Privacy Policy (GDPR)
1. The protection of privacy and personal data is a commitment of FRICON.
The protection of privacy and personal data is a fundamental commitment of the companies of the FRICON Group and its affiliates (FRICON), to the holder of personal data (also, “proprietor”) that uses digital platforms, communication and distribution channels and / or FRICON services.
With the application of the new General Regulation on Data Protection (RGPD), as of May 25, 2018, FRICON states that it remains strongly committed and committed to the protection of the privacy and personal data of the respective holder that uses the digital platforms, communication and distribution channels and / or FRICON services and to this extent update its Privacy Policy in accordance with all data protection principles and standards that underpin the RGPD.
2. General Regulation on Data Protection.
The new RGPD lays down rules concerning the processing by a person, company or organization of personal data relating to persons in the European Union (EU).
RGPD protects personal data irrespective of the technology used for the processing of such data, the protection is technologically neutral, and applies to both automated and manual processing, provided the data is organized according to pre-defined criteria ( for example, in alphabetical order). Also irrelevant is the way data is stored, in a computer system, via video surveillance, or on paper; in all these cases, personal data are subject to the protection requirements of the RGPD.
3. Who is responsible for data processing?
FRIGOCON – Industria de Frio e Congelação, SA, with its head office at Rua das Calçadas, 568, 4480-492 Touguinha, Vila do Conde, Portugal, corporate entity 500 606 552, share capital € 10.000.000,00 (ten million euros ), is responsible for the processing of personal data under the RGPD.
4. Data Protection Officer.
FRICON has a Data Protection Officer (EPD) who: (I) provides information and advises the controller or subcontractor of their obligations regarding privacy and data protection; (II) controls the compliance of data processing with applicable standards; (III) advises, when requested, on the impact assessment on data protection and controls its implementation; (IV) is a point of contact with the holder of personal data to clarify questions regarding the treatment of your data by FRICON; and (V) is the contact point for the control authority (National Commission on Data Protection – CNPD) on treatment-related issues, cooperating with this entity.
The FRICON Data Protection Officer can be reached at marketing@fricon.pt.
5. Treatment of personal data, scope and amendment of the Privacy Policy.
By providing your personal data to FRICON, the holder of personal data will consent to the processing of your personal data in accordance with this Privacy Policy.
This Privacy Policy applies to data that has been directly provided by the respective owner or collected in accesses of the holder to digital platforms, communication and distribution channels and / or FRICON services. Therefore, it is advised that digital platforms, communication and distribution channels and / or FRICON services may contain links (links) to other digital platforms and refer to contents of third parties that are not covered by the FRICON Privacy Policy, by that it is advisable that whenever the holder of personal data navigates in these platforms, he / she is informed of the content of their respective privacy policies, as well as the applicable terms and conditions.
FRICON reserves the right to change its Privacy Policy, so we encourage you to consult this document regularly.
6. What kind of information does FRICON collect?
FRICON collects two kinds of information: personal information and anonymous information. Anonymous information occurs while the holder of personal data visits the digital platforms and aims to improve the operation of the same, including the management and prioritization of content. Personal information is voluntarily provided by the holder of personal data at the time of the voluntary registration. All data collected is processed automatically.
The registration serves the holder of personal data access document processing (billing, etc …), subscription services FRICON newsletters, comments and other features provided by FRICON.
In order to provide certain services, FRICON may have to make personal and anonymous information available to third parties. This will only happen, however, in these specific circumstances:
a) With the express consent of the holder of personal data;
b) When in good faith we believe it is required by law;
c) When in good faith we believe that it stems from contractual stipulation;
d) When in good faith we believe it necessary to protect our rights or property;
e) When there is a transfer to a successor or buyer in a merger, acquisition, liquidation, dissolution or sale of assets.
The consent of the holder of personal data shall not be required for disclosure in the situations referred to in points b) to e). In any event, we will attempt to notify you to the extent permitted by law.
7. What is personal data?
Personal data is information relating to an identified or identifiable person. Any person who can be identified directly or indirectly is considered identifiable. Also personal data is the set of distinct information that may lead to the identification of a particular person.
Examples of personal data:
Name and Nickname;
Address of a residence;
E-mail address;
Number of an identification card;
Location data (for example, the location data function in a mobile phone);
IP address (internet protocol);
Cookies;
Your phone’s advertising identifier;
Data held by a hospital or doctor, which unequivocally identifies a person;
Sound or image.
8. Who is the holder of personal data?
The holder of personal data is the natural person to whom the data relates and who has used digital platforms, communication and distribution channels and / or FRICON services.
9. Categories of personal data
Identifiers – Name, Civil or fiscal identification number, Passport number, date of birth, marital status, address, telephone, e-mail address, nationality, photos and files of the mobile device, aggregate data family relationship data.
IBAN, geo-location, educational level, gender, occupation, socio-economic data, personal ID, IP address, social network addresses, mobile device type, operating system, operating system version.
10. For what purposes does FRICON treat your personal data?
Provision of information and communication services, digital platforms:
Interactive participation, participation in competitions, analysis of navigation profiles, adaptation and development of new products, content creation or information services (notifications, newsletters, digital platforms of programs and content apps).
Analysis of browsing profiles, adaptation and development of new products, content or information services (notifications, newsletters, digital platforms and informative dossiers and content apps).
Content development:
Analysis of navigation profiles, products, adaptation and development of new products, contents or services.
