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1st Meeting of Academia Sintra Vila Digital
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Privacy Policy
1. Objective
The purpose of this privacy policy is to establish the rules for the processing of personal data carried out by AESINTRA, in the legitimate exercise of its activity as an Employer Association.
From this, it can be seen that AESINTRA complies with the General Data Protection Regulation (GDPR) and with the principles contained therein relating to the processing of personal data, as well as with other national and European legislation in force, relating to the protection of personal data.
2. Data Controller and DPO (Data Protection Officer)
AESINTRA is the Data Controller, as it holds the power of decision over what data is collected, the means of processing, and the purposes for which the personal data is processed.
The contact details of the Data Controller are as follows:
Address: Rua Capitão Mário Pimentel, 17 B, 2710-589 Sintra
Phone: 219 106 283 | 932 323 348
E-mail Address: geral@aesintra.pt
AESINTRA has appointed a DPO who monitors the compliance of the processing of personal data with the legislation in force, is the point of contact for clarifying questions related to data protection by personal data subjects, cooperates with the National Data Protection Commission (CNPD) in its capacity as a supervisory authority, provides information and advises AESINTRA on its obligations regarding privacy and data protection.
The DPO acts independently and is not subject to any instructions from the Data Controller and is obliged to maintain secrecy and confidentiality with regard to the performance of their duties in the area of data protection.
The appointment of a DPO does not exempt AESINTRA from its responsibility as Data Controller.
The DPO’s contact details are:
Address: Rua Capitão Mário Pimentel, 17 B 2710-589 Sintra
Phone: 219 106 283 | 932 323 348
E-mail: dpo@aesintra.pt
3. Commitment
AESINTRA is committed to acting in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – General Data Protection Regulation (GDPR) and other applicable data protection legislation, namely the national legislation that complements the GDPR, and as such to communicate transparently about the personal data collected and the type of processing it performs, to protect the security, privacy and confidentiality of personal data, to provide adequate mechanisms for data subjects to exercise their rights over that data, to provide security systems designed to prevent the access, modification, destruction or addition of personal data by unauthorized third parties and that allow for the detection of possible information deviations, and organizational measures designed to maintain the control of personal data by its owners.
4. Basic Concepts
Personal Data is any information that, regardless of its nature or support, directly or in combination with other data, allows a natural person to be identified.
Therefore, Personal Data Subjects are natural persons identified or identifiable, directly or indirectly, through any information that concerns them.
Data Processing is the operation or set of operations performed on personal data by manual or automated means, including among others the collection, storage, use, copying and transfer of personal data.
Some personal data are, under the General Data Protection Regulation (GDPR), considered sensitive data, that is, they are classified as “Special Category Data”.
AESINTRA processes special category data, as it processes “Health Data”, defined in the Regulation as “personal data related to the physical or mental health of a natural person, including the provision of health services, which reveal information about their health status”.
Health data is restricted to access by health professionals (technicians with adequate training and legally qualified to carry out an activity with a direct impact on people’s health) in the provision of healthcare to data subjects.
5. Protection of Personal Data
AESINTRA considers the confidentiality of personal data to be one of the fundamental pillars in building relationships of trust with employees, collaborators, suppliers, partners, members, potential members and any other personal rights holders who are otherwise related to it.
In this sense, AESINTRA has implemented organizational measures, policies, procedures, processes and security systems adequate to protect personal data, namely access control mechanisms for information systems and personal data and security systems (e.g. firewalls, antivirus).
