PRIVACY POLICY AND PROCESSING OF PERSONAL DATA

COMMITMENT:

The Intermunicipal Community of Alto Tâmega e Barroso, hereinafter CIMAT, a public law collective person of an associative nature, was constituted as an administrative unit, which corresponds to NUT III of Alto Tâmega and develops its administrative activity, within the scope of its legal competences, in the geographical area of the municipalities that comprise it: Boticas, Chaves, Montalegre, Ribeira de Pena, Valpaços and Vila Pouca de Aguiar.

 

In strict compliance with the law, and with respect for the principles of transparency and equality, it adopts safety procedures and practices with the aim of, on the one hand, always guaranteeing the pursuit of the public interest in the areas of its intervention and, on the other hand, minimizing any possible collision this desideratum with the personal sphere of rights of each individual.

 

Taking into account the proportionality and adequacy inherent to the capacity to allocate the resources and technical means at its disposal, CIMAT is committed to the creation of protection measures inherent to the privacy and the processing and circulation of the personal data of its citizens, workers and collaborators, regular or occasional users, beneficiaries of grants, support or prizes, students, trainees, trainers, holders of internal and external institutional positions, partners, respective legal representatives or volunteers, as well as all those who access or are integrated or considered in its various supports and platforms, whether physical or digital, especially paper dossiers, digital files and websites in use or to be implemented.

 

CIMAT ensures that Personal Data are subject to lawful, fair and transparent treatment, within the scope of the purpose(s) for which they are collected.

 

CIMAT is committed to implementing a Data Minimization culture, in which it only collects, uses and retains the Personal Data strictly necessary for the development of its activity, the pursuit of the public interest and the satisfaction of the targeted interests and individual rights.

 

CIMAT does not disclose or share Personal Data for commercial purposes or commercial advertising.

 

PERSONAL DATA COLLECTION DEVICES AND MEDIA IN USE:

 

CIMAT disposes, edits and manages the following personal data supports:

• Computer system consisting of a set of software solutions supported by a set of hardware devices and other similar solutions, including email services and other external digital repositories and communication solutions;
• Digital Photographic Archive;
• Audiovisual Archive;
• Paper files with restricted access;
• Historical Archive with restricted access;
• CIMAT website – cimat.pt;
• Other digital platforms in use or being implemented;

 

SCOPE OF APPLICATION OF THE PRIVACY POLICY:

This privacy policy applies to CIMAT, with regard to the personal data it collects, processes and circulates, by itself or through third parties, in accordance with the Regulation on Data Protection approved by the Regulation (EU) 2016/679, of April 27.

 

The same or similar policy will also be assumed, by contractual means, by the entities that process the same personal data on behalf of CIMAT, that is, under a subcontracting regime, subject to the supervision of CIMAT.

 

The availability of other links access via the website“www.cimat.pt”, is done in good faith and in the interest of the user, and CIMAT cannot be held responsible, for the collection, treatment and destination of the data processed on these platforms, nor for the reliability, accuracy, lawfulness and functionalities available there, and therefore this privacy policy is not applicable to them.

 

In this sense, CIMAT considers it mandatory and will presume for all purposes, without the possibility of proof to the contrary, the reading and understanding of the privacy policies of all platforms to which the user accesses.

OBJECTIVES AND PUBLICATION OF THE PRIVACY POLICY:

 

In addition to implementing it in its organizational processes, CIMAT has drawn up this Privacy Policy with the aim of providing an explanatory instrument of the general rules of privacy and processing of the Personal Data it collects, always in strict compliance with the applicable legislation.

 

For this purpose, the text of this Privacy Policy will be available in paper format posted in the usual places of CIMAT information and in digital format on the website www.visialtotamegaebarroso.pt.

 

The provisions of this Privacy Policy complement contracts or other procedures or normative acts, formal or informal, that data subjects enter into or participate with CIMAT.

 

Therefore, a careful reading of this Privacy Policy should be carried out, since, by making your Personal Data available, either in person, or when accessing the said Website, it results that you are aware of and accept these conditions, as well as that the processing of your data is intended for the purposes provided for by law.

 

CIMAT may, at any time, change this Privacy Policy, the changes being duly publicized by the same means.

PERSONAL DATA:

By Personal Data it is understood, regardless of the respective support or format, information or registration of any nature relating to an identified or identifiable natural person, such as: sound, image, writing, chirograph, characteristic, opinion , other.

 

An identifiable person is considered to be a natural person who can be directly or indirectly identified by reference to specific personal data, considered separately or in conjunction with each other, namely relating to physical, physiological, psychological, economic, ethnic, cultural, geographic, social, philosophical, religion or location.

 

RESPONSIBLE FOR PROCESSING PERSONAL DATA:

 

The entity responsible for the collection and processing of personal data is CIMAT, which together with the Personal Data Holder establishes, always on a lawful and legitimate basis, which data are collected, the means of treatment and the purposes for which they are intended.

