Política de Privacidade

FORWINNERS Lda, hereinafter referred to as “FORWINNERS”, respects your privacy and values the relationship it maintains with you. This Data Protection and Privacy Policy aims to inform you about how FORWINNERS processes your Personal Data and ensures your privacy in the development and performance of its activities, including:

The Controller of your Personal Data is the company FORWINNERS, which, individually or jointly, provides you with services and/or supplies products, determining for this purpose, without limitation:

• The Personal Data that must be processed in the context of providing services and/or supplying products;
• The Purposes for which the Personal Data are processed;
• The means to be used for processing the Personal Data.

The processing of your Personal Data is carried out in accordance with the general principles set out in the General Data Protection Regulation (“GDPR”), namely regarding:

• Lawfulness, fairness and transparency: in the context of the relationship with you, FORWINNERS ensures that your Personal Data will be processed lawfully, fairly and transparently;
• Purpose limitation: FORWINNERS collects your Personal Data for specified, explicit and legitimate purposes and does not further process them in a manner incompatible with those purposes;
• Data minimisation: FORWINNERS ensures that only Personal Data that are adequate, relevant and limited to what is strictly necessary for the purposes for which they are processed are processed;
• Accuracy: FORWINNERS adopts appropriate measures to ensure that inaccurate Personal Data, taking into account the purposes for which they are processed, are erased or rectified;
• Storage limitation: FORWINNERS keeps Personal Data in a form which permits identification of data subjects only for as long as necessary for the purposes for which they are processed;
• Integrity and confidentiality: FORWINNERS ensures that your Personal Data are processed in a manner that ensures their security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by adopting appropriate technical or organisational measures.

Personal Data means any information and/or elements that, regardless of their medium, can identify you or make you identifiable, directly or indirectly, to FORWINNERS, in particular by reference to an identifier such as a name or identification number.

Processing of Personal Data means any operation or set of operations performed on the Personal Data of Data Subjects, whether or not by automated means, from collection to destruction. This cycle includes, among others, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure. The concept of Processing of Personal Data is very broad and applies to all operations or sets of operations carried out by FORWINNERS with respect to your Personal Data.

In the context of the activities carried out by FORWINNERS, the Data Subject is, without limitation, the customer and/or former customers, potential customers, investors, partners, job applicants, employees and former employees, employees of partners, suppliers and service providers and their employees, visitors and individuals captured on CCTV images, and all those natural persons who have a relationship with FORWINNERS to whom the Personal Data relate.

FORWINNERS processes Personal Data relating to a significant number of categories of Data Subjects. The Personal Data that FORWINNERS collects always depend on the nature of the interaction, but may include the following categories:

• Contact details;
• Commercial data for the provision of services and/or products;
• Relationship history;
• Security credential data;
• Social media data;
• IT usage data.

We note that you are not obliged to share your Personal Data with FORWINNERS. However, if you choose not to share your personal information, in some cases FORWINNERS may not be able to provide the services or supply the products you require, ensure certain specialised features, or respond effectively to any issue you may have.

The development and performance of the various activities pursued by FORWINNERS involve a relevant set of specific, explicit and legitimate purposes for the processing of your Personal Data, such as:

• Accounting, Tax and Administrative Management;
• Commercial and Marketing Activities;
• Profiling and Analysis;
• Capture and Recording of Images by CCTV Devices;
• Access Control Management;
• Human Resources Management;
• Electronic Communications Management;
• Litigation Management;
• Compliance with Legal Obligations.

In accordance with the principle of lawfulness enshrined in current and future data protection laws, in the development and performance of its activities, FORWINNERS only processes your Personal Data when there is a lawful basis that legitimises the processing, namely:

• Consent: FORWINNERS will only process your Personal Data if you consent to the respective Processing through a free, specific, informed and explicit expression of will, by which you accept, by written declaration or unequivocal positive act (e.g. by ticking a box), that your Personal Data be processed;
• Pre-contractual measures or performance of a contract: FORWINNERS may process your Personal Data if they are necessary, without limitation, for the performance of a service provision and/or product supply contract to which you are a party as Employee, Customer and/or Supplier, or to take pre-contractual steps at your request;
• Compliance with a legal obligation: FORWINNERS may process your Personal Data to ensure and guarantee compliance with legal obligations to which it is subject under the legislation;
• Protection of vital interests of the Data Subject: FORWINNERS may process your Personal Data to ensure the protection of your vital interests, particularly where such processing is essential to your life;
• Legitimate interests: FORWINNERS, other Controllers or Third Parties may process your Personal Data provided that such processing does not prevail over your interests or fundamental rights and freedoms.

