PRIVACY POLICY
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CONTACTS
Pedrouços Street, 37 – Warehouse 5
1400-285 Lisbon
+351 21 361 61 20
info@steam.pt
SERVICES AND SOLUTIONS
The protection of privacy and personal data is a fundamental commitment of STEAM – Smart Business Services, SA, to the data subject (also, "data subject") who uses its platforms and services.
With the application of the new General Data Protection Regulation (GDPR), from May 25, 2018, STEAM wishes to state that it remains strongly committed to protecting the privacy and personal data of the respective data subject who uses the STEAM digital platforms and services and, to that end, is updating its Privacy Policy in accordance with all the principles and standards of data protection that underpin the GDPR.
In this document, we aim to explain what personal data we collect, for what purposes we may use it, how we process it, with whom we share it, how long we retain it, as well as how to contact us and exercise your rights.
SERVICES AND SOLUTIONS
The new GDPR establishes the rules regarding the processing, by a person, a company or an organization, of personal data relating to individuals in the European Union (EU).
The GDPR protects personal data regardless of the technology used to process that data; the protection is technologically neutral and applies to both automated and manual processing, provided that the data is organized according to predefined criteria (for example, alphabetically). The way the data is stored—whether in a computer system, through video surveillance, or on paper—is also irrelevant; in all these cases, personal data is subject to the protection requirements set out in the GDPR.
SERVICES AND SOLUTIONS
STEAM is responsible for the processing of personal data, within the scope of the GDPR.
SERVICES AND SOLUTIONS
By providing their personal data to STEAM, the data subject consents to its processing in accordance with this Privacy Policy.
This Privacy Policy applies to data that has been directly provided by the data subject or collected during the data subject's access to digital platforms and STEAM services.
STEAM reserves the right to change its Privacy Policy, so we advise you to consult this document regularly. If the Privacy Policy is changed, we will post a notice on our digital platforms.
SERVICES AND SOLUTIONS
STEAM collects personal information, voluntarily provided by the data subject during optional registration. All collected data is processed automatically.
SERVICES AND SOLUTIONS
Personal data is information relating to an identified or identifiable person. A person is considered identifiable if they can be identified directly or indirectly. A set of distinct pieces of information that can lead to the identification of a specific person also constitutes personal data.
Examples of personal data:
First and last name;
Email address;
An identification card number;
Location data (for example, the location data function on a mobile phone);
IP address (Internet Protocol);
Cookies;
Your phone's advertising identifier;
Sound or image.
SERVICES AND SOLUTIONS
The data subject is the natural/legal person to whom the data relates and who has used the STEAM digital platforms and services.
SERVICES AND SOLUTIONS
TYPES / DATA
Key identifiers: Name, Civil or Tax Identification Number, Passport Number, Date of Birth, Marital Status, Address, Telephone Number, Email Address, Nationality, Photographs and Files from Mobile Device, Family Member Information, Relationship Information.
Additional identifiers: IBAN, geolocation, education level, gender, profession, socio-economic data, personal ID, IP address, social media addresses, mobile device type, operating system, operating system version.
Special protection: Personal data of children under 16 years of age.
SERVICES AND SOLUTIONS
PURPOSES / DATA PROCESSING / DATA STORAGE PERIOD
Telephone contacts: Contacts following requests for clarification of doubts related to the services provided by STEAM. One year.
Email contact: Contacts following requests for clarification of doubts related to the services provided by STEAM. One year.
Newsletter delivery: Sending financial information related to services provided by STEAM. One year.
CV reception and job information: Contacts for filling job positions at STEAM. One year.
We will request your explicit consent before using your information for purposes other than those expressly set forth in this Privacy Policy.
SERVICES AND SOLUTIONS
The holder of personal data has the rights to information, access, rectification or erasure of personal data, and the right to data portability, as well as the right to restrict or object to the processing of their data, within the scope and terms of the GDPR and other applicable legislation.
The data subject may withdraw, at any time, the consent given for the processing of their personal data, within the framework of the GDPR. The revocation of consent will not affect the lawfulness of the processing of personal data carried out up to that point, based on the consent previously given.
You also have the right to lodge a complaint regarding the processing of your data with the CNPD (National Data Protection Commission).
Exercise your rights through the following contacts:
E-mail
info@steam.pt
Letter
STEAM – Smart Business Services
To the attention of the Data Protection Officer
Condominium-Alcântara Rio, Rua da Cozinha Económica, 36 – 2nd Floor, 1300-149 Lisbon
Exercising these rights is free of charge, except in the case of a manifestly unfounded or excessive request, or one that is unjustifiably repeated, in which case a reasonable fee may be charged taking into account the costs.
Responses to requests should be provided without undue delay, within one month of receipt of the request, unless the request is particularly complex 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 requests received.
As part of your request, you may be asked to prove your identity to ensure that personal data is only shared with the rightful owner.
SERVICES AND SOLUTIONS
Personal data may be transmitted to subcontractors for processing on behalf of and under the account of STEAM. In this case, STEAM will take the necessary contractual measures to ensure that subcontractors respect and protect the data subject's personal data.
The data may also be transmitted to third parties – entities other than STEAM or its subcontractors – such as companies within STEAM, companies with which STEAM develops partnerships, if the data subject has consented – or entities to whom the data must be communicated by law, such as the Tax Authority, judicial authorities, criminal police bodies, among others.
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General Data Protection Regulation (GDPR): Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016).