Thank you very much for your interest in our company. Data protection is of a particularly high priority for the management of the Trustec, Unipessoal Lda. The use of the Internet pages of the Trustec, Unipessoal Lda. is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR) (EU) 2016/679, and in accordance with the country-specific data protection regulations applicable to the Trustec, Unipessoal Lda. Through this data protection declaration, we inform the general public about the nature, scope and purpose of the personal data we collect, use and process. In addition, data subjects are informed of their rights through this data protection declaration.
As data controller, Trustec, Unipessoal Lda. has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, data transmissions over the Internet may, in principle, present security gaps, so absolute protection may not be guaranteed. For this reason, each data subject is free to transfer their personal data to us by alternative means, for example by telephone.
1. Definitions
The data protection declaration of the Trustec, Unipessoal Lda. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration must be legible and comprehensible to the general public, as well as to our customers and business partners. To ensure this, we would like to start by explaining the terminology used.
In this data protection declaration, we use the following terms, among others:
a) Personal Data
Personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an electronic identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data Subject
The data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or interconnection, restriction, erasure or destruction.
d) Limitation of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Data controller or data processor
The controller or processor is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria applicable to his appointment may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
i) Recipient
The recipient is a natural or legal person, public authority, agency or other body to which the personal data are communicated, regardless of whether or not it is a third party. However, public authorities that may receive personal data in the context of a specific enquiry under Union or Member State law are not considered recipients; the processing of such data by such public authorities must comply with the applicable data protection rules depending on the purposes of the processing.
j) Third parties
A third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or the processor, are authorised to process personal data.
k) Consent
The data subject’s consent is any freely given, specific, informed and unambiguous indication of his or her wishes by which he or she accepts, by means of a statement or an unambiguous positive act, the processing of personal data concerning him or her.
2. Name and address of the data controller
Responsible for processing for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union and other provisions relating to data protection is:
Trustec, Unipessoal Lda.
Rua Padre Manuel Guimarães, nº 23
4700-284 – Braga
Portugal
Telefone: +351 253 467 346
Email: info@trustec.pt
3. Data Protection Office contacts
Trustec, Unipessoal Lda.
Rua Padre Manuel Guimarães, nº 23
4700-284 – Braga
Portugal
Telefone: +351 253 467 346
Email: info@trustec.pt
Any data subject can, at any time, contact our Data Protection Officer directly with any questions or suggestions regarding data protection.
4. Subscribe to our newsletters
On the Trustec Unipessoal, Lda. website, users have the opportunity to subscribe to our company newsletter. The input mask used for this purpose determines which personal data is transmitted, as well as when the newsletter is ordered from the controller.
Trustec Unipessoal, Lda. regularly informs its customers and business partners via a newsletter about corporate offers. The company newsletter can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter to be sent. A confirmation e-mail will be sent to the e-mail address registered by the data subject for the first time for sending the newsletter, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove that the owner of the e-mail address as the data subject is authorised to receive the newsletter.
During newsletter registration, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to understand the (possible) misuse of a data subject’s e-mail address at a later date, and therefore serves the purpose of the legal protection of the data controller.
The personal data collected as part of a newsletter registration will only be used to send our newsletter. In addition, newsletter subscribers may be informed by e-mail, provided that this is necessary for the operation of the newsletter service or for a registration in question, as may be the case in situations of changes to the newsletter offer, or in the event of a change in technical circumstances. Restricted personal data collected by the newsletter service may be shared with a processor for the sole purpose of sending the newsletter. Subscription to our newsletter can be cancelled by the data subject at any time. Consent to the storage of personal data, which the data subject has given for the sending of the newsletter, can be revoked at any time. For the purpose of withdrawing consent, a corresponding link can be found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website, or to communicate this to the controller in a different way.
5. Newsletter-Tracking
The Trustec Unipessoal, Lda. newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to allow log files to be recorded and analysed. This enables a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Trustec Unipessoal, Lda. will be able to check if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters is stored and analysed by the controller in order to optimise the sending of the newsletter, as well as to adapt the content of future newsletters to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects have the right to revoke their separate declaration of consent issued through the double opt-in procedure at any time. Upon revocation, this personal data will be deleted by the data controller. Trustec, Unipessoal Lda automatically considers a withdrawal from receiving the newsletter as a revocation.
5. Routine deletion and blocking of personal data
The data controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or other competent legislator expires, the personal data is routinely blocked or deleted in accordance with legal requirements.
6. Rights of the data subject
a) Right to confirmation
Each data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether or not personal data concerning them is being processed. If a data subject wishes to make use of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access
Each data subject has the right granted by the European legislator to obtain from the controller free information about their personal data stored at any time and a copy of this information.
If the data subject wishes to exercise this right of access, he or she may, at any time, contact any employee of the controller.
c) Right to rectification
Each data subject has the right granted by the European legislator to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, in particular by submitting an additional declaration.
