For Climar, S.A., the security and privacy of your Personal Data is very important.
1. What are personal data?
Personal data are all information, in any form, collected on any type of medium, relative to an identified or identifiable natural person. Identifiable information refers to a set of information that can lead to the identification of a specific person, namely by reference to an identifier (such as for example an identification number or a location datum).
2. Who is responsible for processing my data?
The entity responsible for the processing of my Personal Data is:
Climar – Indústria de Iluminação, S.A.
Estrada Real, 50 – 3750-866 Borralha – Portugal
Electronic mail address: email@example.com
3. What information do we collect?
Climar, S.A. only collects information which is adequate, relevant and limited to what is necessary relative to the purposes for which the data are processed.
In order to fulfil different purposes, we may collect the following types of Personal Data:
- identification data (such as name, place of birth, number of citizen card or date of birth);
- contact data (such as telephone number and mobile phone number, address or electronic mail address);
- qualification and professional situation data (such as level of education, Curriculum Vitae or name of company);
- information related to health and biometric data of workers (such as fingerprint);
- bank, financial and transaction data (such as bank identification number or tax identification number);
- location data (such as IP address);
- images of recording of events or of videoconferences;
- images collected through video-surveillance systems.
If you decide to provide other information, in addition to those required by Climar, S.A., the processing of this information is based on your consent, which will be demonstrated by giving it voluntarily. You have the right to withdraw this consent at any time. You may do so by communicating your intention in writing and sending it to the address identified above or by sending an electronic mail message to the address mentioned above.
You do not need to register or provide personal information to use the websites of Climar, S.A.. To register for our Newsletter, the only information you need to provide is your electronic mail address, name and nationality. All the other information fields are optional.
4. What processing is the information subject to?
“Processing” shall mean everything that Climar, S.A. does with the information that concerns you, including its collection, storage, use and disclosure.
a) Marketing: the main purpose for which Climar, S.A. will process the Personal Data that concerns you consists in the marketing of its products. This includes identifying you when you contact us; monitoring your preferences, in order to allow you to save time when you conduct searches on our website; permitting access to services, downloads or other activities you select; processing your requests to participate in marketing promotions; understanding which parts of the website of Climar, S.A. and which products and services are of greatest interest to you; helping us create relevant content and better products and services that meet your needs.
b) Communication: Climar, S.A. may use your Personal Data to communicate with you, namely to send you news related to products and services, promotional campaigns or disclosure of activities, such as fairs, exhibitions or other events, as well as to provide assistance on aspects related to customer support, follow-up on your complaints or your requests for information.
c) Provision of Products and Services: Climar, S.A. uses your Personal Data to conclude the purchase and sale contract of its products or the service provision contract that it enters into with you. We can also use your Personal Data to inform you when a product that you intended to acquire is available; process and track your order, including the delivery of the product at the address indicated by you; manage the payment of your order; manage any contact with us that you make regarding your order; prevent and investigate possible incorrect uses of the latter and provide assistance on aspects related to customer support.
d) Performance of the Work Contract: Climar, S.A. uses your Personal Data to be able to draft the work contract and communicate the employment relationship, namely to Social Security; to the Tax Authority; to the company that Climar, S.A. has selected to conduct Hygiene, Health and Safety at Work; to the financial institution selected to transfer salaries and other remunerations; to the insurance company selected for the purposes of mandatory and/or optional insurance (accidents at work and occupational diseases); to the company selected for the recruitment/selection and contracting of Temporary Workers, among other entities necessary for compliance with our legal and/or regulatory obligations.
e) Control of Accesses and of Attendance: Climar, S.A. shall collect and use the biometric data of its workers for the purposes of controlling accesses and attendance as required by law.
f) Video-surveillance: some spaces of Climar, S.A. have a video-surveillance system that is clearly marked. The aim of the capture of images is the security of people and goods.
g) Recruitment: Climar, S.A., during the staff selection and recruitment process, collects and processes the personal data of the respective candidates. The processed Personal Data shall be those included in the application form and Curriculum Vitae, as well as all the Personal Data that you spontaneously decide to transmit, including but not limited to, name, age, sex, photography, contact details (electronic mail address and telephone number), information on education, employment history, immigration status (in case you need a work permit).
With the exception of processing for the purpose of provision of goods and services (processing necessary for fulfilling a contract), collection of biometric data, capture of images through the video-surveillance system and of processing within the scope of the recruitment processes, in which the processing is based on the legitimate interest of Climar, S.A., the legal basis for data processing is the consent of the data holders.
The Personal Data collected during the performance of a work contract or the processing of an order by Climar, S.A. are necessary for the purposes of fulfilment of the respective contract, such that, if the data holder, in any way, is opposed to the respective processing, Climar, S.A. may not comply with the fulfilment of the contract.
5. Where do we store your data?
The protection of your data is important to us, which is why we apply appropriate measures to guarantee its security, preventing non-authorised access and the improper use of your Personal Data.
Climar, S.A. adopts the adequate procedures to guarantee that your information is correct, complete and current, but it is up to the user to correct or update his/her personal information when necessary.
Since Personal Data is collected on an open network (internet), these may eventually circulate in a network without security conditions, and may be viewed and/or used by third parties that have not been authorised to do so, notwithstanding appropriate security measures having been taken against accidental or unauthorised destruction, and accidental loss, as well as against access, modification or unauthorised disclosure.
