© 2018 Smaare Consulting. All rights reserved

In accordance with the EU Regulation 2016/679, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data (GDPR), this policy aims to provide you with the information provided for in articles 13 and 14 of this Regulation, as well as any other considered necessary on how we collect and how we use your personal data.

Who is the controller of the processing of your data?

The controller of the processing of your personal data is Smaare Consulting - Unipessoal, Lda. She collects, uses and is responsible for certain personal information about you, with the following information:

Name: Smaare Consulting - Unipessoal, Lda

Address: Alameda do Atlântico, Edifício Panoramic, Nº 16, 14º andar, Escr. 8 - Lisboa - Portugal

Email: maria.varela@smaareconsulting

For what purposes and on what legal basis do we process your personal data?

  • For legitimate interests:

    • Respond to your enquiries, requests, suggestions, error notifications and complaints.

    • Process your job vacancy applications and CVs.

    • Improve the services we offer.

  • On the basis of your consent:

    • Promote and provide you with information about the activities we carry out, products and other aspects related to the services we offer, through emails, the web, social networks and other mechanisms.

  • For contractual relationship:

    • Manage the product orders you make through the e-shop.

    • Manage the administrative hiring procedures and fulfil the obligations arising from the contracts you have entered into with us.

  • For legal reasons:

    • Respond to your requests of public information.​

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What personal data do we collect and how is it collected?

Information you provide us through web forms
Some of the web forms through which we collect your personal data are:

  • Contact mailboxes

  • Newsletters subscription

  • Request of public information (transparency)

  • User registration, to download information and / or to use certain services

Information you provide us through email, phone, social networks and other communication channels
In these cases, the information we collect is what you provide us proactively and voluntarily, and we use it only to manage your enquiries, requests, suggestions, complaints, etc. Some of these data may reside on third-party servers (LinkedIn, Facebook, etc.).

Information we collect from your visits to our websites
For the simple fact of browsing our webs, we collect limited information from users and anonymous global statistics. We use this information to improve the access to the contents and services we offer, and to monitor its performance. We obtain this information through the cookies that are stored in your browsers and the logs that are stored in our web servers. For detailed information, check our cookie policy.

How long your personal data will be kept?

All data will be held in line with the retention schedules of the organisations sharing data with Smaare Consulting. 

We store your personal information only to the extent that we need it, in order to be able to use it for the purposes we collected it for, and according to the legal base of its processing, in accordance with the applicable law.

 

We will retain your personal information for as long as you are registered as user of our services, while there is a contractual and / or a commercial relationship, or while you do not exercise your right to erasure and / or to restriction of processing of your data (for detailed information, please check the section about your rights). In these cases, we will keep the information duly blocked, without using it, for as long as it may be necessary for the exercise or defence of claims or to handle any kind of judicial, legal or contractual responsibilities that may arise from the processing of your data, and for which it may be necessary to recover it.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for statistical purposes. In these cases, we may store this information (anonymous) indefinitely, without further notice to you.

To whom can we disclose your data

Most of the data we collect resides in our servers, but in some cases it is necessary to disclose the information that you have provided us to third parties, in order to provide the requested service; 

There are also companies that provide us with other kinds of services, for example, in the information technology environment. These third parties only have access to the personal information they need to carry out their services. They are required to maintain confidentiality regarding your data and cannot use them in any other way than the one we have requested.

In all cases, we assume responsibility for the personal information that you provide us and we request those companies with whom we share your data that apply the same degree of protection we apply.

Likewise, your personal information will be available to the public administrations, judges and courts, for the attention of the possible responsibilities arising from the processing.

 

The data will not be disclosed to other categories of recipients, except in the cases provided for by law or when you had previously consented it.

Your Rights

Under the GDPR you have a number of rights which you can access free of charge which allow you to:

  • Know what we are doing with your information and why we are doing it

  • Ask to see what information we hold about you

  • Ask us to correct any mistakes in the information we hold about you

  • Object to direct marketing

  • Make a complaint to the Comissão Nacional de Proteção de Dados

Depending on our reason for using your information you may also be entitled to:

  • Ask us to delete information we hold about you

  • Have your information transferred electronically to yourself or to another organisation

  • Object to decisions being made that significantly affect you

  • Object to how we are using your information

  • Stop us using your information in certain ways

We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. If you would like to exercise a right, please contact our GDPR Team at maria.varela@smaareconsulting.com

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you through email. If necessary, in order to continue your use of our services, you may be required to read and accept the new terms.

Who to Contact

Please contact the GDPR Team at maria.varela@smaareconsulting.com to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in Portugal is the Comissão Nacional de Proteção de Dados.

 

Last Updated: November 2018.