Privacy Policy

José Silvério and Micael Franco - EBEN, with VAT No. 513905715 and registered address on Rua da Barreira 866 Lote 56, 4990-645 Gemieira (Zona industrial) Ponte de Lima, Portugal, have established the protection of personal data collected and treated by them as a priority within their policies.

As such, this Policy serves to integrate concepts and the directives underpinning good practice in the light of Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation or GDPR).

This POLICY is legally binding on EBEN in the exercise of its activity and it cuts across the relationships it maintains or intends to maintain with its employees, clients, users and partners, which can be changed at any time when it is necessary for it to be updated and corrected.  Any significant change will be communicated.

01

How we collect your personal data

Your personal data will be collected and treated in the following situations:

• If you apply for employment, your data is collected for the purposes of recruitment
• If you are an employee, your data is collected for the purposes of the work contract
• If you are our client, supplier or service provider, your personal data is provided for collaboration in teams, aimed at carrying out services/purchasing goods.

02

For what purpose and on what basis your personal data can be used

Your personal data will be collected and used when:

• It is necessary to enter into a contract with you or to proceed to its execution;
• Treatment is necessary to comply with legal obligations to which EBEN is subject;
• Treatment is necessary to achieve a legitimate interest, and our purposes for its use outweigh your data protection rights;
• Treatment is necessary for us to declare, exercise or defend a right in a legal action. Your data will be kept for this purpose during the legal time for which it is required or for a period that is strictly necessary.

03

How we keep your personal data secure

We use a variety of security measures to maintain the security, integrity and availability of your personal data.

Although transmission of data through the internet or website cannot guarantee total security against intrusions, we and our service providers and commercial partners will make every effort to implement and maintain physical, electronic and procedural measures aimed at protecting your personal data, in compliance with the applicable requirements of data protection.

Among others, we will implement the following:

• Restricted personal access to your personal data based on the criteria ‘need to know’ and only within the scope of the purposes that have been communicated
• Transfer of personal data to external entities, using encryption systems
• Protection of information technology systems by firewall, with the aim of impeding unauthorised access to your personal data
• Constant monitoring of access to information technology systems with the aim of preventing, detecting and impeding the improper use of your personal data.

04

How long we keep your personal data

We will keep your data only for the period necessary within the scope of the purpose for which it is collected.
When the maximum period for keeping them has expired, your personal data will be safely destroyed.

For the purposes described in this Privacy Policy, your personal data will be stored for the period legally required or up to a maximum period of 5 years from the date of receipt of your consent, or from the last contact (according to what happens in the last place) and if, within this period, you have not withdrawn your consent.

05

With whom we share your personal data and how we keep it secure

Your personal data will be treated by companies subcontracted by EBEN for the purposes of service provision and for legal, fiscal and regulatory authorities, in compliance with legal requirements.

Only the necessary personal data is supplied to subcontracted companies for the provision of the services in question.

Your personal data is stored in the protected servers of our suppliers/service providers, accessed and used exclusively under our policies and standards (or the policies and standards of our suppliers/service providers).  In compliance with the GDPR, EBEN has written contracts with all the subcontracted entities, including clauses which ensure their commitment to comply with the GDPR.

06

Your rights

You can request the following at any time:

• Access to information we have about you
• Correction of information if it is incorrect or incomplete
• To erase or limit the treatment of your personal data
• If the treatment is dependent on your consent or agreement and this is carried out by automated means, you have the right for your personal data supplied beforehand to be sent in a structured, commonly used format that is machine-readable.

Your request will be treated with special care for us to guarantee the effectiveness of your rights. You can be asked for proof of identity to ensure that sharing personal data is only done with the owner of the data.

If you exercise any of these rights, we will proceed to conduct an analysis and will respond where possible within one (1) month. Please be aware that in certain cases (for example, owing to legal requirement), your request may not be satisfied immediately.

If you are not satisfied with our use of your personal data or with our response after the exercise of any of these rights, you have the right to lodge a complaint with our Head of Data Protection and/or the National Commission for Data Protection

Right of Access

The owner of the personal data has the right to obtain confirmation from EBEN that data corresponding to him is / is not the object of treatment and, if appropriate, his personal data and information set out in law is / is not being accessed.

