Square View – Investment Advisory Lda., a company with headquarters at Avenida Fontes Pereira de Melo, nº 21, Piso 8, 1050-116 Lisboa, with the tax payer no. 513568603 (henceforth “Square View “), in the execution of its activities, processes personal data, meaning any information relating to an identified or identifiable natural person (henceforth “Data subject(s)”); an identifiable natural person is 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.
In the cases where Square View determines the purposes and means of the processing of personal data within the performance of its activities it shall be considered as a controller, ensuring full compliance with Data Protection Legislation.
According with the aforementioned Legislation, Square View stands for the processing of personal data pursuant to all applicable principles: Principle of Lawfulness, Principle of Fairness and Transparency; Principle of Purpose Limitation; Principle of Data Minimisation; Principle of Accuracy; Principle of Storage Limitation; Principle of Integrity and Confidentiality.
In full accordance with the principles outlined above, Square View fully respects the data protection rights of Data Subjects. Hence, Data Subjects may contact Square View to obtain any information related to the processing of personal data, using the contacts provided in paragraph 7.
- Legal Basis and Purposes for the Processing of Personal Data
The personal data of Data Subjects will be processed by Square View with the following legal basis:
What does it consist of?
Square View will only process your Personal Data if you consent to its processing through a free, specific, informed and unambiguous act, by which you accept, by means of a statement (in writing or orally) or an unequivocal positive act (by completing an option), that your Personal Data is subject to processing.
Pre-contractual information’s or performance of a contract
Square View may process your Personal Data if it is necessary, without limitation, for the execution of a service and / or product supply contract in which you are a part of the Company as a Collaborator, Customer and / or Supplier, or to perform pre-contractual agreements at your request.
Compliance with a legal obligation
Square View may process your Personal Data to ensure and guarantee compliance with legal obligations to which you are subject under the legislation of a Member State and / or the European Union.
Defence of vital interests of the Data Owner
Square View may process your Personal Data to ensure the defence of your vital interests, especially when the same processing is essential to your life.
Square View, other Controllers or Third Parties, may process your Personal Data provided that such processing legitimately prevails over your interests or fundamental rights and freedoms.
Taking into account the abovementioned, the collection of personal data on the basis of the grounds of lawfulness set forth will be primarily for purposes related to the development of Square View’s corporate purpose, for the execution of contracts and to comply with legal obligations. Hence, the non-collection of personal data will imply the impossibility of processing data for the aforesaid purposes.
- Processing Methods
The processing of personal data will be executed automated and manually by computer tools, which are strictly related to the mentioned purposes and, in any case, guaranteeing the security and confidentiality of personal data.
- Disclosure and Transmission of Personal Data
Regarding the disclosure and transmission of personal data, Square View’s employees will process personal data and, as a result, they can access to the personal data of Data Subjects. The referred SquareView employees will solely process personal data of Data Subjects for the purposes specified in this Policy and in strict compliance with current or future Data Protection Legislation.
Third parties who may process personal data on behalf of Square View may also access to personal data of Data Subjects as subcontractors, including without limitation the providers of IT services required for the operation of information systems, outsourcing service providers or cloud computing services, professionals and consultants.
Data Subjects have the right to obtain a complete and up-to-date list of the subcontractors (if any) elected by Square View and for this purpose they shall submit a specific request to Square View under the terms specified in paragraph 7 of this Policy.
- Data Subjects Rights
What do they consist in?
Right to information
Right of access
Square View may refuse to provide the requested information whenever, in order to do so, Square View has to disclose Personal Data of another person or the information negatively impacts the rights of another person.
Right to rectification
If your Data is incorrect or incomplete (for example, if your name or address is wrong), you may ask Square View to take reasonable measures to correct it.
Right to erasure
This right is also known as the “right to be forgotten” and, in a simple way, allows you to request to permanently erase your data, as long as there are no valid grounds for Square View to continue using them or their use is illicit. This is not a general right to erasure, since exceptions are allowed (for example, where such data are necessary for the defence of a right in a judicial proceeding).
Right to restriction of the processing activities
You have the right to “block” or prevent future use of your Data while Square View evaluates a request for rectification or as an alternative to deletion. Whenever the processing is limited, Square View continues to be able to store its data, but cannot use it later. Square View maintains a list of the holders who have requested the “blocking” of the future use of their data to ensure that this limitation is respected.
Right to data portability
You have the right to obtain and reuse certain Personal Data for your own purposes in various organizations. This right applies only to the data that you have provided to Square View and that Square View deals with your consent and those that are handled by automated means.
Right to object
You have the right to object to certain types of processing, for reasons related to your particular situation, at any time during which this processing is carried out, for the legitimate interest of Square View or of Third Parties. Square View may continue to process such Data if it can prove “legitimate reasons for the processing that overlap its interests, rights and freedoms” or if such Data is necessary for the establishment, exercise or defence of a right in a judicial process.
Right to lodge a complaint
You have the right to complain to the competent control authority, the Comissão Nacional de Proteção de Dados (CNPD), if you believe that the processing carried out on Personal Data violates your rights and / or applicable data protection laws
You may at any time, in writing, exercise the rights enshrined in the Data Protection Legislation and other applicable legislation through the methods described in paragraph 7 of this Policy.
- Confidentiality and Security
- How to Contact Square View for Data Protection and Privacy Matters
Data Subjects may exercise their rights by contacting Square View through the following methods: i) sending a registered letter with acknowledgement of receipt to the address Avenida Fontes Pereira de Melo, nº 21, Piso 8, 1050-116 Lisboa ii ) sending e-mail to the following e-mails firstname.lastname@example.org.
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