Privacy Policy and Personal Data Processing

Any nature, and regardless of support or format, namely sound, image, written, handwritten, or characteristic, related to an identified or identifiable natural person.

A person is considered identifiable if they can be directly or indirectly identified by reference to one or more specific personal data points, considered in isolation or in combination, particularly relating to their physical, physiological, psychological, economic, ethnic, cultural, geographic, social identity, or their location.

I – The entity responsible for the processing of personal data

The entity responsible for the collection and processing of personal data is Intervenção Eficaz which, in the context of its relationships with the data subject, always establishes on a lawful and legitimate basis, which data is collected, the means of processing, and the purposes of that collection and processing.

II – Types of personal data collected and processed

In the scope of its activity, Intervenção Eficaz collects and processes, namely:

  1. Personal data necessary for the provision and/or receipt of services and/or supply of products to its customers and/or suppliers, including data such as name, tax identification number, address, phone number, and email address, among others strictly necessary, proportional, and lawful.
  2. Personal data necessary for the execution of the employment contract or service agreements concluded with its employees, including data such as name, identification document number and other data thereof, tax identification number, family composition, social security number, address, phone numbers, and email address, health data, access data, location data, among others strictly necessary, proportional, and lawful.
  3. Personal data necessary for compliance with legal obligations, whether to public entities or private entities, including data such as name, identification document number and other data thereof, tax identification number, family composition, social security number, address(es), phone numbers, and email address, health data, among others strictly necessary, proportional, and lawful.
  4. Data necessary for:
    – managing clients and suppliers;
    – contracting and managing the contractual relationship with clients and suppliers;
    – tailoring the provision of services to meet the needs and interests of the client;
    including sending suggestions, information and marketing actions, informing about campaigns, promotions, advertising, and news regarding services and/or products, conducting market research and/or satisfaction surveys, and managing complaints. This involves handling data such as addresses, phone numbers, and email addresses, among others that are strictly necessary, proportional, and lawful.
  5. All personal data necessary for the exercise of Intervenção Eficaz's rights within the scope of the aforementioned relationships, and in pursuit of its activities and legitimate interests, specifically includes: accounting, tax, and administrative management; litigation management; judicial proof; fraud detection; revenue protection and auditing; network and systems management; information security and physical security control; and the security of facilities.

Notwithstanding compliance with legal norms or legitimate orders from competent authorities regarding the retention and transmission of data, Intervenção Eficaz processes only the personal data necessary for its activities, in the fair and strict measure required by the nature of the contractual or other relationship established with the data subject, or from the subject’s prior, legitimate, lawful, and informed consent, if applicable.

III – Timing and Method of Personal Data Collection

Intervenção Eficaz collects personal data in person, in writing, by phone, by email, or through its website.

As a general rule, personal data is collected when the contractual or other necessary relationship for the pursuit of Intervenção Eficaz's activities begins between the company and the data subject.

Our websites may collect data through contact forms. This data is sent directly to our email server via an encrypted connection and is accessible only to our contact processing officer. Whenever necessary, the information will be made available to a responsible person in a specific department for the resolution of the request.

Some personal data is mandatory and necessary for the initiation and normal and legal development of the aforementioned relationship or collaboration. Therefore, if such data is missing or insufficient, the relationship or collaboration will neither commence nor continue. In such cases, Intervenção Eficaz will inform the data subject of the mandatory and necessary nature of the data.

Aside from data of that nature, data listed in any public lists, and data that can be used for the legitimate interest of Intervenção Eficaz, your data will only be collected and processed if and for the purposes you have previously consented to, freely, informedly, specifically, and unequivocally, through written, oral declaration, or by validating an option, such as subscribing to newsletters or marketing communications. In such cases, the other rules of this privacy policy will also apply.

If you wish to stop receiving these communications, you can object at any time.

The collected data will be processed in documentary form, whether on paper or digital support, in strict compliance with the legislation regulating the protection of personal data. The data will be stored and contained in paper files and/or specific databases, created and managed for this purpose, with restricted and exclusive access to Intervenção Eficaz employees who need to process the data in the course of their activities. Under no circumstances will the collected data be used for purposes other than those for which consent was given by the data subject, if necessary, or for the lawful and legitimate purpose that justified the collection.

