Privacy Policy

Quaternaire Portugal, Consultoria para o Desenvolvimento SA., hereinafter referred to as Quaternaire, is aware of the implications and of its responsibility to comply with the changes introduced on personal data protection, namely with the coming into effect on 25 May 2016 of the General Data Protection Regulation (GDPR), approved by Regulation (EU) 2016/679, of 26 April 2016 and Law 58/2019, of 8 August. 

 

Quaternaire assumes, therefore, the commitment to ensure the protection of all personal data provided to it, having adopted several technical and organisational security measures in order to protect personal data against any form of unlawful processing.

 

Quaternaire also assumes the commitment to continuously improve the set of procedures and techniques implemented for the protection of personal data, in addition to relying on all the suggestions that the users of this website may send us.


 

These Privacy Terms and Conditions apply exclusively to the processing of personal data by Quaternaire collected through its website or commercial and promotional actions.

 

Data Collection and Processing

 

Personal data is requested when the User requests a contact and/or the sending of newsletters. 

 

Personal data is collected exclusively for the following purposes:
– Response to contact request;
– Sales management;
– Improving or customising our services;
– Sending newsletters and other promotional actions. Customers can cancel their subscription to the e-mail newsletter service by clicking on the newsletter link that we send by e-mail; 
– Spontaneous applications.

 
 

Personal Data Collected

 

Depending on how you contact us (online, and/or in person), we collect various types of information about you, as described below:
– Personal contact information: this includes information you provide to us that allows us to contact you, such as your name, email address, telephone and mobile phone numbers. 
– Website/communications usage information: when you browse and interact with our Websites or newsletters, we use automatic data collection technologies in order to collect certain information about your activity. This includes information such as the links you click on, the pages or content you view and for how long, as well as other similar information and statistics about your interactions such as content response times, download errors and length of visits to particular pages. This information is captured through automated technologies such as cookies and is also collected through third party tracking services (such as Double Click, Google Analytics, Adobe Dynamic Tag Management and/or Omniture). If can, if you so wish, object to the use of such technologies. 



 

Subcontracted Entities 

 

Quaternaire uses or may use third parties, subcontracted by it, to process User Data on behalf of Quaternaire and in accordance with the instructions given by the latter, in accordance with the law and the terms of this privacy policy. 

 

These subcontracted entities may not transmit the User Data to other entities without Quaternaire's prior written authorisation, being prevented from subcontracting other entities without Quaternaire's prior authorisation. 

 

Quaternaire assumes the commitment to subcontract only entities that offer the maximum security in the execution of adequate technical and organisational measures, in order to guarantee the defence of the User's rights. 

 

All subcontracted entities are bound to Quaternaire's privacy policy through a written contract which regulates, inter alia, the object and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties. 

 

After the collection of personal data, Quaternaire provides the user with information about the categories of subcontracted entities that, in the specific case, may perform data processing on its behalf. 
 

 

General Principles Applicable to the Processing of User Data

 

In terms of general principles regarding the processing of personal data, Quaternaire undertakes to ensure that the User Data it processes are:
- The object of processing that is lawful, fair and transparent in relation to the User; 
- Collected for specified, objective and legitimate purposes and not further processed in a manner contrary to those purposes;
- Adequate, justified, and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and up to date where necessary, with all necessary steps being taken to ensure that data which are inaccurate, in light of the purposes for which they are processed, are erased or corrected without delay;
- Kept in a form which permits identification of the User only for the period necessary for the purposes for which the data are processed; 
- Processed in a manner that ensures their security, including protection against unauthorised or unlawful processing and against their loss, destruction or unforeseen damage, with appropriate technical or organisational measures being taken;
- Data processing carried out by Quaternaire is permitted and legal when at least one of the following situations occurs: 
- The User has unambiguously given consent to the processing of User Data for one or more specific purposes; 
- Processing is necessary for the performance of a contract to which the User is a party, or for pre-contractual procedures at the User's request; 
- Processing is necessary for the fulfilment of a legal obligation to which Quaternaire is subject;
- Processing is necessary in order to protect the fundamental interests of the User or another individual;
- Processing is necessary for the purposes of the legal interests pursued by Quaternaire or third parties (except if the interests or fundamental rights and freedoms of the User that require the protection of personal data prevail). 