6. What are the rights of the data holders?
Under current legislation, Climar, S.A. undertakes to respect the confidentiality of your personal information and guarantee the exercise of your rights, namely:
- Right of access: right that permits you to obtain information relative to the processing of your data and its characteristics (namely the type of data, the purpose of processing, to whom your data can be communicated, storage periods and which data must be provided, and which data is optional.
- Right of correction: right that permits you to request the correction of your data, requiring them to be accurate and current, such as for example when you consider that they are incomplete or outdated.
- Right to the deletion of your data or "Right to be forgotten": right that permits you to request the deletion of your data, when you consider that there are no valid justifications for the storage of the data and provided there is no other valid justification that legitimises this processing (such as the fulfilment of a contract or compliance with a legal or regulatory obligation).
- Right of opposition, including direct marketing: you can cancel the subscription of the Newsletter of Climar, S.A. or opt to be removed from our direct marketing communications at any time. The easiest way of doing it is by clicking on the "Remove" connection on any electronic message or communication that we send you, but you can also contact us to that end by sending an electronic mail message to the email address firstname.lastname@example.org.
- Right to portability: right through which you can request that your commonly used data be sent in digital format, permitting the reuse of said data. Alternatively, you may request the transmission of your data to another entity that becomes responsible for the processing of your data.
- Right to limitation: right that permits you to suspend the processing or limit the processing to certain categories of data or purposes.
- Right to, at any moment, withdraw your consent for the processing of data: right that permits you to withdraw your consent, but which can only be exercised when your consent is the only condition for legitimacy.
- Right to lodge a complaint with CNPD: if you consider that the processing of your Personal Data conducted by Climar, S.A. breaches the applicable data protection legislation, you may lodge a complaint with the National Data Protection Committee ("CNPD”). Do not hesitate to contact us before lodging a complaint with CNPD.
7. How can you exercise your rights?
The data holder guarantees that the Personal Data communicated to Climar, S.A. are correct and accurate and undertakes to notify Climar, S.A. of any change or modification, and assumes exclusive liability for the loss and damage caused by erroneous, inaccurate or incomplete communication of the data.
The data holder recognises and accepts that by revealing Personal Data through public media of Climar, S.A. such as Social Media (Facebook, and Linkedin, among others...), this information may be seen and used by third parties.
9. For how long do we store your data?
Climar, S.A. processes and stores your data only during the period that is deemed necessary for the pursuit or conclusion of the processing purposes for which they are intended, in observance of the maximum necessary periods to comply with contractual, legal or regulatory obligations.
To determine the period during which we store your data, we use the following criteria. If various criteria apply simultaneously, we will store your Personal Data in accordance with the criteria that entails the storage of your Personal Data for the longest period of time.
a) When you acquire products and/or services, we will store your Personal Data throughout the duration of our commercial relationship, as well as during the period of time foreseen in applicable legislation following the termination of the latter (for example, for the purposes of fulfilment of tax obligations, the Personal Data relative to invoicing must be stored for the legal period in force at the date of issue of the documents);
b) When you contact us to pose questions, we will store your Personal Details for the period of time necessary to resolve your issue;
c) When you register on our website, we will store your data until you ask us to delete them or after a period of inactivity of two years;
d) When you have consented to the sending of direct marketing, we will store your Personal Data until you cancel your subscription or ask us to delete it;
e) When you perform a work contract, we will store your Personal Data throughout the duration of our contractual relationship, as well as for a period of ten years following the termination of the contract;
f) Regarding the collection of workers' biometric data, we will store their Personal Data throughout the duration of the contractual relationship;
g) Regarding the images captured by the video-surveillance system, we will store the Personal Data for the maximum period of 90 days;
h) Regarding the data collected in the recruitment process, we will store the Personal Data for a maximum period of 1 year as of the conclusion of the process;
i) Regarding the data provided to governmental entities (State, Finance Offices, Social Security or other), in order to comply with legal or regulatory obligations, the period of storage of the data shall be in accordance with the period of time established in applicable legislation;
j) Until the specified purpose applicable to certain data ceases to exist.
In any of the abovementioned situations, if there are pending legal or administrative offence proceedings, the data will also be stored during the period of duration of the proceedings and up to six months following a formal judicial decision.
We may also store some of your Personal Data to the extent necessary to comply with our legal obligations, as well as to manage or enforce our rights, namely by judicial means.
On expiry of these storage periods, the Personal Data will be eliminated and/or deleted in a secure manner.
10. With whom do we share your Personal Data?
Climar, S.A. may subcontract other companies for the provision of specific services, as in the case of network analysis services, marketing automation platforms, social network services, website maintenance or other digital suppliers. In these cases, these third-party companies may need to access certain information and data of the data holders. Climar, S.A. guarantees that, in such cases, these third parties will have limited access to the information of the data holders, expressly restricted to those data necessary for the execution of the contracted tasks. Climar, S.A. also guarantees that it only resorts to service providers that comply with the General Data Protection Regulation and present guarantees of execution of technical and organisational measures necessary and appropriate to protect your Personal Data.
In the same vein, Climar, S.A. may communicate your Personal Data when required by law, within the scope of legal proceedings or within the scope of investigations into suspicious activities.
Cookies are small data files which are downloaded by your access device (computer, mobile phone/smartphone or tablet), through the Internet browser, when a website is visited by the user. These cookies can be used for various objectives, including monitoring users' preferences and the webpages visited during the use of the Service.
12. Links to third-party websites
The processing of users and customers' personal data undertaken by Climar, S.A., as well as the sending of commercial communications by electronic means are in conformity with national and community legislation in force, namely the General Data Protection Regulation [Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016].
Last update: July 2018