This text presents a general overview of how The Ideias Dinâmicas Group treats personal data at its disposal in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council – General Regulation on Data Protection ( RGPD) – and other applicable legislation on privacy and data protection, including local legislation supplementing the RGPD. Whenever personal data are required, the use of such data is described in terms of this document and with respect to data protection legislation.
1.The Ideias Dinâmicas Group
The Ideias Dinâmicas Group integrates a group of companies with an international vocation dedicated to providing services in various business areas.
It is made up of teams with recognized competencies in their areas of activity, evaluating new business opportunities and creating conditions for different entrepreneurs to develop and formalize their ideas and projects. Ensures solid platforms for the launch of new business projects considering the degree of innovation as a differentiating factor.
The Group comprises the following companies:
- ITGest – Software e Sistemas Informáticos, Lda.;
- Kentra Technologies, Lda.;
- Pryog Technologies, Lda.;
- PositiveBlue – Soluções Tecnológicas, Lda.;
- Wakaru Consulting, Lda.;
- Ideias Dinâmicas Serviços, Lda.;
- Ideias Dinâmicas Tecnologias, Lda.;
- Ideias Dinâmicas, SGPS, Lda.;
- Ideias Dinâmicas Consulting, Lda.;
- Think Tank – Management and Marketing Experts, Lda.
- ITGest, Lda.;
- ICA – Internacional Consulting & Accounting, SA;
- Think Tank – Marketing, Communication and Design, Lda.;
- TT – New Architecture & Interior Design.
- ITGest Moçambique, Lda.;
- ICA Moçambique – Internacional Consulting & Accounting, SA;
- Ideias Dinâmicas Tecnologias de Moçambique, Lda.
In Cape Verde:
- ITGest – Software e Sistemas, Lda.
- In South Africa: ITGest South Africa (pty), Ltd.
- In India: Ideias Dinamicas, Technologies India Private Limited.
2. Scope of Application
Personal Data – is any information related to the Data Owner and that allows him to identify.
Data Holder – any identified or identifiable natural person to whom the Personal Data is associated. The natural person may be directly or indirectly identifiable or identified, including by name, civil or tax identification number, location data, online identifiers (such as IP addresses and logs). Identification can also be made through factors of physical, physiological, genetic, mental, economic, cultural or social identity. The user of the website, applications and digital platforms is considered as Data Holder in relation to the Group.
Treatment – any operation carried out in the scope of Personal Data, by means of automatic or not, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, dissemination by transmission, dissemination or, alternatively, availability, harmonization or association, restriction, elimination or destruction. Any other operation contemplated under the RGPD is also considered to be the Treatment of Personal Data.
4. Responsible Entity and Responsibilities
The Group has internally implemented a “Personal Data Protection Commission”, which is responsible for ensuring compliance and compliance with the RGPD standards. This Committee is made up of the Head of Personal Data Protection of each company of the Group, representatives of the Department of Information Technologies, representatives of the Legal Department, as well as representatives of the Department of Human Resources and Department of Organization and Quality.
5. Collection and Processing of Data
The Group only compiles the data considered essential, making the necessary processing according to the purpose.
The collection of your data, including personal data, takes place in the interactions with the Group, namely:
- General requests for information;
- Documentation download;
- Commercial process;
- Sales process;
- Customer management process;
- Accounting, tax and administrative management;
- Compliance with legal and regulatory obligations;
- Litigation management;
- Human resources management process;
- Marketing and event management (on-site and / or online);
- Information security control;
- Other data that are in the documentation delivered to the company or obtained as a result of the relationship established.
Depending on the nature of the interaction, and only when necessary, the Group may request certain personal data, such as: name, email address, address / location, telephone, mobile phone, citizen / passport card number, physical and digital), date of birth, nationality, marital status, academic qualifications, profession, bank data, and, in general, any documentation and information of the contacts maintained with the client by different means, including marketing campaigns.
Data processing for marketing purposes will be done according to the consent option stated by the data subject. Consent must be prior, free, informed, specific and unambiguous, expressed in a written statement, oral or through the validation of an option. The data subject may object to the processing of data for marketing purposes at any time and by any means.
Optionally, the data subject may authorize the collection of complementary data that may assist the Group in providing a better and more personalized service or service.
6. Purpose of the Treatment of Personal Data
The personal data provided by the data owner or generated in relation to the service provided will be processed and stored in a computerized way, and will be used by the Group.
The Group collects and processes the strictly necessary data, which is only requested when related to the purpose in question, and for legitimate purposes, such as:
- Provide an adequate and targeted response to information / proposal requests;
- Communicate better with the holders of personal data, for relevant subjects and only as often as necessary, according to the characterization of their data and their preferences;
- Comply with business purposes, namely, statistical data to improve the performance of the various services provided;
- Comply with the human resource management assumptions;
- Comply with legal or regulatory requirements, which depend on the validity of the certificates of some of the services provided, namely, training actions;
- Billing services / products.
