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.
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.
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.
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.
5.1. Collection of Personal data
Personal data can be collected directly through the following ways:
The personal data can be also collected indirectly by the following method:
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:
Human Resources Management
Capturing surveillance images or video.
Internal and External Communication
Registration of customer contact in ERP.
Registration and archiving of commercial proposals.
Information System Management
E-mail accounts and related services systems management.
Preparation of machines for delivery to customers.
Retention of customer data for the previous purpose.
Query partners´ contacts.
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:
Portuguese legal authorities
Portuguese control authority for the protection of personal data
Accounting Services Provider
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:
The current legal requirements are applicable.
Data related to applications for employment
Data related to human resources
Data related to occupational health
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
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 firstname.lastname@example.org
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.
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.
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.
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.