Apra Hill Capital, S.A., NIPC 504910108, (hereinafter referred to as “Quinta de Apra”) is guided by the respect of your personal data and respective privacy.
- Responsible for the processing of your Personal Data
- Principles applicable to the protection of your Personal Data
- Personal Data, Processing of Personal Data and Data Subject
- Category of Personal Data that Quinta de Apra handles
- Purposes for the processing of your Personal Data
- Basics of Lawfulness
- Period of retention of your Personal Data
- Sharing your Personal Data
- Your rights and how to exercise them
- Security of your Personal Data
RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA
The person in charge or those responsible for the processing of your Personal Data is Quinta de Apra, determining, for this purpose, without limiting:
- Personal Data that must be processed in the context of providing services and/or providing products;
- The Purposes for which your Personal Data are processed; and,
- The means to be applied for the processing of your Personal Data.
PRINCIPLES APPLICABLE TO THE PROTECTION OF YOUR PERSONAL DATA
In the context of the relationship established with you, Quinta de Apra handles your Personal Data in accordance with the general principles set out in the General Regulation on Data Protection (“RGPD”), namely:
- Ensures that your Personal Data will be treated in a lawful, fair and transparent manner (“Principle of lawfulness, loyalty and transparency”);
- Collects your Personal Data for specific, explicit and legitimate purposes and does not further process the same Data in a way that is incompatible with those purposes (“Purpose limitation principle”);
- Ensures that only Personal Data that are adequate, relevant and limited to what is strictly necessary for the purposes for which they are processed («Principle of data minimization») are processed;
- Takes appropriate measures so that inaccurate Personal Data, taking into account the purposes for which they are processed, are erased or rectified without delay (“Principle of Accuracy”);
- Keeps Personal Data in a way that allows its identification only for the period necessary for the purposes for which they are processed (“Principle of conservation”);
- Ensures that your Personal Data are treated in a way that guarantees its security, including protection against its unauthorized or unlawful processing and against its accidental loss, destruction or damage, adopting the appropriate technical or organizational measures (“Principle integrity and confidentiality’)
Additionally, and despite not being expressly included in the RGPD, Quinta de Apra processes your data through the application of technical and organizational measures that ensure Data Protection from Design and by Default, so that your Personal Data are processed in accordance with best practices from the time of collection to destruction.
PERSONAL DATA, PROCESSING OF PERSONAL DATA AND DATA HOLDER
Personal Data are all information and/or elements that, regardless of their support, can identify or make you identifiable, directly or indirectly, to Quinta de Apra, in particular by reference to an identifier, such as a name, a number of identification, your electronic location data and/or identifiers or to one or more specific elements of your physical, physiological, genetic, mental, economic, cultural or social identity.
Processing of Personal Data means the operation or set of operations carried out on the Personal Data of Data Subjects, through automated or non-automated means, from the collection of information to its destruction. Within this cycle, among others, are included the registration, organization, structuring, conservation, adaptation or alteration, retrieval, consultation, use, dissemination by transmission, dissemination or any other form of availability, the comparison or interconnection, limitation, deletion. The concept of Personal Data Processing is quite broad and will apply to all operations or set of operations carried out by Quinta de Apra with reference to your Personal Data.
In the context of the activities developed by Quinta de Apra, the Data Subject is, without limitation, the customer and/or former customers, potential customers, investors, partners, job applicants, employees and former employees, employees of partners, suppliers and service providers and their collaborators, applicants and claimants and/OR all those individuals who maintain a relationship with Quinta de Apra and to whom the Personal Data relate.
Quinta de Apra only processes the personal data of minors in strict compliance with the personal data protection legislation and, as well, with other applicable legislation, or when provided by the parents or a legal guardian who expressly consents to such collection . If Quinta de Apra discovers that it has inadvertently collected personal data from a minor under the age of 18, it will immediately proceed with the elimination of the records with the personal data of that minor. If you are the holder of the parental responsibilities of a child and you learn that the child has provided us with information, please contact us through the means detailed below, so that Quinta de Apra can, together with you, resolve the issue.