 

TYPES OF PERSONAL DATA COLLECTED AND PROCESSED:

 

Within the scope of its activity, CIMAT collects and processes, namely:

1. Personal data necessary for the provision and/or receipt of services to its users and suppliers;
2. Personal data necessary for the performance of employment contracts or service provision, entered into with its employees and collaborators;
3. Personal data necessary for the fulfillment of legal obligations, either with public entities or with private entities;
4. Personal data necessary for the management of users and suppliers, the contracting and management of the contractual relationship with users, the provision of services or the granting of subsidies, support or prizes, the adequacy of the provision of services to the needs and interests of users, the organization of events, sending suggestions, information and marketing actions, disseminating campaigns, promotions, publicity and news about services, activities, events and valences, carrying out market studies or satisfaction surveys, and managing complaints;
5. Personal data necessary for the collection of evidence (sound, video and photography) for the implementation and dissemination of actions, events, programs and projects organized by CIMAT in a public venue, open or closed, or in a private venue open to the public;

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6. Personal data necessary for mandatory or optional training actions provided;
7. Personal Data necessary for the exercise of CIMAT’s rights and duties within the scope of the relationships mentioned in the previous items, and in the development of its activity for the pursuit of the public interest, namely labor, accounting, fiscal and administrative management, litigation management , judicial evidence, fraud detection, revenue protection and auditing, network and systems management, information security and physical security control and facility security,

 

The processing of this type of data:  Identification Data, Contact Data, Institutional Data, Location Data, Payment Data, Socioeconomic Data, Education and Professional Life Data, Health Information Data, Physical and Biometric Data, Tax Data and Declarations Tax, Financial and Banking Data, Household Data and Professional Situation, must be proportional, lawful and strictly necessary for the purpose for which they are intended.

 

Without prejudice to the fulfillment of legal norms, or legitimate orders from the competent authority, regarding the conservation and transmission of data, CIMAT bases the processing of data in three aspects:

• Processing of personal data necessary for its activity, to the fair and strict extent required by the nature of the contractual or other relationship;
• Upon consent of the data subject, provided in a specified, prior, legitimate, lawful, free and informed manner;
• Legal obligations to which it is subject.

TIME AND METHOD OF COLLECTION OF PERSONAL DATA:

 

CIMAT collects Personal Data by different means: face-to-face, postal, telephone, video, image, sound, and/or through its electronic platforms in use and in implementation.

CIMAT tends to collect personal data when it initiates a relationship, or contractual or other collaboration with the Data Holder, and which is necessary for the pursuit of its activity.

In the act of collecting personal data, some are mandatory and necessary for the normal and legal development of the relationship or collaboration. In this sense, CIMAT must inform the data subject of this need and obligation, otherwise the relationship or collaboration will not continue.

Apart from those of this nature, those appearing on any public list and those that may be used in the pursuit of the public interest developed by CIMAT, personal data will only be collected and processed if, and for the purposes, which you previously consent, freely, informed, specific and unequivocal, by means of a written or oral statement 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 any time.

The data collected will be processed in documents, whether on paper or digitally, in strict compliance with the legislation that regulates data protection, being stored and contained in paper files and/or specific databases, created and managed for this purpose. , with restricted, limited, exclusive access and subject to total confidentiality, by CIMAT employees who necessarily have to deal with them in the pursuit of their activity.

 

Under no circumstances will the collected data be used, disseminated, assigned or transmitted for any purpose other than that for which consent was given by the holder, when necessary, or for the lawful and legitimate purpose for which the collection was based.

PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA:

 

In general, the personal data collected are based on the following purposes: management of users, suppliers and employees, contracting and management of the contractual relationship with users, suppliers, workers and employees, receipt and provision of services, support, subsidies or contracted or awarded prizes, adequacy of these services or assignments to the needs and interests of users, organization of festive, recreational or sports events, sending suggestions, information and marketing actions, campaigns, promotions, publicity and news about the services, carrying out market studies or surveys of satisfaction, claims management, labor management, accounting, tax and administration, litigation management, judicial evidence, fraud detection, revenue protection and auditing, network and systems management, control of information security and physical security, security of installations, compliance with legal obligations and other purposes for which the Law provides for the pursuit of the public interest pursued by CIMAT.

When collecting data and whenever you request it, you will be informed in more detail about the treatment that CIMAT will make of your data.

PERIODS OF CONSERVATION OF YOUR PERSONAL DATA:

 

If there is a specific legal requirement that obliges the conservation of data for a minimum period of time, this will be observed by CIMAT.

CIMAT 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, as well as the need for judicial or administrative proof of the facts on the basis of that purpose. After this period, they will be deleted.

RIGHT OF ACCESS, CORRECTION, OPPOSITION, DELETION, LIMITATION AND PORTABILITY OF YOUR PERSONAL DATA:

 

CIMAT guarantees the holder of personal data the right of access, rectification, opposition, deletion, limitation, portability, withdrawal of consent given and complaint to the control authority.

