A. GENERAL PART
TO 1. COLLECTION AND PROCESSING OF USER DATA
A.2. SUBCONTRACTED ENTITIES
A.3. DATA COLLECTION CHANNELS AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA
AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA may collect data directly (i.e., directly from the User) or indirectly (i.e., through partner entities or third parties). Collection can be done through the following channels: Direct collection: in person, by phone, by email and through the Website; Indirect collection: through partners or official entities.
B. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA
In terms of general principles relating to the processing of Personal Data, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA undertakes to ensure that the User Data processed by it is: • Object of a lawful, fair and transparent treatment in relation to the User; • Collected for specific, explicit and legitimate purposes, and not further processed in a way that is incompatible with those purposes; • Adequate, relevant and limited to what is necessary for the purposes for which they are treated; • Accurate and updated whenever necessary, with all appropriate measures being taken so that inaccurate data, taking into account the purposes for which they are processed, are erased or rectified without delay; • Kept in a way that allows the identification of the User only for the period necessary for the purposes for which the data is processed; • Treated in a way that guarantees their safety, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, with appropriate technical or organizational measures being adopted. The data processing carried out by AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA is lawful when at least one of the following situations occurs: • The User has given his explicit consent to the processing of User Data for one or more specific purposes; • The processing is necessary for the execution of a contract to which the User is a party, or for pre-contractual measures at the User’s request; • The treatment is necessary for the fulfillment of a legal obligation to which AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA is subject; • The processing is necessary for the defense of the vital interests of the User or another natural person; • The processing is necessary for the purpose of legitimate interests pursued by AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA or by third parties (unless the interests or fundamental rights and freedoms of the User that require the protection of Personal Data prevail). AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA undertakes to ensure that the processing of User Data is only carried out under the conditions listed above and with respect for the aforementioned principles. When the processing of User Data is carried out by AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA based on the User’s consent, the User has the right to withdraw his consent at any time. The withdrawal of consent, however, does not compromise the lawfulness of the processing carried out by AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA based on the consent previously given by the User. The period of time for which data is stored and preserved varies according to the purpose for which the information is processed. Effectively, there are legal requirements that oblige you to keep data for a minimum period of time. Thus, and whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that motivated its collection or subsequent processing, after which it will be eliminated.
B.1. USE AND PURPOSES OF PROCESSING USER DATA
In general terms, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA uses User Data for the following purposes: • To market products and provide services AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA; • Inform the User of new products and services, through any means of communication, it being a legitimate interest of AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA to do so, without prejudice to the right of the data subject to object to this treatment at any time; • Allow access to restricted areas of the Site, in accordance with previously established terms; • Ensuring that the Site meets the User’s needs, through the development and publication of content as adapted as possible to the requests and type of User, improving the Site’s search capabilities and functionalities and obtaining aggregated or statistical information regarding the User’s typical profile; • Provision of Services, and other services, such as newsletters, opinion surveys, or other information or products requested or consented to by the User; In addition, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA may also contact representatives of business customers, for the purpose of presenting products and services , without prejudice to the right of the data subject to object to this processing at any time. User Data collected by AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA are not shared with third parties without the User’s consent, with the exception of the situations referred to in the following paragraph. However, if the User contracts with AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA services that are provided by other entities responsible for the processing of Personal Data, the User Data may be consulted or accessed by these entities, insofar as this is the case. necessary for the provision of said services. Under the applicable legal terms, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA may transmit or communicate User Data to other entities in the event that such transmission or communication is necessary for the execution of the contract established between the User and AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA, or for pre-contractual measures at the User’s request, if necessary to fulfill a legal obligation to which AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA is subject or if necessary for the purpose of pursuing AGROVINAZ’s legitimate interests – SOCIEDADE AGRÍCOLA, LDA or third party.
B.2. TECHNICAL, ORGANIZATION AND SAFETY MEASURES IMPLEMENTED
To ensure the security of User Data and maximum confidentiality, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA treats the information you have provided us in an absolutely confidential manner, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated according to the needs, as well as in accordance with the terms and conditions established by law. Depending on the nature, scope, context and purposes of data processing, as well as the risks arising from the processing for the rights and freedoms of the User, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA undertakes to apply, both at the time of definition of the means of processing such as at the time of the processing itself, the technical and organizational measures necessary and adequate for the protection of User Data and compliance with legal requirements. It also undertakes to ensure that, by default, only data that are necessary for each specific purpose of the processing are processed and that such data are not made available without human intervention to an indeterminate number of people. In terms of general measures, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA adopts the following: • Regular audits in order to assess the effectiveness of the technical and organizational measures implemented; • Raising awareness and training of personnel involved in data processing operations; • Pseudonimization and encryption of Personal Data; • Mechanisms capable of ensuring the confidentiality, availability and permanent resilience of information systems; • Mechanisms that ensure the restoration of information systems and access to
Personal Data in a timely manner in the event of a physical or technical incident;
B.3. INTERNATIONAL TRANSFERS
In certain types of treatment, the personal data collected by AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA may be made available to third parties, and may involve its transfer outside the European Economic Area. In such case, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA undertakes to ensure that the transfer complies with the applicable legal provisions, namely regarding the determination of the suitability of such country with regard to data protection and the requirements applicable to such transfers.
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C. USERS’ RIGHTS (DATA HOLDERS)
C.1. PROCEDURES FOR THE EXERCISE OF RIGHTS BY THE USER
The right of access, the right of rectification, the right of deletion, the right to limitation, the right to portability and the right to object can be exercised by the User by contacting AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA, via e-mail firstname.lastname@example.org. AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA will respond in writing (including by electronic means) to the User’s request within a maximum period of one month from receipt of the request, except in cases of special complexity, in which this period may be extended up to two months. If the requests submitted by the User are manifestly unfounded or excessive, namely due to their repetitive nature, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA reserves the right to charge administrative costs or refuse to proceed with the request.
C.2. PERSONAL DATA VIOLATIONS
In case of data breach and to the extent that such breach is likely to imply a high risk to the rights and freedoms of the User, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA undertakes to communicate the breach of Personal Data to the User concerned in the within 72 hours of becoming aware of the incident. Under legal terms, communication to the User is not required in the following cases: • If AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA has applied adequate protection measures, both technical and organizational, and these measures have been applied to the Personal Data affected by the Data breach Personal, especially measures that make Personal Data incomprehensible to any person not authorized to access such data, such as encryption; • If AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA has taken subsequent measures to ensure that the high risk to the User’s rights and freedoms is no longer likely to materialise; or • If communication to the User implies a disproportionate effort for AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA. In this case, AGROVINAZ – SOCIEDADE AGRÍCOLA, LDA will make a public communication or take a similar measure through which the User will be informed.
D. FINAL PART
D.2. APPLICABLE LAW AND JURISDICTION