6. Rights of Personal Data Subjects
In the table below, the personal data subject, whose data is processed by AESINTRA, will find a list of the rights conferred by law in that capacity, duly accompanied by a brief description of each one.
| Rights of Personal Data Subjects | Description of the Right |
|---|---|
| Access | Consists of the right to obtain confirmation as to whether or not personal data concerning them, and which was provided to AESINTRA, is being processed, and if so, the right to access it and the respective processing conditions. |
| Rectification | Consists of the right to have AESINTRA rectify your personal data that is inaccurate or incomplete. |
| Objection | Consists of the right of the data subject to object at any time and for reasons related to their particular situation to the processing of their personal data by AESINTRA based on the legitimate interest of the latter or of third parties. |
| Erasure | Consists of the right to obtain the erasure of their personal data which is no longer necessary for the purpose for which it was collected and processed, or to withdraw consent for all personal data if that is the sole legal basis for the data processing. |
| Portability | Consists of the right of the data subject to receive the personal data they have provided to AESINTRA and the respective processing conditions, in a structured, commonly used and machine-readable format, as well as the right to demand the transmission of this data to another data controller. |
| Restriction | Consists of the right to obtain the restriction of data processing in the following situations: (a) if you have contested the accuracy of your personal data and did so for a period that allowed AESINTRA to verify its accuracy; (b) if the data processing is unlawful and you object to its erasure; (c) if AESINTRA no longer needs the personal data for the purposes of processing, but this data is required by you for the purposes of establishing, exercising or defending a right in a judicial process; (d) if you have exercised the right to object and during the period of evaluation by AESINTRA. |
| Right to be forgotten | Consists of the right to request the erasure of your personal data held by AESINTRA, provided there are no valid reasons for its retention. |
| Not to be subject to exclusively automated decisions | Consists of the right to request human intervention or to contest decisions based on fully automated processing of personal data that may produce significant effects on your legal or private life, except for exceptions arising from current legislation. |
| Complaint to the CNPD | Consists of the right of the data subject to file complaints with the CNPD – National Data Protection Commission (www.cnpd.pt) regarding the protection of their personal data and the rights related to it. |
7. Categories and Types of Personal Data processed by AESINTRA
Below, a table presents, on one hand, the categories and types of personal data we process and, on the other, the means of collecting personal data.
| Categories of Personal Data | Types of Personal Data Processed |
|---|---|
| Identification and Contact Data | Full Name, Personal Identification Document Number, Tax Identification Number, Signature, Photograph, Voice Recordings, Social Security Number, Driving License, TVDE Driver’s License. |
| Contact Data | Address, Telephone Contact, Email Address. |
| Biographical Data | Date of Birth, Sex, Nationality, Place of Birth, Marital Status. |
| Financial Data | Monthly Salary, IBAN and NIB of the Bank Account, Debit/Credit Card Number. |
| Professional Data | CV, Training Certificate, Academic Qualification Certificate. |
| Opinions and Preferences | Comments on Social Media, Responses to Satisfaction Surveys. |
| Website Usage | Pages visited, Information about the Equipment Used (e.g., IP address, geographic location, browser used). |
| Content | Information contained in the clinical reports written by AESINTRA’s health professionals regarding their patients. Information contained in interviews conducted for the Jornal da AESINTRA. |
| Health Data | Complete Clinical History, i.e., past and present, any complementary clinical diagnostic tests (namely x-rays, clinical analyzes, among others) and clinical records obtained through clinical observation performed by a work medicine doctor and a curative medicine doctor (e.g., weight, height, age, blood pressure, electrocardiogram result). |
| Segments and Profiles | Commercial segment, propensity for acquiring goods or services. |
| Means of Personal Data Collection | Personal Data Collection Vehicles within each Means of Collection |
|---|---|
| Data Provided by the Data Subject | Provided directly by the subjects (members, patients, trainees, entrepreneurs, etc.), in the completion of the member registration form, in the SEPA direct debit authorization form, in the training registration form, in the exchange of electronic communications with AESINTRA, in response to satisfaction surveys, in CPE projects. |
| Data Collected within the Scope of Services provided by AESINTRA | Health and Safety at Work Contracts, Food Safety Contracts, Various Training Courses. |
| Data Obtained Through Third Parties | Schools, Institutions. |
| Profiling | Data produced by AESINTRA through the application of analytical models to personal data related to the provision of services supplied by AESINTRA. |
| Cookies | Collected through the use of the AESINTRA website. For more information on the type of cookies used and the data collected, consult the cookie policy published on the website www.aesintra.pt |
8. How AESINTRA processes Personal Data
The processing of personal data corresponds to the operation or set of operations performed on personal data, namely the collection, organization, storage, use, rectification, erasure, consultation, copying and transfer.
