PRIVACY POLICY AND PERSONAL DATA PROCESSING OF ACO - FOOTWEAR MANUFACTURER, S.A.
I- About us and our commitment:
ACO - Fábrica de Calçado, S.A. is a company incorporated as a joint stock company, hereinafter referred to as
ACO SHOES AND is engaged in the manufacturing of footwear.
Given the proportionality and appropriateness imposed by the ability to allocate the resources and technical means at its disposal,
ACO SHOES is deeply and genuinely committed and dedicated to protecting its regular and occasional customers and employees, as well as users of our various physical and digital media platforms and in particular paper files, digital files and / or websites already in use or to be implemented regarding one´s privacy and the processing and circulation of one's personal data.
II- Our personal data collection devices in use:
We have, edit and manage the following personal data carriers:
• Computer system consisting of a set of software solutions supported on a set of hardware devices and other similar solutions, including email services and other external digital repositories and communication solutions.
• Paper files stored in cabinets and shelves in restricted access rooms;
•
ACO SHOES websites:
www.acoshoes.pt.
III- Personal and material coverage of the present Privacy Policy:
This privacy policy obliges the company solely with respect to the personal data that it collects, treats and circulates.
The same or equivalent policy will also be assumed, by contractual agreement with
ACO SHOES, by the entities that process the same personal data on its behalf.
The availability through the referred website
www.acoshoes.pt and other links to other websites other than
ACO SHOES, is bona fide and in the interest of the user, and can not be held responsible in any way for the collection, treatment and the processing and destination of the data on those same websites, or the reliability, accuracy, legality and functionality available therein; therefore this privacy policy not applying to them.
ACO SHOES considers it mandatory and will for all intents and purposes assume, without the possibility of proving the contrary, that it will read the privacy policies of all websites to which it accesses.
IV- The raison d'être/ rational and the disclosure of this Privacy Policy:
In addition to implementing it in its organizational processes,
ACO SHOES has drafted this Privacy Policy in order to make available, make known and publicize an explanatory instrument of the general rules of privacy and treatment of the personal data that it collects, always in strict compliance with the relevant Legislation.
For all due purposes, the text of this privacy policy will be available on paper posted in a visible place and also digitally on the website
www.acoshoes.pt
The provisions of this Privacy Policy complement those, on the same subject, mentioned in the formal or informal contracts, that the parties enter into with
ACO SHOES.
We kindly ask you to read this Privacy Policy carefully, as making your personal data available, whether in person or upon access to the referred Websites, implies that you know and accept the conditions contained therein and the usage of the same for lawful and legitimate purposes foreseen by the law.
ACO SHOES expressly reserves the right to change its privacy policy at any time, the result being duly published by the same means.
V- Concept of personal data:
Personal data refers to any information or record of any nature whatsoever and regardless of its nature or format, namely sound, image, writing, chirograph or feature, relating to an identified or identifiable natural person.
By identifiable one recognizes the person who can be directly or indirectly identified by reference to one or more specific personal data, individually or jointly combined, especially their physical, physiological, psychic, economic, ethnic, cultural, geographical, social or location.
VI- The entity responsible for handling the personal data:
The entity responsible for the collection and processing of the personal data is
ACO SHOES, which, in context of its relationship with the holder of the personal data, always establishes on a legitimate basis, which data is collected, the means of processing and the purposes for its collection and treatment.
VII- Type of personal data collected and processed:
As part of its activity,
ACO SHOES collects and processes, namely:
1. Personal data necessary to provide and / or to receive services and / or the supply of products to its customers and / or to its suppliers, dealing in this context with data such as name, tax identification number, address, telephone number and e-mail among others that are strictly necessary, proportionate and legal.
2. Personal data necessary for undergoing of the employment contract or the provisions of services with its collaborators, dealing with data such as name, ID number and other data thereof, tax ID number, household composition, social security number, address, phone numbers and e-mail, health data, access data, location among others strictly necessary, proportionate and legal.
3. Personal data required to comply with legal obligations, either to public or to private entities, dealing with data such as, name, ID number and other data thereof, tax ID number, household composition, Social Security number, address (es) telephone numbers and e-mail, health data, among others strictly necessary, proportionate and legal.
4. The data being necessary for, the management of customers and suppliers, for the contracting and management of the contractual relationship with the customers and suppliers, applying the provision of services most appropriate to fulfill the needs and interests of the customer, including the sending of suggestions, information and marketing actions, informing of campaigns, promotions, advertising and product news, to conducting marketing surveys and / or satisfaction surveys, managing complaints, therefor dealing with telephone number(s) and email address, among others strictly necessary, proportionate and legal.
5. All personal data necessary for the exercise of the rights of
ACO SHOES within the scope of the relationships mentioned in the previous items, and in the pursuit of its activity and legitimate interest, namely, accounting, tax and administrative management, litigation management, proof of fraud detection, revenue and audit protection, network and system management, information security and physical security control, and facility security.
Notwithstanding compliance with the legal rules, or any legitimate orders from competent authorities, regarding the retention and transmission of data,
ACO SHOES only processes the personal data considered necessary for its activity, in a fair and strict manner as required by the nature of the contractual relationship or of any other nature that may be established with the holder of the data, or with their prior, legitimate, lawful and informed consent, if there be any.
VIII- Time and method of collecting personal data:
ACO SHOES collects personal data personally, in writing, over the phone or through its website.
As a rule, the personal data is collected when the relationship, collaboration, contract or as otherwise seen as necessary for the activity between
ACO SHOES and the holder of the data.