IV – Purposes of Collecting and Processing Personal Data

In general, the personal data collected are intended for managing clients, suppliers, and employees, for contracting and managing contractual relationships with clients, suppliers, and employees, for receiving and/or providing the contracted services/supplies, for adapting service/supply delivery to the needs and interests of the client, for sending suggestions, conducting information and marketing actions, informing about campaigns, promotions, advertisements, and news about services and/or products, for carrying out market studies and/or satisfaction surveys, for managing complaints, for accounting, fiscal, and administrative management, for managing litigation, for legal proof, for fraud detection, revenue protection and auditing, network and system management, information and physical security control, facility security, compliance with legal obligations, and for other purposes where the law recognizes Intervenção Eficaz's legitimate interest.

When collecting the data, or upon request, you will be provided with more detailed information about how we handle your data.

V – Data Retention Periods for Your Personal Data

Whenever there is a specific legal requirement mandating the retention of data for a minimum period, Intervenção Eficaz will comply with this requirement.

Intervenção Eficaz will retain your personal data for the minimum period strictly necessary for the purpose for which the information is collected and processed. After this period, the data will be deleted.

VI – Rights of Access, Rectification, Opposition, Erasure, Restriction, and Portability of Your Personal Data

Intervenção Eficaz guarantees to data subjects the right of access, rectification, opposition, erasure, restriction, and portability of their personal data.

These rights can be exercised by phone at +351 225 573 090 or through written communication sent to the postal address Rua 1º de Maio, 655, 4445-242 Alfena, or electronically to geral@ieficaz.com.

If you find it relevant, you may submit a complaint to the National Data Protection Commission at Av. D. Carlos I, 134 – 1st floor, 1200-651 Lisbon – Tel.: +351 213 928 400 – Fax: +351 213 976 832 – email: geral@cnpd.pt.

VII – Measures We Take to Ensure the Security of Your Personal Data

Intervenção Eficaz adheres to best practices and has adopted appropriate technical and organizational measures to manage risks related to the security and protection of personal data. We have approved and implemented a rigorous compliance plan that aligns with legal requirements and the interests of data subjects. This plan ensures the protection of data provided to us by anyone who interacts with us, safeguarding it against dissemination, loss, misuse, alteration, processing, or unauthorized access, as well as any other form of unlawful processing.

Thus, the digital or paper personal data collection forms, whether completed at Intervenção Eficaz premises, on our websites (which require encrypted browser sessions), or with any of our employees, are securely stored in our physical repositories and digital systems.

All personal data you provide to us is stored in a data center owned by Intervenção Eficaz or one of its subcontractors, protected by advanced physical and logistical security measures that we deem essential for safeguarding your personal data.

Whenever, in the legitimate and lawful pursuit of its objectives, Intervenção Eficaz implements measures to monitor its employees, particularly regarding access control, working hours, tasks and productivity, and movement and transportation, the affected individuals will be informed in advance about the implementation of such measures. Whenever legally required and permissible, their consent will be sought. The tools used for this purpose will ensure the same level of security for the personal data collected and processed.

As part of the compliance and security plan, there is a designated Data Protection Officer (DPO) whose responsibilities include, among other tasks, reviewing this Privacy Policy, maintaining clear rules for the processing of personal data, and communicating with regulatory authorities. The DPO ensures that all individuals who entrust their personal data to Intervenção Eficaz are effectively informed about how their data is processed and their rights regarding this matter.

VIII – Communication of Data to Other Entities, Subcontractors, or Third Parties

Intervenção Eficaz may engage subcontractors for the collection and processing of personal data, with the same purposes as those pursued by Intervenção Eficaz. In such cases, Intervenção Eficaz ensures that these entities provide contractual assurances of their reputation and commit to implementing appropriate technical and organizational measures for data protection, as well as safeguarding the rights of data subjects. Under certain legal circumstances, personal data may need to be communicated to public authorities, such as tax authorities, courts, and law enforcement agencies.

Therefore, any of these subcontracted entities will process our Clients' personal data on behalf of and under the instruction of Intervenção Eficaz, with an obligation to implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized dissemination or access, and against any other form of unlawful processing.

IX – Transfer of Personal Data

The operation of Intervenção Eficaz may involve the transfer of your data outside of Portugal.

In such cases, Intervenção Eficaz will strictly adhere to applicable legal provisions, particularly regarding the determination of the reliability and adequacy of the destination country concerning the protection of personal data and the requirements applicable to such transfers.

X – Cookies:

"Cookies" are small pieces of software that are stored on your computer via the browser. Generally, they only retain information related to your preferences and do not include your personal data.

Whenever this is not the case, the user will always be asked for consent to provide them, in accordance with legal requirements.