PRIVACY POLICY

This Privacy Policy includes information about the personal data processing activities carried out by GeoPoint Unipessoal, Lda., a company registered at the Commercial Registry Office of Lisbon with the unique registration and legal person number 505 097 133, with the share capital of € 15,000.00, with headquarters at Largo Doutor António Viana 3- 5º esq 1250-096 Lisboa (hereinafter referred to as “GeoPoint”) in the context of its activities as distributors of licensing and provision of consultancy and development systems services GIS software, including activities carried out through its website.

This Privacy Policy is governed by the provisions of the legislation applicable to privacy and data protection matters, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), applicable since May 25, 2018 and the respective implementing Law in the domestic legal order, Law no. 58/2019 of August 8.

As part of its main activities of licensing distribution and provision of GIS software consultancy services, and also its ancillary activities, GeoPoint processes personal data as data controller. The purpose of such processing operations is personal data that is voluntarily made available by the respective holders, who will be, in particular, customers, potential customers, business partners and suppliers of GeoPoint who are natural persons, or in the case of legal persons, representatives / people acting on behalf of such entities, holders of positions in the competent administrative entities that interact with GeoPoint, and users of the respective website (hereinafter collectively referred to as “Data Subjects”).

GeoPoint may also act as a Subcontractor, in relation to personal data that it processes in the context of activities carried out on behalf of third parties, namely in the context of the technical support it provides to customers who have acquired the licensing of products marketed by its partners and distributed by GeoPoint.

GeoPoint created and makes available through its website www.geopoint.pt relevant information about its activities, organization, products, offers, services, and the events it organizes and supports (hereinafter referred to as the “Website”).

GeoPoint respects and values ​​the privacy of all visitors and users of its Website, and only collects and processes their personal data in accordance with the provisions of this Privacy Policy, and in accordance with applicable laws.

1. What personal data is processed by GeoPoint?

GeoPoint is responsible for processing the following categories of personal data:

(i) Customer and potential customer data

Identification data and contact details of its customers who are natural persons, and of the representatives and contact persons of its clients who are legal persons, which are necessary data for the purposes of concluding contracts relating to the services provided by GeoPoint, as well as information relating to the history of customer relationships with GeoPoint.

(ii) Business partners

Identification data, including professional data, and contact data, namely, of GeoPoint’s business partners, or representatives, collaborators, consultants acting on their behalf.

(iii) Competent administrative entities

Identification data, including professional data, and contact data, namely, of professionals who perform functions in public bodies of direct or indirect administration of the State, or of local authorities, notaries or commercial or civil registry offices, Social Security delegations, public service concessionaires and other entities that provide public services relevant to the development of GeoPoint’s activities.

(iv) Suppliers

Identification data, including professional data, and contact data, namely, GeoPoint technicians or service providers, namely engineers, representatives and/or employees of entities that provide goods or services to GeoPoint.

(v) GeoPoint Website Users

The type of personal data that we collect and process through the use of our Website results from the information provided to us by the Data Subject through their registration/subscription to the newsletter on our Website, the subscription to the services provided by GeoPoint through the website by filling in the forms made available for this purpose. The personal data subject to processing consists of identification data and contact data. Additionally, the GeoPoint website uses functional and performance (analytical) cookies, in order to collect information regarding its users, with the purpose of improving and customizing the browsing experience, as well as tracking the use and effectiveness of the Website. The activation of these functionalities will be subject to the express acceptance of the Data Subjects. To find out more about our Cookies Policy, please see www.geopoint.pt/cookies

The Website contains add-ons that allow interconnection and data flow with social networks such as LinkedIn, directing website users to the website of this social network. This social media operator uses its own cookies and may also use pixelation, web beacons and other storage tools to collect and/or receive information from the website, and use this information to measure service and target advertising. GeoPoint warns that it does not have any control, nor does it exercise any influence over any social media operator, nor over their respective privacy and security policies, and users must inform themselves adequately about them.

The GeoPoint Website also contains content that is hosted on external websites, and the entities responsible for making this content available on the Website may use cookies (the “Third-Party Cookies”). Interaction with such content may result in the placement of Third Party Cookies on the Website user’s device, and GeoPoint does not control the way in which such cookies are used, so we suggest that you confirm on the respective websites how they are used, and how they can be managed by you.

To find out more about cookies, please seehttps://www.allaboutcookies.org/.

(vi) Workers and collaboratorsfrom GeoPoint and candidates who send their respective curriculum vitae to the latter;

(vii) Traineesor candidates for training promoted and/or managed by GeoPoint, by registering on the Website.

2. How does GeoPoint process personal data?

Under the terms of the GDPR, our use of your personal data must always be based on a lawful basis, including:

(i) the need for processing to contract the services provided by GeoPoint, and for the execution and management of the contractual relationships in question;

(ii) when processing is necessary to comply with GeoPoint’s legal obligations;

(iii) in a legitimate interest of GeoPoint; or

(iv) in consent provided by Data Subjects.

In the context of operating its Website, GeoPoint also processes the personal data of Data Holders to pursue its legitimate interests, namely promoting its functionalities, and establishing an effective means of communication with all visitors to it, taking into account the processing purposes described below.