Right of correction

The owner of the personal data has the right to obtain from EBEN, without unjustified delay, correction of inaccurate or incomplete data corresponding to him.

Right to erasure (data erasure)

The owner of the personal data has the right to ask EBEN to erase his data, without unjustified delay, and EBEN has the obligation to erase the personal data when it applies, specifically, to one of the following reasons:

• Personal data cease to be necessary for the purpose for which it was collected or treated.
• The owner withdraws his consent for his data to be treated (in cases where the treatment is based on consent) and if there is no other reason for the aforementioned treatment.
• The owner opposes the treatment and there is no legitimate overriding reason for justifying treatment.

Right to limitation of treatment

The owner of the data has the right to obtain from EBEN a limit to treatment, if applicable, specifically in one of the following situations:

• Contest the accuracy of personal data, for a period of time to enable ENEN to verify accuracy
• The treatment of data is lawful and the owner of this data is opposed to the erasure of his personal data and, in contrast, requests a limitation to their use.
• EBEN no longer needs the personal data for treatment, but this data is required by the owner for the purposes of declaration, exercise or defence of a right within a legal process.
• If having opposed treatment, until it has been verified that the legitimate motives of the person responsible for the treatment outweigh those of the owner of the personal data.

Right to transfer data

If treatment depends on the consent of the owner of personal data and this consent has been given by automated means, the owner of the data has the right to receive the personal data corresponding to him, which had been supplied to EBEN, in a structured, currently used format that is machine-readable.

Right to oppose

The owner has the right to oppose treatment of his personal data in cases where the treatment of data is done for:

• Direct marketing purposes;
• Profiling.

Revocation of Consent

It the consent is legally necessary for the treatment of personal data, the owner of the personal data has the right to withdraw consent at any time, although this right does not invalidate the legality of the treatment carried out on the basis of consent previously given, nor later treatment of the aforementioned data, based on another legal basis, as is the case of compliance with contractual or legal obligation to which EBEN is subject.

If he intends to withdraw his consent, he can do so by contacting us by letter, telephone or email.

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Recruitment

The information and personal data on Curriculum Vitae or other similar document, sent in by a candidate applying for a job by mail or by other means, will be the object of treatment by automated means for the purpose of recruitment and selection of candidates.

By supplying the aforementioned information and personal data to the company, the candidate gives consent for his information and personal data to be treated by the company.

The supply of possible sensitive data will be treated for the purposes of recruitment and selection of candidates if they are deemed to be important and pertinent for these purposes, considering that this data has been supplied based on the consent of the owner of this data.

Candidates have the right at any time, in accordance with the current law, to access, correct, erase, limit or oppose the treatment of data corresponding to them; and if they intend to exercise these rights, use the space available for this purpose on the company’s website or  send an email to: geral@eben.pt.  Candidates also have the right to withdraw their consent at any time, within the terms of the Law, and to lodge a complaint to a supervisory authority.

The company will keep the personal data of candidates for the time necessary to carry out the purposes for which they have been collected. Data collected within the scope of this Privacy Policy does not constitute compliance to any legal or contractual obligation. However, if the candidate is selected, his personal data will be used to prepare the respective contract. Data received will not be the object of automated decisions. Data may be used for profiling for the sole purpose of determining the candidate to be selected, but the final decision for selection or not will not always be automatic and is subject to human intervention. If the candidate does not give permission to be subject to a decision based on a profile, he should declare it expressly or should not send his application. The company has implemented appropriate technical and organisational measures, with the aim of protecting personal data against destruction, accidental or illicit, alteration, unauthorised access and disclosure, and any other form of illegal treatment. Employees authorised to access personal data are legally bound to the duty of confidentiality.

For any query linked to the treatment of your personal data, please contact us by the following means:

Rua do Barreira 866 - Lote 56
4990-645 Gemieira
Portugal
T (+351) 258 247 600
E geral@eben.pt