This document concerns the protection of natural persons with regard to the processing of personal data and the free movement of such data and is fully regulated by Portuguese law.
CLOSER CONSULTORIA, LDA is permanently committed to protecting the privacy of personal data provided by its customers in connection with its services.
The client declares to know and accept the rules of the privacy code available on the website of CLOSER CONSULTORIA, LDA consenting to the publication / disclosure of your personal data.
The personal data provided by users during the subscription process of the services by CLOSER CONSULTORIA, LDA will be processed under legal and regular terms.
The processing of personal data shall mean any operation or set of operations carried out with or without the aid of electronic or automated means for the collection, recording, organization, maintenance, interrogation, preparation, modification, selection, extraction, comparison, use, interconnection, blocking, communication, disclosure, deletion and destruction of data, whether or not the data are contained in a database.
The processing of personal data may consist – in part as a result of how the customer decides to use the Services in text files, photographic or video images, audio tracks, telephone lines and any other information that may be used to identify the person concerned, according to the type of services requested.
This procedure shall respect the principles of legality, good faith and transparency and shall ensure respect for users’ rights, including their right to privacy.
The purpose of this procedure is to allow the provision of services by CLOSER CONSULTORIA, LDA in the manner intended by the client, as well as the independent management of the service by the latter. To that end, the customer must register as a user and create his profile, when the services are provided by CLOSER CONSULTORIA, LDA. Collection, storage and processing of data for subsequent operations, technical and administrative management of services and exchange of electronic communications.
The processing of the data by CLOSER CONSULTORIA, LDA will comply with all applicable legal rules, namely in compliance with the tax and accounting obligations that they prevent.
Users’ personal data will also be processed in order to allow “Web browsing”.
The purpose of this processing is also the collection, storage and organization of the client’s personal data in order to carry out statistical analyzes anonymously. This analysis will not allow the identification of the customer and will only be used to ascertain the quality of the services provided by CLOSER CONSULTORIA, LDA.
The personal data of the clients will be processed through electronic means and automatically.
Communication and dissemination of common personal data
CLOSER CONSULTORIA, LDA: personal data (of a non-sensitive nature) may be communicated by:
To individuals and companies providing legal, tax, financial and accounting consultancy services to CLOSER CONSULTORIA, LDA;
Institutions, entities and / or authorities to whom the data must be transmitted under the statutory and / or legally established terms;
Commercial partners of CLOSER CONSULTORIA, LDA, but only in case the customer gives their express consent.
Optional or Required Consent
If the client does not provide his / her personal data, the subscribed services may not be activated, this being a decision of CLOSER CONSULTORIA, LDA.
Customer consent is also optional for data processing for market research, research and statistical analysis; to the sending of advertising and information material through telephone service providers, through automatic messages without the intermediary of an operator or by fax.
Customer consent is also optional for receiving unsolicited commercial messages. These have to be immediately and unambiguously identified as such and contain the indication that the recipient of the message may in the future refuse to receive messages with that content.
If the customer chooses not to give his express consent to the processing of his personal data for commercial purposes when questioned for that purpose, such refusal shall have no consequence in relation to the provision of the service by CLOSER CONSULTORIA, LDA.
If the client gives his / her consent, in the terms described above, he / she may be admitted to participate in promotional contests organized / promoted by CLOSER CONSULTORIA, LDA.
Processing sensitive data.
When the customer uses the services of CLOSER CONSULTORIA, LDA, certain personal data classified as sensitive may be processed, particularly data revealing race or ethnic origin, religious, philosophical or other beliefs, political opinions, party affiliation, health status or sexual orientation.
CLOSER CONSULTORIA, LDA suggests that the client does not publish sensitive personal data, unless it is strictly necessary or that it chooses services that do not imply such publication.
In any case and apart from exceptional circumstances, such data may only be published with the express and specific consent of the client in writing or otherwise equivalent.
On the basis of the above, CLOSER CONSULTORIA, LDA recalls that if the customer does not expressly consent to the processing of sensitive data and wishes to subsequently use services involving the processing of sensitive personal data, giving the necessary consent.