Personal data collected through the Website may be used for the following purposes:

– To produce statistical analyses, particularly on Website traffic;

– To manage and improve the Website for optimal user navigation;

– To respond to requests or questions from users, and to provide them with technical assistance, if necessary;

– To respond to requests for registration in training or participation in events, available and/or promoted on the Website;

– To control requests for GeoPoint products and services that are made by users;

– To process any complaints or requests for assistance made by GeoPoint customers, or other users of the Website;

– To process applications (spontaneous or directed to an advertised vacancy) that are submitted via the Website.

In cases where data processing is based on the consent of Data Subjects, they are free to withdraw any consent they have previously given at any time, at their sole and exclusive discretion.

3. Security of your data when browsing the Internet

We have created appropriate and commercially reasonable technical and organizational security measures to store the personal data collected, to keep it confidential and to protect it against unauthorized or unlawful disclosure or access, accidental loss, destruction, alteration or damage, taking into account the state of the technology and the cost of implementation.

The Website may contain links to third party websites. We cannot be held responsible for the security and content of such third party websites. Owners must ensure that they have read the privacy and cookie policies of these companies before using or transferring personal data to them. The same applies to any third-party websites or content that you access using our products and services.

The Data Subject may choose to disclose their personal information, for example on social media or using third party services that allow them to post comments or other information, which means that these third parties may use this information. The information disclosed by the Holder through social networks, and social applications, are explored by the social network itself and are subject to its own terms of use, privacy and cookie policies. The Data Holder must ensure that he or she is aware of them and accepts or rejects them freely and clearly.

4. What are the rights of data subjects?

4.1. Right to access and rectify personal data

Data Holders have the right to access their data and demand its rectification if it is not correct or has changed. The Holder has the right to request a copy of the personal data that GeoPoint holds about him or her.

The Holder must formulate and present these requests for the exercise of the Holders’ rights by contacting them by email, or by post addressed to GeoPoint, using the contact details indicated below.

4.2. Right to data portability

Data Subjects have the right, under certain circumstances, to receive the data they communicated to GeoPoint, and to transmit it to another data controller.

The Holder has the right to request a copy of the personal data that GeoPoint has about them, in a structured and readable format.

4.3. Right to object to the processing of personal data

The Holder has the right to object to the processing of their personal data whenever the exercise of this right does not conflict with the need to comply with a legal or contractual obligation, nor with a legitimate interest of GeoPoint.

If Data Holders become aware of any situation related to the protection of their personal data, namely any practice with which they do not agree, or which raises objections, they must communicate it to GeoPoint, via email to address: geopoint@geopoint.pt

4.4. Right to complain

If the Data Holder wishes to lodge a complaint about the way GeoPoint processes their personal data, they must contact us by email at the addressgeopoint@geopoint.pt.

If after contacting GeoPoint any questions remain, you can contact the CNPD – National Data Protection Commission whose contact details can be found atwww.cnpd.pt.

4.5. Right to limit the processing of your data

If the Holder considers that their personal data is incorrect/incomplete, or that they should not be processed by GeoPoint, they must immediately communicate this to the latter by email at the address: g geopoint@geopoint.pt . In certain circumstances, the Data Subject will have the right to request the limitation of the use of their data by GeoPoint.

4.6. Right to delete your data

GeoPoint processes and stores personal data for which it is responsible for processing, for the time strictly necessary to pursue its respective purposes. In certain circumstances, the Data Subject has the right to request the deletion of their personal data.

Finally, the Data Holder has the possibility of filing a complaint with the competent Supervisory Authority regarding the compliance of the processing of their personal data by GeoPoint with applicable data protection legislation.

To do this, you can contact the CNPD – National Data Protection Commission whose contact details can be found atwww.cnpd.pt.

5. How long do we keep personal data?

Personal data collected by GeoPoint is kept in a way that allows the identification of Data Subjects for no longer than is necessary to pursue the purposes for which the personal data is processed. More specifically:

– Personal data collected to respond to users’ requests and/or questions, via the Chatbot, are kept for 24 hours;

– Personal data collected in relation to complaints are kept for 10 years, after the complaint has been resolved;

– Personal data collected for the purpose of preparing commercial proposals and concluding contracts are kept for 20 years;

– Personal data collected for the purpose of training management is kept for 3 years, with the exception of external training, whose personal data is kept for 20 years.

– Personal data collected for recruitment purposes is kept for 5 years;

– Personal data collected for the purpose of holding events is kept for a period of 5 years, after the event takes place;

Personal data collected for the purpose of developing marketing actions are kept for 5 years, after the end of the campaign, with the exception of sending newsletters, whose personal data will only be kept for a period of 1 year, after the last contact with the Data Holder.

6. Do we share the personal data collected?

Personal data collected and processed by GeoPoint will only be accessed by a limited number of recipients, based on the “need to know” principle or when required by law, including, but not limited to,

– GeoPoint employees due to the “need to have knowledge”;

– GeoPoint’s suppliers, particularly Nomadia Group in the context of software licensing granted by this entity, and to which the services provided by GeoPoint are complementary. For the purposes of transferring personal data, GeoPoint informs that Nomadia Group is certified under the GDPR. Additionally, GeoPoint may also share with those responsible for creating the Website, producing the Website, and service providers that GeoPoint uses within the scope of the services it provides to its customers for purposes strictly within the scope of carrying out its functions;

– The competent authorities, in certain cases defined by law.

 

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