AGRO.GES – Sociedade de Estudos e Projetos, Lda., with head office at na Avenida da República, nº 412, parish of Cascais, with the zip code 2750-475 Cascais, legal and fiscal person no. 502 467 380, (hereinafter referred to only as “AGRO. GES”) is a Company primarily dedicated to the provision of consultancy services in the fields of agriculture, forestry, agro-industrial and rural development, namely: the preparation and implementation of studies, projects, consultancy and opinions, commissioned by national or foreign entities; the preparation and monitoring of investment projects; the preparation and monitoring of applications for existing public support; the organization of seminars; real estate valuation; the preparation and execution of pilot, research and demonstration projects, and the like.
As part of its activity, AGRO.GES collects personal data, either in person or remotely, ensuring that its processing is done in accordance with the privacy protection rules originating in Regulation (EU) 2016/679 (“GRDP”) and other applicable national legislation, as well as in accordance with the confidentiality obligations to which AGRO. GES is subject.
The data collected correspond to data that are provided by the holders themselves or their legal representatives by filling out forms, sending emails, delivering various documentation (both on paper and digital format) or personal data resulting from the working relationships that AGRO.GES establishes with its customers, including data that arrives through the use of AGRO.GES’ digital channels, namely Facebook, Linkedin, etc.
RESPONSIBLE FOR TREATMENT
The entity responsible for the processing of personal data is AGRO.GES, in so far as it is responsible for determining the purposes and means of processing the data which it has in its possession.
DATA PROCESSED BY AGRO.GES
What is personal data?
Personal data means any information, of any nature and regardless of its format, relating to an identified or identifiable natural person. A person who can be identified directly or indirectly, in particular by reference to an identification number or one or more specific elements of his physical, physiological, psychological, economic, cultural or social identity, shall be considered identifiable.
Who are the personal data subjects?
The subjects of personal data are the Clients, as well as Partners, Employees, or natural persons to whom the data relate and who enjoy AGRO.GES’ services, collaborate, enter into relationship, or are in any contact had with AGRO.GES.
What is the personal data?
They correspond to all the data necessary for the relationship with customers and others related to them, which are provided by the subjects themselves or their legal representatives, in particular by filling out forms, sending emails, or even the personal data resulting from these same relationships, such as the information provided by the clients in the context of consulting or other work they decide to do with AGRO.GES.
Personal data collected by AGRO.GES are treated, namely, for the following purposes:
- The provision of consultancy services, in pursuit of AGRO.GES’ corporate purpose;
- Communication of an administrative nature;
- Compliance with legal obligations;
- AGRO.GES’ Financial and economic management;
- Preparation and follow-up of applications to existing public grants;
- Historical record of AGRO.GES’ activity, in particular the maintenance of an updated curriculum of the work carried out;
- Human resources management;
- Participation in Seminars;
- Preparation of reports and presentations;
- Sending a newsletter and other business information;
- Regular sending of information on relevant events in the sector where AGRO.GES operates;
- Publicizing of AGROGES activities;
- Management of social networks (Instagram, Facebook, etc.);
- The adoption of means and procedures for the safety of persons and property; this purpose may entail, in certain cases, the collection of images in the context of video surveillance.
It should be made clear that the purposes here mentioned are not the only ones, and others may derive from these as far as possible. If there is a new purpose independent of the previously mentioned, AGRO.GES will inform, on a case-by-case basis, the holder at the time of collection of the personal data.
FOUNDATION FOR DATA PROCESSING
AGRO. GES will only process personal data to the extent that the processing is lawful and necessary. The processing of personal data is only lawful if and to the extent that at least one of the following situations occurs:
Where the data subject has given his/her prior express written consent orally (after ratification, where necessary), or by validating an option, if such consent is free, informed, specific and unequivocal for the processing of his/her personal data for one or more specific purposes referred to above.
Compliance with contractual obligations and pre-contractual procedures:
Where the processing of personal data is necessary for the fulfilment of contractual obligations to which the data subject is a party, or for pre-contractual steps at the request of the data subject, such as for the performance of an assignment, response to a consultation, or the preparation of a service proposal.
Compliance with legal obligations:
When the processing of personal data is necessary to comply with a legal obligation to which AGRO.GES is subject, such as the communication of identification data to police, judicial, tax or regulatory bodies.
Where the processing of personal data corresponds to AGRO.GES’ legitimate interest or that of third parties (e.g. the processing of data to improve the quality of service) and when AGRO.GES’ reasons to use the information should prevail over data protection rights.