 

Quaternaire undertakes to ensure that the processing of User Data is only done under the conditions listed above and with respect for the principles mentioned above.

 

When the processing of User Data is carried out by Quaternaire based on the User's consent, the User has the right to withdraw his or her consent at any time. The withdrawal of consent, however, does not compromise the legality of the processing carried out to date by Quaternaire based on the consent previously given by the User. 
 

 

Conservation period

 

The length of time for which data is stored and retained varies depending on the purpose for which the information is processed.

 

In fact, there are legal requirements that require data to be kept for a minimum period of time. Thus, and whenever there is no specific legal obligation, the data will be stored and kept only for the minimum period necessary for the purposes that motivated their collection or their subsequent processing and, upon expiration, they will be deleted. 
 

 

Data Security

 

Technical, Organisational and Safety Measures Implemented 

 

To ensure the security of the User Data and maximum confidentiality, Quaternaire treats the information provided in an absolutely confidential way, according to its internal security and confidentiality policies and procedures, which are periodically updated according to the needs, as well as to the terms and conditions legally provided. 

 


Depending on the nature, scope, context and purposes of the data processing, as well as the risks arising from the processing for the rights and freedoms of the User, Quaternaire undertakes to apply, both when defining the means of processing and at the time of the processing itself, the necessary and appropriate technical and organisational measures to protect the User Data and to comply with legal requirements. 

 

It further undertakes to ensure that, by default, only data that are necessary for each specific purpose of the processing shall be processed and that such data shall not be made available without human intervention to an indefinite number of persons. 


 

Communication between the user's device and the Quaternaire Website is made through secure channels and communications using the HTTPS protocol and the SSL security standard. 

 

Still, in terms of general measures, Quaternaire adopts the following:
- Regular audits to identify the competence of the technical and organisational measures implemented;  
- Awareness raising and training of staff involved in data processing operations; 
- Pseudonymisation and encryption of personal data;
- Mechanisms capable of ensuring the permanent confidentiality, availability and resilience of information systems; 
- Mechanisms to ensure that information systems are rapidly re-established and personal data can be accessed in the event of a physical or technical incident.
 

 

Sharing of personal data

 

Within the scope of its activity, Quaternaire may use third parties for the provision of certain services. 

 

Sometimes, the provision of these services implies access, by these entities, to our Customers' personal data. Quaternaire remains responsible for the personal data provided. 

 

When this happens, the appropriate measures are taken to ensure that the entities that have access to the data are reputable and offer the highest guarantees at this level, which will be duly enshrined and safeguarded in a contract to be entered between the parties.

 

Therefore, any subcontractor shall be obliged to adopt the necessary technical and organisational measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

 

Rights of Users (data subjects) 

 

Users have their rights enshrined in the GDPR, namely, under Article 15 and following, the right to rectification, right to erasure (right to be forgotten), right to restriction of processing, right to portability, right to object, and for this purpose may use the "Form for the Exercise of Rights of the Data Subject".

 

Information provided to the User (when data is collected directly from the User): 
- The identity and contacts of Quaternaire, as controller;
- The purposes  for which the personal data are processed, as well as, where applicable, the legal reasons for the processing; 
- If the data processing is based on legitimate interests of Quaternaire; 
- If applicable, the recipients or categories of recipients of the personal data; 
- Period of conservation of the personal data; 
- The right to request from Quaternaire information on the use of personal data, as well as its correction, deletion or limitation, the right to oppose processing and the right to data accessibility;
- If the processing of data is based on the User's consent, the right to withdraw it at any time, without compromising the legality of the processing carried out on the basis of the consent previously given; 
- The right to lodge a complaint with the CNPD or other supervisory authority;                 
 - Indication whether the communication of personal data is a legal or contractual obligation, or a necessary requirement to enter into a contract, as well as whether the data subject is obliged to provide the personal data and the possible consequences of not providing such data; 
- where applicable, the existence of automated decisions (carried out by computer algorithms), including profiling, and information concerning the basic concept and the significance and expected consequences of such processing for the data subject. 
 

In the event that User Data are not collected directly by Quaternaire from the User, in addition to the information referred to above, the User is also informed about the categories of personal data subject to processing as well as about the origin of the data and, possibly, whether they come from publicly accessible sources.
 

