Manuel Rui Azinhais Nabeiro, Lda, a company with registered offices at Av. Calouste Gulbenkian, 7370 Campo Maior, legal person number 500 853 975 (“Delta Ventures“), in carrying out its activities on the website https://deltaventures.gruponabeiro.com/ (“Website“), processes Personal Data, i.e. information relating to an identified or identifiable natural person (“Data Subject(s)“), an identifiable person being one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (“Personal Data“).
The use of the Website by any user shall be governed by the Terms and Conditions of Use (“Terms and Conditions“), the use of which implies acceptance by the User. If the User rejects the Terms and Conditions, he/she must immediately cease using the Website.
Delta Ventures, whenever it determines the purposes and means of processing Personal Data, will be qualified as an autonomous Personal Data Controller, ensuring compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, and other applicable data protection and privacy legislation (“Data Protection Legislation“).
Regarding Personal Data processing activities carried out through the Website, Delta Ventures will act as the Personal Data Controller, and Data Subjects should use the contacts provided in Point 9 for any question related to data protection.
Under the terms of the Data Protection Legislation, Delta Ventures strives to process Personal Data in accordance with all applicable principles, namely: i) Principle of Lawfulness, Loyalty and Transparency; ii) Principle of Purpose Limitation; iii) Principle of Data Minimization; iv) Principle of Accuracy; v) Principle of Conservation; and vi) Principle of Integrity and
Confidentiality.
For the foregoing reasons, this Data Protection and Privacy Policy (“Privacy Policy“) is hereby established, and Delta Ventures undertakes to conduct all Personal Data processing operations in accordance with the provisions of the following points.
| Fundamentals of Lawfulness | What do they consist of? |
|---|---|
| Consent | The Data Subject may consent to the processing of his or her Personal Data by means of a free, specific, informed and explicit expression of will, by which he or she accepts, by means of a declaration (in writing or orally) or an unequivocal positive act (by filling in an option), that his or her Personal Data will be processed. |
| Pre-contractual procedures or the execution of a contract | Personal Data may be processed if it is necessary, without limitation, for the performance of a contract for the provision of services and/or supply of products to which you are a party as an Employee, Customer and/or Supplier, or to conduct pre-contractual steps at your request. |
| Fulfillment of a legal obligation | Personal Data may be processed to ensure and guarantee compliance with legal obligations to which it is subject under the legislation of a Member State and/or the European Union. |
| Defense of vital interests of the Data Subject | Personal Data may be processed to ensure the defense of your vital interests, namely when such processing is essential to your life. |
| Legitimate interests | Delta Ventures, other Controllers or Third Parties may process Personal Data provided that such processing does not override your interests or fundamental rights and freedoms. |
Delta Ventures processes the Data Subject’s Personal Data as follows:
| Purpose of treatment | Treatment Activities | Personal Data | Legal grounds | Shelf life |
|---|---|---|---|---|
| Website management | Analysis and processing of web browsing data | Personal identification data, contact data, authentication data, navigation data (IP) | Execution of the contract, the terms of which are governed by the Terms and Conditions | Up to 3 months after the last visit to the website |
| Client Management | Fill in the participation forms available on the website | Identification and contact details and, where applicable, nationality, country of residence and image | Execution of the contract, the terms of which are governed by the Terms and Conditions | For 1 year after collection |
| Client Management | Response to contact requests | Identification and contact details | Legitimate Interest | For the period necessary for the contact to be made |
Delta Ventures employees will process Data Subjects’ Personal Data for the performance of their work duties and will process Personal Data exclusively under the terms specified in this Privacy Policy.
Personal Data may be made available to third parties entrusted with providing services for Delta Ventures (“PROCESSORS”), who are bound by a written contract and process the data under the terms of this Privacy Policy, and may not process it, directly or indirectly, for any other purpose, for their own benefit or that of a third party.
Data Subjects have the right to obtain a complete and up-to-date list of the PROCESSORS (if any) engaged by Delta Ventures, by sending a specific request to Delta Ventures under the terms specified in Point 9 of this Privacy Policy.