Defense of the vital interests of the data subject or of another natural person:
The processing of personal data should also be considered lawful where it is necessary to protect an essential interest in the life of the data subject or any other natural person. In principle, the processing of personal data on the basis of the vital interest of another natural person may take place only where the processing cannot be clearly based on another legal basis. Some types of processing can serve both important public interests and vital interests of the data subject, for example if processing is necessary for humanitarian purposes.
Exercise of functions of public interest:
Where treatment is necessary for the performance of public interest functions, or for the exercise of the public authority vested in the controller.
DATA COMMUNICATION AND SUBCONTRACTORS
AGRO. GES shall not transmit personal data to third parties, except in the conditions under which there is at least one of the following situations:
- It has obtained express consent to that effect from the information subject;
- communication is necessary for the performance of a contract to which the subject is a party;
- transmission is made in the context of the fulfilment of a legal obligation or for the fulfilment of a court order;
- communication is carried out for any legitimate purpose provided for by law.
AGRO. GES is obliged by law to communicate personal data of its customers and employees to regulatory authorities that oversee its activity, and to other public authorities/official entities (such as the Ministry of Agriculture and its bodies, the Tax and Customs Authority, Social Security, etc.).
Finally, AGRO.GES may use service providers, in the course of its activity, who may have access to personal data. Such service providers/subcontractors will process personal data provided exclusively for the purposes set out by AGRO.GES and, in compliance with the instructions transmitted by it.
AGRO. GES ensures that, in these circumstances, it adopts all technical and organizational measures deemed appropriate to ensure that subcontractors are reputed and offer the highest guarantees of information security. These entities also guarantee compliance with the applicable legislation on confidentiality, privacy and protection of the data subjects, including with respect to the exercise of their rights.
RETENTION PERIOD OF PERSONAL DATA
The processing of data by AGRO.GES will remain as long as the data are necessary for the relationship established with its holders. After the relationship, AGRO.GES will retain personal data only for the period of time necessary for the accomplishment of the defined purpose and/or mandatory legal deadlines, or until the rights and duties arising from this relationship prescribe, in accordance with the law.
RIGHTS OF THE HOLDERS
Under applicable law, the Holders of personal data have the following rights:
- Information Right , the right of the Holders to be informed by AGRO.GES, on all aspects relating to the collection and processing of their personal data, in particular on: (i) the purposes of the processing of their data, (ii) to whom they may be communicated, (iii) what rights they have and (iv) under what conditions they may exercise them, as well as (v) what data they must provide in the context of the relationship established with AGRO.GES, in a clear, concise and transparent way;
- Right of Access , the right of the Holders to access the personal data that have been provided, without restrictions, without delay or excessive costs, as well as to know any information available about the origin of such data;
- Right of Rectification , the right of the Holders to require that their data be accurate and current, and may request its rectification with AGRO.GES;
- Right of Deletion (or “forgetfulness”), the right of the Holders to require the deletion of their personal data from AGRO.GES’ records when they are no longer used for the purposes for which they were collected, without prejudice, however, to the retention periods applicable by law and their respective treatment;
- Right of Opposition , the right of the Holders to be opposed, at their request and free of charge, to the processing of their personal data for the purposes of direct marketing;
- Right to Portability , the right of the Holders to receive their personal data provided to AGRO.GES, in a structured format, of current use and automatic reading, and transmit this data to another controller, where technically possible.
- Right to Limitation of Treatment , the right of the Holders to, in certain circumstances, request AGRO. GES to limit the processing of their data, namely: (i) when they dispute the accuracy of their personal data, for a period that allows AGRO. GES check its accuracy; (ii) if the processing is unlawful and the Data Subject opposes the erasure of the data, requesting, on the other hand, the limitation of its use; or (iii) when AGRO. GES no longer needs the Personal Data of the Holder for processing purposes, but such data are required by the Holder for the purpose of declaration, exercise or defense of a right in a judicial process;
- Right to Complaint to the CNPD , the right to lodge, without prejudice to any other means of administrative or judicial appeal, a complaint to a supervisory authority, in particular in the Member State of his habitual residence, his place of work or the place where the infringement was allegedly committed, if the data subject considers that the processing of personal data concerning him/her violates the GDPR and other national legislation applicable. In Portugal, the supervisory authority is the National Data Protection Commission (CNPD).
