PRIVACY POLICY
Protecting your Privacy is one of our main goals.
This Cookies and Privacy Policy establishes the terms and conditions under which Callpoint Segurança, Lda, legal person number 508521823 (hereinafter “Callpoint Segurança”), with headquarters at Rua Inácio Perdigão, Letra I, Lote 9, Zona Industrial , 2500-755 Caldas da Rainha, Portugal, is permanently committed to the online protection of its customers and/or users of its IT platform.
This document thus aims to make known our Privacy Policy, and specifically the terms and conditions under which your personal data are processed within the scope of the provision of services by Callpoint Segurança, so that you can give your consent to free and clear form to the treatment in question when this is necessary for the provision of subscribed services, as shown in our website.
Please note that on the various pages of the Callpoint Security website where personal data are collected in order to provide the services we provide, specific information will be published in accordance with the provisions of article 13 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC – General Regulation on Data Protection (hereinafter, “Regulation”) for its analysis before providing the personal data requested and collected by us, as mentioned above.
The information and personal data by you or to which we have access in connection with the provision of the various services by Callpoint Segurança, will be treated in accordance with the provisions of the Regulation and with the confidentiality obligations to which all employees of Callpoint Segurança are contractually and legally linked.
In accordance with the provisions of the Regulation, the processing of personal data carried out by Callpoint Segurança is subject to the principles of lawfulness, loyalty and transparency; limitation of purposes; data minimization and accuracy; limiting conservation; integrity and confidentiality and responsibility.
1. RESPONSIBLE FOR THE PROCESSING AND IN CHARGE FOR THE PROTECTION OF PERSONAL DATA
A Personal Data Protection Officer (DPO) is part of our organizational structure, who will be available to provide you with any information regarding the processing of your personal data by Callpoint Segurança, including a list of our subcontractors in matters of personal data protection. It is possible to contact the DPO by sending an email to [email protected]
2. PERSONAL DATA PROCESSED
As the processing of personal data, we understand in the terms that expressly result from the Regulation “an operation or a set of operations carried out on personal data or on sets of personal data, by automated or non-automated means, such as collection, registration, organization , the structuring, conservation, adaptation or alteration, recovery, consultation, use, disclosure by transmission, dissemination or any other form of availability, comparison or interconnection, limitation, elimination or destruction”.
Please note that the personal data we collect will depend on your decisions regarding which services to subscribe to and how to use them (hereinafter only “Personal Data”).
The personal data processed through our website are as follows:
a) NAVIGATION DATA
The software systems and procedures used to operate our website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified stakeholders, but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of users connecting to our website, addresses in Uniform Resource Identifier (URI) notation of requested resources, time of request, method used to send request, request to server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system. These data are used for the sole purpose of obtaining anonymous statistical information about the use of our website and to verify its correct functioning, to identify anomalies and/or abuse and are immediately and definitively eliminated after the treatment in question. The data in question can be used to determine liability in case of crimes against Callpoint Security or third parties committed through our website.
b) COOKIES
Cookies are small text files that the online portals visited by the user send and record on their computer or mobile device, to then be retransmitted to the same online portals in the next visit. Thanks to cookies, the online portal remembers user actions and preferences (such as login data, chosen language, font size and other display settings, etc.) so that they are shown again when the user re-visits that online portal or navigates from one page to another. Cookies are, therefore, used to perform computer authentications, monitoring sessions and storing information about the activities of users who access one and may also contain a unique identification code that allows monitoring the user’s navigation within the online portal to statistical or advertising purposes. While browsing an online portal, the user may also receive on his computer or mobile device cookies from online portals or web servers other than those he is visiting (so-called “third party cookies”). Some operations cannot be performed without the use of cookies, which, in some cases, are technically necessary for the functioning of the online portal.
There are several types of cookies, depending on their characteristics and functions, and they can remain on the user’s computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user’s equipment for a predetermined period.
According to the legislation in force in Portugal, the use of cookies does not always require an express consent by the user. In particular, “technical cookies” do not require such consent, that is, those used for the sole purpose of transmitting a communication through an electronic communications network, or to the extent strictly necessary to provide a service expressly requested by the user. These are, in other words, cookies that are indispensable for the functioning of the online portal or necessary to carry out activities requested by the user, namely: “analytics cookies” when used directly by the manager of the online portal to collect information, in aggregate, about the number of users and how they visit the website, browsing or session cookies (to authenticate themselves), functionality cookies that allow the user to browse according to a series of selected criteria (for example , the language, the products selected for purchase) in order to improve the service provided to it. For “profile creation cookies”, vice versa, that is, those intended to create profiles relating to the user and used to send advertising messages in line with the preferences expressed by the same in the context of internet browsing, consent is required prior user.
