SOWIN S.A. was born as a result of a set of initiatives and experiences of passionate about innovation, aligned with the changing world. We offer a portfolio of solutions focused on the CRM and ERP ecosystems in tune with the technological transformation and the organic and sustainable growth of each company. We want to be recognized for contributing to a better world through the balance between technological evolution, companies, people, and societies. We aim to bring together technology lovers who want to do the same.
Headquartered at Rua Sousa Martins nº 10, Lisbon, registered at the Lisbon Commercial Registry, under the registration number 516 428 667, SOWIN S.A., within the scope of its consulting and engineering services, needs to collect and process personal data of candidates, employees, customers, suppliers and third parties.
As the protection of privacy and personal data of all those who interact with SOWIN S.A. is a concern and priority for us, this privacy and data protection policy was prepared accordingly. In this way, it is possible to transmit in a clear and transparent way the good practices concerning this process. Any and all personal data provided will be treated with the guarantee of security and confidentiality required by the legal framework with regard to the protection of personal data.
This policy describes a set of guidelines, rules and principles that must be observed by SOWIN S.A. to ensure the protection of the rights of data subjects.
SOWIN, S.A. undertakes to comply with this policy in accordance with the obligations of Regulation 2016/679/EU, of the European Parliament and of the Council, of 27 April 2016, regarding the protection of individuals regarding the processing of personal data and the free movement of such data (hereinafter referred to as “GDPR”).
In this sense, SOWIN S.A. seeks to ensure that its internal procedures comply with the legal obligations of the GDPR and that the personal data of its employees, customers, suppliers or service providers and any other data subjects whose personal data SOWIN, S.A. treats in the exercise of its activity, they are treated in accordance with the regulatory and legal standards in force and kept securely.
SOWIN S.A., localized in Rua Sousa Martins, 10, 1050-218 Lisbon enrolled in the Lisbon Commercial Registry Office, under the registration number and legal entity number 516 428 667 has the Data Controller for the processing of personal data, committed to apply the necessary technical and organizational measures, taking into account all the aspects that may influence the GDPR Compliance fulfilling the fundamental rights of the Data Subjects. To this task, SOWIN S.A. has technologic measures (“privacy-enhancing technologies”) that we seek to constantly upgrade, having collaborators specially assigned to this purpose, revealing our concerns and commitment to the Data Subjects. Besides this, we maintain a nature register of the scope, context, and finalities of the treatments about the stored data that allows us to ensure and prove that the treatments are realized with the guarantee of a total Data subjects protection has a commitment that attests our responsibility.
Contact Details:
The Present Privacy Policies applies to the collaborators, Data Processors, Joint Controllers, clients, site user’s, trainees, and candidates operating in this Company Universe.
To effect of the present Privacy Policy, each company detains her own legal registration number having her own Privacy Policies independent and autonomous (however, it’s detained by the Group Moongy, S.A.) for responsibility effects, each company (and they’re assents) are independent, not being responsible any of these entities for the acts or omissions of the other entities in the group on what concerns to data privacy aspects.
The Department of Global Projects (DPG) is a part of Moongy S.A, which is the mother Companie of the Moongy Group, to which SOWIN S.A. also belongs.
The Department is constituted by professionals with a curriculum, technical and organizational knowledge from different areas who provide support to various subjects, among others: Information Security and Data Protection.
The DPG assists SOWIN S.A, in the application of the GDPR, being aware, it gets involved properly and in a timely manner, in all issues related to the protection of personal data, taking into account the risks associated with the processing operations, such as its nature, scope, context and purposes. Also ensuring compliance with all established processes in order to preserve the confidentiality of data. With regard to requesting the rights of holders, reporting violations of personal data and other communications related to the GDPR, this is the point of contact:
Personal data is the information relative to a Singular Person (Natural Person) identified or identifiable (Data Subject) excluding from its scope the data relative to Legal Persons. It’s considered identified a Natural Person that can be identifiable, direct, or indirectly, in special references to an identificatory, for example, a name, an ID number, tracking data, etc.
Any specific element of the physical, physiological, genetic, mental, economic, cultural, or social identity of a natural person.
The collectible data is the strictly necessary being limited to the purposes for which they are intended, which are determined, explicit, legitimate, and kept for the strict period in which they may be necessary for their purpose. Personal data must be processed lawfully, fairly, and transparently in relation to the data subject.
