I- We and our commitment:
Our " group of undertakings " or "group of companies involved in a joint business activity", as these concepts are defined and considered by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, designated in art. 4th, als. 19) and 20), is composed of four commercial companies, namely Afg - Adalberto Fashion Group SGPS, Lda, which exerts control, AD Style Lda, Têxteis Adalberto SA and Estamparia Têxtil - Adalberto Pinto da Silva SA, here hereinafter referred to as Grupo Empresarial or ADALBERTO, which are engaged, respectively, in the activities of non-financial holding companies; agents involved in the wholesale of textiles, clothing, footwear and leather goods; rental of real estate and the stamping and manufacture of textile articles.
Taking into account the proportionality and appropriateness imposed by the capacity to allocate resources and technical resources within its reach, Adalberto is deeply and genuinely committed and dedicated to protecting its regular and occasional clients and employees, as well as the users of our various supports and platforms, physical or digital, namely paper dossiers, digital files and websites in use or to be implemented, with respect to their privacy and the processing and circulation of their personal data.
II- Our collection devices and personal data media in use:
We provide, edit and manage the following personal data processing media:
• Information Technology systems consisting of a set of software solutions supported on a set of hardware devices and other similar solutions, including e-mail services and other external digital repositories and communication solutions.
• Paper files packaged in cabinets and shelves in restricted access rooms;
• Adalberto Website - www.adalberto.pt
• Gamanatura Website - www.gamanatura.pt
• AD Style Website - www.adstyle.com
III- Personal and material scope of this Privacy Policy:
This privacy policy obliges the company exclusively regarding the personal data it collects, processes and circulates.
Equal or similar policy will also be assumed, contractually signed with Adalberto, by entities that treat the same personal data on behalf of our company.
The availability through the above-mentioned Adalberto website of other access links to other websites unrelated to Adalberto is made in good faith and in the interest of the user, and Adalberto cannot be held responsible, in any way, for the collection, processing and destination of the data in those Websites, nor for the reliability, correctness, legality and functionalities available there, being therefore not applicable to them in this privacy policy.
Adalberto considers it obligatory and will presume for all effects, without possibility of proof in the contrary, that it will read the privacy policies of all the websites to which it accesses.
IV- The reason for and the publication of this Privacy Policy:
In addition to implementing it in its organizational processes, Adalberto drafted this Privacy Policy with the purpose of making available, make known and publicize an explanatory instrument of the general rules of privacy and treatment of the personal data it collects, always in strict compliance with the Legislation concerned.
For this purpose, the text of this privacy policy will be available in paper support posted in a visible place and in digital format on the website www.adalbertoestampados.com.
What is prescribed in this Privacy Policy complements what is stipulated in the same matter in the formal or informal contracts that our customers, partners and employees celebrate with Adalberto.
We ask you to please read this Privacy Policy carefully, because by making your personal data available, either in person or when accessing the said Website, implies that you know and accept the conditions contained herein and the treatment of them for lawful and legitimate purposes.
Adalberto expressly reserves the right to change the present privacy policy at any time, with any changes made being duly publicized by the same means.
V- Concept of personal data:
Personal data shall mean any information or registration of any nature and regardless of its support or format, namely sound, image, written or feature/characteristic, relating to any identified singular person or any identifiable singular person.
Any person is considered identifiable when he/she can be directly or indirectly identified by reference to one or more specific personal details, isolated or in conjunction with each other, including their physical, physiological, psychological, economic, ethnic, cultural, geographical, social or their location.
VI- The entity responsible for the processing of personal data:
The entity responsible for the collection and processing of personal data is Adalberto, who, in the context of its relations with the people whose personal data it protects, always establishes, on a licit and legitimate basis, which data is collected, the means of treatment and the purposes of such data collection and treatment.
VII - Types of personal data collected and processed:
As part of its activity, Adalberto collects and treats, in particular:
1. Personal data necessary to provide and/or receive services and/or the supply of products to its customers and/or their suppliers, dealing in this area with data such as name, tax identification number, address, telephone number and the e-mail address among other data that may be strictly necessary, proportionate and lawful.
