EGF - Empresa Geral do Fomento, S.A. (hereinafter EGF) and its 11 companies are committed to ensuring the security of personal data.
As a result, EGF has drawn up this Privacy Notice, in order to make known the terms by which it collects and processes personal data, in accordance with Regulation (EU) 2016/769 of the European Parliament and of the Council, of April 27, 2016, (hereinafter GDPR), Law no. 58/2019, of August 8, which ensures the implementation, in the national legal order, of Regulation (EU) 2016/679, of April 27.
The processing of personal data described in this Notice concerns the personal data of citizens who interact with EGF (all those who interact with us in any way).
This document describes the conditions under which EGF processes your personal data, hereinafter referred to as “Data Subjects”. EGF respects Data Subjects' right to privacy and declares that it complies with the applicable legal and regulatory provisions on privacy and personal data protection, adopting the appropriate measures to guarantee the privacy and confidentiality of the personal data transmitted by Data Subjects.
In order to clarify the processing of data, as well as its purpose and the rights of data subjects, it is advisable to periodically read this Privacy Notice.
Who is responsible for processing your personal data?
EGF is the entity responsible for data processing, under the terms of the GDPR, and can be contacted via email at egf@egf.pt or by telephone at +351 214 158 200 (national landline) or by going to our offices at Rua Mário Dionísio, nº2, 2799-557, Linda-a-Velha.
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 activity and in fulfillment of the duties assigned to it by law.
EGF collects and processes personal data that is voluntarily provided by the data subject through the various contacts that are established, both in person and via the website, by telephone, by post or by email.
Any information provided by the data subject will only be used for the purpose described and in strict compliance with data protection legislation.
What purposes precede the collection of your personal data and what are the grounds for processing it?
EGF ensures that the processing of your personal data is carried out within the scope of the purpose for which it was collected, or for purposes compatible with the initial purpose for which it was collected. In addition, we process your personal data for legally prescribed purposes.
Customer support services
EGF uses customer Personal Data for customer support purposes, including to answer customer questions. This usually requires the use of certain personal contact information and information about the reason for the customer's question (e.g.: requests for information, service requests, complaints about a product or service, general questions, suggestions, compliments, environmental communication programs, etc.). In these situations, the processing of your data is necessary for the performance of the contract to be concluded between you and EGF, or for carrying out pre-contractual procedures at your request. If you do not provide your data, we will not be able to provide you with the services requested or contracted. Your data will be kept for this purpose for the duration of the contract(s), plus 10 years after termination. Potential clients' data will be kept for 2 years. The personal data of customers may be processed by EGF for the purpose of litigation management. The legal basis is the existence of a legitimate interest on the part of EGF and the data will be kept for the period necessary to exercise the respective rights.
Marketing Communications
EGF, with the customer's consent (where necessary), uses the customer's Personal Data to provide the customer with information about new goods, products or services (e.g.: marketing communications or campaigns and promotions). This may be done via e-mail, advertisements, SMS, telephone calls and postal correspondence, to the extent permitted by applicable law. Some of EGF's campaigns and promotions are conducted on third party websites and/or social networks. This use of your Personal Data is voluntary, which means that you can object or withdraw your consent whenever you wish. Your data will be kept for this purpose until you exercise your right to withdraw your consent.
Management of complaints and contacts received
In your relationship with EGF, you may send us suggestions or complaints regarding the services provided by EGF. In these situations, your data will be collected in order to analyze and resolve the situation underlying your request/complaint, and will be processed on the basis of EGF's legitimate interests.
Events
In events promoted by EGF, the processing of your personal data is necessary to ensure the management of your registration and participation in the event, and images may also be collected, based on your consent. This use of your personal data is voluntary, which means that you can object or withdraw your consent whenever you wish. Your data will be kept for this purpose until you exercise your right to withdraw your consent.
Supplier management
The processing of your data is necessary for the performance of the contract to be entered into between you and EGF, or for carrying out pre-contractual steps at your request. If you do not provide your data, we will not be able to fulfill our contractual obligations. Your data will be kept for this purpose for the duration of the contracts plus 10 years after termination. Potential customers' data will be kept for 2 years. The personal data of suppliers may be processed by EGF for the purpose of litigation management. The legal basis is the existence of a legitimate interest on the part of EGF and the data will be kept for the period necessary to exercise the respective rights. The data of EGF's suppliers, in particular employees, may be communicated to EGF's customers in order to comply with legal or contractual obligations.
Recruitment
EGF, following an open recruitment vacancy or a spontaneous application, will process your data for the purposes of selecting and recruiting candidates, as necessary for carrying out pre-contractual procedures. The personal data collected will be kept for a maximum of 2 years in cases where your application has not been considered for any vacancy. Based on your consent, we will keep your data for a period of more than 2 years if you want your data to be considered for a future vacancy suitable to your profile.
Video surveillance system
EGF has a video surveillance system on its premises to ensure the safety of people and property. It is in EGF's legitimate interest that we collect your image simply by accessing our premises - however, no sound is collected. This data may be communicated to the criminal police or judicial authorities on request. The images collected will be kept for a maximum of 30 days from the moment they were taken (unless other legislation applies).
Recording of telephone calls
As a result of your telephone contact and within the scope of EGF's activity, we may record your calls, subject to the provision of prior information and based on your consent, for the management of the pre-contractual and contractual relationship, as well as for the improvement of our services provided and also for the control of their quality, based on EGF's Legitimate Interest. These call recordings will be kept for the period indicated in the CNPD resolutions that regulate this processing activity, namely Resolution no. 1039/2017.
