ARCABOA – Industria de Frio SA, as the person responsible for the processing of personal data, hereby wishes to make known the general principles that it will observe in the collection, transfer,
storage, use and other forms of processing of personal data in accordance with (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD).
The processing of personal data is carried out by ARCABOA in compliance with the RGPD, with respect for the right to privacy and protection of personal data, in a licit, loyal and transparent manner with respect to the data subject, observing, as applicable, one of the following grounds: ((i) consent, (ii) execution or performance under contract or law, (iii) pursuit of vital, public or legitimate interests.
1 – Responsible for the processing of your personal data
ARCABOA is the Responsible for the Treatment of your Personal Data, which provides services and / or products, determining for this purpose and without limiting:
- Personal Data that must be processed in the context of the provision of services and / or product supply;
- The Purposes for which Personal Data is processed; and,
- The means to be applied for the treatment of Personal Data.
2 – Principles relating to processing of personal data
The Treatment of your Personal Data is carried out in accordance with the general principles set out in the General Regulation on Data Protection and other data protection legislation, namely:
- In the context of the relationship, ARCABOA ensures that your Personal Data will be treated in a licit, legal and transparent (“lawfulness, fairness and transparency”);
- ARCABOA collects your Personal Data for specific, explicit and legitimate purposes and does not subsequently treat the same Data in a manner incompatible with those purposes (“Purpose limitation”);
- ARCABOA ensures that only appropriate, relevant and limited Personal Data are treated as strictly necessary for the purposes for which they are processed (“data minimization”);
- ARCABOA adopts the appropriate measures so that Personal Data qualified as inaccurate, taking into account the purposes of treatment, are erased or rectified without delay (“Accuracy”);
- ARCABOA retains Personal Data in a form that allows its identification only for the period necessary for the purposes for which it is processed (“storage limitation”);
- ARCABOA ensures that your Personal Data is treated in a way that guarantees its security, including protection against its unauthorized or unlawful treatment and against its accidental loss, destruction or damage, adopting appropriate technical or organizational measures (“Integrity and Confidentiality”).
3 – Personal data, processing of personal data
Personal Data is all information and / or elements that, regardless of their support, can identify or make it directly or indirectly identifiable to ARCABOA, in particular by reference to an identifier, such as a name, an identification number , their location data and / or identifiers by electronic means or to one or more specific elements of their physical, physiological, genetic, mental, economic, cultural or social identity.
Treatment of Personal Data means the operation or set of operations carried out on Personal Data of the Data Holders, through automated or non-automated means, from the collection of the information to its destruction. This cycle, among others, includes the registration, organization, structuring, conservation, adaptation or alteration, retrieval, consultation, use, dissemination by transmission, dissemination or any other form of comparison or interconnection, limitation, erasure.
4 – Data and processing category
In the exercise of its activity, ARCABOA processes the personal data of several categories of data holders, such as customer data, workers / employees, former employees / former employees, job seekers, suppliers and service providers.
The personal data that ARCABOA collects or may collect includes, in particular, the following:
Contact details – personal and / or business contacts including name, postal address, telephone number, fax number, email address or other similar information.
Payment data – data needed to carry out payments and for fraud prevention, including NIF, bank account numbers.
Household data – data required to fulfill tax or labor obligations, including name, identification of relationship, and other information required to complete legal forms or exercise rights.
Health Data – data required to comply with legal regulations related to Occupational Safety and Health, such as fitness records, medical reports or clinical information for risk prevention, as well as those related to the worker and his / her household to fulfill contractual obligations , arising from the validity of health insurance.
5 – Lawfulness of processing
By reference to the “Lawfullness of processing”, tresured in the current data protection laws, in the development and execution of its activities, ARCABOA only treats its Personal Data when there is a legal basis for legitimacy, namely:
- Agreement: ARCABOA will only treat your Personal Data if you consent to its Treatment through a free, specific, informed and explicit manifestation of will, by which you accept, by means of a statement (in writing or orally) or unequivocal positive act (through completing an option), that your Personal Data is subject to reatment.
