Technical Sheet
Title: Internal Data Protection Policy
Author. Pelletspor Energy Investments, Unipessoal Lda
Approval Date: October 18, 2023
WHO WE ARE
Pelletspor Energy Investments, Unipessoal Lda, hereinafter referred to as “PELLETSPOR”, is a company that produces and sells pellets in bulk or in packaging; having as complementary activities the production, transformation, import, export and commercialization of any wood and biomass product and the use, supply and commercialization of energy, as well as the transformation of biomass for energy production,
“PELLETSPOR” is committed to protecting the personal data of Customers/Suppliers of its products and services, as well as the personal data of the respective holders in all situations in which personal data is processed. This policy is based on a commitment to respect the rules on the protection of personal data.
WHY THIS PERSONAL DATA PROTECTION POLICY?
This Policy aims to inform Customers/suppliers of the general rules for processing personal data, which are collected and processed in strict compliance with the provisions of the personal data protection legislation in force at any given time, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”).
“PELLETSPOR” respects best practices in the field of security and protection of personal data, having taken the necessary technical and organizational measures to comply with the GDPR and ensure that the processing of personal data is lawful, fair, transparent and limited to authorized purposes.
“PELLETSPOR” is committed to the protection and confidentiality of personal data, having adopted the measures it deems appropriate to ensure the accuracy, integrity and confidentiality of personal data, as well as all other rights that assist the respective holders.
The rules set out in this Data Protection Policy complement the provisions, regarding the protection and processing of personal data, provided for in the contracts that Customers/Users enter into with “PELLETSPOR”, as well as the rules provided for in the terms and conditions that regulate the offer of the various products and services. br />If you are under 16 years of age, please do not provide us with your personal data unless you have permission from your parents or guardians to do so.
Please help us keep your personal data up to date. To this end, you must inform “PELLETSPOR” of any changes to your personal data, in particular any changes to your contact details.
WHAT THIS DATA PROTECTION POLICY COVERS
This Data Protection Policy applies exclusively to the collection and processing of personal data for which “PELLETSPOR” is responsible for the respective processing, within the scope of the services and products made available to its Customers/Suppliers and in all situations where personal data is processed.
WHAT IS PERSONAL DATA?
Personal data is any information, of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable natural person.
A natural person who can be identified is considered identifiable, directly or indirectly, in particular by reference to a name, identification number, location data, electronic identifiers or to one or more specific elements of their physical, physiological, genetic, mental, economic, cultural or social identity.
WHAT DOES THE PROCESSING OF PERSONAL DATA CONSIST OF?
The processing of personal data consists of an operation or set of operations performed on personal data or sets of personal data, by automated means or otherwise, in particular the collection, recording, organization, structuring, conservation, adaptation, recovery, consultation, use, disclosure, dissemination, comparison, interconnection, restriction, erasure or destruction.
WHO IS RESPONSIBLE FOR DATA PROCESSING?
The entity responsible for processing personal data is “PELLETSPOR”, legal entity 517.009.510, headquartered at Av. Dr. António Macedo, 196, 1st floor, room C3, 4450-617 Leça da Palmeira which determines the purposes and means of processing the same.
For this purpose, if the holder of personal data needs to contact with the person responsible for data processing, you can do so through the means and contacts indicated below:
– Address of “PELLETSPOR” Av.
WHAT TYPES OF PERSONAL DATA ARE PROCESSED?
“PELLETSPOR”, within the scope of the activities it develops, carries out the processing of personal data necessary for the provision of services and/or supply of products, processing data such as name, tax identification number, address, registration number, telephone number and email address, according to more detailed information made available to personal data holders.
When you participate in Events or Projects organized and/or supported by “PELLETSPOR”, some of your personal data may be shared with co-organizing entities of these initiatives.
Without prejudice to compliance with legal standards regarding the conservation and transmission of data for the purposes of investigation, detection, and repression of serious crimes, as well as other processing to which it is legally obliged, the data of traffic, geographic location, profile and/or consumption of the Customer/Users will be processed by “PELLETSPOR”, to the extent necessary for the respective provision of services. In this way, based on location, profile and/or consumption, the Customer/Supplier will have access, in particular, to specific service features, content suggestions and local information services.
Location information may also be recorded and transmitted to organizations with legal competence
to receive emergency calls, for the purpose of responding to incoming calls.
Personal, traffic, geographic location, profile and/or consumption data are also processed for marketing purposes or for the dissemination of offers of goods or services from “PELLETSPOR”, if the respective holder has authorized it.
personal data will also be processed, if the respective holder has authorized it, for the purposes of disseminating information services and lists. If there is prior consent from the Customer/Supplier, this may be withdrawn at any time, without , however, the lawfulness of the processing carried out based on the consent previously given is compromised
WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?
“PELLETSPOR” collects your personal data, especially by telephone, in writing, e-mail, ensuring, whenever necessary, the prior consent of the holder of the personal data.
Some personal data are essential for the execution of the contract and, in case of lack or insufficiency thereof, “PELLETSPOR” will not be able to make the product or service in question available.
The personal data collected may be processed electronically and in a manner automated or non-automated, ensuring in all cases strict compliance with personal data protection legislation, being stored in specific databases, created for this purpose and, in no situation, the data collected will be used for any purpose other than the one for which they were collected or consent was given by the data subject.
WHO ARE THE RECIPIENTS OF PERSONAL DATA?
Without prejudice to the recipients indicated throughout this Data Protection Policy, “PELLETSPOR” may communicate the Customer/Supplier’s personal data, for the purpose of complying with legal obligations, namely to police, judicial, fiscal and regulatory.
WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA AND THEIR LEGAL BASIS?
