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PRIVACY POLICY

  1. SCOPE

SUMOL+COMPAL's Privacy Policy covers all the companies that are part of the SUMOL+COMPAL Group and is based on the principles expressed below.

  1. PRIVACY STATEMENT

SUMOL+COMPAL is committed to protecting the privacy of its Customers and Suppliers, as well as that of Users of the various websites owned by the various companies and brands of the SUMOL+COMPAL Group.

In this context, it prepared this Privacy Policy in order to demonstrate its commitment and respect for the Privacy rules, as well as compliance with all legal provisions in force regarding the protection of personal data, namely those contained in the General Regulation of Data Protection (RGPD).

The rules provided for in this Privacy Policy complement the provisions on the protection and processing of personal data provided for in contracts that have been signed with the various companies of the SUMOL+COMPAL Group, as well as the rules provided for in the Terms and Conditions of Contests and Campaigns and which are duly advertised on the websites of the SUMOL+COMPAL Brands, as well as in the General Conditions of use of the various websites of the SUMOL+COMPAL Brands.

  1. ENTITY RESPONSIBLE FOR DATA PROCESSING

Without prejudice to the content of this Policy, SUMOL+COMPAL is the entity responsible for processing the personal data of its customers and/or potential customers, so it is available to provide any information or clarify any doubts you may have regarding the collection, processing or protection of your personal data and your rights as data owner, so you can send your questions to:

SUMOL+COMPAL Marcas, S.A.

Privacy Officer

  1. Dr. António João Eusébio, no. 24, 2790-179 Carnaxide

Telephone: 214200082

E-mail address: privacy@sumolcompal.pt

  1. PERSONAL DATA

The RGPD defines "personal data" broadly as "information relating to an identified or identifiable natural person". An identifiable person is considered to be a person who can be identified, directly or indirectly, through, for example, the name, personal identification number, location data, an electronic identifier or other elements that allow for the identification of that natural person.

SUMOL+COMPAL, within the scope of its activity, collects and processes the personal data necessary for the provision of services and the supply of products, dealing in this context with data such as name, address, age, personal identification number and tax, telephone number, mobile number and e-mail address, among others. SUMOL+COMPAL may also collect other data, depending on the moment and the activity it intends to develop.

  1. DATA COLLECTION

Personal data will be collected directly from the respective holder, always ensuring that SUMOL+COMPAL obtains prior consent and provides all legally required information. When data are collected as part of a legal obligation or pursuant to a contract, this consent may be waived.

SUMOL+COMPAL collects data in writing or through its websites, with the consent of the holder. As a rule, personal data are collected when the Customer interacts with the services or campaigns provided by SUMOL+COMPAL.

Some personal data must be provided and, in case of lack or insufficiency of such data, SUMOL+COMPAL will not be able to provide the product or service in question, whereby Customers will be informed of the mandatory nature of the provision of the data.

  1. PURPOSES OF PROCESSING PERSONAL DATA

Without prejudice to compliance with the legal norms relating to the conservation and transmission of data, SUMOL+COMPAL only processes data that are necessary to fulfil the purpose for which they were collected. Upon obtaining consent, Customers, suppliers and users of the websites owned by the various companies and brands of the SUMOL+COMPAL Group will be informed of the purpose of the collection, as well as more detailed information on  SUMOL+COMPAL's use of your data.

Usually, SUMOL+COMPAL collects your personal data for marketing purposes (development of competitions and campaigns), sending prizes, managing the contractual relationship, providing contracted services, adapting services to the Customer's needs and interests, adapting offers Customers' needs, information actions or even to answer questions that the Customer may address to SUMOL+COMPAL or other communications that it triggers.

Data may also be requested for other purposes, such as for the purposes of sending complaints and suggestions or disseminating institutional information from the Group.

Note that, under the RGPD, the use of personal data must be justified on at least one legal basis. With regard to SUMOL+COMPAL, this use takes place in the following situations: (a) processing takes place based on the consent of the data subject for this purpose (the consent may, at any time, be withdrawn); (b) is necessary to conclude a contract with the data subject or to carry out the same; (c) is necessary to comply with the legal obligations to which SUMOL+COMPAL is subject; (d) it is necessary to achieve a legitimate interest and SUMOL+COMPAL's reasons for its use prevail over the data protection rights of the respective holders; (e) it is necessary for the declaration, exercise or defense of a right in a legal proceeding.

  1. USE OF SUMOL+COMPAL BRANDS WEBSITES

Users of the SUMOL+COMPAL website or other websites of its brands can browse these sites without being required to provide any personal information. However, for different reasons, information of this nature is occasionally requested, namely within the scope of the request for information or participation in competitions.

The Client or user, by making their data available to SUMOL+COMPAL, is consenting to their being treated in accordance with this Privacy Policy. Without prejudice, SUMOL+COMPAL will not fail to respect the forms of obtaining consent and providing all legally required information.

The personal data collected through the use of the various websites of the SUMOL+COMPAL Brands are processed by computer and in strict compliance with the legislation for the protection of personal data, being stored in a specific database created for this purpose and, under no circumstances will the data collected be used for a purpose other than that for which consent was given by the data subject.

  1. DATA SHARING

Within SUMOL+COMPAL, employees who need them have access to data to comply with contractual/pre-contractual and legal steps or obligations. It is possible that, from time to time, other companies in the SUMOL+COMPAL Group are responsible for the treatment, so information will be provided in this regard whenever justified.