To the Compliance of the Company’s activity and has a Data Controller, SOWIN, S.A. needs to collect and treat the following data:
| Data Category | Data to be Collected |
|---|---|
| Candidate Data - Recruitment | Name; date of birth or age; sex; nationality/citizenship/place of birth; residence address; phone number; e-mail address, first language; data and copy of the identification document; immigration status (in case you need a work permit); academic qualifications; academic record; professional history; photography; marital status; household and data on any dependents. |
| Candidate Data - Contractual Process (Admission) | Name; date of birth or age; sex; nationality/citizenship/place of birth; residence address; phone number; e-mail address, first language; data and copy of identification document (citizen's card or passport), BSN; data and copy of your driver's license and/or other proof of address; financial information (country of banking address, account holder, domiciliation (name of bank), IBAN, BIC (or SWIFT)); other tax information; immigration status (in case you need a work permit); academic qualifications, proof of qualifications, academic record; professional history, photography, emergency contacts; marital status, household and data on any dependents. |
| Customer Data - Contractual Process | Name, telephone number and e-mail address of employees of the client company. |
| Supplier Data - Contractual Process | Name, telephone number and e-mail address of employees of the client company, as well as financial information (country of bank domicile, account holder, domiciliation (name of bank), IBAN, BIC (or SWIFT)). |
| External Trainees Data | Name, telephone number and e-mail address; identification document; nationality; date of birth. |
| User Data of Website | Cookies collect generic information, namely: i) IP address; ii) date, time, duration and frequency that you access the site; iii) the way you arrive and use the website; ii) information related to your authorizations; iii) the area of the country in which you access the website. |
| Data Category | Purpose of the Treatment |
|---|---|
| Candidate’s Data | The following are used for recruitment:
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| Colaborator’s Data | The following are used to:
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| Client’s Data |
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| Supplier’s Data |
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| External Trainees Data |
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| Site user’s data |
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The Purposes of treatment of the personal data are determined by the execution of diverse kinds of formalized contracts that become needed to continue the entire activity of the company, among them we state:
In GDPR terms, we are legitimated by the following legal purposes (Lawfulness of Processing):
The withdrawal of consent can be requested at any time, by sending a simple request to the email address: gdpr@sowin.pt .
The Personal Data collected by us will be treated and kept according to the purposes and for the minimum period legally necessary.
SOWIN, S.A. may, in the scope of its basic activities, disclose the data collected to fulfill the purposes indicated in this policy, being provided to the entities of the SOWIN, S.A. network’s only the data strictly necessary for the execution of the service, based on the fulfillment of legal obligation (for example salary processing or any tax obligation that requires it), and may also, to the strictly necessary, be communicated to official entities whenever this is legally required and may be handled by suppliers of the company (for example internal and external auditors that allows us to preserve and improve the quality of the service).
In this sense, the entire scope of this policy extends to the treatments of third parties and data processors, considering:
Whenever a new product is developed, it is ensured in the design itself (as a primary aspect) that it has the most advanced technical and organizational measures available to SOWIN, S.A. (taking into account the risks arising from the treatment for the rights and freedoms of the data, as well as the arising risks to the treatment for the rights and freedoms of the natural persons, being aware of the variability, probability and severity) while maintaining privacy as a pillar throughout the processing process. In this way, the application of all the principles determined by the GDPR from conception is guaranteed, protecting Data Subjects, and ensuring the rights of data subjects.
In short, SOWIN, S.A. is commited to implement and have privacy present in the product development phase and throughout the treatment to ensure data protection from the very conception of the product (“Privacy by Design”).
How long will the data be kept?
The data will be kept for: the period necessary for the purposes they are intended too, and they are processed within the scope of our activity; for a maximum period of 5 years for staff selection and recruitment; for the periods required by the legal obligations to which we are subjects.
Rights of the data subject
The Data subject has the following rights, which he can easily and free of charge request, through the following e-mail: gdpr@sowin.pt
Only in case of manifestly unfounded or excessive requests may a fee be charged for the exercise of these rights (in accordance with article 15, No. 3 from GDPR).
The data subject has the right to question whether or not the data is being processed and, if so, the right to access their personal data and to be provided with the following information:
The data subject also has the right to obtain a copy of the personal data being processed.
The data subject has the right to request and obtain the rectification of inaccurate data and to request that incomplete personal data is completed without undue delay.
Right to be Forgotten
The data subject has the right to request the erasure of his personal data, without undue delay, whenever they are no longer accurate for the purpose that motivated their collection or treatment. He may also decide to withdraw his consent to the processing of his personal data whenever he wants to enjoy the right to oppose it.
There are some exceptions to this right, such as, if they are against the exercise of freedom of expression and information, if they are necessary for the fulfillment of legal obligations, if they are necessary for reasons of public interest or public health, if they are necessary for archival matters of public interest, scientific, historical research, for statistical purposes or the exercise or defense of rights in legal proceedings. In these cases, the data subject must be informed of the reason why it is not possible to respond to his request.
The data subject has the right to limit/restrict the processing of his/her personal data whenever one of the following situations occurs:
In the situations listed above, you may be asked to suspend processing or limit the scope of processing to certain categories of data (for example only providing full name and address) or even specific processing purposes.
Whenever the data subject is requested to rectify, erase or limit the processing of data, the person responsible for the treatment informs the data subject that he has proceeded in accordance with the request, unless such communication proves impossible or involves a disproportionate effort. If the data subject so requests, the controller provides information on said recipients.
The data subject has the right to receive personal data concerning him in a structured, commonly used, and machine-readable format without SOWIN S.A. being able to object under the terms of article 20 No. 1 of the GDPR:
To exercise any of these rights or for any questions regarding the processing of their personal data, the data subject must address a request to the person responsible for processing, the e-mail address to make the request: gdpr@sowin.pt .
