POLITIQUE DE CONFIDENTIALITÉ

The user or subscriber, person, to whom the data relate and who has used the services or products of AFJ. The User will be the person who uses or exploits AFJ products and the Subscriber is the person who subscribes to AFJ’s forms of dissemination, namely newsletters and e-books.

Regardless of this distinction, AFJ informs that it also protects personal data and respects the rights of users and subscribers.

Identification and contacts
Name, telephone contact or email address, date of birth and VAT number.

Profile
Company in which you work and role performed.

Service usage data
Location: geographical reference at a given moment (request for information or subscription).

The person responsible for the collection and processing of your personal data will be AFJ and in this scope decides what data collected, means of treatment and purposes for which the data are used.

Note: In the scope of its activity, AFJ will be able to access personal data of clients (e.g. correction of a database), not having any intervention either in the control or in the processing of the same. In any case, there is a commitment to confidentiality in order to assure customers that they will not use the same data for any purpose.

1. Consent

When we have your express consent – in writing, orally or through the validation of an option – and prior and if such consent is free, informed, specific and unambiguous. Examples are your consent to AFJ to analyse the use of services and consumer profile and make recommendations or send marketing messages (email marketing, SMS marketing, among others).

or

2. Contract execution and pre-contractual procedures

When the processing of personal data is necessary for the celebration, execution and management of the contract concluded with AFJ, such as for the preparation of a service proposal, for the management of contacts, information and requests, for the management of invoicing, collection and payments;

or

3. Legitimate interest

When the processing of personal data corresponds to a legitimate interest of AFJ or of third parties. E.g.: to respond to a request for contact.

Your personal data are treated by AFJ only for the period of time necessary to achieve the defined purpose or, depending on what is applicable, until you exercise your right of opposition, right to be forgotten or withdraw consent. After the respective storage period has elapsed, AFJ will eliminate or anonymize the data when they are not to be stored for a different purpose that can be maintained.

AFJ treats and preserves your personal data according to the purposes for which they are processed.
There are cases in which the law requires the processing and preservation of data for a minimum period of time, namely: for 10 years the data necessary to informe the Tax Authority for accounting or tax purposes.

But, where there is no specific legal obligation, then the data will be processed only for the period necessary to fulfil the purposes that led to their collection and preservation and always in accordance with the law, guidelines and decisions of the CNPD. Thus, AFJ will treat and maintain your personal data for the period in which it has a contractual relationship with you.

AFJ may keep other personal data for periods longer than the duration of the contractual relationship, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that justify it, but always for the period strictly necessary to the fulfilment of the respective purposes and in accordance with the guidelines and decisions of the CNPD, namely the contact for marketing and sales purposes
.

We collect personal data by your consent when you purchase AFJ products or services or when you download or use our brand marketing and sales materials. The collection can be done orally, in writing or through the AFJ website. But your personal information may also be collected from sources accessible to the public or other sources.

AFJ’s cookie policy is an additional form of personal data collection for the purpose of detecting and correcting problems on the website, providing strong and comfortable digital experiences, streamlining navigation on the pages of the channel. Cookies are pieces of data, such as names and email addresses, that are stored by a website on your first visit. In subsequent visits, the website can already identify the visitor as not being new, for example.

AFJ uses Google Analytics as the main tracking system for the consumer journey on all digital channels of the company, such as the website, blog and social networks. Our purpose in using this tracking tool is to monitor traffic, identify trends, and analyse behaviours, always to verify the performance of digital marketing campaigns and to implement improvements in them.

AFJ uses E-Goi as an email marketing management system. The Portuguese company’s mission is to create effective digital communication solutions in the following segments: email marketing, smart sms, autobots and marketing automation. The E-Goi datacentre is located in Portugal and has its own AS (where is all the information about its customers, including TEOCOCIL). Of note is the anonymity of information flow outside the databases of each client and of firewalls configured in the regime of semi-independent fortifications.

Address
Avenida Menéres, 834
4450-190 Matosinhos
Portugal

See below your rights and the detail of what is safeguarded in each one.