If the processing of the data is based on consent, the holder has the right to withdraw consent at any time, without compromising the lawfulness of the processing carried out on the basis of the consent previously given.
The exercise of any of its rights is guaranteed to the Holder upon written request addressed to AGRO.GES, sent by registered mail to:
AGRO.GES – Sociedade de Estudos e Projetos, Lda.
Avenida da república, nº 412
Or alternatively, via the following email address: firstname.lastname@example.org
The provision of incorrect or inaccurate data is the sole responsibility of the data subject.
AGRO.GES collects and processes the personal data necessary for the availability and operation of its Website, also called Digital Channels, while ensuring adequate levels of security and protection of personal data to the data subjects who use them and provide personal data through them.
The website owned by AGRO. GES is as follows: http://www.agroges.pt
Thus, several physical, logical, technical and organizational security measures were adopted in order to protect personal data against its dissemination, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of unlawful processing.
Despite the security measures adopted by AGRO. GES, the Owner/User of the Digital Channels shall keep secret the access codes that he/she may have, not sharing them with third parties, and shall, in the particular case of mobile devices, maintain and store the device on which he accesses the Digital Channels in security conditions and follow the security practices advised by the manufacturer and/or operator, installation and updating of the necessary security applications, including antivirus.
AGRO. GES uses in its Digital Channels “cookies”, understood as such small text files with relevant information stored on the access device (computer, mobile phone/smartphone, tablet or other) and uploaded by the internet browser (browser) when a website is visited by the Owner/User, namely allowing to store and retrieve information about the browsing habits of a user of a device, and, depending on the information they contain, and how the equipment is used, may be used for the recognition of the Holder/User.
The “cookies” used by AGRO. GES respect anonymity and will not be used to collect any personal information.
The use of “cookies” is a normal practice between internet websites, and through most browsers the user can allow, block or delete the “cookies” installed on his device, by configuring the options. If the information subject blocks them, certain services that require them may not be available for use.
If the Holder wants to restrict, block or delete the cookies of this website he/she can disable cookies by modifying browser settings (the parameterization of each browser is different so they should read the instructions and manuals of your browser for more information about the operation and control of cookies). However, if the holder selects this setting they may not be able to access certain parts of the AGRO.GES website or navigation may become less effective.
These Digital Channels may contain links to other websites on which AGRO. GES does not exercise any control, nor is it responsible for its content. The inclusion of links to other websites is made solely as an informative reference and without binding or liability for the contents, owners, services or products offered. AGRO.GES reserves the right to require the withdrawal of any link it deems inappropriate, and this criterion is its sole responsibility. The content of the Digital Channels owned by AGRO. GES may not be fully or partially integrated into the structure of any other website without AGRO.GES’ express permission.
In the development of its service provision offer, AGRO.GES also uses third-party digital platforms, such as “WordPress”, “Mailchimp”, and social networks (Facebook, Linkedin, Instagram, etc.). Providers of these software services are considered subcontractors for data protection and therefore included in the chapter on data protection. For more information, the Holder/User should become aware of the Privacy Policies of the respective platforms, which bind the respective owners and not AGRO.GES.
PROTECTION AND CONFIDENTIALITY MEASURES
AGRO. GES is committed to ensuring the security and confidentiality of personal data collected and processed.
To this end, AGRO.GES adopts various security measures, of a technical and organizational nature, in order to protect personal data against dissemination, loss, misuse, alteration, processing or unauthorized access, as well as against any other form of unlawful processing.
Such measures include, inter alia, the following:
- the protection of information technology systems through firewalls in order to minimize the risk of unauthorized access;
- regular monitoring of access to information technology systems with the aim of preventing and detecting the misuse of personal data.
In addition, AGRO.GES requires its partners to adopt the security measures, of a technical and organizational nature, equivalent to those it practices.
AGRO.GES is also committed to maintaining the confidentiality of your information, so it does not distribute or commercially make your personal information available to any partner.
All employees are covered by a confidentiality agreement or subject to confidentiality rules, within the framework of the employment relationship with AGRO.GES, in relation to the data to which they have access in the course of the exercise of their activity, being duly informed of the importance of fulfilling this legal duty of confidentiality and being responsible for the fulfillment of this obligation of confidentiality.
AGRO.GES reserves the right to change this policy from time to time. The date of the last modification is indicated at the end of this document. If AGRO.GES is to make changes to this policy and the way it uses the personal data of the Data Subject, an updated version will be provided through the publication on AGRO.GES’ website.
Last Updated: 25/05/2018