Engineering, Systems and Technology:
Technical responses and complaints.
Control of the physical security of the premises:
Control of access to facilities, security in buildings by specialized technicians, video surveillance.
Commercial, Marketing and Communication:
Users of digital platforms, communication and distribution channels and / or FRICON services.
Registration of guests and visitors, sending invitations.
We will request your express consent before using the information for purposes other than those expressly set out in this Privacy Policy.
11. When and how do we collect your personal data?
We collect personal data, such as when you contact FRICON (requests for information, quotation, etc.) or purchase FRICON products or services, when you download content or use FRICON services and applications, through contacts with call centers direct (telephone calls). The collection can be done orally, in writing or through FRICON digital platforms.
12. What is the basis for the processing of your personal data?
Consent
Your consent must be expressed – in writing, orally or through the validation of an option – and prior, provided in a free, informed, specific and unambiguous manner.
Contract execution and pre-contractual procedures
When the processing of personal data is necessary for the conclusion, execution and management of a contract with FRICON, such as for establishing a business relationship; or
Compliance with legal obligation
Where the processing of personal data is necessary to fulfill a legal obligation to which FRICON is subject, such as the communication of identification or traffic data to police, judicial, tax or regulatory bodies or location data to ensure emergency services; or
Legitimate interest
The processing of personal data by FRICON may be justified on grounds of legitimate interest related to the performance of the tasks related to its activity as a company, such as data processing to improve quality of service, fraud detection and protection of revenue and when our reasons for using it should prevail over your data protection rights.
13. How long does FRICON treat and retain your personal data?
FRICON treats and preserves your personal data according to the purposes for which they are processed and only for the period of time necessary for the fulfillment of the purposes that motivated their collection and conservation, and always in accordance with the law, guidelines and decisions of the CNPD, or, whichever is applicable, until you exercise your right of opposition, right to be forgotten or withdraw consent.
There are situations in which the law determines the retention of data for a minimum period of time, namely: for one year, traffic and location data for the purpose of investigation, detection and prosecution of serious crimes or for 10 years the data necessary for information to the Tax Authority.
After the expiration of the period of conservation, FRICON shall eliminate or anonymize the data when they are not to be kept for a purpose other than that which may last.
14. Rights of the holder of personal data.
The holder of personal data has rights to information, access and rectification or deletion of personal data and the right to portability of data, the right to limit or oppose the processing of your data, within the scope and under the terms of the RGPD and other applicable legislation.
The holder may withdraw, at any time, the consent that he has given for the processing of his personal data, within the framework of the RGPD. The revocation of consent shall not affect the lawfulness of the processing of personal data hitherto made, based on the consent you have previously provided.
You also have the right to complain about the processing of your data to the CNPD.
Exercise your rights through the following contacts:
Email- marketing@fricon.pt
Letter
FRIGOCON – Industria de Frio e Congelação, S.A. (FRICON)
Rua das Calçadas, 568, 4480-492 Touguinha, Vila do Conde, Portugal
The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive or unjustifiably reiterated request, in which case a reasonable fee may be charged against costs.
The reply to the request shall be made without undue delay within one month of the receipt of the request, unless it is a particularly complex request or occurs in exceptional circumstances. This period may be extended by up to two months, where necessary, taking into account the complexity of the request and the number of applications received.
In the context of your request, you may be asked to prove your identity so as to ensure that the sharing of personal data is only done with its owner.
15. Transmission of personal data
Personal data may be transmitted to subcontractors for processing in the name and on behalf of FRICON. In this case, FRICON shall take the necessary contractual measures to ensure that subcontractors respect and protect the personal data of the holder.
Data may also be transmitted to third parties – entities other than FRICON or subcontractors – such as companies within FRICON, companies with which FRICON develops partnerships, if the holder has consented – or entities to whom the data must be communicated under the law, such as the Tax Authority, judicial authorities, criminal police agencies, among others.
FRICON may occasionally have to transfer its personal data to a third country outside the EU and not included in the list of countries which the EU has already considered to meet adequate levels of protection of personal data. In such cases, FRICON will ensure that data transfers are carried out in strict compliance with applicable legal standards.
16. Responsibility for digital platforms, communication and distribution channels, FRICON services and third parties.
FRICON is not responsible for the content accessed through any link that causes the holder of personal data to navigate outside the digital platforms FRICON and for the processing of personal data in these made, where such links are the responsibility of third parties. The websites and content of third parties are not subject to this Privacy Policy, so we advise that whenever you browse these sites, look for and read the privacy policies, as well as the applicable terms and conditions.
17. What security procedures guarantee the protection of your data?
FRICON takes all necessary and legally required precautions to ensure the privacy of personal data processed and / or transmitted through its digital platforms. These precautions ensure online and offline security of this information.
Whenever sensitive information is collected or used, the data will be encrypted using the SSL protocol. This so-called Secure Socket Layer technology is used to improve the security of data transmission over the Internet, encrypting and protecting sensitive data and information using the HTTPS protocol. SSL guarantees the holder of personal data that the data will not be fraudulently intercepted and that all information is treated with the utmost security.
18. Doubts?
If you have any questions about any of the topics covered in this document, please contact us to:
Email:
marketing@fricon.pt
Letter
FRIGOCON – Industria de Frio e Congelação, S.A. (FRICON)
Rua das Calçadas, 568, 4480-492 Touguinha, Vila do Conde, Portugal