Commitment with Data Protection and Privacy
Definitions
Entity Accountable for the Data Processing
Data Processing Responsible Contact
Personal Data Collection and Processing
Legal Principles
Legitimacy Fundamentals
Data Processing Purposes
Data Retention Period
Cookies Usage
Data Communication to Third Parties
Data Receivers
International Data Transfer
Safety Measures
Personal Data Owners rights
Complaints, Suggestions and Incident Reports
Incident Reporting
Privacy Policy Changes
Express Consent and Acceptance
Data Protection Officer
Specific Data Protection and Privacy Policy

Commitment with Data Protection and Privacy

Neves de Almeida | HR Consulting abides with all existing European and Portuguese legal framework applicable to data protection, privacy and information security.

Neves de Almeida | HR Consulting is implementing a Personal Data Protection System and an Information Security System which aims to ensure the regulation compliance and the demonstration or evincement and corporate responsibility regarding data protection and information security, implementing all technical and organisational necessary procedures, to current Data Protection Law general legal framework and to abidance of the special legal framework of General Data Protection Regulation, applicable from May 25th 2018.

For any clarification or additional information or rights exercise regarding this scope, please, contact Neves de Almeida Data Protection Officer at protecaodedados@nevesdealmeida.pt.

Definitions

«Personal Data»
«Personal Data», information regarding a single person identified or identifiable (“data owner”); is regarded identifiable a single person that may be identified, directly or indirectly, specially by reference to an identifier. For instance, name, identification number, location data, electronic identifiers or one or more specific elements of physical, physiologic, genetic, mental, economic, cultural or social identity of that single person.

«Personal Data Processing»
«Processing», an operation or a set of operations conducted over personal data or sets of personal data by automatized or non-automatized means such as collection, registration, organization, structuration, conservation, adaptation or alteration, recovery, usage, disclosure by transmission, diffusion or any other form of release, comparation or interconnection, limitation, erasure or destruction.

«Cookies»
«Cookies» are small files of text withholding information considered relevant that devices used to access (computers, mobile phones or portable mobile devices) load through the internet browser whenever an online site is visited by the Client or the User.

Entity Accountable for the Data Processing

Neves de Almeida | HR Consulting – Neves de Almeida, Alves & Monteiro, with head office at Av. Casal Ribeiro, 14, 5.º piso, 1000-092 Lisboa, registered in Conservatória do Registo Comercial de Lisboa, with plate number and Legal Person 506471659, a capital stock of €5.000, from now on referred as Neves de Almeida | HR Consulting, is the entity responsible for the online sites www.nevesdealmeida.pt and www.indicedaexcelencia.pt and for the informatized applications, from now on referred by channels or applications, through which Users, Candidates or Clients have remote access to the services and products of Neves de Almeida | HR Consulting that are presented, traded or provided, anytime, via the same. The channels or applications used by any User, Candidate or Client may imply the execution of personal data processing whose protection, privacy and security are assured by Neves de Almeida | HR Consulting as the entity accountable for the corresponding processing in the terms of these Data Protection and Privacy Policy.

Data Processing Responsible Contact

To the purpose of contact with the Data Protection Officer of Neves de Almeida | HR  Consulting, please, send an email to protecaodedados@nevesdealmeida.pt, describing the topic of the request and providing an email address, a telephone number and a mailing address.

For any other effect the following contacts of Neves de Almeida | HR Consulting may be used:

Mailing address:  Av. Casal Ribeiro., 14, 5.º piso, 1000-092 Lisboa
email: geral@nevesdealmeida.pt
Central Telephone: 218 444 480
Central Telefax: 218 444 489 

Personal Data Collection and Processing

Neves de Almeida | HR Consulting processes the personal data strictly necessary to provide information and to run its channels, according to the usage of its Users, Candidates or Clients, being those provided by Users or Candidates to request registration or information, or being those provided by Clients to access those channels, or being those resulting from services provided by Neves de Almeida | HR Consulting via the same, such as accesses, checks, instructions, transactions and other registers regarding its use.

In particular, the use or activation of certain features of the channels may imply the processing of several direct or indirect personal identifiers, such as name, home address, contacts, devices’ address or geographical location, whenever there is an explicit consent from Users, Candidates or Clients.

In every case Users, Candidates or Clients will always be informed of the need to access such data regarding the use of the features of these channels. 

The personal data collected by Neves de Almeida | HR Consulting have an informatic processing, in certain cases in a automatized form, including file processing or profile definition and in the scope of pre-contractual, contractual or post-contractual management with the Users, Candidates or Clients, according to the current Portuguese and Community legislation.

Legal Principles

Every personal data processing operation abides with the fundamental legal principles regarding the scope of the data protection and privacy, namely its circulation, lawfulness, loyalty, transparency, purpose, minimisation, conservation, accuracy, integrity and confidentiality, being Neves de Almeida | HR Consulting available to express its responsibility in front of the data owner or any third party that has a justifiable interest in this subject.