The personal data collected may also be shared with subcontractors, so that they are responsible for ensuring part or all of the purposes for which the data has been collected. Personal data collected with subcontractors may also be shared, for the purposes of hosting and managing IT equipment and systems.

In these cases, SUMOL+COMPAL undertakes to ensure its security and privacy policy with these entities, through a rigourous selection, ensuring that the subcontracted entities ensure compliance with the rules imposed by the applicable legislation regarding procedures of data protection concerns, as well as guaranteeing the exercise of the rights of the subjects of the personal data in question.

Finally, SUMOL+COMPAL may also share your data with the Tax Authority, regulatory or judicial entities, when this is legally required.

Finally, SUMOL+COMPAL may also share your data with the Tax Authority, regulatory or judicial entities, when this is legally required. With regard to SUMOL + COMPAL, this use takes place in the following situations: a) processing takes place based on the consent of the data subject for this purpose (the consent may, at any time, be withdrawn); (b) if it is necessary to conclude a contract with the data subject or to carry it out; (c) if it is necessary to comply with the legal obligations to which SUMOL+COMPAL is subject; (d) if it is necessary to achieve a legitimate interest and SUMOL+COMPAL's reasons for its use prevail over the data protection rights of the respective holders; (e) if it is necessary for the declaration, exercise or defence of a right in a legal proceeding.

  1. PERSONAL DATA STORAGE TIME

The period of time for which data is stored and kept varies according to the purpose for which the information is processed.

Whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that motivated its collection or subsequent processing or, if any, for the period of time authorized by the National Data Protection Commission. Once the maximum retention period is reached, your personal data will be irreversibly anonymized (and the anonymized data may be preserved) or will be securely destroyed.

When there are legal requirements that oblige you to retain data for a minimum period of time, the data will be kept for that period of time.

  1. RIGHTS OF PERSONAL DATA HOLDERS

Under the law, the data subject is guaranteed the following rights: right of access, rectification, limitation or opposition, portability, oblivion, opposition to automated decisions and profile definitions.

SUMOL+COMPAL guarantees to the holders of legitimately collected data the exercise of these rights.

In particular, it should be noted that SUMOL+COMPAL guarantees that the data subject may, at any time, object to the processing of their data and/or request that it be forgotten.

Without prejudice to the exercise of the rights of the respective holder, the right to oblivion can only be exercised when (i) the data are no longer necessary for the purpose for which they are processed (when its processing period expires), (ii) consent is withdrawn by the holder, (iii) if the latter is opposed to the treatment of data for a valid reason and there are no prevailing interests for the treatment of data to take place, (iv) if the data is used illegally or have to be deleted according to the law, or if they ( v) concern minors under the age of 16, to the extent that consent is not given or authorized by the holders of the minor's parental responsibilities.

The exercise of any rights may be carried out through the email address privacy@sumolcompal.pt or through the other contacts that SUMOL+COMPAL makes available above.

Note that data subjects also have the right to file a complaint with the National Data Protection Commission (www.cnpd.pt).

  1. PERSONAL DATA SECURITY MEASURES

SUMOL+COMPAL is committed to ensuring the protection of the security of the personal data made available to it, having approved and implemented strict rules in this matter.

SUMOL+COMPAL adopted several security measures, of a technical and organizational nature, in order to protect the personal data provided against its dissemination, loss, misuse, alteration, processing or unauthorized access, as well as against any other form of illicit treatment.

We highlight the following measures:

a) Security of facilities: entry into the facilities (including subcontracted entities) is restricted to workers and, in exceptional cases, to individuals who are duly authorized by SUMOL+COMPAL;

b) Video Surveillance Cameras, to ensure the physical security of workers and documents;

c) Access to computer systems protected by login and password, with different security levels and which must be periodically changed;

d) Personal data collection forms require encrypted browser sessions;

e) Access by passwords, shared folders referring to each subject and physical files with limited access.

Note that all personal data obtained are securely stored in SUMOL+COMPAL's systems.

SUMOL+COMPAL will guarantee the fulfilment of its communication obligations, in the legal terms, in case of loss or misuse of personal data whose treatment it assures.

  1. "COOKIES"

"Cookies" are small software tags that are stored on users' computers through the browser (browser), retaining only information related to their preferences, not including personal data, as such.

Users can allow, block or delete Cookies installed on their equipment by configuring browser options. Please read your browser's help section carefully to find out more information on how to enable "private mode" or unlock certain cookies.

  • Internet Explorer: Tools -> Internet Options -> Privacy -> Settings. For more information, you can consult Microsoft support or browser Help.
  • Firefox: Tools -> Options -> Privacy -> History -> Custom Settings. For more information, you can consult Mozilla support or browser Help.
  • Chrome: Settings -> Show advanced options -> Privacy -> Content settings. For more information, you can consult Google's help centre or browser Help.
  • Safari: Preferences -> Security. For more information, you can consult Apple support or browser Help.

To learn more about cookies, visit http://www.youronlinechoices.com/pt/

  1. CHANGES TO SUMOL+COMPAL'S PRIVACY POLICY

SUMOL+COMPAL reserves the right, at any time, to make readjustments or changes to this Privacy Policy, and these changes are duly publicized on the various websites of the companies and brands of the SUMOL+COMPAL Group.

This Privacy Policy will be periodically revised to ensure its permanent adequacy and adaptation to the highest standards of rigor with regard to data protection.

The use of the services after these changes implies acceptance of the privacy policy and future updates.

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