Right of access

Right to obtain confirmation of your personal data that are processed and information about them, such as, what are the purposes of the treatment, what are the conservation periods, among others. Right to see / hear or obtain a copy, for example of invoices or written agreements in which it is intervening.

Right of rectification

Right to request the rectification of your personal data that are inaccurate or to request incomplete personal data to be completed, such as address, email, telephone contacts, or others.

Right to erase data or « right to be forgotten »

Right to obtain erasure of your personal data, since there are no valid grounds for its conservation, such as the cases in which AFJ has to keep the data as required by official entities.

Right to portability

Right to receive the data you provided us in digital format of current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new responsible for your personal data.

Right to withdraw consent or right of opposition

Right to object or withdraw consent at any time to data processing, for example in the case of data processing for marketing purposes, since there are no legitimate interests that prevail over your interests, rights and freedoms.

Right of limitation

Right to request the limitation of the processing of your personal data, in the form of:

1. Suspension of treatment
2. Limitation of the scope of treatment to certain categories of data or treatment purposes.

Automated profile and decisions

AFJ can profile clients based on their preferences, personal interests, service utilization, location, among other indicators, namely to provide services, increase the quality and experience of products and services, tailor marketing communications etc. However, such treatment must be based on the consent of the holder.

When the processing of personal data, including processing for profiling, is exclusively automatic (without human intervention) and can have effects in its legal area or significantly affect it, it shall have the right not to be subject to any decision based on that automatic treatment, except as provided by law, and shall have the right to have AFJ to take appropriate measures to safeguard your rights and freedoms and legitimate interests, including the right to have human intervention in the decision making by AFJ the right to express their point of view or contest the decision taken on the basis of automated processing of personal data.

Right to complain

Right to submit a complaint to the supervisory authority, the CNPD, in addition to the company.

CNPD – Comissão Nacional de Proteção de Dados
Rua de São Bento, n.º 148-3º
1200-821 Lisboa
W.: www.cnpd.pt
E-mail: geral@cnpd.pt
P. (+351) 213 976 832

AFJ has implemented the appropriate logical, physical, organizational and security measures necessary and sufficient to protect your personal data against destruction, loss, alteration, unauthorized access or any other form of accidental treatment or illicit.

We have implemented:

1. Logical security requirements and measures, such as the use of firewalls and intrusion detection systems in their systems, the use of backups, the existence of a strict policy on access to systems and information and the recording of actions taken by AFJ employees on personal data of customers or users (logging);

2. SSL / HTTPS protocol: As soon as the user accesses a site with the HTTPS protocol, all communications between the user and the online store are encrypted. The HTTPS protocol is used to protect transactions and transmission of confidential data as is the case in e-Commerce and e-Banking systems;

3. Scrutiny, audit and control mechanisms to ensure compliance with security and privacy policies;

4. An information and training program for AFJ employees;

AFJ undertakes to notify the entity that regulates the GDPR (the National Data Protection Commission in Portugal) of the problem within 72 hours after the verification of the security problem as well as all the intended holders / clients.

The cache of a web browser or search engine is the instrument through which the browser saves data, namely images and HTML code, needed to load and display a website. AFJ’s intention in using this device is to help bandwidth and provide a better browsing experience.

1. AFJ website

Regarding the use and processing of personal data on the AFJ website, be sure to consult the rules on the use of cookies on their website.

The AFJ website may contain links to websites, products or services of third parties, that do not have any kind of relationship with AFJ or that are not covered by this Privacy Policy.

The collection or processing of personal data requested by these third parties is the sole responsibility of AFJ and cannot be held liable under any circumstances for the content, accuracy, veracity or legitimacy of these websites or the misuse of data collected or processed by between them.

The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged against costs. The information must be provided in writing, but may be given orally if requested. In this case, AFJ must verify your identity by other means than oral. The response to requests should be provided within a maximum of 30 days, unless it is a particularly complex request.

Exercise your rights through the following addresses:

AFJ

Rua dos Sobrais 626
3885-307 Cortegaça
Ovar, Portugal
W.: www.afjsanitarios.com
Mail: afj@afjsanitarios.com
P.: (+351) 256 790 160