Legitimacy Fundamentals

Every personal data processing operations conducted by Neves de Almeida | HR Consulting have a legitimacy basis, namely due to the fact that the data owner has given his consent to processing his personal data to one or more specific purposes, or due to the fact that processing is considered necessary to the fulfilment of a legal obligation of the responsible for the data processing, or due to the fact that processing is necessary to the purpose of legitimate interests sustained by Neves de Almeida | HR Consulting or by third parties.

Data processing purposes

All personal data treated within Neves de Almeida | HR Consulting channels is for exclusive availability of information to Users, management of candidates’ personal information regarded as necessary for recruitment and selection or training in the scope of human resources consulting purposes, as well as the delivery of services acquired by Clients, and to the overall pre-contractual, contractual or post-contractual relationship management with Users or Clients.

Personal data collected may, still and eventually, be object of processing for statistical purposes, for information dissemination or promotional activities, and commercial and marketing actions, namely to promote dissemination activities of new features or new products and services through direct communication by means of mailing, electronic mailing, messages or phone calls or any other electronic communications service. 

Always assuring the previous information and the collection of the express consent for the latter purposes, Users or Clients may, at any given moment in time, exercise their right to object the use of their personal data for other purposes that extrapolate the management of the contractual relationship, specifically to marketing purposes, to information communications sending, or to the insertion in lists or information services having to, for such, send a written request to the Neves de Almeida Data Protection Office according to the procedure bellow.

Data Retention Period

Personal data will be subject to conservation only for the period necessary for the purposes that motivated its collection and posterior processing, being assured the fulfilment of all the legal principles applicable in archiving matters.

Cookies Usage

Neves de Almeida | HR Consulting may use two big categories of «cookies»: «cookies» in the scope of the channels of direct electronic communication, being always, in any of the categories, assured the respective deactivation by Users or Clients.

Neves de Almeida | HR Consulting uses «cookies» in its online sites with the purpose of enhancing the performance and navigation experience of Users and Clients, increasing, on the one hand, the response speed and efficiency, and, on the other hand, removing the need to introduce the same information repeatedly.

Using «cookies» helps sites to recognize the devices of Users and Clients the next time they visit them, being also, in some cases, indispensable to its functioning.

The «cookies» used by Neves de Almeida | HR Consulting in all its channels do not retrieve personal information that allow Users or Clients identification, only withholding some generic information, namely the form or geographic location of the access and how the channels are used, among others. The «cookies» withhold only information regarding Users or Clients’ preferences, not registering personal identifiers. 

Users, Candidates and Clients may, at any time, through the informatic application used to navigate the internet («browser») make the decision of being notified about receiving cookies, as well as block the corresponding entry in their system.

Regarding the sort of purposes intended, Neves de Almeida | HR Consulting may use three different kinds of «cookies», according to the following specifications: (i) essential «cookies» – some «cookies» are essential to access specific areas of the online channels, allowing navigation and the use of its applications, such as access to secure areas of sites through user registration – without these «cookies» the services that demand them cannot be provided; functionality «cookies» – the functionality «cookies» allow the remembrance of the user preferences regarding the navigation in online sites, not needing, therefore, reconfiguration or personalization in each visit; (iii) analytical «cookies» – these cookies are used to analyse how Users navigate online sites, allowing to highlight articles or services that may be of their interest, monitoring sites’ performance, as well as, knowing which are the most popular pages, which connection method between pages is more effective, or to establish the reason why some pages are receiving error messages – these «cookies» are used solely to build and analyse statistics, without ever collecting information of personal nature.

With these goals, Neves de Almeida | HR Consulting may provide a high-quality experience to Users and Clients, personalizing information and offers, and identifying or correcting possible problems that may appear in the scope of the related usage.

Regarding the period, there are two types of «cookies»: (i) permanent «cookies» – are «cookies» that are stored in devices used to access channels (computers, mobile phones, etc.) at the level of the informatic application used to navigate the internet («browser»), being used every time Users or Clients revisit any of the channels – the general use is to direct navigation accordingly to the User or the Client’s interests, allowing Neves de Almeida | HR Consulting to provide a more personalized service; (ii) session «cookies» – are temporary «cookies» that are generated or are only available until the session ends, since the next time the User or the Client accesses his or hers internet navigator («browser») the «cookies» are already stored – the information retrieved allows the sessions’ management, to identify problems, and to offer a better a navigation experience.

Users and Clients may deactivate part or the totality of the «cookies» at any moment – to do so, they should follow the instructions available on each of the informatic applications used to navigate the internet («browser»). However, with the deactivation, they may lose access to some of the features of the sites. 

Neves de Almeida | HR Consulting, in the scope of the direct electronic communications channels, may still use «cookies» when opening the different electronic communications sent, as «newsletters» and emails, for example, for statistical purposes – allowing to know if those communications are opened and verifying the clicks through links or advertisements within those communications.

Also, in these «cookies» category Users and Clients have the permanent capacity of deactivating the sending of electronic communications using the specific option located in the footer of those.