The exercise of these rights can be exercised by means of written communication sent to the postal address Avenida dos Aliados N.º 9 5400-038 Chaves or electronically geral@cimat.pt

 

MEASURES WE HAVE ADOPTED WITH A VIEW TO THE SECURITY OF YOUR PERSONAL DATA:

CIMAT observes best practices. Having for this purpose adopted technical and organizational measures in the field of security and protection of Personal Data, appropriate to the risk. To this end, it has approved and implemented a demanding compliance plan with the objectives, the Law and the interests of the holders of personal data, capable of safeguarding the protection of the data made available to us, in order to protect them against their distortion, dissemination, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of illicit treatment. In this plan, personal data classified as sensitive are collected and treated, not only in full compliance with the applicable legal requirements, but also with the zeal, care and reserve that is justified in the case.

 

Thus, the form(s) for the collection of digital or paper personal data, filled in at CIMAT’s physical facilities or on the website, are stored securely in its physical repositories and digital systems.

All personal data provided are located in a CIMAT Datacenter, covered by all advanced physical and logistical security measures, which CIMAT considers to be essential for its protection.

Despite these security measures, all those who surf the Internet are warned that they should take additional measures, namely ensuring that they use a computer and a Browser up to date in terms of “ patches” properly configured security, with active firewall, anti-virus and anti-spyware and ensure the authenticity of the sites that accesses, and should avoid platforms whose reputation they do not trust.

 

Whenever, in the legitimate and licit pursuit of the objectives of CIMAT’s activity, it adopts measures to monitor its employees, with regard to access control, working hours, tasks and productivity, circulation and transport, not only Targeted parties will have prior knowledge of the respective implementation – and, whenever legally necessary and lawful, their respective consent will be requested – as the tools used, will ensure the same level of security of the Personal Data collected and processed by them.

 

The said compliance and security plan includes the existence of a designated Personal Data Protection Officer , who is responsible, among other things, for verifying this Privacy Policy, keeping clear the rules for processing of personal data and communicate with the control authorities, guaranteeing that all those who entrust CIMAT with the processing of their personal data, effective knowledge of how it treats them and what rights they have in this matter.

 

Whenever there is a violation of personal data that justifies it, whether due to acts of God or force majeure, or resulting from human action, it will be communicated in a timely manner to the control authority, and will be subject to prompt appropriate measures to mitigate as much as possible. its extent and effects.

 

DESIGNATED PERSONAL DATA PROTECTION OFFICER:

 

CIMAT has designated a Data Protection Officer (DPO) who can be contacted directly by letter sent to the postal address Avenida dos Aliados n.º 9 5400-038 Chaves or to the email address geral@cimat.pt

COMMUNICATION OF DATA TO OTHER ENTITIES, SUBCONTRACTORS OR THIRD PARTIES:

CIMAT may resort to subcontractors for the purpose of collecting and processing data, obtaining from these entities by contractual means, guarantee of reliability, security and obligation to develop the appropriate technical and organizational measures for its protection. However, by legal imposition, certain personal data may be communicated to public authorities, such as tax authorities, courts, security forces or similar nature.

 

In this way, any of these subcontracted entities will process the Personal Data of employees/users/suppliers/students/trainees/trainers, others, in the name and on behalf of CIMAT, under the obligation to adopt the technical and organizational measures appropriate to the risk, in order to protect personal data against accidental or unlawful destruction or loss, distortion, alteration, dissemination or unauthorized access and against any other form of unlawful treatment.

 

TRANSFER OF PERSONAL DATA:

 

The pursuit of CIMAT’s activity may imply the transfer of your data outside Portugal. In this event, CIMAT will strictly comply with the legal provisions applicable to such transfers, namely regarding the determination of the reliability and suitability of the destination country for the protection of personal data.

WEBSITE:

“Cookies” are small software tags that are stored on the computer used to visit the Website, through the browser (browser), which as a rule retain only information related to preferences navigation, and which only aim to improve the user experience, not saving, as a rule, personal data.

Whenever this is not the case, the user will always be asked for consent to provide them, under the legal terms.

 

When the user visits the CIMAT website, data known as a “click path” is collected (server address, domain name, etc…).

This information/data is stored anonymously and is only used for generalized statistical analysis and webmining, with the aim of improving the services to be provided.

 

All data provided by visitors to the website enjoy the same treatment and protection as mentioned above. However, visitors should bear in mind that when providing personal information online, there is a risk of interception and illicit use of this information by third parties. It will therefore always be at the expense and risk of those who provide them, the degree of preventive security adopted and the consequences arising therefrom.

 

The use of CIMAT’s website implies acceptance of the terms of this privacy policy.

 

UPDATES

This Privacy Policy may be subject to updating, in order to reflect the evolution of the interest of data subjects, or the relevant legislation, and whenever justified.

 

When changes to this policy are published, CIMAT will simultaneously change the respective “update date”.

 

Periodic consultation of the current Privacy and Data Processing Policy is recommended, so that holders remain informed about how CIMAT protects Personal Data and what information and rights they have.

 

Update date: March 6, 2019

 

 

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