PRIVACY POLICY

1.1 This Privacy Policy explains how we collect and process the personal data needed to provide the WEBSITE and the services made available through the WEBSITE.

1.2  Examples of such services are sending messages, subscribing to newsletters or applying for positions within the scope of recruitment and selection processes.

1.3  The aim of the WEBSITE and said services to be provided in an expeditious and undisturbed manner, describing the practices adopted for this purpose.

2.1 It is all information (regardless of nature and support) relating to a person and that identifies that person.

2.2 It is also the information that makes a person identifiable.

2.3 Identifiable means a person who can be identified, directly or indirectly, namely by reference to an identification number or other specific elements of his physical, physiological, mental, economic, cultural or social identity.

2.4 Examples of personal data that we collect are “name” and “email” when you contact us or “IP address” when you visit us.

3.1 GLINTT will use the personal data you provide us with for the following purposes:

3.2  These personal data processing operations are a necessary tool for your experience and satisfaction as a user, but also for the operation of the WEBSITE and the associated services, carried out in compliance with applicable legislation and in accordance with best practices.

3.3 Your personal data will not be reused for other purposes not previously identified or that bear no relation to the purposes for which they were initially collected.

4.1 The personal data that GLINTT processes has specific grounds, depending on the purposes for which they are intended.

4.2 In the following table you may see the fundamentals according to the identified purposes:

5.1 GLINTT will collect and process the following personal data, understood as minimal, necessary and appropriate for the respective purposes:

6.1 We will collect your personal data through the forms on the WEBSITE, but also through the WEBSITE itself and the communication and interaction between it and your equipment, and also through the messages you send us.

6.2 Your personal data is collected through your equipment as follows:

(a) Through your messages in the context of requests for information, and the relevant contact details;

(b) Through your subscription to the newsletter;

(c) Through your browser;

(d) Through cookies, pixel tags and other similar technologies;

(e) IP address.

6.3 GLINTT is committed to processing your data in accordance with the law and legitimately.

6.4 GLINTT will not sell, lease or share your personal data with third parties. However, in the cases clearly identified in this Privacy Policy, GLINTT may communicate your personal data to third parties. See Point 14 for more information.

6.5 The use of the WEBSITE and services provided by GLINTT is not meant for minors, and personal data of minors is not intentionally processed.

6.6 We repeat that the positions and vacancies you may apply for if you wish to collaborate with GLINTT or the ANF universe are on a specific platform under the responsibility of FARMINVESTE – INVESTIMENTOS, PARTICIPAÇÕES E GESTÃO, S.A.; we recommend reading Point 11 of this Policy.

7.1 Cookies are small files that collect information and are stored on your device through your browser.

7.2 They may be strictly needed for the operation of the WEBSITE, for example, to:

(a) Identify and authenticate the user; or

(b) Memorise the user’s usual preferences; or

(c) Allow the user to complete tasks without having to re-enter information (for example, when changing pages or returning, as in the case of form data, shopping basket, etc.); or

(d) Make, allow, facilitate or support notices from/through the WEBSITE; or

(e) Provide some features that the user requested; or

(f) Security of information systems and/or fraud prevention.

7.3 These cookies will be stored on your device and do not require consent.

7.4 Cookies can also be used to collect information, for example, to:

(a) Measure and obtain statistics on the use of the WEBSITE, for example, number of unique visitors, detect the keywords of search engines, detect aspects of navigation such as the duration of the visit, most visited pages or most accessed content (analytics cookies); or

(b) Adapt advertising and marketing based on your behaviour and profile, adapting the ads to be displayed (tracking cookies, advertising, analytics); or

(c) Third parties, other than the website owner, who collect browsing information through different websites in order to create said profiles (third-party cookies).

7.5 Storage of these tracking, advertising, analytics and third-party cookies will always depend on your acceptance and prior consent, which consent can be withdrawn at any time through specific tools and/or your browser.

7.6 Like cookies, tracking pixels, web beacons and other similar tools are images and/or pieces of code loaded when the user visits a website, page or content, but also when opening an email.

7.7 These tools contain an external link to a tool server and allow tracking user behaviour, obtaining data for online marketing, analysis, but also, redirecting marketing.

7.8 When the user visits the destination website, this operation is registered and noted in the log files of the tool server, and may include miscellaneous information about the user, namely, operating system, duration of, or IP address.

7.9 Storage of these tools will always depend on your acceptance and prior consent, which consent can be withdrawn at any time through specific tools and/or your browser.

8.1 The following table describes and explains how these tools are used on the WEBSITE:

9.1  Your personal data is kept safe by adopting various security measures, of a technical and organisational nature, that seek to ensure the confidentiality, integrity and availability of processing operations, for example, ensuring that your access happens only by those who are duly authorised.

9.2 To protect your personal data, we only use data centre providers that offer us adequate and documented security measures, namely guarantees that your personal data is stored on servers that are kept in controlled environments with limited access and offer resilience guarantees.

9.3 Personal data is kept on servers that provide us with adequate security guarantees to protect personal data against its dissemination, loss, misuse, alteration, unauthorised processing or access, and against any other form of unlawful processing.

9.4 Likewise, when you browse the WEBSITE, we protect your data with encryption, such as Transport Layer Security (TLS is a security protocol that protects telecommunications over the Internet).

9.5 Although we take the care and precautions, we feel appropriate to protect the personal data you provide and collect, we must be aware that no security system is completely impenetrable.