CATEGORY OF PERSONAL DATA THAT QUINTA DE APRA DEALS
In carrying out its activities, Quinta de Apra processes Personal Data from a significant number of categories of Data Subjects. The Personal Data that Quinta de Apra collects always depends on the nature of the interaction, but may include the following:
The. Personal contact details: name, surname, postal address, telephone or mobile number, fax number, email address or other similar contact information.
- Commercial data for the provision of services: data related to the provision of services or supply of products, billing data, payment data and/or information in the context of responding to any questions, requests or complaints.
ç. Payment details: credit/debit card numbers, security code numbers or other related billing information.
- Account information: Service purchase method, your transaction, billing history and assistance in the context of Quinta de Apra services you use or any other related information.
and. Demographics: country, gender, age, preferred language, general education and employment history, as well as general interest data about work.
- Preference Data: Information on the holder’s preferences and interests, insofar as this is related to the services and on how he prefers to receive communications.
- Social media data: Information shared on social media when interacting with Quinta de Apra, where transparency is guaranteed through the existence of adequate privacy policies.
- IT usage data: user ID, roles, rights, login times, computer name and IP address.
We emphasize that you will not be obliged to share your Personal Data with Quinta de Apra. However, if you choose not to share your personal information, in some cases Quinta de Apra may not be able to provide the services or products you want, ensure certain specialized features or effectively answer any question you may have.
PURPOSES FOR THE PROCESSING OF YOUR PERSONAL DATA
By reference to the «Purpose limitation principle», the development and performance of the various activities pursued by Quinta de Apra means the existence of a relevant set of purposes for the processing of your Personal Data, such as:
- The. Accounting, Tax and Administrative Management: customer management, supplier management, administrative management and economic and accounting management;
- Commercial and Marketing Activity: contact management, customer management for the provision of services, marketing activities and opinion polls and surveys;
- Profile Creation and Analysis;
- Human Resource Management: personnel selection and recruitment;
- and. Electronic Communications Management: management of website usage and traffic data retention;
- Compliance with Legal Obligations: data transfer to Third Parties.
FUNDAMENTALS OF LEGAL
By reference to the «Principle of Lawfulness», in the development and carrying out of its activities, Quinta de Apra only processes your Personal Data when there is a legal basis that legitimizes the processing, namely:
Consent: Quinta de Apra will only process your Personal Data if you consent to the respective Processing through a free, specific, informed and explicit expression of will, by which you accept, by means of a declaration (in writing or orally) or unequivocal positive act (through filling in an option), that your Personal Data are subject to Processing.
Pre-contractual measures or the execution of a contract: Quinta de Apra may process your Personal Data if they are necessary, without limitation, for the execution of a contract for the provision of services to which you are a party as a Employee, Client and/ or Supplier, or to carry out pre-contractual arrangements at your request.
Fulfillment of a legal obligation: Quinta de Apra may process your Personal Data to ensure and guarantee the fulfillment of legal obligations to which it is subject under the legislation of a Member State and/or the European Union.
Defense of vital interests of the Data Subject: Quinta de Apra may process your Personal Data to ensure the defense of your vital interests, namely when the same treatment is essential to your life.
Legitimate Interests: Quinta de Apra, other Responsible Persons or Third Parties may process your Personal Data as long as this same Processing does not prevail over their interests or fundamental rights and freedoms.
PERIOD FOR STORAGE OF YOUR PERSONAL DATA
By reference to the «Principle of conservation», Quinta de Apra keeps your Personal Data only for the period of time necessary to carry out the specific purposes for which they were collected. However, Quinta de Apra may be required to retain some Personal Data for a longer period, taking into account factors such as:
- Legal obligations, under the laws in force, to retain Personal Data for a certain period;
- Limitation periods, under the laws in force;
- (if any) Litigation; and,
- Guidance issued by competent data protection authorities.
