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PROCALÇADO, S.A.
PRIVACY MANAGEMENT POLICY

1. Application

The Privacy Management Policy presents the commitment of Procalçado, S.A. in relation to the privacy management of the personal data of data holders, as well as compliance with the General Regulation on Data Protection, identified as Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27th April 2016.
Taking into account the inventory of personal data that Procalçado, S.A. keeps updated, all the data considered private and / or sensitive managed according to the requirements of the General Regulation on Data Protection in order to guarantee the data holders rights.



2. Confidentiality and Privacy of Personal Data

For Procalçado, S.A. personal data holders are all contractual corporate customers, web clients, company employees and suppliers / service providers (subcontractors).
Personal and/or sensitive data that are placed in custody of Procalçado, S.A. are accessed by company employees formally authorized to perform such tasks. The data are used only for activities that were previously authorized by the data holders through prior, informed and free consent.
Therefore, in the commitment to guarantee the privacy of personal data, confidentiality is also guaranteed.
The guarantee of confidentiality is ensure through the celebration, with Design and More, S.A. employees, of agreements for the protection of personal data that they access and work in the course of their professional activities.



3. Identification of the Responsible for Personal Data Treatment

The responsible for the personal data treatment is Design e More, SA, headquartered in Largo Alminhas das Barrancas, 97 4415-343 Pedroso, Vila Nova de Gaia, Portugal, VAT nr. PT 501 200 720.



4. Collection, Treatment, Sharing and Retention of Personal Data

4.1 Collection of Personal Data

4.1.1 Situations that do not involve Web tools

Personal data are collected directly from the following sources: form filling in Procalçado, S.A. website, job application with curriculum vitae sharing, filling out paper forms, capturing images and videos, biometric data, e-mail adresse or phone. Personal data can also be collected indirectly by importing Curriculum Vitae content into the internal candidate management platform.
No other method of indirect collection of personal data will be executed.
The collection of sensitive personal data will only be carried out in strictly necessary cases justified by legislation, in particular, and as exemple, for the work medicine.


4.1.2 Situations Involving Web Tools

Personal data are collected directly through the Procalçado, S.A. official Web tools, such as online shopping sites, or indirectly through “marketing automation” tools and “online” advertising through duly authorized and fully compliant subcontracting partners with privacy management policy.
There are also indirect collections through subcontracting partners regarding order placement, such as Amazon and Overcube.
The cookie management policy complements this topic by presenting the "opt-in" and "opt-out" options that are available at Procalçado, S.A. official website.
The data holder can also “opt out” of online advertising services in Procalçado, S.A. social tools, namely Facebook, Google Ads and Instagram.
Procalçado, S.A. assumes that in no case will a manual or computerized form have pre-filled options. All alternatives are selected by the data holder.
The collection of personal data will always be minimized for activities strictly necessary to the legitimate commercial interest of Procalçado, S.A.


4.2 Personal Data Treatment

Authorized personal data will only be used by Procalçado, S.A. with the strict objective of sustaining its commercial activities and legal obligations.


4.2.1 Situations that do not involve Web tools

Included Activities:



No data will be used for the creation and use of sales profiles or indicators of products, regions or trends.


4.2.2 Situations Involving Web Tools

Included Activities:




4.3. Personal Data Sharing

4.3.1 Situations that do not involve Web tools

Personal data sharing will be made for strictly necessary and authorized purposes by the data holder as a support for the development of Procalçado, S.A., activities, including:



Any additional requirements will be subject to a supplemental request for informed consent to the respective data holders.
These data-sharing will be fully realized in the European Union.
Regarding these principles, personal data may be transmitted to subcontractors who, by means of a formal agreement specific to each case, undertake to comply with the necessary security controls in accordance with the privacy management policy of Procalçado, S.A.


4.3.2 Situations Involving Web Tools

Personal data sharing will only be done with subcontracting partners who have signed the security management agreement in accordance with the determinations of the privacy management policy of Procalçado, S.A.



There is data sharing with formally authorized subcontractors for digital marketing purposes. The personal data involved in these actions are subject to the consent of the data holder and, at any time, there is the possibility of “opt-out”.
In case of targeting digital marketing campaigns with intercontinental subcontracting partners, these actions can lead to the transfer of data outside the European Union.
In these cases, Procalçado, S.A. will implement appropriate security controls to each identified risk situation, also ensuring data holders the guarantee of unconditional execution of their rights and all the requirements of the General Regulation on Data Protection.


4.4 Personal Data Storage

For each treatment purpose Procalçado, S.A., will retain the personal data, for the maximum periods indicated below:



Retention is the secure storage of data, in digital or paper format, in resource(s) under the responsibility of Procalçado, S.A., which guarantees the conditions of longevity and use in function of the defined time.



5. Data Holder Rights

Procalçado, S.A., ensures that data holders will be able to exercise their rights, f provided for and described in the General Regulation on Data Protection, and for this purpose a Data Protection Officer (DPO) has been appointed.
Data holder, in order to exercise their rights and/or submit any question related to this subject, namely the presentation of complaints, should send their request, in writing, to the email address dpo@procalcado.com.
In the event of a breach of privacy, the data holder may communicate through this same route or directly with the controlling authority.
Following the complaint or privacy violation records, Procalçado, SA ensures the execution of a communication procedure with the data holder, informing, in a timely manner, and in accordance with the provisions of the General Regulation on Data Protection, at each stage of the processing of the complaint, and in strict compliance with the deadlines and conditions defined by the regulation.



6. Roles and Responsibilities

Procalçado, S.A. management ensures that the Privacy Management Policy is aligned with the company's strategy, in addition to ensuring its continuous improvement.
Data Protection Officer has the role of ensuring compliance with the requirements of the General Regulation on Data Protection in a continuous and systematic manner, that all rights of the data holders are being met and that the security controls are adequate for these purposes.
All Procalçado, S.A. employees, as well its subcontractors, have the responsibility to comply with and enforce the commitments of the Privacy Management Policy.



7. Review and Continuous Improvement

Privacy Management Policy will be reviewed annually, or whenever there are significant changes in the personal data inventory and/or in the informatics or documentary supports that warrant the rights of data holders.
Each revision will give rise to a new version of the Privacy Management Policy.



8. Disclosure and Publication

The Privacy Management Policy will be disclosed to all data holders who interact with Procalçado, S.A. and will be available upon request, as the information contained therein is classified as publicly accessible.
The Privacy Management Policy is available on the institutional website, on the Internet tools that support the business and also in the social networks where Procalçado, S.A. is present.