I. We and our commitment
ACL IMPEX, L.da, is a limited liability company (Lda) hereinafter referred to as ACL IMPEX.
ACL IMPEX is profoundly committed in maintaining the confidentiality, integrity, and security of personal information of clients, business partners and any person that interacts with ACL IMPEX through various channels such as websites, digital files and third party social networks.
II. Collection and processing of personal data
We collect personal data from the following sources:
• A computer system consisting of a set of software solutions supported on a set of hardware devices and other similar solutions, including email services and other external digital repositories and communication solutions;
• Paper records stored in a restricted access area;
• ACL IMPEX website: www.aclimpex.com.
The same or similar policies will also be assumed, contractually signed with the ACL IMPEX, by entities that process the same personal data on behalf of ACL IMPEX.
ACL IMPEX considers it mandatory and will presume for all intents and purposes, without the possibility of proof to the contrary, that each individual will read the Privacy Policies of all the websites acceded to.
V. Concept of personal data
Personal data means any information or registration, of any nature and regardless of its support or format, namely sound, image, writing, chirograph or feature, relating to an identified or identifiable singular person.
An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
VI. The entity responsible for the processing of personal data
The entity responsible for collecting and processing the personal data and that determines the means of their processing is ACL IMPEX. Personal data is processed fairly and lawfully, and only to the extent necessary to fulfil their specific and legitimate purpose.
VII. Types of personal data collected and processed
In the course of its daily organisational activities, the ACL IMPEX acquires, processes and stores personal data, namely:
1. Personal data necessary to provide products to its customers, such as name, tax number, address, telephone number and email address, among others, which are necessary to fulfil their specific and legitimate purpose;
2. Personal data necessary to fulfil legal obligations, either to public entities or to private entities;
3. Data needed to manage customers and users, to fulfil contractual obligations with customers and suppliers, to satisfy legal obligations, to implement marketing actions, to conduct market studies and satisfaction surveys, to handle complaints. All of these actions involve dealing with personal data, such as names, tax numbers, addresses, telephone numbers and email addresses;
4. All personal data processed to reach compliance with applicable laws and to pursue ACL IMPEX’s legitimate business interests and legal rights, in particular tax and administrative management, enforcement of legal claims, the performance of compliance investigations and for regulatory and investigative purposes, and to ensure security of the installations.
Under applicable law, personal data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
VIII. When and how personal data is collected
ACL IMPEX collects personal data through direct contact, phone calls or through it’s website.
As a general rule, personal data is collected in the beginning of a contractual relationship or other business-related activity between the ACL IMPEX and the holder of personal data.
Some of the personal data are essential for the purposes of performing a contract or taking relevant pre-contractual steps, so in the absence or insufficiency of this data, it will not begin or continue. In these cases, ACL IMPEX will inform the data subject of the compulsory and essential nature of the personal data.
The personal data holder can object to the processing of personal data for purposes of advertising and data analysis at any time.
The data collected will be documented, whether in paper or digital format, in a strict compliance with the legislation that regulates the protection of personal data, being stored and contained in specific paper files and database, created and managed for this purpose and of restricted and exclusive access to ACL IMPEX employees who necessarily have to use these data in the pursuit of ACL IMPEX’s activity. In no case shall the data collected be used for any purpose other than that for which the consent has been given by the personal data holder, where necessary, or for the lawful and legitimate purpose of the collection.
IX. Purposes of the collection and processing of personal data
Personal data is processed for administering inquiries and agreements, as well as providing information and services in connection with such inquiries and agreements. Personal data may also be used for marketing and follow ups, as well as for sales and product development with the aim of improving ACL IMPEX’s products and services. Finally, personal data is also processed for tax and administrative management, enforcement of legal claims, the performance of compliance investigations and for regulatory and investigative purposes, and to ensure security of the installations.
At the moment that the personal data is collected, ACL IMPEX will precisely detail the sort of personal data collected and how it will be processed, held and stored.
X. For how long will personal data be kept
ACL IMPEX will store data for the shortest time possible. That period should take into account the reasons why ACL IMPEX needed to process the data, as well as any legal obligations to keep the data for a fixed period of time. After this period of time, the personal data will be erased.
XI. Right of access, to rectification, to erasure, to data portability and to restriction of processing
ACL IMPEX provides data subjects a copy of their processed personal data upon request at our registered office, at Rua Monte de Cima, n.º 314, 4835-606 Gondar, Guimarães, or by email at [email protected]
If you think your data protection rights have been breached, you can lodge a complaint with the National Data Protection Commission – Avenida D. Carlos I, n.º 134, 1.º, 1200-651 Lisboa; phone number: +351 213928400; fax: +351 213976832; email: [email protected]
XII. How ACL IMPEX protects personal data
ACL IMPEX took all steps reasonably necessary to ensure that your data is processed securely and protected against unauthorised access or processing.
All personal data collected through digital or paper forms, whether completed on the physical premises of ACL IMPEX or on the website (which requires encrypted sessions of the browser) are stored safely in our physical repositories and digital systems.
All the personal data is stored in a Datacenter owned by ACL IMPEX, or of its subcontractor, which possesses all the advanced physical and logistic security measures, that ACL IMPEX considers necessary for the protection of personal data.
ACL IMPEX will inspect and monitor work-related conduct of employees, only to the extent necessary to fulfil ACL IMPEX’s specific and legitimate purpose and in a strict compliance with the legislation. This monitorization consists in monitoring access controls, working hours, tasks and productivity, displacements and use of company’s vehicles. Not only the employees will have prior knowledge of these actions – being, whenever legally necessary and lawful, requested their consent –, but this data will be processed securely and protected by ACL IMPEX.
XIII. Appointed data protection officer
ACL IMPEX has appointed and maintains a Data Protection Officer, namely Sincronideia, Lda., who can be contacted by letter to ACL IMPEX’s address at Rua Monte de Cima, n.º 314, 4835-606 Gondar, Guimarães, or by email at [email protected]
, or by phone 253 539 780.
XIV. Communication of data to other entities, subcontractors or third parties
ACL IMPEX may have to transfer your personal data outside of Portugal. In such case, ACL IMPEX will rigorously comply with all applicable legal provisions, namely with respect to the determination of the reliability and suitability of the country of destination with respect to protecting personal data and the requirements applicable to such transfers.
“Cookies” are small software tags that are stored on your computer through your browser. As a rule, they only retain information related to your preferences and as such they do not contain your personal data.
Whenever this is not the case, the user shall always be asked for his or her consent to supply the data in accordance with applicable legislation.