2. Personal data necessary for the execution of the employment contract or services rendered with its employees, dealing in this area with data such as the name, identification document number and other data like tax identification number, composition of the household, social security number, address, telephone numbers and e-mail address, health data, access data and location, among other data that may be strictly necessary, proportionate and lawful.
3. Personal data necessary to fulfil legal obligations, either to public or to private entities, dealing in this area with data such as the name, identification document number and other data, tax identification number, composition of the household, social security number, address(es), telephone numbers, e-mail address and health data among other data that may be strictly necessary, proportionate and lawful.
4. Data necessary for the management of clients/users and suppliers, to contract and manage the contractual relationship with clients and suppliers, the adequacy of the provision of services/supplies to the needs and interests of the client/consumer/user, sending suggestions, information and marketing actions, publicizing campaigns, promotions, advertising and news about the services and/or products, conducting market studies and/or satisfaction surveys, handling complaints, addressing in this context, data such as: address(es) telephone numbers and e-mail address, among other data that may be strictly necessary, proportionate and lawful.
5. All personal data necessary for the exercise of the rights of Adalberto within the scope of the relations referred to in the previous items, and in the pursuit of their activity and legitimate interest, in particular tax and administrative management, litigation management, judicial proof, fraud detection, revenue and audit protection, network and systems management, control of information security, physical security and security of the installations.
Notwithstanding the compliance with legal norms or legitimate orders from competent authorities regarding the storage and transmission of data, Adalberto only treats personal data necessary for its activity, in the just and strict extent required by the nature of the contractual relationship or of another nature, established with the holder of such data, with his/her prior, legitimate, lawful, informed consent.
VIII- Time and manner of collecting personal data:
Adalberto collects the personal data in person, in writing, by phone or through its website www.adalbertoestampados.com
As a general rule, personal data is collected when a relationship or collaboration is initiated, contractual or other, necessary to the continuation of the activity of Adalberto, between Adalberto and the data subject.
Our websites may collect spontaneous applications, these will be sent directly to our email server via an encrypted link and will only be available to our human resources managers. When necessary, the information of a candidate will be made available for evaluation by a person in charge of each specific department, always under the supervision of the human resources managers.
Some personal data is of mandatory collection and necessary for the beginning and normal and legal development of any said relationship or collaboration. Therefore, in the absence or insufficiency of this data, the relationship will not begin or continue, and in this case, Adalberto will inform the holder of the data that the information is compulsory and necessary.
Apart from data of this nature, data appearing on any public list and that may be used in the legitimate interest of Adalberto, your data will only be collected and processed if and for the purposes that are previously agreed, in a free, informed, specific and unequivocal manner, by means of a written statement, orally or through the validation of an option, namely for the subscription of newsletters or marketing communications, in which case the other rules of this privacy policy will apply.
If you wish to stop receiving these communications, you can express your opposition at all times.
The data collected will be documented, whether in paper or digital format, in the strict compliance with the legislation that regulates the protection of personal data, being stored and contained in paper files and/or specific database, created and managed for the effect and restricted and exclusive access to Adalberto employees who necessarily have to deal with them in the pursuit of Adalberto's activity. Under no circumstances shall the information collected be used for any purpose other than that for which consent has been given by the holder, where necessary, or for the lawful and legitimate purpose of the collection.
IX- Purposes of the collection and processing of personal data:
In general, personal data collected aims at the management of customers, suppliers and employees, the contracting and management of the contractual relationship with customers, suppliers and employees, the receipt and/or delivery of services/supplies contracted, the adequacy of service provision/supplies to the needs and interests of the client, sending suggestions, information and marketing actions, publicizing campaigns, promotions, advertising and news about the services and/or products, conducting market studies and/or surveys satisfaction management, claims management, accounting, tax and administrative management, litigation management, judicial evidence, fraud detection, revenue protection and auditing, network and systems management, information security control, physical security, the safety of the installations, the fulfilment of legal obligations and for the other purposes for which the Law recognizes Adalberto´s legitimate interest.
When your data is collected, or when you request it, you will be informed in more detail about the treatment of your data and how we handle it.
X- Storage period of your personal data:
Whenever there is a specific legal requirement that obliges to keep the data for a minimum period of time, it will be fulfilled by Adalberto.