Personal data are processed by the Group only for the period of time necessary to achieve the defined purpose.
The Group collects and processes the strictly necessary data, which is only requested when related to the purpose in question, and for legitimate purposes, such as:
- Human resource Management It includes the processing of data necessary for the celebration, fulfillment and termination of a work contract, work time management, absences and holidays, processing of salaries and other benefits, relationship with the Tax Administration and Social Security, promotions and development of the career, training, evaluation, representation expenses and communication with workers, exercise of disciplinary power.
- Internal and Business Management It includes activities such as project planning, work time registration, company asset management, provision of centralized services to increase the efficiency of operations, conducting audits and investigations, implementing management controls, using internal databases, file management, insurance, prevention, preparation and conflict management.
- Safety, Hygiene and Health at Work It includes activities related to safety, hygiene and health at work, protection of workers and company assets, worker authentication and access management.
- Analysis and Management It includes activities such as satisfaction questionnaires, merger process management, business unit acquisitions and sales, and the processing of employee data for reporting and analysis purposes.
- Compliance with Legal Obligations It includes the processing of personal data strictly necessary for the fulfillment of its legal obligations, such as the disclosure of data following judicial mandates, collaboration with regulators and the defense of the legitimate interests of the Group.
- Protection of Vital Interests The processing of personal data for the protection of the vital interests of workers.
- Recruitment It includes recruitment activities such as research and selection as well as related activities. In this context, data related to salary processing and human resources management will also be processed.
- Execution of Contracts It includes activities such as entering into contracts with clients and partners, as well as communication with third parties involved in contracts (insurance companies, beneficiaries, intermediaries).
- Development and Improvement of Services It includes activities necessary for the development and improvement of the services provided by the Group, activity analysis and processing for statistical and scientific purposes.
7. Automated Decisions
In order to justify and execute the business relationship, the Group generally does not use decision-making procedures solely on the basis of automated processing, as provided in the RGDP. If you have or will use this procedure, the data owners will be informed.
8. Access and Sharing of Personal Data
Within the Group, employees who need them to comply with contractual / pre-contractual and legal procedures or obligations, or treatments for which there is explicit and informed consent, have access to the data.
The data can be used in Group companies in the context of the provision of shared services between Group companies and for the purpose of internal reporting, always preserving the principle of the lawfulness of the treatment.
They may also be made available to suppliers and other sub-contractors who, under the terms of the RGDP, can access the data for these specific purposes, but subject to data protection guarantee measures and always acting in the name and on behalf of the Group.
In certain circumstances, certain personal data may need to be communicated to public authorities, such as the Working Conditions Authority, Health Regulatory Authority, Courts and Security Forces.
The transmission of data to other countries (countries outside the European Union) only occurs if the holder of the personal data has given an express authorization for this purpose or if this is necessary by legal requirement. Where third-country service providers are required, they will be obliged to comply with the written instructions on the subject in order to comply with the level of data protection applicable in the European Union.
9. Data Retention Time
Personal data are kept for different periods of time, depending on the purpose for which they are intended and taking into account legal criteria, the need for and the minimization of conservation time, or for periods legally defined for investigation and prosecution of a criminal or criteria. After the retention period, the personal data is destroyed.
10. Rights of Owners of Personal Data
The Group guarantees all the rights of the data owners in relation to the treatment of their data and at any time. To know:
- Licit treatment and conditions applicable to consent (Article 6 and Article 7)
- Right of access of the data subject (Article 15)
- Right of rectification (Article 16)
- Right to erasure (Article 17)
- Right to limit processing of data (Article 18)
- Right of opposition (Article 21)
- Portability (Article 20)
In addition, without prejudice to the possibility of complaining to the Group, the data subject may submit a complaint directly to the Data Protection Supervisory Authority using the following channels:
Telephone: +351 21 392 84 00 – Website: http://www.cnpd.pt/ – Courier: National Commission for Data Protection – CNPD Ava Carlos I, 134 – 1st 1200-651 Lisbon
At any time, customers or prospective customers of the Group, as holders of the data, may withdraw previously given consents and exercise any of the aforementioned rights.
The exercise of rights can be requested through:
- Email address: email@example.com;
- Postal address: Ideias Dinâmicas Group Personal Data Protection Commission Rua Álvaro Castelões, 821 – 2nd, room 2.2 4450-043 Matosinhos Telephone: 229 398 320
11. Obligation to Provide Personal Information
In the commercial relationship, you will have to present the personal data necessary to establish and create a commercial relationship and to fulfill the contractual and contractual obligations and diligences, as well as those legally required to collect. Without these data, the Group will generally refuse to conclude the contract or, furthermore, it will not be able to maintain the contract and have to resolve it.
12. Security of Personal Data
The Group protects your personal data against destruction, loss, accidental or unlawful changes and unauthorized disclosure or access. To this end, the Group uses security systems, rules and other procedures to ensure the protection of personal data, as well as to prevent unauthorized access to data, improper use, disclosure, loss or destruction.
The changes will be duly published (site).
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