There are several cookies that can be unmarked, with the exception of third-party cookies for which the user must refer directly to the respective modes of marking and unmarking the respective cookies, indicated through the links:
Essential cookies: for browsing or session and strictly necessary for the functioning of the online portal or to allow the user to use the content and services requested by him.
Analytics cookies, which allow us to understand how the online portal is used by users. These cookies do not collect information about the user’s identity or any personal data.
Information is treated in an aggregated and anonymous way.
Functionality cookies, this is used to activate specific functionality of the online portal and a series of selected criteria (eg language, products selected for purchase) in order to improve the service provided.
Profile creation cookies, used to send advertising messages in line with the preferences expressed by the user in the context of internet browsing.
Third-party cookies, that is, cookies from online portals or web servers other than those of the Owner, used for their own purposes by these third parties, including also profile creation cookies. It is stated that these third parties, listed below with the respective links to the privacy policies, are independent holders of the processing of data collected through the cookies served by them; therefore, the user must consult their personal data processing policies, information and consent forms (marking and unmarking of the respective cookies). In addition, it should also be noted that Callpoint Segurança does what is reasonably required to be able to monitor cookies on its online portal. These are updated on a regular basis on the landing page at the link below, where we give transparency about cookies sent directly by Callpoint Segurança and about their purpose, and with specific reference to cookies sent by third parties through our online portal. In relation to these cookies, we provide the following links to third-party privacy statements: to these third parties, as noted above, we assign the responsibility to provide the privacy statement and collect the consent of users. This responsibility refers not only to cookies that third parties send directly, but also to any additional cookies that are sent through our online portal as a result of using services from which the third parties themselves benefit. Regarding these cookies, sent by service providers of these third parties, Callpoint Segurança cannot exercise any control and does not know their characteristics or purposes.
Below are links to information about third-party cookies.
Callpoint Segurança sends essential cookies through its website. Some cookies are essential to access specific areas of our website. These are required for some areas of the site to function, but are not used in any way to personally identify you. Functionality cookies are temporary and are automatically deleted once you leave the site. These cookies are essential for the proper functioning of the website.
Cookies management instructions in major browsers:
Settings related to cookies
The user may block or delete (in whole or in part) essential or functional cookies through specific functions of his browser. However, the user is informed that the non-authorization of essential cookies may make it impossible to use the online portal, view its contents and use its services. Inhibiting functionality cookies may mean that some services or certain functions of the online portal are not available or not working correctly and you may be required to change or manually enter some information or preferences each time you visit the online portal.
3. PURPOSE OF PROCESSING PERSONAL DATA
The processing of personal data that we intend to carry out, with your specific and express consent when necessary, has the following purposes:
a) Allow the provision of the Services requested by you, including the collection, storage and processing of data for the purposes of operational, technical and administrative management of the commercial and contractual relationship related to the provision of the Services and with a view to carrying out related communications with the referred relationship between Callpoint Segurança and the customer;
b) Allow browsing and consultation of the Callpoint Segurança website;
c) Respond to requests for assistance or information, which Callpoint Segurança may receive via email, telephone or through the appropriate form available on its website. With regard to responses to assistance requests received by Callpoint Segurança over the telephone, we inform you that calls can be recorded so that Callpoint Segurança can show that it has correctly processed your requests;
d) Comply with legal, accounting and tax obligations;
e) Send direct marketing communications (by sending electronic communications) relating to services similar to those already subscribed to by the Customer, except in case of initial opposition or regarding subsequent communications. Please note that in the case of a legal person, Callpoint Segurança may send electronic communications for direct marketing purposes regarding goods and services provided by itself or by a company of the same Group, unless the Customer expressly refuses to receive this type of communications and subscribe to the national list of legal persons who expressly object to receiving unsolicited communications for direct marketing purposes.
f) Prepare studies, surveys, market statistics; in order to be able to send advertising material, information or satisfaction surveys with a view to improving the quality of the service provided through electronic communications and/or telephone calls, or through the official pages of Callpoint Segurança on social networks;
g) To make personalized commercial proposals based on the products or services you have purchased, or in which you have shown interest. This process is necessary for the purposes of the data controller’s legitimate interest in customizing its business propositions. You may object to this process by sending your request to Callpoint Segurança via the following email: [email protected]
h) For the sole purposes of security and preventing fraudulent behavior.
