Sotécnica – Sociedade Electrotécnica, S.A., construction license no. 55-PUB which, in Portugal, operates in the areas of energy, transmission, substations and renewable energies, under the brand Omexom, a brand of VINCI Energies, recognizes the utmost importance of protecting your Personal Data.
We are fully committed to ensuring that any Personal Data is processed in a responsible manner, and in accordance with applicable data protection legislation.
To continue to develop our activity and provide our services at a level of excellence, we believe that the protection of your data is essential. To achieve this goal, we believe the following information is indispensable:
A. Responsible for the treatment of your Personal Data
B. Principles applicable to the protection of your Personal Data
C. Personal Data, Treatment of Personal Data and Data Subject
D. Category of Personal Data that SOTÉCNICA treats
E. Purposes for the processing of your Personal Data
F. Lawfulness Basics
G. Term of retention of your Personal Data
H. Transmission of your Personal Data
I. International Transfers of Personal Data
J. Your rights and how to exercise them
K. The Internal Data Protection Officer
L. Security of your Personal Data
M. Confidentiality
N. Cookies
O. Contacts
P. Changes to this Data Protection and Privacy Policy
A. Responsible for the treatment of your Personal Data
The Responsible entity for the Treatment of your Personal Data is SOTÉCNICA – Sociedade Electrotécnica, S.A. (“SOTÉCNICA”) that provides services and/or supplies products, determining for this purpose, without limiting:
- Personal Data that must be processed in the context of providing services and / or supplying products;
- The Purposes for which your Personal Data is processed; and,
- The means to be applied for the processing of your Personal Data.
B. Principles applicable to the protection of your Personal Data
The Treatment of your Personal Data is carried out in accordance with the general principles set out in the General Regulation on Data Protection (“GDPR”), namely:
- In the context of the relationship with you, SOTÉCNICA ensures that your Personal Data will be treated in a lawful, loyal and transparent manner («Principle of lawfulness, loyalty and transparency»);
- SOTÉCNICA collects your Personal Data for specific, explicit and legitimate purposes and does not subsequently treat the same Data in a manner incompatible with those purposes («Principle of limiting purposes»);
- SOTÉCNICA ensures that only appropriate and relevant Personal Data is processed, and limited to what is strictly necessary for the purposes for which they are processed («Principle of data minimization»);
- SOTÉCNICA takes the appropriate measures so that the inaccurate Personal Data, considering the purposes for which they are processed, are erased or rectified as stipulated in the Regulation («Principle of accuracy»);
- SOTÉCNICA keeps Personal Data in a way that allows its identification only for the period necessary for the purposes for which they are processed («Conservation principle»);
- SOTÉCNICA ensures that your Personal Data is treated in a way that guarantees your security, including protection against its unauthorized or unlawful treatment and against its loss, destruction or accidental damage, adopting the appropriate technical or organizational measures («Principle of integrity and confidentiality»).
C. Personal Data, Treatment of Personal Data and Data Subject
Personal Data is all information and / or elements that, regardless of their support, can identify you or make you identifiable, directly or indirectly, before SOTÉCNICA, especially by reference to an identifier, such as a name, an identification number , your location data and / or identifiers electronically or to one or more specific elements of your physical, physiological, genetic, mental, economic, cultural or social identity.
Treatment of Personal Data means the operation or set of operations carried out on Personal Data of the Data Subject, 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, recovery, consultation, use, dissemination by transmission, diffusion or any other form of availability, comparison or interconnection, limitation, erasure. The concept of Personal Data Treatment is very broad and will apply to all operations or set of operations carried out by SOTÉCNICA with reference to your Personal Data.
In the context of the activities developed by SOTÉCNICA, the Data Subject is, without limitation, the client and / or former clients, potential clients, investors, partners, jobseekers, employees and ex-employees, employees of partners, suppliers and providers of services and their collaborators, claimants, visitors and individuals captured in video surveillance images and all those individuals who maintain a relationship with SOTÉCNICA and to whom the Personal Data relate.
SOTÉCNICA does not voluntarily requests or collects personal data from minors. If SOTÉCNICA discovers that it has inadvertently collected the personal data of a child under the age of 18, it will immediately delete the records containing that child’s personal data. We emphasize, however, that SOTÉCNICA may collect personal data relating to minors, when provided by parents or by a legal guardian who expressly consents to such collection.