Data processing is carried out physically and/or electronically by AESINTRA, for the purpose of analyzing, deciding, managing and proving operations arising from and related to the execution of contracts entered into within the scope of its activity, for the fulfillment of legal obligations to which AESINTRA and/or the Personal Data Subjects are bound, for the pursuit of their legitimate interests, for the declaration, exercise or defense of a right in a judicial process or whenever personal data is requested by courts when acting in the exercise of their jurisdictional function.
AESINTRA only processes personal data with due legal basis, and subject to prior information of the respective subjects.
Data processing is always carried out by AESINTRA in a lawful, legitimate, transparent and strictly necessary manner for the specific purposes.
Consent of Personal Data Subjects:
AESINTRA may process personal data for other purposes different from those contemplated in the previous paragraph when it obtains from the subjects due prior, express, written consent, through an informed, free and specific action for the purposes of the personal data subject.
Obligation to Provide Personal Data:
Within the scope of AESINTRA’s contractual and commercial relationships, it is mandatory and necessary to present and collect certain personal data from employees, service providers, suppliers, partners, members, potential members and any other personal rights holders who are otherwise related to it, for the fulfillment of contractual obligations, pre-contractual diligence or others arising from current legislation.
In general, if such data is not presented and provided, AESINTRA will have to refuse to enter into a contract that initiates the labor, commercial or professional relations between the parties.
9. Purposes of Processing and Legal Bases
Below, a table presents, on one hand, the purposes of processing, on the other hand, the method used to achieve that purpose, and finally, the legal bases for the intended purposes.
| Purposes of Processing | Method Used to Achieve the Purpose | Legal Basis |
|---|---|---|
| Provision of Healthcare Services | Collection and registration of data subjects’ health data. | Contract Execution, Performance, and Management. |
| Opening of Member File | Collection and registration of personal data of data subjects, opening of a member file. | Contract Execution, Performance, and Management. |
| Communication in case of need | Collection of personal data of data subjects, communication for administrative or operational reasons. | Contract Execution, Performance, and Management. |
| Preparation of Clinical Reports | Collection and registration of data subjects’ health data, preparation of the medical assistance report. | Contract Execution, Performance, and Management. |
| Management of Contacts and Complaints | Reception, analysis and response to information requests and complaints from data subjects. | Contract Execution, Performance, and Management. |
| Execution of a Labor or Commercial Contract | Collection and insertion of personal data necessary to be included in contracts of different natures. | Contract Execution, Performance, and Management. |
| Accounting | Accounting record. | Compliance with Legal Obligation. |
| Documentary Archive Management | Storage and Organization of paper-based documents in the documentary archive, which constitute mandatory evidence for potential inspection by the Tax Authority or other institutions with inspection capacity. | Compliance with Legal Obligation. |
| Provision of Information to Members | Sending of various informative material in the context of the subscription of services by data subjects. Sending proposals for changes to the conditions of services subscribed by data subjects. | Contract Execution, Performance, and Management, and Legitimate Interest. |
| Service Development | Conducting satisfaction questionnaires regarding the quality of services provided. | Contract Execution, Performance, and Management, and Legitimate Interest. |
| Personalization of Website Experience | Use of persistent cookies to record website Browse activities and preferences. | Prior, Express, Written, Explicit, Informed, Free, and Specific Consent. |
| Direct Marketing | Provision of information or carrying out campaigns, by telephone, SMS, email, to stimulate the use or promote the subscription of services. | Prior, Express, Written, Explicit, Informed, Free, and Specific Consent. |
| Profiling | Collection of data related to age and consumption preferences with a view to directing services to the needs and preferences of members and improving the quality of services provided (e.g., co-financed training). | Prior, Express, Verbal, Explicit, Informed, Free, and Specific Consent. |
10. Outros Fundamentos de Licitude
A AESINTRA tratará ainda dados pessoais sempre que necessário no âmbito da defesa dos interesses vitais do titular dos dados, no âmbito de declaração, exercício ou defesa de um direito num processo judicial ou sempre que os dados pessoais lhe forem solicitados por tribunais quando atuem no exercício da sua função jurisdicional.
