1. Allpanna Commitment
Allpanna, within the scope of its duties, processes personal data, aiming to ensure with rigor, efficiency and security the protection of all data that it collects and processes daily.
Please read this Privacy Policy which describes how we process your personal data and how you can exercise your rights as the holder of personal data processed by Allpanna.
2. Data Protection Officer
Within the scope of its activities and attributions, Allpanna is the entity responsible for the collection and processing of personal data, which are processed and stored in an automated and non-automated manner.
Allpanna has a Data Protection Officer, who can be contacted via email at info@allpanna.pt .
The Data Protection Officer is responsible, in particular, for monitoring compliance of activities involving the processing of your data with applicable legal and regulatory standards, and is also the point of contact between Allpanna and the National Supervisory Authority, as well as between Allpanna and its customers and users in matters relating to the processing of personal data.
3. Personal data, personal data subjects and categories of personal data
What is personal data?
Personal data is any information of any nature, collected on any type of medium, relating to an identified or identifiable natural person. Identifiable information is considered to be the set of information that can lead to the identification of a specific person, in particular by reference to an identifier (such as an identification number or location data).
In view of Allpanna's duties, most of the data of legal entities (companies and associations) are processed. However, in order to carry out its duties, data of the following types of individuals may be collected and processed (non-exhaustive list):
What personal data do we process and how do we collect it?
Allpanna only collects data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
Your data may be collected orally, in writing (namely through forms and contracts), as well as through the Allpanna website. As a general rule, we collect your data directly, and personal data may also be collected through public sources (such as websites and official public lists), as well as from incentive management entities..
To carry out the different purposes, we may collect the following types of personal data:
As a rule, Allpanna does not collect special data, such as health data or data relating to misdemeanors or criminal offenses.
4. Basis and purposes of processing personal data
Why and on what basis do we use your personal data?
All data collected and processed by Allpanna is based on one of the legitimacy conditions below.
Consent
When the collection is preceded by your express, specific and informed consent, through written support or via the web. We collect your consent, for example, for purposes related to registration in the INOV Contacto program, for subscribing to newsletters or for registering for actions promoted by Allpanna.
Execution of a contract or pre-contractual steps
When processing is necessary for the execution of a contract to which you are a party or for pre-contractual steps.
This condition will be met when we process your data for the purposes of managing financing and cooperation programs and protocols or supply and service provision contracts.
Compliance with legal obligations
When processing is necessary for compliance with a legal obligation. This includes, for example, the communication of data to other public bodies (national and EU), tax authorities or judicial authorities.
Public interest
When processing is necessary for the exercise of functions of public interest. As Allpanna is a public body, whose duties mostly concern missions that involve supporting companies’ investment in Portugal and supporting the internationalisation of Portuguese companies, this includes processing related to the implementation of community programmes, the granting of incentives, as well as the management of the relationship with sectoral associations with which the companies are related.
Legitimate interest
When processing is necessary for the pursuit of the legitimate interests of the entity responsible for processing or third parties, without prejudice to the rights and freedoms of its customers and/or users.
This includes all processing operations resulting from powers conferred by law, namely the internal and external disclosure of Portuguese entities, at national and international level.
For what purposes do we collect your data?
Personal data collected by Allpanna are only processed for specific, explicit and legitimate purposes. Whenever personal data is collected, it is exclusively intended for the purposes expressly identified at the time of collection. We list here the main purposes that justify the collection of personal data by Allpanna:
5. Period of retention of personal data
Allpanna processes and stores your data only for the period necessary to pursue or complete the purposes of the processing for which they are intended, in compliance with the maximum periods necessary to comply with contractual, legal or regulatory obligations.
As a general rule, and when there is a contract that legitimizes the processing of your data, Allpanna will keep such data for as long as such contractual relationship is maintained. Other circumstances exist, such as compliance with legal or regulatory obligations (for example, for the purposes of complying with tax obligations, personal data relating to invoicing must be kept for a maximum period of ten years from the date of the act), as well as the pendency of legal proceedings, which may legitimize the retention of your data for a longer period of time.
Once the conservation period has ended, Allpanna will proceed to eliminate said data.
6. Rights of data subjects
Under current legislation, from the moment we collect and process your data, there is a set of rights that you may exercise at any time with Allpanna.
What are your rights?
Right of access
Right that allows you to obtain information regarding the processing of your data and its characteristics (namely the type of data, the purpose of the processing, to whom your data may be communicated, retention periods and which data you must provide either mandatorily or optionally).
Right to rectification
Right that allows you to request the rectification of your data, requiring that they are accurate and up to date, for example, when you consider that they are incomplete or out of date.
Right to erasure of data or “Right to be forgotten”
Right that allows you to request the erasure of your data, when you consider that there are no valid grounds for retaining the data and provided that there is no other valid ground that legitimizes such processing (such as the execution of a contract or compliance with a legal or regulatory obligation).
Right to Restriction
Right that allows you to suspend processing or limit processing to certain categories of data or purposes.
Right to Portability
Right through which you may request that your data be sent in a digital and commonly used format, which allows the reuse of such data. Alternatively, you may request that your data be transferred to another entity that becomes responsible for processing your data.
Right to Object
Right that allows you to object to certain purposes provided that there are no legitimate interests that prevail over your interests. One example of this right concerns the objection to direct marketing purposes.
Right to Withdraw Consent
Right that allows you to withdraw your consent, but which can only be exercised when your consent is the sole condition of legitimacy.
How can you exercise your rights?
All rights described above may be exercised, with the limitations provided for in applicable legislation, by means of a written request, to be sent using our form .
You may also submit questions relating to the processing of your data directly to the Data Protection Officer, using the email address indicated in point 2.
You may also submit any complaint to the National Control Authority.
7. Data transmission
Who do we share your personal data with?
In accordance with Allpanna's duties, and depending on the respective purpose, your data may be shared with third parties, including national and international public bodies and private entities for the purpose of fulfilling legal or regulatory obligations, contractual obligations or functions of public interest.
Your data may also be accessed by Allpanna service providers, deemed necessary for the execution of the purposes described above, in particular with regard to information security and archiving services. Allpanna guarantees that it only uses service providers that provide guarantees of implementing the necessary and appropriate technical and organizational measures to protect your personal data.
Transfers of personal data outside the EEA
Allpanna may, exceptionally, transfer your personal data to third countries (outside the EEA – European Economic Area).
In such cases, Allpanna will ensure that data transfers are carried out in strict compliance with applicable legal standards.
8. Legislation
The processing of personal data of users and customers carried out by Allpanna, as well as the sending of commercial communications carried out by electronic means, are in compliance with the national and community legislation in force, in particular with the General Data Protection Regulation (Regulation (EU) 2016/679, of April 27, 2016).