FORWINNERS retains your Personal Data only for the period necessary for the execution of the specific purposes for which they were collected. However, FORWINNERS may be required to retain certain Personal Data for a longer period, taking into account factors such as:

• Legal obligations under applicable laws to retain Personal Data for a certain period;
• Limitation periods under applicable laws;
• (Potential) Disputes;
• Guidelines issued by the competent data protection authorities.

During the processing period of your Personal Data, FORWINNERS guarantees that they are processed in accordance with this Data Protection and Privacy Policy. As soon as your Data are no longer necessary, FORWINNERS will securely delete them.

FORWINNERS shares your Personal Data with:

• Processors: your Personal Data may be shared with companies entrusted with providing services to FORWINNERS. Service providers are bound to FORWINNERS by written contract and may only process your Personal Data for the specifically established purposes and are not authorised to process your Personal Data, directly or indirectly, for any other purpose, for their own benefit or that of a third party.
• Other Controllers and/or Third Parties: Your Personal Data may be shared internally with companies in which FORWINNERS participates, which will comply with the applicable data protection rules depending on the purposes assigned to the processing carried out.

At your request and with your consent, your Personal Data may be shared with other entities. In compliance with legal and/or contractual obligations, Personal Data may also be transmitted to judicial, administrative, supervisory or regulatory authorities and to entities that lawfully carry out data compilation actions, fraud prevention actions, market studies or statistics.

FORWINNERS may transfer your Personal Data outside the European Union, to locations that may not guarantee the same level of protection. However, FORWINNERS only transfers your Personal Data outside the European Union by means of binding rules applicable to FORWINNERS companies.

As the Data Subject of Personal Data processed by FORWINNERS, you have the right of access, rectification, restriction, portability, erasure and the right to object to the processing of Personal Data, under certain circumstances, which may be exercised in accordance with the terms of this chapter of the Data Protection and Privacy Policy. Namely:

• Right to be informed: You have the right to obtain clear, transparent and easily understandable information about how FORWINNERS uses your Personal Data and what your rights are;
• Right of access: You have the right to obtain information about what Personal Data FORWINNERS processes (if it is processing them) and how those Data are processed;
• Right to rectification: If your Data are incorrect or incomplete, you may request FORWINNERS to take steps to correct them;
• Right to erasure: Also known as the “right to be forgotten”, it allows you to request the deletion or removal of your data where there are no valid grounds for FORWINNERS to continue using them;
• Right to restriction of processing: You have the right to “block” or prevent future use of your Data while FORWINNERS assesses a rectification request or as an alternative to erasure;
• Right to data portability: You have the right to obtain and reuse certain Personal Data for your own purposes across different organisations;
• Right to object: You have the right to object to certain types of processing for reasons related to your particular situation;
• Right to lodge a complaint: You have the right to lodge a complaint with the competent supervisory authority (in Portugal, the National Data Protection Commission – CNPD) if you consider that the processing of your Personal Data violates your rights and/or applicable data protection laws.

You may at any time, in writing and free of charge (unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged taking into account the costs), exercise the rights enshrined in the Personal Data Protection Law and other applicable legislation through the following contacts:

Email: info@forwinners.pt
Postal address: Avenida 16 de Maio, Zona Industrial de Ovar, 3880-102, Ovar, Portugal.

Your Personal Data will be processed by FORWINNERS, in the context of the purposes identified in this Policy, in accordance with the internal policies and rules of the FORWINNERS Group and using appropriate technical and organisational measures to promote their security and integrity, particularly in relation to unauthorised or unlawful processing and accidental loss, destruction or damage.
FORWINNERS uses physical and digital security requirements and measures to protect your Personal Data, implements internal audit and control procedures, and periodically reviews its security policies and procedures to ensure that FORWINNERS systems are secure and protected.
However, since the transmission of information over the Internet is not completely secure, FORWINNERS cannot guarantee the security of your Data when transmitted over an open network.

FORWINNERS recognises that the information you provide may be confidential. FORWINNERS does not sell, distribute, or otherwise commercially make available Personal Data to any third party, except where it needs to share information with Service Providers for the purposes set out in this Data Protection and Privacy Policy. FORWINNERS preserves the confidentiality and integrity of your Data and protects them in accordance with this Policy and all applicable laws.

FORWINNERS Lda reserves the right to update this policy at any time in accordance with legal requirements and/or business needs. Users are therefore invited to visit www.forwinners.pt regularly to check our policy.
This Privacy Policy was last updated on 24 May 2018.