D. Category of Personal Data that SOTÉCNICA treats
In the development of its activities, SOTÉCNICA processes the Personal Data of a significant set of categories of Data Owners.
The Personal Data that SOTÉCNICA collects always depends on the nature of the interaction, but may include the following:
| Personal Data Category | Personal Data |
| Personal Contact details | Name, surname, postal address, telephone or mobile number, fax number, e-mail address or other similar contact information. |
| Business Data for the provision of services and / or products | 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. |
| Account Data | Way of purchase or subscription of products and/or services, its transaction, billing history and assistance in the context of the services used (from SOTÉCNICA) or any other related information. |
| Demographic Data | Country, sex, age, preferred language, general education and professional background, as well as data of general interest about work. |
| Preferences Data | Informação sobre as preferências e interesses do titular, na medida em que isso esteja relacionado com os produtos e/ou serviços e sobre a forma como prefere receber as comunicações.
Information about the holder’s preferences and interests, as far as this is related to the products and/or services and how he prefers to receive communications. |
| Social networks Data | Information shared on social networks when interacting with SOTÉCNICA, where transparency is guaranteed through the existence of adequate privacy policies. |
| IT usage Data | User ID, roles, rights, login times, computer name, IP address. |
We emphasize that you will not be required to share your Personal Data with SOTÉCNICA. However, if you choose not to share your personal information, in some cases, SOTÉCNICA may not be able to provide the services or supply the products you want, ensure certain specialized features or effectively answer any questions you may have.
E. Purposes for the processing of your Personal Data
The development and performance of the various activities pursued by SOTÉCNICA, mean the existence of a relevant set of specific, explicit and legitimate purposes for the treatment of your Personal Data, such as:
| Purposes | Treatment Purposes |
| Accounting, Tax and Administrative Management | Client management
Supplier management Administrative management Economic and accounting management |
| Commercial Activity | Contact Management
Customer Management for the provision of services and/or supply of SOTÉCNICA products |
| Image Capture and Recording by CCTV Devices | Video surveillance for the safety of people and property |
| Access Control Management | Access control for the protection of people and property |
| Human Resources Management | Personnel selection and recruitment |
| Electronic Communications Management | Management of the use of websites and applications
Traffic/location data retention |
| Compliance with Legal Obligations | Data transfer to third parties |
F. Lawfulness Basics
By reference to the «Principle of Lawfulness» enshrined in current and future data protection laws, in the development and performance of its activities, SOTÉCNICA only treats your Personal Data when there is a lawfulness foundation that legitimizes the treatment, namely:
| Lawfulness Basics | What do they consist of? |
| Consent
|
SOTÉCNICA will only process your Personal Data if you consent to the respective Treatment through a manifestation of will, free, specific, informed and explicit, by which you accept, by means of a declaration (in writing or orally) or an unequivocal positive act (by filling an option), that your Personal Data is subject to Treatment. |
| Pre-contractual arrangements or execution of a contract | SOTÉCNICA may process your Personal Data if it is necessary, without limiting, for the execution of an employment contract, for the provision of services and / or supply of products to which it is a part as an Employee, Client and / or Supplier, or to perform pre-contractual steps at your request. |
| Compliance with a legal obligation | SOTÉCNICA 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 Holder | SOTÉCNICA may process your Personal Data to ensure the defense of your vital interests, particularly when the same Treatment is essential to your life. |
| Legitimate Interests | SOTÉCNICA, other Responsible or Third Parties, may process your Personal Data as long as that same Treatment is based on legitimate interests and does not prevail over your interests or fundamental rights and freedoms. |
G. Retention period of your Personal Data
SOTÉCNICA keeps your Personal Data only for the necessary period of time to carry out the specific purposes for which it was collected. However, SOTÉCNICA may be required to retain some Personal Data for a longer period, considering factors such as:
- Legal obligations, under the laws in force, to keep Personal Data for a certain period;
- Limitation periods, under the laws in force;
- (eventual) Disputes; and,
- Guidelines issued by the competent data protection authorities.
During the period of Treatment of your Personal Data, SOTÉCNICA guarantees that they are treated in accordance with this Data Protection and Privacy Policy. As soon as your data is no longer needed, SOTÉCNICA will proceed to its safe removal.