Our website may contain contact forms and information request forms, these will be sent directly to our email server via an encrypted connection and will only be available to our data controllers. Where necessary, the information will be made available to a person in a specific department for order resolution.
Some personal data are compulsorily and necessary for the beginning, normal and legal development of such relationship or collaboration, so in the absence or insufficiency of such data, the processing will not start or continue, in which case
ACO SHOES will inform the holder of such compulsory and necessary data.
Apart from the data mentioned, those on any public list and those which may be used in the legitimate interest of
ACO SHOES, one´s data will only be collected and processed if and for the purposes one previously consents to, freely, conscientiously, specifically and unambiguously, in written form, verbally or by validating an option, particularly for newsletters subscriptions or marketing communications, in which case the other rules apply.
If you wish to stop receiving these communications, one may express this at any time.
The data collected shall be documented, whether in paper or digital form, in strict compliance with the legislation governing the protection of personal data, being stored and stored in paper format and / or specific database, created and managed for the purpose and with restricted and exclusive access to
ACO SHOES employees who have to deal with the data in the pursuit of
ACO SHOES activity. Under no circumstances shall the data collected be used for any purpose other than that for which the consent has been given by the holder, this consent being necessary, or for the legal and legitimate purpose for which the collection was made.
IX- Purposes of Collection and Processing of Personal Data:
In general, the personal data collected are aimed at the management of customers, suppliers and employees, the contracting and management of the contractual relationship with customers, suppliers and employees, the provision of contracted supplies, the adequacy of delivery to the needs and interests of the Customer, including the sending of suggestions, information and marketing actions, informing of campaigns, promotions, advertising and product news, to conducting marketing surveys and / or satisfaction surveys, managing complaints, tax and administrative management, litigation management, proof of fraud detection, revenue and audit protection, network and system management, information security and physical security control, and facility security in compliance with legal obligations and for other purposes by which the Law recognizes
ACO SHOES´ legitimate interest.
When collecting or requesting the data, one is informed in more detail on how we handle one´s data.
X- Time limit for the storage of personal data:
Whenever there is a specific legal requirement, for keeping the data during a minimum time period, this will be taken into account by
ACO SHOES.
ACO SHOES will keep one´s personal data stored for, the minimum time period strictly necessary for the purpose it is collected and processed, after which it will be deleted.
XI- Right of access, rectification, opposition, deletion, limitation and portability of one´s personal data:
ACO SHOES guarantees the holder of the personal data the right of access, rectification, opposition, deletion, limitation and portability of their personal data.
O exercício destes direitos poderá ser exercido mediante comunicação escrita remetida para o nosso endereço na Avenida Padre António Ferreira 599, 4770-350 Mogege.
Any questions regarding the processing of personal data in progress at
ACO SHOES can be made by contacting us via email at
privacy@acoshoes.pt
If considered relevant, one may file a complaint with the National Data Protection Commission Av. D. Carlos I, 134 1st 1200 651 Lisbon Tel: 351 213928400 Fax: 351 213976832 and mail:
geral@cnpd.pt
XII- Measures we take to secure one´s personal data:
ACO SHOES undergoes the best practices, for which it adopts appropriate risk-sensitive technical and organizational measures, in the field of security and protection of personal data, having for such approved and implemented a strict compliance plan according to its objectives, the law and the interest of the holders of personal data, capable of protecting the data made available to us by all who in any way relate to us, in order to protect them against its dissemination, loss, misuse, alteration, processing or unauthorized access as well as against any other form of ilegal treatment.
Thus, the form (s) for collecting digital or paper based personal data, whether completed on the physical premises of
ACO SHOES, on the website (these requiring encrypted browser sessions) or with any
ACO SHOES collaborator, are securely stored in our physical repositories and digital systems.
All personal data provided is in
ACO SHOES repository, or in one of its subcontractors, under advanced physical and logistical security measures, which we believe to be indispensable for the protection of one's personal data.
Whenever, in the legitimate and legal pursuit of
ACO SHOES business objectives, the same adopts measures to monitor its employees, especially with regards to access control, working hours, tasks and productivity, circulation and transportation, not only those concerned will have prior knowledge of the implementation of such actions - being one´s consent asked for, whenever legally required and necessary - along with the tools used for this purpose will ensure the same level of security of the personal data collected and processed.
XIII- The Communication of data to other entities, subcontractors or third parties:
ACO SHOES may use subcontractors for the purpose of data collection and its processing, for the same purposes it itself seeks, obtaining from those entities by contractual means, the guarantee of reputation and obligation to develop the appropriate technical and organizational data protection measures and also to ensure the the rights of holders. In certain circumstances determined by law, specific personal data may need to be disclosed to public authorities, such as the tax authorities, courts and the security forces.
Accordingly, any of the subcontracting entities shall treat the personal data of our Customers on behalf of
ACO SHOES, under the obligation of taking the appropriate risk-sensitive, technical and organizational measures needed to protect personal data against accidental or unlawful destruction, accidental loss, alteration, diffusion or unauthorized access and also against any other form of unlawful treatment.
XIV- Transfer of personal data:
The pursuit of
ACO SHOES activity may involve the transfer of one´s data outside Portugal.
In this event
ACO SHOES will strictly comply with the applicable legal provisions, in particular with regards to regards the reliability and suitability of the country of destination in terms of personal data protection and the applicable requirements relating to such transfers.
XV- Cookies:
“Cookies” are small software tags that are stored on your computer via a browser, which as a rule only retain information related to your preferences, and therefore do not include personal data that
ACO SHOES processes.
Whenever this is not the case, the user will always be asked to consent to provide them, under the legal terms.
For more information we advise you to consult our
specific cookies policy.