- Pre-contractual formalities or execution of a contract: ARCABOA may treat your Personal Data if it is necessary, without limitation, for the execution of a service contract and / or supply of products in which it is a part of Collaborator, Client and / or Supplier, or to carry out pre-contractual procedures at your request.
- Compliance with a legal obligation: ARCABOA may treat your Personal Data to ensure and ensure compliance with legal obligations to which it is subject under the legislation of a Member State and / or the European Union.
- Protection of vital interests of the Data Owner: ARCABOA may treat your Personal Data to ensure the protection of your vital interests, especially when the same Treatment is essential to your life.
- Legitimate Interests: ARCABOA, other Responsibles or Third Parties, may treat their Personal Data as long as this treatment does not prevail the interests or fundamental rights and freedoms of the data holder.
6 – Term of data retention
ARCABOA retains its Personal Data only for the period of time necessary for the execution of the specific purposes for which it was collected. However, ARCABOA may be obliged to keep some Personal Data for a longer period, taking into account factors such as:
- Legal obligations, under current laws, to keep Personal Data for a certain period;
- Limitation periods, under the laws in force;
- if any) Litigation; and,
- Guidelines issued by the competent data protection authorities.
7 – Sharing of personal data
Subcontractors: Your Personal Data may be shared with companies that provide services to ARCABOA. The service providers are linked to ARCABOA by means of a written agreement, only being able to process their Personal Data for the specifically established purposes and are not authorized to treat their Personal Data, directly or indirectly, for any other purpose, for their own benefit or for third.
At your request and / or with your consent, your Personal Data may be shared with other entities.
In compliance with legal and / or contractual obligations, Personal Data may also be transmitted to judicial, administrative, supervisory or regulatory authorities, as well as entities that lawfully perform data collection actions, actions to prevent and combat fraud, market or statistical studies.
8 – Rights and Exercise of Rights
- Right to information: As the holder of the data, you have the right to obtain clear, transparent and easily understandable information about how ARCABOA uses your Personal Data and what your rights are.
- Right of access: As the holder of the data, you have the right to obtain information about the Personal Data that ARCABOA deals with (if you actually treat them) and certain information about how these Data are processed. This right allows you to know and confirm that we use your Data in accordance with data protection laws. ARCABOA may, however, refuse to provide the requested information whenever, in order to do so, it must disclose Personal Data of another person or the information requested damages the rights of another person.
- Right of rectification: As the holder of the data, you have the right to ask ARCABOA to take reasonable steps to correct your Personal Data that is incorrect or incomplete.
- Right to erasure: This right, also known as the “right to be forgotten “, in a simple way, allows you as data holder to request erasure or deletion of your data, as long as there are no valid grounds so that ARCABOA continues to use them or, when, their use is unlawful.
- Right to restriction of processing: As the holder of the data, you have the right to "block" or prevent future use of your Data while ARCABOA evaluates a request for rectification or as an alternative to erasure.
- Right to data portability: As the holder of the data you have the right to obtain and reuse certain Personal Data for your own purposes. This right applies only to your own Data that you have provided to ARCABOA and that ARCABOA deals with your consent and those processed by automated means.
- Right of object: You have the right to object to certain types of treatment, on grounds relating to your particular situation, at any time during which this treatment takes place.
- Right to complaint: You have the right to complain to the competent control authority, the National Data Protection Commission (CNPD), if you believe that the Treatment made to Personal Data violates your rights and / or applicable data.
You may at any time, writing, exercise the rights enshrined in the Law of Protection of Personal Data and other applicable laws through the email firstname.lastname@example.org
9 – Security and integrity
Your Personal Data will be treated by ARCABOA only in the context of the purposes identified in this Policy, in accordance with the internal policies of ARCABOA and using technical and organizational measures designed according to the risks associated with the specific treatment of Personal Data. The technical and organizational measures designed ensure, to the maximum extent possible, the security and integrity of the Personal Data, namely in relation to the unauthorized or unlawful treatment of your personal data and their accidental loss, destruction or damage.
However ARCABOA cannot guarantee the security of the Data when transmitted through an open network, since the transmission of information over the Internet is not absolutely secure.
10 – Confidentiality