Ewen - Soluções Globais Em Energia E Ambiente, Lda, with NIPC 506 912 957 and registered office at Rua Manuel Pinto De Azevedo, 626 R/C Esq 4100-320 Porto ("Ewen"), for the purposes of operating the domain ewen.energy domain ("Website"), processes personal data, i.e. information relating to an identified or identifiable natural person ("Data Subject(s)"), an identifiable person being one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person ("Personal Data").
The use of the Website by any user will be governed by the Terms and Conditions of Use ("Terms and Conditions"), implying its use an acceptance of them by the User.
Whenever Ewen determines the purposes and means of processing Personal Data, it shall be qualified as a Data Controller, ensuring compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, and other applicable data protection and privacy legislation ("Data Protection Legislation").
In accordance with Data Protection Legislation, Ewen strives to process Personal Data in accordance with all applicable principles, namely: i) Principle of Lawfulness, Fairness and Transparency; ii) Principle of Purpose Limitation; iii) Principle of Data Minimization; iv) Principle of Accuracy; v) Principle of Retention; and, vi) Principle of Integrity and Confidentiality.
For the foregoing reasons, this Data Protection and Privacy Policy ("Privacy Policy") is hereby established, and Ewen undertakes to carry out any and all Personal Data processing operations in accordance with the provisions of the following points:
GROUNDS FOR LAWFULNESS AND PURPOSES OF DATA PROCESSING
The Personal Data of the Data Subjects will be processed by Ewen on the following legal grounds:
Grounds for Lawfulness What do they consist of?
Consent
The Data Subject may consent to the respective processing by means of a freely given, specific, informed and explicit indication of his or her wishes, by which he or she accepts, by means of a declaration (in writing or orally) or an unambiguous positive act (by filling in an option), that his or her Personal Data will be processed.
Pre-contractual procedures or performance of a contract
Personal Data may be processed if it is necessary, without limitation, for the performance of a contract for the provision of services and/or supply of products to which you are a party as an Employee, Customer and/or Supplier, or to carry out pre-contractual steps at your request.
Compliance with a legal obligation
Personal Data may be processed to ensure and guarantee compliance with legal obligations to which Ewen is bound.
Defense of vital interests of the Data Subject
Personal Data may be processed to ensure the protection of the vital interests of the Data Subject, in particular where the processing is essential to his or her life.
Legitimate Interests
Ewen, other controllers or third parties may process Personal Data provided that such processing does not override your interests or fundamental rights and freedoms.
PROCESSING OF PERSONAL DATA ON THE WEBSITE
Ewen processes the Data Subject's Personal Data within the scope of the Website as follows:
| Purpose | Treatment activities | Reasonableness of time limit | Basis for retention period |
| Website Management | Analysis and processing of Web Browsing Data | Performance of the contract, the terms of which are governed by the Website Terms and Conditions | Up to 3 months after the last visit to the website |
| Making Contacts | Contact an Ewen employee | Unequivocal Consent | For a period of 1 year, unless a legal time limit applies |
| Commercial and marketing activities | Newsletter communication | Consent | Up to 1 year after last contact |
PERSONAL DATA PROCESSED ON THE WEBSITE
For these purposes, Ewen processes the following Personal Data:
| PURPOSE | PERSONAL DATA |
| Website Management | Personally Identifiable Information, Contact Data, Authentication and Access Data [electronic identifier (Mac and IP), connection start date/time, connection end date/time, web browsing origin location, URL visited, social network address, social media interaction history or host name] and/or Web Browsing Data (commonly known as Cookies). |
| Making Contacts | Personal Identification Data, Contact Data |
| Commercial and marketing activities | Personal Identification Data, Contact Data |
TREATMENT METHODS
The processing of Personal Data will be carried out automatically and manually by computer tools, applying logics strictly related to the purposes and, in any case, promoting the security and confidentiality of Personal Data.
DISCLOSURE AND TRANSMISSION OF PERSONAL DATA
Ewen employees will process the Personal Data of Data Subjects for the performance of their work duties and will process Personal Data exclusively under the terms specified in this Privacy Policy.
Personal Data may be made available to third parties entrusted with providing services for Ewen ("Subcontractors"), who are bound by a written contract and process the data under the terms of this Privacy Policy, and may not process it, directly or indirectly, for any other purpose, for their own benefit or that of a third party.
In the event of compliance with legal obligations, the Personal Data of the Data Subjects may be transmitted to third parties, for the pursuit of their own purposes, namely banks and insurance companies, judicial, administrative, supervisory or regulatory authorities and also entities that lawfully carry out data compilation actions, actions to prevent and combat fraud.