11. Prazos de Conservação de Tratamento dos Dados Pessoais
A AESINTRA conserva os dados pessoais pelo tempo necessário e enquanto subsistirem as legítimas finalidades para as quais os dados são tratados com base nos devidos fundamentos de licitude.
Infra, são apresentados em tabela, por um lado os motivos da conservação e por outro lado os tempos de conservação.
Os prazos de conservação dos dados pessoais encontram-se definidos na Política de Conservação, da AESINTRA, que é complementar à presente Política de Privacidade.
| Motivos de Conservação | Tempo de Conservação |
|---|---|
| Cumprimento do Contrato | Período de vigência do contrato. Só se mantêm por períodos superiores à vigência do contrato no caso de ser necessário assegurar direitos ou deveres relacionados com o contrato, com base em interesse legítimo da AESINTRA que o fundamente ou em consentimento dado pelo titular dos dados pessoais. |
| Obrigação Legal, Fiscal ou Regulamentar | Prazos legais de prescrição associados a obrigações legais, fiscais ou regulamentares, ou prazos previstos em legislação especial (ex: 7 anos após relação contratual no âmbito da Lei de Prevenção do Branqueamento de Capitais e Financiamento do Terrorismo). |
12. Sharing of Personal Data
Only employees who need the collected personal data to perform their professional activity have access to it.
If personal data is communicated to third parties, taking into account the grounds for its processing, AESINTRA will inform the personal data subjects.
In case it is necessary to use foreign service providers, AESINTRA will contractually ensure that they comply with all legal obligations regarding data protection.
13. Technical and Organizational Measures Adopted
AESINTRA has implemented technical and organizational measures to protect the personal data for which it is the Data Controller. Thus, it keeps its computer systems updated and has developed procedures that prevent unauthorized access, accidental loss and/or destruction of personal data. It holds annual training sessions, in which the topic of data protection is presented and is an integral part of them.
14. Review and Changes to the Privacy Policy
AESINTRA reserves the right, at any time, to introduce the changes it deems necessary to this privacy policy, in order to better adapt it to the best market practices or to legislative or regulatory changes that may arise. The current version of the policy will always be the one that is printed for consultation at AESINTRA’s headquarters and also on the website www.aesintra.pt
The policy will be reviewed annually or whenever it becomes necessary.
Whenever the changes are relevant and substantive, AESINTRA will make all appropriate and reasonable efforts, using the normal and common communication and contact channels with the data subjects, to bring such changes to their attention.
User Terms and Conditions
Welcome to Sintra Vila Digital! By using our platform, you agree to the following User Terms and Conditions. Please read them carefully before making any purchase.
1. Object
The Sintra Vila Digital platform ("Marketplace") allows the purchase of products and services from registered local merchants. The Marketplace acts as an intermediary, providing a digital space for the commercialization of products and services, and is not responsible for the direct sale or the quality of the products presented by the merchants. The Marketplace is managed by "AESINTRA - Associação Empresarial do Concelho de Sintra," with the VAT number 500968357 and headquartered at Rua Capitão Mário Pimentel, 17 - B / 2710-589 SINTRA.
2. Registration and Account
To make purchases, the user must create an account, providing true and complete data.
The user must be over 18 years of age or have authorization from a legal guardian.
The user is responsible for maintaining the confidentiality of their account and password, assuming all responsibility for activities carried out through the account.
