Privacy Management Policy

1.    Objective

The objective of this policy is to present the commitments of WINPROVIT regarding personal data privacy management of data subjects with whom it interacts, as well as for the compliance 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

Having regard to the inventory of personal data of WINPROVIT, the management of all personal data considered private and/or sensitive is made in accordance with the requirements of the abovementioned Regulation in order to ensure the fulfilment of the rights of the respective data subjects.

3.    Personal Data Privacy

Access to Personal and / or sensitive data placed in the custody of WINPROVIT is made by employees formally authorized to perform such tasks, and only using such data for activities that are previously authorized by their holders through prior, informed and free consent.

This means that, within the framework of our commitment to guarantee the privacy of personal data, we will also ensure their confidentiality.

4.    Personal Data Controller

It is established through this policy that the responsible for the collection and processing of personal data, or Data Controller, is WINPROVIT - Soluções Inteligentes, SA, with permanent representation in Portugal, at Rua César das Neves, no. 163, in Porto, corporate entity number 507 478 045.

5.    Collection, processing, transfer and storage of personal data

5.1.   Personal Data Collection

Personal data may be collected directly through the following forms:

  • Form filling in Winprovit website;
  • Response to job postings with Curriculum Vitae sharing;
  • Filling in paper forms;
  • Capturing Images and Videos;
  • E-mail or telephone.

Personal data may be collected indirectly through the following forms:

  • Import of Curriculum Vitae content into the internal candidate management platform.

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

WINPROVIT assumes that in no case will a manual or computerized form have pre-filled options. The data subject makes all selections.

The collection of personal data will always be minimized for the strictly necessary activities to pursue the legitimate business interest of the company.

The collection of sensitive personal data will only be carried out for the cases strictly necessary and justifiable by the current legislation, namely for the case of medicine at work.


5.2.   Personal Data Processing

WINPROVIT will use the personal data authorized by the respective owners for the strict purpose of sustaining its commercial activities and the legal obligations arising therefrom.

Such activities include:

Justification Processing Purposes Substantiation

Job applicants management

Curricular analysis and selection for interview.

Operational management of the Professionals business area

Export CV data to internal candidate management platform.

Contact with the candidate in the various phases of the process.

Communication of personal data to the customer in case of selection.

Data storage for upcoming opportunities.

Contact the candidate for new opportunities and for updating data.

Human resources management


Administrative management of human resources

Operational management of the organization support area

Processing of wages.

Physical security

Access control.

Capture of video surveillance images.

Control of the physical security of buildings

Internal and external communication

Publication of news, testimonies, images and videos on the company's website, in the internal newsletter and in social networks.

Promotion of the company and the events in which it participates

Commercial management

Registration of customer contact in ERP.

Registration and archiving of commercial proposals.

Customer relationship management

Financial management

Billing and collections.

Sharing of information with the external accounting service.

Operational management of the support area

Purchasing Management

Registration of suppliers in ERP.

Query supplier contacts and activity log.

Operational management of the support area

Technical support

ERP registration of technical assistance.

Marking the beginning and end of the technician’s route to record the distance travelled.

Provision of customer service

Management of the Information Systems area



E-mail accounts systems management and related services.

Provision of customer service

Preparation of machines for delivery to customers.

Retention of customer data for the previous purpose.

Provision of customer service

Query partner contacts.

Managing the relationship with partners


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

The sharing of personal data will be made for the purposes strictly necessary and authorized by the holders of personal data, as a support for the development of WINPROVIT activities, including:

Sharing destination Shared personal data Substantiation

Portuguese legal authorities

Name, address, NIF, NISS, date of admission, citizen's card number

Enrolment in social security. Communication with the tax authority, or other legal entities.

Portuguese control authority for the protection of personal data

Name, address, e-mail, telephone, citizen's card number

Communication of complaints or privacy breaches.

Communication with the DPO

Medicine at work

Name, date of birth, date of admission, social security number

Creation of the medical aptitude sheet.


Name, NIF, address, date of birth, date of admission.

Enrolment in employee accident insurance.

Bank entities

Name, IBAN

Wage processing and payment of expenses

Accounting services provider

Name, NIF, address, citizen's card number

Compliance with tax obligations and management of company accounting.


Name, job history

Presentation of candidates for the outsourcing service.


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

These data sharing will never be made outside the European area.


5.4.   Storage of personal data

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

Storage Objective Storage period Substantiation

Legal deadlines

10 years

The current legal requirements are applicable.

Data related to applications for employment

5 years

Data related to human resources

1 year

Data related to medicine at work

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 be able to exercise their rights, as foreseen and described by the regulation.

Any data subject, in order to exercise their rights and / or submit any question related to this topic, must submit their request in writing using the email address

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

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

7.    Roles 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.


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