4. FOUNDATION OF THE TREATMENT AND ITS MANDATORY OR OPTIONAL NATURE
The legal basis for processing personal data for the purposes indicated in points a), b) and c) of the previous clause is what is set out in subparagraph b) of paragraph 1 of article 6 of the Regulation, since the processing in question is necessary for the provision of the Services subscribed to by the Customer. Please note that the provision of personal data for these purposes is optional, however, failure to provide them makes it impossible for Callpoint Segurança to provide the Services.
The purpose indicated in point d) above translates into a legitimate processing of personal data pursuant to paragraph c) of paragraph 1 of article 6 of the Regulation, since such processing is necessary for Callpoint Segurança to be able to comply with legal obligations to which is subject.
The processing of personal data carried out for marketing purposes is based on the express and unambiguous consent of the Customer, in accordance with the provisions of paragraph a) of paragraph 1 of article 6 and paragraph c) of paragraph 2 of article 22 of the Regulation. The provision of your personal data for this purpose is therefore optional. If you wish to object to the processing of your personal data for direct marketing purposes, you may do so at any time by sending your request to Callpoint Segurança via the following email: [email protected]
The purpose referred to in point h) above is based on Callpoint Security’s legitimate interest in detecting fraud committed against it, in accordance with the provisions of paragraph f) of paragraph 1 of article 6 of the Regulation.
5. RECIPIENTS OF PERSONAL DATA
Your personal data may be communicated, for the purposes described above, to the following entities:
a) Subjects who normally act as subcontractors, that is: natural or legal persons who provide assistance and advice to Callpoint Security in accounting, administrative, legal, tax, financial matters. Your personal data may be communicated, for the purposes described above, to the following entities :acquisitions and credit recovery; entities with which it is necessary to interact with a view to providing the Services or persons performing technical maintenance functions (including maintenance of equipment and electronic communications);
b) Entities to which Callpoint Security must communicate personal data in accordance with the provisions of applicable legislation and/or in response to requests from competent authorities, duly substantiated for this purpose;
c) Persons authorized by Callpoint Segurança to handle personal data strictly necessary to carry out operations related to the provision of the Services, which are contractually and/or legally bound by confidentiality and professional secrecy duties;
d) Business partners for specific purposes only in case the Client has given his express, unambiguous and specific consent for the purpose.
You can request, in writing, a list of data controllers with whom Callpoint Segurança relates in relation to your personal data, sending your request to Callpoint Segurança via the following email: [email protected]
6. CONSERVATION OF PERSONAL DATA
The personal data processed for the purposes indicated in clause 3 will be kept for the period of time strictly necessary for the accomplishment of these same purposes.
Thus, the retention periods for the following customer’s personal data are as follows:
Personal data processed for marketing purposes when the contract between Callpoint Security and the personal data holders is no longer in force: such data may be retained until the data subject revokes the consent given. However, Callpoint Segurança established that it must erase them two years after the provision of consent and after the termination of the service provision contract.
Customers’ personal data made available upon contracting: this type of personal data will be kept for ten years, if it concerns data relating to the billing of services, and 5 years after the termination of the contract, if the reasons for its preservation only concern the need for Callpoint Security defends itself against a legal claim based on contractual or tort liability.
Personal data relevant to compliance with tax obligations: Such data will be erased after 10 years of conservation, in accordance with the Tax Law.
7. RIGHTS OF PERSONAL DATA HOLDERS
The Customer has the right to request Callpoint Segurança, at any time, to access his/her personal data, update or delete it, in accordance with the provisions of the Regulation. You also have the right to request the limitation of the processing of your personal data, in accordance with the provisions of article 18 of the Regulation, as well as the right to obtain your personal data in a structured format, for common use and readable by automatic device, in the cases provided for in Article 20 of the Regulation.
The requests in question must be sent in writing to the e-mail address: [email protected]
If you believe that the processing of your personal data violates the provisions of applicable law, you may file a complaint with the competent supervisory authority, in accordance with the provisions of the Regulation.
8. TERM
This privacy policy is effective as of June 21, 2021.
Callpoint Segurança reserves the right to modify or simply update, in part or in full, its content, in order to comply with the applicable legislation and in force at any given time. Callpoint Segurança will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Callpoint Segurança website. this Privacy Policy and, specifically, on the treatment of your personal data carried out by Callpoint Segurança.