Procedures and measures implemented with a view to fulfilling the right to information. 

The information is provided in writing (including by electronic means) by Quaternaire to the User prior to the processing of personal data concerned. Under the terms of the applicable law, Quaternaire has no obligation to provide the user with the aforementioned information when and insofar as the user is already aware of it. 

 

Upon request, Quaternaire will provide the User, free of charge, with a copy of the User Data that is being processed. The supply of other copies requested by the User may involve administrative costs. 
 
 
Right of Access to Personal Data

 

Quaternaire guarantees the means that allow the User to consult his/her Personal Data. The User has the right to obtain from Quaternaire the confirmation that personal data concerning him or her are or are not subject to processing and, if applicable, the right to access his or her personal data and the following information: 
- The purposes of data processing;
- The categories of personal data concerned
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or belonging to international organisations;
- The retention period of the personal data;
- Right to request that Quaternaire corrects, deletes or limits the processing of personal data, or the right to prevent such processing; 
- Right to lodge a complaint with the CNPD or another supervisory authority; 
- If the data has not been collected from the User, the available information on the origin of such data;
- The existence of automated decisions, including profiling, and information concerning the logic involved and the significance and expected consequences of such processing for the data subject;
- Right to be informed about the appropriate safeguards associated with the transfer of data to third countries or international organisations. 
Upon request, Quaternaire will provide the User, free of charge, with a copy of the User Data that is being processed. The supply of other copies requested by the User may involve administrative costs. 

 


Rigth to Rectification of Personal Data 

The User has the right to request at any time the rectification of his or her Personal Data as well as the right to have incomplete Personal Data completed, including by means of an additional declaration. 
 
In the event of data rectification, Quaternaire shall inform each recipient to whom the data have been transmitted of the respective rectification, unless such communication is considered impossible or involves a disproportionate effort for Quaternaire. 

 


Right to the Erasure of Personal Data ("Right to be Forgotten") 

The user has the right to obtain, from Quaternaire, the deletion of his or her data when one of the following reasons applies: 
- The User Data is no longer necessary for the purpose for which it was collected or processed; 
- The User withdraws the consent on which the data processing is based and there is no other legal ground for such processing; 
- the User objects to the processing under the right to object and there are no overriding legitimate interests justifying the processing;
- If the User Data is unlawfully processed; 
- If the User Data must be deleted in order to comply with a legal obligation to which Quaternaire is subject; 
- Under applicable legal terms, Quaternaire is not obliged to delete User Data to the extent that the processing is necessary for compliance with a legal obligation to which Quaternaire is subject or for the purposes of the declaration, exercise or defence of a right of Quaternaire in legal proceedings.

 


In the event of data deletion, Quaternaire shall inform each recipient/entity to whom the data have been transmitted of their deletion, unless such communication proves impossible or involves a disproportionate effort for Quaternaire. 

 

When Quaternaire has made the User Data public and is obliged to delete it pursuant to the right of such deletion, Quaternaire undertakes to ensure the measures that are reasonable, including of a technical nature, taking into consideration the available technology and the costs of its implementation, to inform the parties responsible for the actual processing of the personal data that the User has requested them to delete the links to such personal data, as well as the copies or reproductions thereof. 

 

 
Right to Limitation of Processing of Personal Data

The User has the right to obtain, from Quaternaire, the limitation of the processing of the User Data if one of the following situations applies (limitation consists in inserting a mark on the personal data stored with the aim of limiting their processing in the future, thus placing them in a state of quarantine):
- If you contest the accuracy of the personal data, for a period that allows Quaternaire to verify its accuracy; 
- If the processing is unlawful and the User objects to the deletion of the data and instead requests limitation of its use; 
- If Quaternaire no longer needs the User Data for processing purposes, but such data is required by the User for the purposes of stating, exercising or defending a right in legal proceedings;
- If the User has opposed the processing, until it is ascertained that Quaternaire's legitimate reasons prevail over those of the User. 
 

Where the User Data is subject to limitation, it may, with the exception of storage, only be processed with the consent of the User or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person, or for reasons of public interest as provided by law. 

 
The User who has obtained the limitation of the processing of his or her data in the cases mentioned above will be informed by Quaternaire before the limitation to processing is cancelled.