In general, the personal data collected is based on and intended for the management of the contractual relationship, the provision of contracted services, the adaptation of services to the needs and interests of the Customer/Supplier, in particular for the purposes of access to specific features of the services, content suggestions, information services, information and marketing actions.
Additionally, personal data may also be processed for the purposes of complying with legal obligations and for the purposes of research, detection and prosecution of serious crimes.
Without prejudice to the additional information provided when collecting data, “PELLETSPOR” may also, as long as legally admissible, use the personal data provided by the holder for other purposes, such as sending complaints and suggestions, disseminating institutional information. and/or to publicize campaigns, promotions, advertising and news about its products and/or services, as well as to carry out market research or evaluation surveys.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
The period during which personal data is stored and maintained varies according to the purpose for which the information is processed
In fact, there are legal requirements that oblige data to be kept for a period minimum. Therefore, and whenever there is no specific legal requirement, the data will be stored and maintained only for the minimum period necessary to achieve the purposes that motivated its collection or subsequent processing, under the terms defined by law.
WHAT ARE YOUR RIGHTS AS THE HOLDER?
As holders of personal data, Customers/Suppliers are guaranteed, at any time, the right to access, rectify, update, limit and erase their personal data (except for data that is indispensable the provision of services by “PELLETSPOR”), duly identified in the Form as being mandatory or to comply with legal obligations to which the controller is subject), the right to object to the use of the same for commercial purposes by “PELLETSPOR” and to the withdrawal of consent, without compromising the legality of the processing carried out under that consent, as well as the right to data portability.
HOW YOU CAN ACCESS, RECTIFY, UPDATE, LIMIT, DELETE, OPPOSE THE PROCESSING OF YOUR PERSONAL DATA, OR WITHDRAW CONSENT
Without prejudice to the provisions of the GDPR, the holder of personal data may do so, directly or by means of a written request addressed to the respective Controller, through the contacts made available for this purpose in this document.< /p >
HOW YOU CAN OBJECT TO RECEIVING CONTACTS FOR MARKETING PURPOSES
“PELLETSPOR” may promote promotional actions among its Customers/Suppliers, of new products or services, namely by telephone, email, SMS, MMS or any other electronic communications service, if the the holder of the personal data has given the respective consent.
If the holder of the personal data does not wish to continue receiving these communications, he/she may, at any time, withdraw his/her consent to the use of his/her data for marketing purposes .
HOW YOU CAN COMPLAIN
Without prejudice to being able to submit complaints directly to “PELLETSPOR”, through the contacts made available for this purpose, the Customer/Supplier may complain directly to the Control Authority, which is the National Data Protection Commission (CNPD) ), using the contacts provided by this entity for this purpose.
WHAT MEASURES HAS “PELLETSPOR” TAKEN TO ENSURE THE SECURITY OF YOUR PERSONAL DATA?
“PELLETSPOR” 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. Compliance with these rules is an obligation for all those who legally access them.
In view of the concern and commitment that “PELLETSPOR” shows in the defense of personal data, several security measures of a technical and organizational nature have been adopted. , in order to protect the personal data made available to it against its dissemination, loss, misuse, alteration, processing or unauthorized access, as well as against any other form of unlawful processing.
Additionally, third parties that , in the within the scope of service provision, process the personal data of the Customer/Supplier on behalf of and on behalf of “PELLETSPOR”, are obliged, in writing, to implement appropriate technical and security measures that, at any given time, satisfy the requirements provided for in current legislation and ensure the defense of the rights of the data subject (in particular, the Protection of the privacy and personal data of Customers/Suppliers).
Notwithstanding the security measures adopted by “PELLETSPOR”, we warn all who surf the Internet and must adopt additional security measures, namely, ensure that they use a PC and a Browser updated in terms of properly configured security patches, with an active firewall, antivirus and anti spyware and that they verify the authenticity of the websites that they visit on the Internet, and should avoid websites whose reputation they do not trust.
UNDER WHAT CIRCUMSTANCES IS DATA COMMUNICATION SENT TO OTHER ENTITIES (THIRD PARTIES AND SUBCONTRACTORS)?
“PELLETSPOR”, within the scope of its activity, may use third parties to provide certain services. Sometimes, the provision of these services implies access, by these entities, to personal data of Customers/Suppliers. When this occurs, “PELLETSPOR” takes the appropriate measures to ensure that the entities that have access to the data are reputable and offer the highest guarantees at this level, which is duly enshrined and safeguarded contractually.
Therefore, any entity subcontracted by “PELLETSPOR” will process the personal data of our Customers/Suppliers, in the name and on behalf of “PELLETSPOR” and adopting the necessary technical and organizational measures in order to protect personal data against destruction, accidental or unlawful, accidental loss, alteration, dissemination or unauthorized access and against any other form of unlawful processing.
In any case, “PELLETSPOR” remains responsible for the personal data that is
available.
UNDER WHAT CIRCUMSTANCES DO WE TRANSFER YOUR PERSONAL DATA
The provision of certain services by “PELLETS*OR” may involve the transfer of your data outside of Portugal, including outside the European Union or to International Organizations.
In such a case, “PELLETSPOR” will strictly comply with the applicable legal provisions, in particular regarding the determination of the adequacy of the destination country(ies) with regard to the protection of personal data and the requirements applicable to such transfers, including, whenever applicable, the conclusion of appropriate contractual instruments that guarantee and respect the legal requirements in force.
HOW CAN YOU FIND OUT ABOUT ANY CHANGES TO PT PORTUGAL’S PERSONAL DATA PROTECTION POLICY
“PELLETSPOR” reserves the right to, at any time, make adjustments or changes to this *Personal Data Protection Policy, and these changes will be duly publicized in the various communication channels, and therefore recommends periodic consultation.
Approved on September 18, 2023