercial proposals.	Commercial legitimate interest
Financial Management	Invoicing and Billing. Sharing information with the external accounting service.	Performance of a contract Legal obligations
Purchasing Management	Registering Suppliers in ERP Query supplier contacts and activity log.	Performance of a contract
Technical support	Registering in the ERP of the Technical Assistance. Marking the start point and end of the technicians´ route to record the travelled distances.	Performance of a contract
Information System Management	E-mail accounts and related services systems management.	Performance of a contract
	Preparation of machines for delivery to customers. Retention of customer data for the previous purpose.	Performance of a contract
	Query partners´ contacts.	Performance of a contract

There will be no use of data for the creation and use of sales profiles or indicators of products, regions or trends.

5.3. Personal data sharing

Sharing of personal data will only be made for the strictly necessary purposes and authorized by their holders and only as a support for the development of WINPROVIT’s activities, including:

Sharing Destination	Shared Data	Substantiation
Portuguese legal authorities	Name, Address, Fiscal Number, Social Security Number, Admission Date, Citizen Card´s Number.	Registration in the Social Security. Communication with the Tax Authority and or other legal entities.
Portuguese control authority for the protection of personal data	Name, Address, Email, Telephone, Citizen Card´s Number.	Communication of any complaint or privacy breach. Communication with the DPO.
Occupational Health	Name, Birth Date, Admission Date, Social Security Number	Enrolling in this service. Creating the medical aptitude sheet.
Insurance companies	Name, Fiscal Number, Birth Date, Address, Admission Date	Registration for the work accident insurance of the employees.
Banking Entities	Name, IBAN	Salary and expenses payment process
Accounting Services Provider	Name, Fiscal Number, Citizen Card´s Number	Fulfillment of the Fiscal obligations and Company´s accounting management
Clients	Name, Professional and work record	Presenting the candidates for the outsourcing service

Any additional needs shall be the object of a supplementary request for informed consent by the respective data subjects.

Sharing of those data will never be made outside the European area.

5.4. Conservation of personal data

WINPROVIT, for each processing purpose presented, retains the personal data collected, for the maximum periods indicated below:

Storage Objective	Storage period	Sustentation
Legal deadlines	10 years	The current legal requirements are applicable.
Data related to applications for employment	5 years
Data related to human resources	2 years
Data related to occupational health	5 years
Video Surveillance	1 month
Communication publications containing personal data of employees	Until the end of the contract	Depending on the operational needs and the organization's communication strategy.
Communication publications containing personal data	3 years

6. Data subject rights

Winprovit ensures by the nomination of a Data Protection Officer, also known as DPO, that all data subjects will have conditions to exercise their rights, as foreseen and described in the regulation.

Any data subject, to pursue their rights and/or to present any question related with this theme, must write and send their request to the Data Protection Officer via dpo@winprovit.pt

This address may also be used for the case where there is the need to submit a complaint.

Following the registration of the complaint thus made, WINPROVIT ensures the execution of a communication procedure with the data subject, informing him/her in a timely manner and in accordance with the stipulated by the above-identified regulation, at each step of the treatment of his/her complaint, and strictly compliant with the deadlines and conditions defined by the regulation.

7. Functions and Responsibilities

WINPROVIT top management ensures the alignment of this policy with the company’s strategy as well as its continuous improvement.

The Data Protection Officer ensures continuous compliance with the requirements of the Regulation, that all rights of data subjects are being met and that appropriate security controls are in place for these purposes.

All WINPROVIT employees have the responsibility to comply with and enforce the commitments of this policy.

8. Revision and continuous improvement

This policy will be reviewed at least annually, or whenever there are significant changes in the personal data inventory and / or in the digital or documentary supports that ensure the rights of the data subjects.

Each of these revisions will result in a new version of this document.

9. Disclosure and Publication

This policy will be disclosed to all personal data subjects who interact with WINPROVIT and it is available whenever requested since that the information it contains is classified as publicly accessible.

It will be available for consultation through the Internet, either in our institutional Website as in the Internet tools that support our business.

10. History of the Revisions

Rev. Nº	Modified Section / Paragraph	Applied Modification (Short Description)	Author / Function	Approval / Function	Date
2	3; 5.1; 5.2	Collection of personal data; Legal basis for processing	DPO	CEO	09/03/2020
1	5.4; 9	Modification of the storage periods and methods of discloser	DPO	CEO	06/12/2019
-	-	Creation of the document	DPO	CEO	14/01/2019

Privacy Management Policy

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