If, for any reason, the client does not expressly consent to the processing of sensitive personal data and subsequently subscribes to services that imply such treatment, ENG & LIFE can not be held liable since the disclosure of sensitive data on the web will be the responsibility exclusive of the client, regardless of whether the management of the web space is provided by CLOSER CONSULTORIA, LDA.
However, CLOSER CONSULTORIA, LDA reiterates the aforementioned importance of the prior modification of the register by the customer, granting the necessary authorization for the processing of sensitive data if it intends to use services that necessarily involve the use / treatment of that information.
Sensitive data, particularly those that reveal the client’s sexual orientation will not be communicated (except in cases of legal imposition) or disclosed by CLOSER CONSULTORIA, LDA.
If the customer intentionally uses the services provided by CLOSER CONSULTORIA, LDA to communicate and / or disclose sensitive personal data on the internet, this does not represent any conduct accepted or practiced by CLOSER CONSULTORIA, LDA to the extent that the customer communicates this information within the scope of the private and independent management that makes the Web space available to it by CLOSER CONSULTORIA, LDA or within the scope of the normal use of the services provided by the latter.
Possible processing of the personal data of third parties provided by the data subject
When the customer uses certain services (eg promotional activities carried out by CLOSER CONSULTORIA, LDA that allow him to request the registration of domain names in favor of third parties, the personal data of third parties supplied by the customer to the operator can be processed, the customer assumes the role of independent data manager and the inherent legal obligations, in particular that of compensation for any damages caused to the third party due to breach of rules regarding the protection of personal data. In any case, if the customer provides or processes personal data of third parties while using services provided by CLOSER CONSULTORIA, LDA, warrants and fully assumes that the third party has previously authorized the processing of their personal data.
Data Controller and Data Processor
The data controller is: CLOSER CONSULTORIA, LDA, headquartered at Av. Eng.º Duarte Pacheco Torre 1 – 15º 1070-101 Lisboa.
You may contact the data processors, under the law, at any time by contacting the offices of the data controller – CLOSER CONSULTORIA, LDA in order to exercise the rights provided for by law.
Data storage and security measures
The data will be stored for the time defined by applicable laws and regulations, on the servers of CLOSER CONSULTORIA, LDA. In any case, your data will be stored strictly for the period of time necessary to achieve the objectives mentioned above, which must correspond to the validity of the contractual relationship between CLOSER CONSULTORIA, LDA and the customer. If you cancel your account, as soon as you stop using the Services, your data will be erased, except when maintaining them is strictly necessary for compliance with legal, financial, tax and accounting obligations, after ceasing the use of the service by the client. Once these obligations are met, your data will be deleted. We also inform you that these data will be collected, processed and maintained in full compliance with legal provisions.
Right of access to personal data and other rights
The client has the right to be informed:
source of personal data;
purposes and methods of treatment;
of the logic applied to treatment, in particular whether it is carried out with the help of electronic means;
the identification of the data controller, the data processor and its representatives;
of the entities or categories of entities for which personal data may be communicated and who may know such data as representative designated in the territory of the State, data processor (s) or person (s) responsible for the processing.
The customer has the right to obtain:
- a) updating, rectification or, when interested, data integration;
(b) the deletion, anonymity or blocking of data that has been illegally processed, including data the maintenance of which is necessary for the purpose for which it was collected or subsequently processed;
(c) certification to that effect that the operations referred to in points (a) and (b) have been notified to the entities to whom the data were communicated or disseminated, unless this requirement proves to be impossible or manifestly disproportionate to the right to be protected.
You have the right to reject, in whole or in part:
(a) for legitimate reasons, the processing of personal data concerning him, even if they are relevant to the purpose of the collection;
b) the processing of personal data concerning him, carried out for the purpose of sending advertising material or direct sales, or for the evaluation of market performance or commercial communication.
For any information in order to exercise the rights provided by law, under the terms described above, the client may write to:
CLOSER CONSULTORIA, LDA
Av. Eng.º Duarte Pacheco Torre 1 – 15º
The Customer may also send his request for information by e-mail to the address firstname.lastname@example.org