INTERNATIONAL TRANSFERS
Ewen may transfer your Personal Data outside the European Economic Area ("EEA") to locations that may not guarantee the same level of protection.
However, if applicable, Ewen will only transfer Personal Data outside the EEA in accordance with the following measures:
- Where the transfer is carried out to a location or by a method or in circumstances which the European Commission considers ensure adequate protection of Personal Data;
- When you have implemented standard contractual data protection clauses approved by the European Commission or a competent supervisory authority; or,
- Where none of the above applies but the law nevertheless authorizes such a transfer, for example if it is necessary for the establishment, exercise or defence of a right in legal proceedings.
You can request detailed information on the security measures that Ewen has in place regarding transfers of Personal Data outside the EEA and, where applicable, a copy of the standard contractual data protection clauses in force at Ewen through the contacts provided in Section 10.
DATA SUBJECTS' RIGHTS
In accordance with current or future Data Protection Legislation, Ewen informs you that Data Subjects have the right of access, rectification, limitation, portability, erasure and the right to object to the processing of Personal Data, in certain circumstances, which may be exercised under the terms of this section of the Privacy Policy.
| RIGHTS | What do they consist of? |
| Right to information provision | The Data Subject has the right to obtain clear, transparent and easily understandable information about how Ewen uses their Personal Data and what their rights are. That is why Ewen provides all this information in this Privacy Policy. |
| Right of access | The Data Subject has the right to obtain information about what Personal Data Ewen processes (if any) and certain information (similar to that provided in this Privacy Policy) about how that Personal Data is processed. Ewen may refuse to provide the requested information where, in order to do so, Ewen would have to disclose Personal Data of another natural person or the information would adversely impact the rights of another natural person. |
| Right of rectification | If your Personal Data is incorrect or incomplete (for example, if your name or address is wrong), you may request that Ewen take reasonable steps to correct it. |
| Right to erasure of personal data | This right is also known as the "right to be forgotten" and, in simple terms, allows the Data Subject to request the erasure or deletion of their data, provided there are no valid grounds for Ewen to continue using it or its use is unlawful. This is not a general right to erasure, as exceptions are allowed (for example, whenever this data is necessary for the defense of a right in legal proceedings). |
| Right to restriction of treatment | The Data Subject has the right to "block" or prevent future use of their Data while Ewen evaluates a request for rectification or as an alternative to erasure. Where Processing is restricted, Ewen may still store your Data, but may not use it at a later date. Ewen keeps a list of the data subjects who have requested the "blocking" of future use of their data to ensure that this limitation is respected |
| Right to portability of personal data | The Data Subject has the right to obtain and reuse certain Personal Data for his/her own purposes in various organizations. This right applies only to Personal Data provided to Ewen and processed by Ewen with consent and those processed by automated means. |
| Right to oppose | The Data Subject has the right to object to certain types of processing, on grounds relating to his or her particular situation, at any time during which such processing takes place, for the purposes of the legitimate interests of Ewen or a third party. Ewen may continue to process such Data if it can prove the existence of "overriding legitimate grounds for the processing which override your interests, rights and freedoms" or if such Personal Data is necessary for the establishment, exercise or defense of legal claims. |
| Right to lodge a complaint | The Data Subject has the right to lodge a complaint with the competent supervisory authority, the National Data Protection Commission - CNPD, if he/she considers that the processing carried out on Personal Data violates his/her rights and/or the Data Protection Legislation. |
If the lawful basis for the processing of your personal data is consent or legitimate interest, you may withdraw your consent or object to the processing at any time, without any consequences, but without compromising the lawfulness of the processing carried out in the meantime. If you withdraw your consent or expressly object, Ewen will immediately cease processing your personal data for the purpose in question, unless it is necessary to process the data in order to comply with legal and/or contractual obligations.
You may at any time, in writing, exercise the rights enshrined in the Data Protection Legislation and other applicable legislation through the means described in Point 10 of this Privacy Policy.
SECURITY AND CONFIDENTIALITY
To guarantee the security and confidentiality of Personal Data, protected databases are used, including appropriate firewalls and passwords, in accordance with the provisions of Data Protection Legislation. Access to Personal Data is only possible for authorized employees who have an actual need to use the Personal Data, in accordance with the principles of security and confidentiality. Violations of this Privacy Policy by Ewen employees may give rise to disciplinary action. Compliance with Ewen's standards and procedures is periodically monitored and verified.
COOKIES
HOW TO CONTACT EWEN ABOUT PRIVACY AND DATA PROTECTION ISSUES
Data Subjects may exercise their rights by contacting Ewen by sending an e-mail to saibamais@helexia.eu.
Data Subjects may also contact Ewen's Data Protection Officer by sending an e-mail to the mailbox at saibamais@helexia.eu.