Privacy Policy
Consulmark 2 – Estudos de Mercado e Trabalho de Campo Lda., hereinafter referred to Consulmark 2, is committed to protecting the privacy of all holders of personal data processed in the course of their professional activity, hereinafter referred to simply as data subjects, and for this purpose, prepared this information.
In order to ensure its commitment to the privacy of the data subjects, Consulmark 2 has adopted the best practices of security and protection of personal data, in the terms described better below.
In this regard, and in order to ensure that all personal data is processed and protected in accordance with the new General Regulation on Data Protection, we ask you to please read the following information, which corresponds to our new policy of privacy and data protection with attention.
1. Personal Data
Personal data correspond to any information, in relation to an identified or identifiable natural person, of any nature and regardless of the type of media.
An identifiable person is any natural person that can be be identified, directly or indirectly, in particular by reference to an identifier (i.e. an identification number, location data, identifiers by electronic means or by one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social nature of such a natural person).
Depending on the purpose of the defined collection and data processing, i.e. the conduction of market research studies, Consulmark 2 may, depending on the specific purpose of each study, and with the consent of the respective holders, collect personal data related to the identification, opinion or history of the data subjects.
In certain cases and with the express consent of the holders, personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data or data relating to sexual life or sexual orientation of data subjects.
2. Person Responsible for the Processing of Personal Data and in Charge of Data Protection
Consulmark 2 - Estudos de Mercado e Trabalho de Campo Lda., a legal person registered under the single registration number of corporate person 506 842 045, with its headquarters in Avenida Miguel Bombarda, nº1, 5º Dto., 1000-207 Lisbon, is the entity responsible for the collection and processing of personal data for the purposes indicated.
In order to advise Consulmark 2 on issues related to data protection, Dr. Paulo Correia was appointed as Data Protection Officer, with whom you can contact, through the email:dpo@consulmark2.pt.
If you believe that the information contained in this information is not sufficiently clear and/or transparent, or for any other reason that you consider relevant, please contact us at: privacy@consulmark2.pt.
3. Purpose of the Processing of Personal Data
The collection and processing of personal data in the context of the abovementioned activity is intended to carry out market or opinion studies.
If the data subject allows expressly and in advance the processing of their personal data (this consent can be withdrawn at any time - see point 5 below), Consulmark 2 undertakes to ensure the processing of personal data to the extent and for the time necessary for the fulfillment of its purposes.
In view of the foregoing, Consulmark 2 clarifies that it only requests, the remission and sending of personal data concerning philosophical or political beliefs, party or trade union affiliation, religious faith, private life and racial or ethnic origin, as well as the processing of data concerning health and sexual life, including genetic data, if the object of the market/opinion study so requires.
Thus, and if unsolicited personal data is transmitted to Consulmark 2, it can not be held responsible for its treatment under the policy described above.
4. Conservation of Personal Data
5. Right of access, rectification, erasure, limitation of treatment and right of portability of Personal Data
The period of time during which personal data is kept and stored corresponds to the period necessary to fulfill the purpose or for the period corresponding to the maintenance of consent by the data subjects.
To this extent, the data subject is entitled to request the deletion of his/her data at any time, as indicated in point 5 below.
The data subject is guaranteed, at any time, the right of access to his/her personal data, as well as its rectification, elimination, portability, limitation and/or opposition to the treatment - to this end, he/she may exercise any of these rights by writing, to Consulmark 2 through the headquarters address or through the following email privacy@consulmark2.pt.
In addition, the data subject may always submit any complaints they deem necessary to the competent authority for this purpose.
6. Security in the Treatment of Personal Data
Personal data may be processed and stored in a computer and in paper format.
Consulmark 2 is committed to ensuring the security and protection of personal data made available to it, and has taken the appropriate measures necessary for this purpose, namely:
Computer security measures:
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There is a code of conduct on the use of IT resources and services;
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Access to the system requires password authentication;
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The password is nominative
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There is a secure data copy (secure servers);
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The system has protection against improper access to personal data;
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The system has the ability to record the executed activities and who executes them (tracing);
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The system has protection against viruses and Malware, and is used systematically;
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The Operating systems are not obsolete and are updated systematically so as not to contain known/published vulnerabilities;
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Use of Firewall;
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Secure third-party data transmission protocols (https);
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Encryption of information in mobile equipment;
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Safe disposal of equipment;
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Profiles according to the functional typologies;
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Use of VPN for remote access to the internal infrastructure;
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Existence of periodic backups
Organizational Measures:
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The subject's data is not transferable outside the European area;
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Limitation of the physical accesses where the data is processed;
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Not storing personal data in the computer's memory;
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Contracts with employees with long-term confidentiality duties;
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All employees are informed of policies and regulations;
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The processing of personal data is done exclusively within the context of the agreed purposes;
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Ensuring the provision of information duties to the data subjects and obtaining consent;
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Performance aligned with the data protection policies and procedures of the Data Protection Officer;
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The data subjected to treatment must always be those strictly necessary for the purpose in question;
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Periodic assessment of the level of fulfillment of requirements (audit)
Consulmark 2 informs that these security measures are reviewed and updated according to the needs and requirements of these matters. If, for any reason, there is a breach of security that causes accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access to personal data, Consulmark 2 agrees, under the terms of the applicable legislation, to notify the competent authorities without undue delay and, when possible, within 72 hours of becoming aware of such occurrence.
In addition, and in the terms referred to in the immediately preceding paragraph, Consulmark 2 agrees to communicate the violation of the personal data to its owner, in accordance with the applicable legislation.
7. Communication of Personal Data to Third Parties
In the scope of its activity, Consulmark 2 may use third parties to provide certain services (located inside or outside the European Union), which may in some cases entail the access by such entities to the personal data of the data subject.
In such a scenario, Consulmark 2 undertakes to take the necessary and appropriate measures, in order to ensure that entities that have access to such personal data are reputed and offer high guarantees at this level, which will be duly enshrined and safeguarded in a written agreement between Consulmark 2 and the third party(ies).
Any entity subcontracted by Consulmark 2 will treat the personal data of the data subject, on their behalf in an undertaking to take the necessary technical and organizational measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access and against any other form of illicit treatment.
In any case, Consulmark 2 remains responsible for the processing of personal data.
Whenever necessary, and in connection with the contracting of third parties by Consulmark 2, personal data may be transferred outside the European Union, under the terms and conditions permitted by the applicable legislation.
8. Right to Oblivion
The holder of the personal data has the right to obtain, from the person responsible for its processing, the elimination of his/her personal data, which he shall be obliged to delete them, whenever one of the following reasons applies: (i) the data are no longer necessary for the purpose for which they were collected or processed; (ii) the data subject withdraws consent, when consent is the legal basis or the data subject opposes the treatment and there are no prevailing legitimate interests justifying their maintenance.
9. Alterations
Consulmark 2 reserves the right at any time to make adjustments or alterations to this policy, provided that such changes will be duly communicated to the data subject.
The version hereby communicated is the one that currently is in effect.