Adalberto will keep your personal data stored for the minimum period of time strictly necessary for the purpose for which the information is collected and processed, after which it will eliminate it.
XI- Right of access, rectification, opposition, erasure, limitation and portability of your personal data:
It is guaranteed by Adalberto to the holder of the personal data, the right of access, rectification, opposition, erasure, limitation and portability of their personal data.
You can exercise the aforementioned rights by direct contact with Adalberto, at our registered office at Rua Adalberto Pinto da Silva, No. 28, Rebordões 4795-177 Santo Tirso, or by e-mail address datospessoais@adalberto.pt
If you consider it appropriate, you can file a complaint with the National Data Protection Commission - Rua de São Bento no. 148-3º 1200-821 Lisboa - Tel: +351 213928400 - Fax: +351 213976832 - e-mail: geral @ cnpd .pt
XII- Measures that we adopt with regard to the security of your personal data:
Adalberto observes the best practices, adopting the technical and organizational measures appropriate to the best of its ability, in the field of security and protection of personal data, having approved and implemented a demanding plan of compliance with the objectives, the Law and the best interests of the owners of personal data, capable of protecting the data that is made available to us by anyone that has any relationship with us, in order to protect them against its diffusion, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of illicit treatment.
Therefore, the form(s) for the collection of personal digital or paper data, whether the ones filled in the physical premises of Adalberto or on the website, (which require encrypted sessions of the Browser) are stored safely in our physical repositories and digital systems.
All the personal data that you give us about yourself are in Adalberto´s own Datacentre, or in one of its subcontractors Datacentres, under cover of all the advanced physical and logistic security measures, that we consider indispensable for the protection of your personal data.
Despite these security measures, we alert everyone who browses the Internet that they should take additional security measures to ensure that they use an updated PC and Browser in terms of properly configured security patches with an active firewall, antivirus and antispyware and make sure of the authenticity of the sites you visit on the internet, avoiding websites whose reputation you do not trust.
Whenever, in the legitimate and lawful pursuit of Adalberto's activity objectives, it adopts monitoring measures for its employees, especially regarding access control, working hours, tasks and productivity, movement and transportation, not only the customers will have prior knowledge of the respective implementation - being, whenever legally necessary and lawful, requested their consent - as the tools for the purpose used will ensure the same level of security of the personal data collected and processed by them.
The aforementioned security and compliance plan includes the existence of a designated Personal Data Protection Officer, who is responsible for, among other things, verifying this Privacy Policy, maintaining clear rules for the processing of personal data and communicating with control authorities, guaranteeing to all those who entrust to Adalberto the treatment of their personal data, the effective knowledge of how they treat them and what rights they have in this matter.
XIII- The person in charge of protection of personal data designated:
The duties of the Data Protection Officer are incumbent upon the entity named Sincronideia, Lda. He may be contacted by letter sent to Adalberto's address at Rua Adalberto Pinto da Silva, No. 28, Rebordões 4795-177 Santo Tirso, or by e-mail address dpo@adalberto.pt, or by phone at the number: 253 036 727.
XIV- Communication of data to other entities, processors or third parties:
Adalberto may use processors for the purpose of data collection and processing, with the same purposes and aims, obtaining from these entities contractually, a guarantee of reputation and obligation to develop technical and organizational measures to protect the data and ensure the protection of the rights of the holders. In certain circumstances determined by law, certain personal data may have to be reported to public authorities, such as courts, and security forces.
Therefore, any of these subcontracted entities will treat the personal data of our Clients, in the name and on behalf of Adalberto under obligation to adopt the appropriate technical and organizational measures as best they can in order to protect the personal data against the accidental or illicit destruction, accidental loss, alteration, dissemination or unauthorized access and against any other form of illicit treatment.
XV- Transfer of personal data:
The course of Adalberto's activity may imply the transfer of your data to a foreign country.
In this event, Adalberto will strictly comply with applicable legal provisions, in particular with regard to the determination of the reliability and suitability of the Country of destination regarding the protection of personal data and the requirements applicable to such transfers.
XVI- Cookies:
"Cookies" are small software labels that are stored on your computer through the browser, which as a rule only retain information related to your preferences, not including your personal data.
Whenever this is not the case, the user will always be asked for consent to provide your personal data, under legal terms.