SHARING YOUR PERSONAL DATA
Subcontractors: Your Personal Data may be shared with companies responsible for providing Quinta de Apra services. These companies are bound by a written contract, and may only process your Personal Data for the purposes specifically established and are not authorized to process your Personal Data, directly or indirectly, for any other purpose, for their own benefit or that of a third party.
Other Persons Responsible and/or Third Parties: Your Personal Data may be shared internally with other Quinta de Apra companies that will comply with the applicable data protection rules depending on the purposes of the Processing carried out.
Upon your request and with your consent, your Personal Data may be shared with other entities.
In compliance with legal and/or contractual obligations, Personal Data may also be transmitted to judicial, administrative, supervisory or regulatory authorities and also to entities that carry out, lawfully, data collection actions, actions to prevent and combat fraud, market or statistical studies.
YOUR RIGHTS AND HOW TO EXERCISE THEM
Right to provide information: You have the right to obtain clear, transparent and easily understandable information about how Quinta de Apra uses your Personal Data and what your rights are.
This right allows you to know and confirm that we use your Data in compliance with data protection laws.
Quinta de Apra may refuse to provide the requested information whenever, in order to do so, Quinta de Apra has to reveal another person’s Personal Data or the information negatively impacts another person’s rights.
Right of correction: If your Data is incorrect or incomplete (for example, if your name or address is wrong), you can ask Quinta de Apra to take reasonable steps to correct them.
Right to data deletion: This right is also known as the “right to be forgotten” and simply allows you to request the deletion or deletion of your data, provided that there are no valid grounds for Quinta de Apra to continue to use them or their use is unlawful. This is not a generic right to erasure, as exceptions are allowed (for example, whenever these data are necessary for the defense of a right in a legal process).
Right to limit the treatment: You have the right to “block” or prevent the future use of your Data while Quinta de Apra evaluates a request for rectification or as an alternative to deletion. Whenever the Treatment is limited, Quinta de Apra continues to may store your data, but may not use them later. Quinta de Apra maintains a list of holders who have requested the “blocking” of the future use of their data to ensure that this limitation is respected.
Right to data portability: You have the right to obtain and reuse certain Personal Data for your own purposes in various organizations. This right applies only to your own Data that you have provided to Quinta de Apra and that Quinta de Apra handles with your consent and that is processed by automated means.
Right to Opposition: You have the right to object to certain types of treatment, for reasons related to your particular situation, at any time such Treatment takes place, for the purposes of the legitimate interest of Quinta de Apra or Third Parties. Quinta de Apra may continue to process these Data if it can provide evidence of “legitimate reasons prevailing for the Treatment that outweigh its interests, rights and freedoms” or if such Data are necessary for the establishment, exercise or defense of a right in a court case.
Right to file a complaint: You have the right to file a complaint with the competent supervisory authority, the National Data Protection Commission – CNPD, if you consider that the Processing of Personal Data violates your rights and/or data protection laws applicable
You may, at any time, in writing, exercise the rights enshrined in the applicable legislation regarding the protection of personal data through the e-mail address [email protected].
SECURITY OF YOUR PERSONAL DATA
Your Personal Data will be processed by Quinta de Apra, in the context of the purposes identified in this Policy, in accordance with the policy and internal rules of Quinta de Apra and using appropriate technical and organizational measures to promote its security and integrity, namely in relation to the unauthorized or unlawful processing of your personal data and the respective accidental loss, destruction or damage.
Without limiting, Quinta de Apra uses logical and physical security requirements and measures to ensure the protection of your Personal Data by preventing unauthorized access, ensures that the information is stored on secure computers in a closed information center and which implements control procedures to ensure compliance with Quinta de Apra’s safety policies.
However, as the transmission of information over the Internet is not completely secure, Quinta de Apra cannot guarantee the security of your Data when transmitted over an open network.
If you have any questions or would like to obtain more information about how we handle your Personal Data, and what our information security practices are, please do not hesitate to contact us at the following addresses:
Email: [email protected]
Address: Rua Cidade de Córdova, nº 1, 2610-038 Alfragide, Portugal
Date: December 1, 2021