In compliance with legal obligations, the Personal Data of Data Subjects may be transmitted to third parties for their own purposes, namely banks and insurance companies, judicial, administrative, supervisory, or regulatory authorities, as well as entities that lawfully carry out data collection, fraud prevention and combating actions.
Delta Ventures may transfer the Data Subject’s Personal Data outside the European Economic Area (“EEA“), to locations that may not guarantee the same level of protection.
However, if applicable, Delta Ventures will only transfer Personal Data outside the EEA in accordance with the following measures:
You can request detailed information on the security measures Delta Ventures has in place regarding transfers of Personal Data outside the EEA and, where applicable, a copy of the standard contractual data protection clauses in force at Delta Ventures through the contacts provided in Section 9.
Under the terms of current or future Data Protection Legislation, Delta Ventures informs you that Data Subjects have the right of access, rectification, limitation, portability, erasure and the right to object to the processing of Personal Data, in certain circumstances, which may be exercised under the terms of this chapter of the Privacy Policy.
| Rights | What do they consist of? |
|---|---|
| Right to information | The Data Subject has the right to obtain clear, transparent, and easily understandable information about how Delta Ventures uses their Personal Data and what their rights are. That is why Delta Ventures provides all this information in this Privacy Policy. |
| Right of access | The Data Subject has the right to obtain information about what Personal Data Delta Ventures processes (if any) and certain information (like that provided in this Privacy Policy) about how that Data is processed. Delta Ventures may refuse to provide the requested information where, in order to do so, Delta Ventures would have to disclose another person’s Personal Data, or the information would adversely impact another person’s rights. |
| Right to rectification | If the Data Subject’s Personal Data is incorrect or incomplete (for example, if their name or address is wrong), a request may be made for Delta Ventures to take reasonable steps to correct it. |
| Right to erasure of personal data | This right is also known as the “right to be forgotten” and, in simple terms, allows the Data Subject to request the erasure or deletion of their data, provided there are no valid grounds for Delta Ventures to continue using it or its use is unlawful. This is not a blanket right to erasure, as exceptions are allowed (for example, whenever this data is necessary for the defense of a right in legal proceedings). |
| Right to oppose | The Data Subject has the right to “block” or prevent future use of their Data while Delta Ventures evaluates a request for rectification or as an alternative to erasure. Where Processing is limited, Delta Ventures may still store your Data, but may not use it at a later date. Delta Ventures keeps a list of data subjects who have requested the “blocking” of future use of their data to ensure that this limitation is respected. |
| Right to lodge a complaint | Ventures or third parties. Delta Ventures may continue to process such Data if it can prove “overriding legitimate grounds for the processing which override your interests, rights and freedoms” or if such Data is necessary for the establishment, exercise, or defense of legal claims. |
| Right to lodge a complaint | The Data Subject has the right to lodge a complaint with the competent supervisory authority, the Comissão Nacional de Proteção de Dados – CNPD (National Data Protection Commission), if they consider that the Processing of their Personal Data violates their rights and/or the Data Protection Legislation. |
You may at any time, in writing, exercise the rights enshrined in the Data Protection Act and other applicable legislation through the means described in Section 9 of this Privacy Policy.
To guarantee the security and confidentiality of Personal Data, protected databases are used, including appropriate firewalls and passwords, in accordance with the provisions of Data Protection Legislation. Access to Personal Data is only possible for authorized employees who have an actual need to use the Personal Data, in accordance with the principles of security and confidentiality. Violations of this Privacy Policy by Delta Ventures employees may give rise to disciplinary action. Compliance with Delta Ventures’ standards and procedures is monitored and verified periodically.
Regarding the processing of Personal Data that Delta Ventures carries out through the use of cookies, please consult the Delta Ventures Cookies Policy and customize your settings according to your preferences.
Data Subjects may exercise their rights by contacting Delta Ventures by sending an e-mail to Privacy@gruponabeiro.com.
Data Subjects may also contact Delta Ventures Data Protection Officer by sending an e-mail to the mailbox at DPO@gruponabeiro.com.