If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact any employee of the controller.
d) Right to exclusion (Right to be forgotten)
Each data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller has the obligation to erase personal data without undue delay.
e) Right to restriction of processing
Each data subject has the right granted by the European legislator to obtain from the controller the restriction of processing.
f) Right to data portability
Each data subject has the right granted by the European legislator to receive the personal data concerning him or her, which has been provided to a controller, in a structured, commonly used and machine-readable format. He or she has the right to transmit this data to another controller, without the controller to whom the personal data have been communicated being prevented.
g) Right to oppose
Each data subject has the right granted by the European legislator to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her.
h) Automated individual decisions, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, or (3) is not based on the express consent of the data subject.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Trustec, Unipessoal Lda shall implement appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
i) Right to withdraw consent in matters of data protection
Every data subject has the right granted by the European legislator to withdraw their consent to the processing of their personal data at any time.
7. Data protection provisions on the application and use of Google Analytics (with anonymisation function)
On this website, the controller has integrated the Google Analytics component (with anonymisation function). Google Analytics is a web analysis service. Web analytics is the collection, collation and analysis of data about the behaviour of visitors to websites. A web analytics service collects, among other things, data about the website a person comes from (the so-called referrer), which subpages were visited or how often and for how long a subpage was viewed. Web analytics are mainly used to optimise a website and to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For web analysis via Google Analytics, the controller uses the application ‘_gat. _anonymizeIp’ application. Through this application, the IP address of the data subject’s Internet connection is abbreviated by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State of the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse traffic on our website. Google uses the data and information collected, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services relating to the use of our website for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. By setting the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject will automatically send data via the Google Analytics component for the purposes of online advertising and the settlement of commissions to Google. In the course of this technical procedure, the Google company becomes aware of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks and subsequently create commission agreements.
The cookie is used to store personal information such as the time of access, the location from which access was made and the frequency of visits to our website by the data subject. With each visit to our website, this personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may transmit this personal data collected through the technical procedure to third parties.
The data subject may, as indicated above, prevent the setting of cookies via our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment of the web browser used would also prevent Google Analytics from setting a cookie on the data subject’s computer system. Furthermore, cookies already in use by Google Analytics can be deleted at any time via a web browser or other software programmes.
In addition, the data subject has the possibility to object to a collection of data that is generated by Google Analytics, which is related to the use of this website, as well as to the processing of this data by Google and the possibility to delete any of this data. To this end, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on informs Google Analytics via JavaScript that any data and information about web page visits cannot be transmitted to Google Analytics. The installation of browser add-ons is considered an objection by Google. If the data subject’s information technology system is subsequently deleted, formatted or newly installed, the data subject must reinstall the browser add-ons to deactivate Google Analytics. If the browser add-on has been uninstalled by the data subject or any other person attributable to their sphere of competence, or is deactivated, it is possible to carry out the reinstallation or reactivation of the browser add-ons.
Additional information and the applicable data protection provisions of Google can be retrieved at https://www.google.com/intl/en/policies/privacy/ and under https://www.google.com/analytics/terms/us.html. Google Analytics is explained in more detail at the following link https://www.google.com/analytics/.
8. Data protection provisions regarding the application and use of YouTube
On this site, the controller has integrated YouTube components. YouTube is an Internet video portal that allows video editors to set up video clips and other users for free, which also offers free viewing, reviewing and commenting on them. YouTube allows you to publish all types of videos, so you can view full-length films and TV broadcasts, as well as music videos, trailers and videos made by users via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube can be found at https://www.youtube.com/yt/about/en/. In the course of this technical procedure, YouTube and Google learn which specific subpage of our website was visited by the data subject.
If the data subject is logged in to YouTube, YouTube will recognise, with each call-up to a subpage containing a YouTube video, which specific subpage of our website was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google will receive information via the YouTube component that the data subject has visited our website, if the data subject at the time of the call-up to our website is logged into YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such transmission of this information to YouTube and Google is not desirable for the data subject, delivery can be prevented if the data subject logs out of their own YouTube account before a call-up to our website is made.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information on the collection, processing and use of personal data by YouTube and Google.
9. Legal basis for processing
At least one of these rules must apply whenever personal data is processed:
- Consent: the individual has given clear consent to the processing of their personal data for a specific purpose.
- Contract: the processing is necessary for the fulfilment of a contract.
- Legal obligation: processing is necessary to comply with the law (not including contractual obligations).
- Vital interests: processing is necessary to protect someone’s life.
- Public task: processing is necessary to fulfil a task in the public interest and the task or function has a clear legal basis.
- Legitimate interests: processing is necessary for the legitimate interests of the controller, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
10. Legitimate interests pursued by the controller or a third party
The processing of personal data is carried out in our legitimate interest is to carry out our activity in favour of the well-being of all our employees and shareholders.
11. Period of retention of personal data
The criterion used to determine the retention period of personal data is the respective legal retention period. After the end of this period, the corresponding data is routinely deleted, provided that it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
12. Provision of personal data as a legal or contractual requirement; Necessary requirement to enter into a contract; Obligation of the data subject to provide personal data; possible consequences of failure to provide such data
The provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information about the contractual partner). Sometimes it may be necessary to enter into a contract in which the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the personal data is provided by the data subject, they must contact any employee. The employee clarifies to the data subject whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of not providing the personal data.
13. Existence of automated decisions
As a responsible company, we do not use automated decision-making or profiling.