Data Communication to other Entities

The availability of information or provision of services by Neves de Almeida | HR Consulting to its Users and Clients through the channels may possibly imply resorting to services provided by third parties that are outsourced, including entities with head offices outside the European Union to certain services delivery that may imply access by this entities to Users or Clients personal data.

In these circumstances and whenever that may be required, Neves de Almeida | HR Consulting will only resort to outsourced entities that provide enough and adequate assurance of organizational and technical measures in a way that the processing satisfies the applicable regulation, being such guaranties formalised in written contract by Neves de Almeida | HR  Consulting and each of those third parties.

Data Receivers

Except for the fulfilment of legal obligations compliance scope, in any case should the personal data of Users, candidates or Clients be communicated to third entities other than those subcontracted or legitimate receivers within the scope of human resources management processes, not being, also, made any other communication to any purposes different from the abovementioned.

International Data Transfers

Any personal data transference for a third country or international organization will only be made within the framework of legal obligations fulfilment or that the compliance with the EU and Portuguese legal standards applicable in such matter is assured. 

Security Procedures

In consideration of the most advanced technics, the application costs and nature, scope, context and purposes of the processing, as well as the risks, of variable probability and gravity, for Users and Clients, Neves de Almeida | HR  Consulting and all entities that are subcontracted apply the technical and organizational measures to assure a security level that is suitable to risk.

For the purpose, are adopted several security measures, in order to protect personal data against the diffusion, loss, misuse, alteration, non-authorized access or processing, as well as any other form of unlawful processing.

Users, Candidates or Clients, are solely responsible for keeping access codes secret, not sharing them with third parties, and should also, in the particular instance of the informatic applications to access channels, keep and withhold access devices in proper security conditions and follow the safety practices recommended by the manufactures and/or operators, namely regarding the installation and update of the necessary security features, namely and among others, antivirus applications. 

Whenever there is the need to outsource services to third party entities that may access personal data of Users or Clients, the subcontracted by Neves de Almeida | HR  Consulting will be obliged to adopt the measures and the security protocols of the organization and the needed measures of technical nature to protect security and confidence, as well as the prevention of non-authorized accesses, losses or destruction of personal data. 

Personal Data Owners Rights

Users and Clients of Neves de Almeida | HR Consulting may, as owners of personal data, at any moment, exercise their rights of data protection and privacy, specifically their right of access, rectification, erasure, portability, limitation or opposition to the processing, according and with the limitation envisaged in the applicable legal norms. Any request for rights of data protection and privacy exercise must be directed, in writing, to the Data Protection Officer, according to the procedure and contact described below. 

Complaints, Suggestions and Incident Reporting

Users and Clients of Neves de Almeida | HR Consulting have the right to complain, either registering the complaint in the Complaint Book, or presenting a complaint to the regulatory authorities. Users and Clients of Neves de Almeida | HR Consulting may also send suggestions by email to the Data Protection Officer.

Incident Reporting

Neves de Almeida | HR Consulting has been implementing an incident management system within the scope of data protection, privacy and information security.

Should any User or Client note a situation of personal data violation that causes, accidently or illegally, the destruction, loss, modification, disclosure or unauthorized access to personal data transmitted, retained or subject to any kind of different processing, should immediately contact the Data Protection Officer or use Neves de Almeida general contacts described above. 

Privacy Policy Modification

In order to ensure the current update, development and continuous improvement, Neves de Almeida | HR Consulting, may, at any moment, operate the changes that are considered adequate or necessary to this Data Protection Privacy and Policy, being assured its publication in the different channels to assure the associated transparency and information to Users and Clients.

Express Consent and Acceptance

The terms of the Data Protection and Privacy Policy are complementary of the terms and regulations, regarding personal data, envisaged in the Neves de Almeida | HR Consulting channels’ General Use Conditions. The free, specific and informed provision of personal data by its owner implies knowledge and acceptance of the conditions included in this Policy, considering that, either by using the channels or by providing personal data, Users, Candidates and Clients are expressly authorizing their processing, according to the rules defined in each of the applicable channels or retrieving instruments.

Data Protection Officer

To exercise any kind of rights regarding data protection or privacy or for any subject referring to data protection issues, privacy and information security, Neves de Almeida | HR Consulting’s Users, Candidates and Clients can contact the Data Protection Officer by e-mail at protecaodedados@nevesdealmeida.pt, describing the subject of the request and providing an electronic mail address, a telephone number and a mailing address for a reply.

Data Protection and Privacy Specific Policies

In order to assure transparency and conformity of the data processing procedures, as well as the provision of information to the respective data owners’, Neves de Almeida | HR Consulting may, at any moment, develop specific policies suitable to each of the data owner categories.

Any of the specific policies that may be developed autonomously must be framed or articulated in context with this Data Protection and Privacy Policy of general nature and transverse to all data owner categories, prevailing the specific policies regarding the general policy clauses.

Version 1.2; Published: 20/08/2018