How long do we keep your personal data?
The personal data collected and processed is stored, taking into account its purpose, in compliance with the applicable legal deadlines.
In cases where no legal time limit applies to the retention and storage of personal data, such data will only be stored and retained for the appropriate period and to the extent necessary, taking into account the purposes for which they were collected, unless at any time the holder of the personal data, within the legal limits, exercises their rights of opposition or erasure, or withdraws their consent.
Once the maximum retention period has been reached, the personal data will be irreversibly anonymized (the anonymized data may be retained) or securely destroyed.
For marketing and contact purposes, your personal data will be stored from the moment your consent is obtained and if you have not withdrawn your consent within this period.
What are the rights of personal data subjects?
- Under the terms of the applicable legislation, you may exercise the following rights:
- Right of Access: to obtain confirmation as to whether or not your personal data is being processed and, if so, to access it. In this case, EGF reserves the right to demand payment of a reasonable fee, taking into account administrative costs;
Right to Rectification: obtain the rectification of inaccurate personal data concerning you and request that incomplete personal data be completed;
Right to Erasure: obtain the erasure of your personal data, except in cases where there are grounds for retaining it;
Right to Restriction of Processing: obtain restriction of the processing of your personal data when it relates to certain categories of data or processing purposes;
Right to Portability: to receive the personal data you have provided in a structured, commonly used and machine-readable format, as well as to request the transmission of your personal data to another controller;
Right to Object: to object, at any time, to certain processing of your personal data, such as the processing of personal data for direct marketing purposes;- Right not to be subject to automated individual decisions, including profiling: not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces effects in your legal sphere or significantly affects you in a similar way.
In order for you to exercise your rights, you must contact us through the contacts mentioned in the chapter below, 'Controller's Contacts'.
In addition, you are guaranteed the right to withdraw your consent whenever you have given it, through the means indicated above. The withdrawal of consent does not, however, invalidate the processing carried out up to the date of withdrawal.
The holder of the personal data also has the right to file a complaint with the CNPD, or other competent supervisory authority, as well as to resort to any other judicial remedy, if he/she considers that his/her personal data is not lawfully processed by EGF, under the terms of current legislation and this notice.
Controller Contacts
EGF is not obliged to appoint a Data Protection Officer (DPO) in accordance with the legislation in force, however, and in order to maintain a form of contact with the data subjects, it may use the following contacts to clarify all the questions it considers relevant related to the processing of your personal data and the exercise of your rights: privacy@egf.pt
What security measures are adopted?
EGF is committed to implementing appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access. An adequate level of security is considered to be applied in relation to the risks presented by the processing, given the nature of the data to be protected.
To this end, EGF carries out all its activities using systems that aim to ensure the security of your personal data, through the creation of procedures that prevent unauthorized access, accidental loss and/or destruction of your personal data, committing itself to respecting and complying with the legislation on the protection of personal data.
Why do we share your personal data?
EGF may share your personal data with third parties who will have access to it. Such third parties include public authorities, partners, service providers, among others. As part of its activity, EGF may use subcontractors, who will access and process your personal data in accordance with our instructions.
To this end, we ensure that such subcontractors offer sufficient guarantees for the implementation of appropriate technical and organizational measures, so that the processing meets the requirements of the GDPR and other applicable legislation, as well as ensuring the protection of the rights of the holders of personal data.
Thus, EGF may also share your personal data when such sharing is necessary or appropriate in the light of applicable legislation, for the fulfillment of legal obligations to which it is bound, to respond to requests from public authorities, in the event that the vital interests of the holder of the personal data or a third party are at stake, for the protection of the rights and property of EGF, or when you have given us your prior consent.
Under what circumstances do we transfer your personal data to third countries?
The activity conducted by EGF may involve the transfer of your personal data to third countries – located outside the European Union or that do not belong to the European Economic Area – even if this occurs occasionally and always in the relationship established with other services used by EGF.
In such situations, all necessary and appropriate measures will be adopted to ensure the protection of your personal data.
One of these situations occurs in the context of EGF's presence on social networks, having a limited influence on the data processing carried out by the operators of these networks (for example, membership management and the management of general information). In situations where we have no influence, we try to ensure, as far as possible, that social media operators act in accordance with the privacy and data protection requirements required by the GDPR. However, in many cases, we have no influence on this data processing carried out by the operators and we have no clear knowledge of the data that is being processed on certain occasions.
The operators of the social networks manage the entire IT infrastructure of the service, applying their own privacy and data protection rules and, in addition, maintain their own relationships with users (insofar as they are registered users of the social network). In addition, the operators are fully responsible for all issues related to user profile data to which EGF does not have access.
For more information on the data processing carried out by the social media operator, please refer to their respective Privacy Policies:
Facebook: https://www.facebook.com/privacy/policy
Instagram: https://privacycenter.instagram.com/policy
YouTube: https://policies.google.com/privacy
LinkedIn: https://www.linkedin.com/legal/privacy-policy
How do we use cookies?
For more information about cookies and how EGF uses them on its website, please see our Cookie Notice.
Changes to the Privacy Notice
All updates to the 'Privacy Notice' will be communicated by means of a notice on the home page of the website: https://www.egf.pt/pt/, so that such changes can be immediately noticed. By continuing to use this website following a modification to the 'Privacy Notice' that has been communicated hereby, it will be presumed that the user has acknowledged and accepts its terms.