H. Transmission of your Personal Data
| Entities with which SOTÉCNICA shares your Personal Data | Why we share your Personal Data |
| Subcontractors | Your Personal Data may be shared with companies in charge of providing services to SOTÉCNICA.
The companies in charge of providing services are bound by SOTÉCNICA by written contract, only being able to 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 third party. |
| Other Responsible and/or
Third Parties |
Your Personal Data may be shared internally with other SOTÉCNICA companies that will comply with the data protection rules applicable according to the purposes attached to the Treatment performed.
At 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. |
I. International Transfers of Personal Data
SOTÉCNICA may transfer your Personal Data outside the European Economic Area (“EEA”), to locations that may not guarantee the same level of protection.
However, SOTÉCNICA only transfers your Personal Data outside the EEA:
- Through binding rules applicable to SOTÉCNICA companies (binding corporate rules);
- When the transfer is made to a location or through a method or in circumstances that the European Commission considers ensuring adequate protection of your Personal Data;
- When you have implemented standard data protection clauses adopted by the European Commission or a competent data protection authority; or,
- When none of the above apply, but the law still authorizes such a transfer, for example, if it is necessary for the declaration, exercise or defense of a right in a judicial proceeding.
J. Your rights and how to exercise them
As the Holder of Personal Data processed by SOTÉCNICA, you have the right to information, access and rectification or erasure of personal data and the right to data portability, the right to limit or oppose the processing of your data, within the scope and terms of the GDPR and other applicable legislation.
The holder may withdraw, at any time, the consent he has given for the processing of his personal data, within the framework of the GDPR. The revocation of consent will not affect the lawfulness of the processing of personal data that has been carried out until now, based on the consent that has previously been provided.
You also have the right to file a complaint regarding the processing of your data to CNPD.
You may at any time, in writing, exercise the rights enshrined in the Personal Data Protection Law and other applicable legislation by e-mail rgpd@sotecnica.pt.
K. The Data Protection Officer
SOTÉCNICA has appointed a person responsible for the protection of personal data, who assumes a fundamental role within SOTÉCNICA in monitoring the data processing activities carried out and ensuring the respective legal compliance.
SOTÉCNICA has not appointed a Data Protection Officer (“DPO”), as it is not mandatory under the terms of articles 37 of the GDPR.
You may, however, at any time, in writing, contact SOTÉCNICA for any questions related to Data Protection and your privacy by emailing: rgpd@sotecnica.pt .
L. Security of your Personal Data
Your Personal Data will be treated by SOTÉCNICA, in the context of the purposes identified in this Policy, in accordance with SOTÉCNICA’s policy and internal rules and using appropriate technical and organizational measures to promote its security and integrity, namely in relation to the unauthorized or unlawful treatment of your personal data and the respective loss, destruction or accidental damage.
Without limiting, SOTÉCNICA uses logical and physical security requirements and measures to ensure the protection of your Personal Data by preventing unauthorized access, ensuring that information is stored on secure computers in a closed and certified information center and that Data is encrypted whenever possible, implements auditing and control procedures to ensure compliance with security and privacy policies and periodically reviews our security policies and procedures to ensure that SOTÉCNICA systems are safe and protected.
However, given that the transmission of information over the Internet is not completely secure, SOTÉCNICA cannot guarantee the security of your Data when transmitted over an open network.
M. Confidentiality
SOTÉCNICA recognizes that the information you provide to us may be confidential. SOTÉCNICA does not sell, rent, distribute, nor commercially or otherwise make Personal Data available to any third party, except in cases where it needs to share information with Service Providers for the purposes set out in this Privacy Policy. SOTÉCNICA preserves the confidentiality and integrity of your Data and protects it in accordance with this Privacy Policy and all applicable laws.
N. Cookies
SOTÉCNICA uses search technology through Cookies. SOTÉCNICA’s Policy on the use of cookies is defined in the Cookies Policy.
O. Contacts
In case you have any questions or would like further information about how we treat your Personal Data, and what our information security practices are, please do not hesitate to contact us at:
Email: rgpd@sotecnica.pt
Address: EN 115 Km 78,67 – Edifício D – 2664-5020 São Julião do Tojal
P. Changes to this Data Protection and Privacy Policy
SOTÉCNICA may periodically update this Privacy Policy, as well as any other specific data protection and privacy statement. When making changes to this Privacy Policy, a new date will be added at the beginning of this document.