In case of limitation of data processing, Quaternaire will inform each recipient to whom the data have been transmitted of the limitation, unless such communication proves impossible or involves a disproportionate effort for Quaternaire. 
 
 

Right of Portability of Personal Data 

 

The User has the right to receive the personal data concerning him or her that he or she has provided to Quaternaire, in a structured, commonly used and automatically readable format by software, and the right to transmit such data to another controller if:
- the processing is based on consent or on a contract to which the User is a party; and 
- The processing is performed by automated means.

 

The right of portability does not include inferred data or derived data, i.e. personal data that are generated by Quaternaire as a consequence or result of the analysis of the data subject to processing. 

 

The User has the right to have his or her personal data transmitted directly between controllers, where technically possible.
 

The user has the right to object at any time, for reasons relating to his or her particular situation, to the processing of personal data concerning him or her that is based on the exercise of legitimate interests pursued by Quaternaire or when the processing is carried out for purposes other than those for which the personal data were collected, including profiling, or when the personal data are processed for statistical purposes.

 

Quaternaire will terminate the processing of the User Data, unless it provides urgent and legitimate reasons for such processing that outweigh the interests, rights and freedoms of the User, or for the purposes of the declaration, exercise or defence of a right of Quaternaire in legal proceedings. 

 

Where the User Data is processed for direct marketing purposes, the User has the right to object at any time to the processing of data concerning him or her for the purposes of such marketing, which includes profiling insofar as it relates to direct marketing. If the User objects to the processing of his or her data for direct marketing purposes, Quaternaire will cease processing the data for this purpose. 

 


The User shall also have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces legal effects concerning him or her or significantly affects the User in a similar manner, unless the decision:
- Is necessary for the conclusion or the execution of a contract between the User and Quaternaire;
- Is authorised by legislation to which Quaternaire is subject or
- Is based on the explicit consent of the User.

            
We inform you that you have the right to lodge any complaint with the supervisory authority - Comissão Nacional de Proteção de Dados through the following contacts: Tel. +351213928400, Fax. +351213976832; email: geral@cnpd.pt. 

 

To exercise any of these rights, you can fill out the annex.
 

Links to partner sites

 

The Quaternaire website may contain links to third party/partner websites. The websites referred to are not under the control of Quaternaire, and thus it is not responsible for the content of any of these websites. It is recommended that users of the Quaternaire website, when accessing other websites, consult the pages that, within these sites, refer to their privacy policies.

Personal Data Breaches

 

In the event of a data breach and insofar as such breach is likely to involve a high risk to the rights and freedoms of the User, Quaternaire undertakes to communicate the personal data breach to the User concerned within 72 hours from becoming aware of the incident.

 

In legal terms, communication to the User is not required in the following cases: 
– 
Where Quaternaire has applied appropriate protection measures, both technical and organisational, and those measures have been applied to the personal data affected by the personal data breach, especially measures that render the personal data incomprehensible to any person not authorised to access such data, such as encryption;  
– If Quaternaire has taken subsequent measures to ensure that the high risk to the rights and freedoms of the User is no longer likely to materialise; or if the communication to the User would involve a disproportionate effort for Quaternaire. In such a case, Quaternaire will make a public communication or take a similar measure by which the User will be informed.  

Changes to the Privacy Policy

 

Quaternaire reserves the right to change this Privacy Policy at any time. If the Privacy Policy is modified, the date of the last change, available at the top of this page, is also updated. If the change is substantial, a notice will be posted on the Website.
 

Applicable Law and Jurisdiction

 

The Privacy Policy, as well as the collection, processing or transmission of User Data, are governed by the provisions of Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016 and Law 58/2019, of 8 August, as well as by other legislation and regulations applicable in Portugal. 

Any disputes arising from the validity, interpretation or implementation of the Privacy Policy, or which are related to the collection, processing or transmission of User Data, shall be submitted exclusively to the jurisdiction of the judicial courts of the district of Porto without prejudice to the applicable mandatory legal rules.
 

Contact us

 

If you have any questions regarding the use of your personal data you may contact our Data Protection Officer through the email address rgpd.epd@quaternaire.pt, andmust put GDPR in the "Subject" of the email.