The Marketplace may suspend or terminate accounts in case of misuse, fraud, or violation of the Terms and Conditions.
3. Purchases and Payments
Products are sold directly by registered merchants, who determine prices, delivery times, and return policies.
The prices shown include VAT and other applicable taxes.
Payments are processed through the methods available on the platform, which may include credit cards, MB WAY, and other electronic payment methods.
The Marketplace is not responsible for payment failures or any problems with financial service providers.
4. Deliveries and Returns
The responsibility for the delivery of products lies with the merchant, who must comply with the deadlines established in the offer.
The buyer may exercise the right of free resolution within 14 days, in accordance with applicable law, except for foreseen exceptions (e.g., personalized products, perishable goods, among others).
The buyer must communicate the intention to return directly to the merchant through the contact means provided.
In case of delay in delivery, the buyer must contact the merchant for information or request a refund, if applicable.
5. Guarantees and Complaints
Merchants are responsible for ensuring that the products sold meet the legal requirements for quality and safety.
The buyer may complain about defective products within the legal warranty period by contacting the merchant directly.
The Marketplace is not responsible for defective products or inadequate services, and the buyer should contact the merchant to resolve the issue.
6. Responsibility
The Marketplace is not responsible for incorrect information provided by merchants, delays in delivery, or any breach of obligations by sellers.
The user agrees to use the platform lawfully, without fraudulent or abusive purposes.
7. Changes to the Terms
The Marketplace may modify these Terms and Conditions at any time. Changes will be notified on the platform, and continued use implies acceptance of the same.
Merchant Terms and Conditions
In order to facilitate your search and ensure that you quickly and efficiently find the content best suited to your needs, the platform allows for the personalization of the ordering criteria for the content displayed.
The results are organized based on the following parameters, in the different sections of the platform, according to the order indicated:
1. Object
The Sintra Vila Digital platform allows local merchants to make their products and services available for online sale, acting as an intermediary in the transaction between buyers and sellers. The Marketplace is managed by "AESINTRA - Associação Empresarial do Concelho de Sintra," with the VAT number 500968357 and headquartered at Rua Capitão Mário Pimentel, 17 - B / 2710-589 SINTRA.
2. Registration and Account
Only legally established merchants can register on the platform.
The merchant must provide truthful information, including tax and bank details, and keep the data updated.
The Marketplace reserves the right to suspend or terminate accounts that do not meet the requirements or violate the Terms and Conditions.
3. Merchant Obligations
The merchant is responsible for the accuracy of the descriptions and images of the products presented.
They must ensure the conformity of the products with applicable legislation, including safety standards and warranty rules.
The merchant sets prices, delivery times, and return policies, provided they comply with current legislation.
The merchant undertakes to provide adequate customer support and respond to buyer complaints.
4. Payments and Commissions
The Marketplace may charge a commission on sales made, the value of which will be disclosed to the merchant in advance, if applicable.
Payments to the merchant will be processed according to the methods and deadlines established by the Marketplace.
The merchant is responsible for issuing invoices to buyers in accordance with current tax rules.
5. Deliveries and Returns
The merchant is responsible for shipping the products and meeting the agreed deadlines.
They must accept returns and refunds in accordance with consumer protection legislation.
In case of logistical problems, the merchant must communicate with the buyer and present alternative solutions.
6. Guarantees and Responsibilities
The merchant assumes full responsibility for the products sold, including warranty and legal compliance.
The Marketplace is not responsible for claims arising from the relationship between merchant and buyer.
The merchant undertakes to maintain a good level of service and comply with the quality policies established by the Marketplace.
7. Penalties and Account Suspension
The Marketplace may suspend or cancel the merchant’s account in case of fraudulent practices, breach of sales conditions, or recurring customer complaints.
In case of suspension, the merchant will be notified and may present justifications.
8. Changes to the Terms
The Marketplace may change these Terms and Conditions upon prior notification. Continued use of the platform implies acceptance of the new conditions.