9.6 We remind you that you must take certain precautions in your navigation and use of the WEBSITE, namely when browsing public or shared networks. You should also be careful to log in and log out whenever you close the browser.

10.1 Your personal data will be kept for as long as necessary for the purposes for which they are intended, as listed in this Privacy Policy. As such:

10.2 If any specific or mandatory period results from the law, that will be the data retention period.

10.3 Notwithstanding, the stated periods do not affect the preservation of personal data beyond those periods in the following situations:

(a) pending the limitation period for any rights related to that purpose;

(b) for the purpose of declaring, enforcing or defending the rights of GLINTT in judicial proceedings;

(c) as long as no judicial decision has become final in the event of a dispute related to this purpose;

(d) to fulfil new legal obligations that GLINTT is subject to;

(e) for compliance with orders from judicial authorities and/or criminal police bodies within the scope of duly identified judicial proceedings, in compliance with a reasoned order from the competent judicial authority;

(f) for the fulfilment of orders issued by administrative authorities and competent regulatory entities within the scope of their powers and competences, namely, duly identified and substantiated administrative processes.

10. In all other cases, personal data will be kept at most for the periods listed above, which GLINTT deems sufficient to fulfil the purposes provided above.

10.5 After the retention period, all personal data collected will be deleted or anonymised.

11.1 FARMINVESTE - INVESTIMENTOS, PARTICIPAÇÕES E GESTÃO, S.A. will use the WEBSITE to direct users to its own platform for selecting and recruiting applicants.

11.2 FARMINVESTE - INVESTIMENTOS, PARTICIPAÇÕES E GESTÃO, S.A. is solely responsible for the processing of personal data for the purposes of selection and recruitment of applicants.

11.3 FARMINVESTE - INVESTIMENTOS, PARTICIPAÇÕES E GESTÃO, S.A. is responsible for complying with the duties of information and the exercise of rights in the scope of the selection and recruitment of applicants.

12.1 Before explaining how you may enforce your rights, you should know what they are.

12.2 Hence, the law gives you the right to ask us to enforce the following rights, which are enforced in accordance and within the limits defined in the law:

12.3 You are also entitled to file a complaint with the competent supervisory authority (in Portugal, the National Data Protection Commission at www.cnpd.pt)

12.4 For the purpose of enforcing the rights listed above, please contact GLINTT by email at privacidade@glintt.com.PRIVACIDADE@GLINTT.COM.

12.5 If you ask us to delete some or all of your personal data, some of the services requested may not be provided to you and GLINTT may retain only the personal data needed to fulfil the legal obligations to which it is bound.

13.1 You have the right to withdraw your consent at any time and without justification.

13.2 We remind you that withdrawing consent does not compromise the lawfulness of processing performed based on the consent previously given and that GLINTT will keep a record of that consent to comply with its legal obligations (demonstrate the lawfulness of the processing until the moment of withdrawal of consent).

13.3 To withdraw consent:

14.1 GLINTT may employ third parties to provide certain services, for example, in terms of data centre management, maintenance and technical support, marketing, which may have access to some of the personal data, namely, the data necessary for the purposes contracted. 

14.2 GLINTT ensures that the entities that have access to the data are credible and offer high guarantees of protection, data never being transmitted beyond what is needed to provide the service(s) hired; however, GLINTT remains responsible for the personal data provided. 

14.3 GLINTT may also communicate your data to the following entities:

(a) Companies of the business group to which GLINTT belongs and with which it has shared services or commercial partnerships to create and offer benefits;

(b) Other partners outside its business group (with your prior authorisation);

(c) Judicial representatives and courts, for the purpose of representing, declaring, enforcing or defending the rights of GLINTT in legal proceedings; 

(d) Competent judicial authorities or criminal police bodies within the scope of duly identified judicial proceedings, in compliance with a reasoned order from the competent judicial authority.

15.1 The WEBSITE may contain links to other websites that may collect and process your personal data for the purposes of those websites, and this processing is the sole responsibility of the owners of those websites, and GLINTT has no responsibility for its policies and/or practices.

15.2 An example of such third parties is LinkedIn, through the button on the WEBSITE, or Google, through the existing map on the WEBSITE. 

16.1 By default, no data transfers will take place outside the European Union.

16.2 If data transfers to third countries that do not belong to the European Union may occur, namely, when necessary for the purpose of providing services to GLINTT, the legal rules will be complied with, namely with regard to the suitability of the destination country as far as personal data protection and the requirements that apply to these transfers, personal data not being transferred to jurisdictions that do not offer guarantees of security and protection.

17.1 The WEBSITE is not aimed at children under thirteen (13) years of age, so we request that such minors do not provide us with personal data through the WEBSITE.

18.1 GLINTT appreciates that you do not send us and do not let us know any information related to:

(a) Physical or mental health, including information about the provision of health services or information that reveals information about your health status;

(b) Racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, genetic information, biometric information or data relating to sexual life or sexual orientation.

18.2 If, still, you send or make known these categories of personal data, they will be immediately deleted.

19.1 GLINTT reserves the right to readjust or change this Privacy Policy, at any time, these changes being publicised.

20.1If you have any questions or concerns regarding this Privacy Policy, please contact us by email at PRIVACIDADE@GLINTT.COM.

• SINTRA (Portugal), Sep. 24^th, 2020.