Although these rights are clarified to the data subject when collecting the respective personal data, in case of doubts, the data subject can contact the person responsible for the treatment by e-mail: gdpr@sowin.pt .
SOWIN, S.A. has been working to maintain and preserve personal data providing a high level of security. In compliance with the principle of security, secrecy, and privacy, we guarantee the processing of your data only by authorized persons, only accessing and processing your data by those who have the legitimacy to do so, always doing so in a confidential manner. The “need-to-know” principle was adopted, where employees can only have access to personal data if it is strictly necessary for the performance of their duties. Treatment outside this scope is considered prohibited and submitted to disciplinary sanctions, in accordance with our internal security and confidentiality policies and procedures, which are periodically updated as necessary.
Depending on the nature, scope, context, and purposes of data processing, as well as the risks arising from the treatment for the rights and freedoms of the data subject, we apply, both when defining the means of treatment and when processing, the necessary and appropriate technical and organizational measures for data protection.
Employees are not allowed to use personal data for private or economic purposes, transmit them to unauthorized third parties and/or allow access in any other way.
SOWIN, S.A. also undertakes to ensure that, by default, only relevant, necessary, and appropriate data will be processed for each specific purpose of the treatment and that such data are not made available without human intervention to an undefined number of people.
Although this is not foreseen, if the transfer of personal data to countries outside the European Union is carried out, the applicable legal provisions are observed, namely regarding the determination of the suitability of such country regarding data protection and the requirements applicable to such transfers. Security measures were also defined, ranging from best practices to the prevention of external threats. These are described in the security policy. If you wish to have access to it, you can request it by sending an e-mail to: gdpr@sowin.pt
SOWIN S.A. assisted by the DPG is responsible for:
It is considered a violation of personal data any act that calls into question the security of the data, in an accidental or unlawful manner, and causes the unauthorized destruction, loss, alteration, disclosure or access to personal data transmitted, stored or subject to any other type of treatment.
We can firmly declare that SOWIN S.A. has been working to maintain and preserve personal data with a high level of security. However, small, unexpected deviations may occur.
If any of our candidates, employees, customers, data processers or third parties detect or suspect of a possible personal data breach, they should immediately send an email to gdpr@sowin.pt, indicating what has happen, as well as identify the data that may be involved. In this way, the responsible department can act quickly and adequately, in accordance with the rules established in the Regulation. In case of a data breach and to the extent that such breach is likely to entail a high risk for the rights and freedoms of customers, workers and other employees and/or partners, we undertake to report such breach to Comissão Nacional de Proteção de Dados (CNPD), within 72 hours of becoming aware of the incident, and to the holders of personal data whenever such breach is likely to entail a high risk for their rights.
Cookies are small text files, which are stored on your computer or on your mobile device through your browser. By browsing, they record their preferences and allow the website to identify your device the next time you access it.
At any time, you can decide to be notified about the receipt of cookies, check or change the type of cookies, and block the entry of cookies in your system, through the settings of your browser
Cookies are an essential part of the operation of our website and to facilitate your navigation on the Platform, the main purpose of which is to improve your search experience. For example, they are used to help determine the usefulness, interest and number of website uses, enable faster and more efficient browsing, and also eliminate the need to repeatedly enter the same information.
The information collected by Cookies also allows us to improve the website through estimates and usage patterns, and to allow its suitability to the individual interests of users As described below, the website uses technical or strictly necessary cookies, performance cookies and functionality cookies. Each of these cookies may be installed by SOWIN websites (own cookies) or websites external to SOWIN (third party cookies) and may be removed as soon as the user leaves the website (session cookies) or remain on the terminal device after the user leaves the website (persistent cookies).
The cookies currently used by the website are as follows:
Technical or strictly necessary cookies are cookies installed for the purpose of allowing navigation on the website, allowing a correct user experience, namely the security of the website or the management of consents. For this reason, these cookies do not require your consent.
| Cookie | Designation of cookie | Purpose | Nature of the cookie | Duration |
|---|---|---|---|---|
| Cookiebot | CookieConsent | Saves the user consent status cookie for the current domain | Third Party | 1 year |
| www.sowin.pt | .AspNetCore.Antiforgery.# | Helps prevent Cross-Site Request Forgery (CSRF) attacks. | Own | Session |
| www.sowin.pt | ARRAffinity | Used to distribute traffic to the website on several servers to optimise response times. | Own | Session |
| www.sowin.pt | ARRAffinitySameSite | Used to distribute traffic to the website on several servers to optimise response times. | Own | Session |
| rc::a | Allows to distinguish between humans and bots. It is necessary for reports of use of the site to be reliable | Third Party | Persitent | |
| rc::c | Allows to distinguish between humans and bots | Third Party | Session |
Performance or performance cookies allow you to count visits and traffic sources, so SOWIN can measure and improve the performance of the website. These cookies help us to know which pages are most visited and to analyse how visitors use the website. All information collected by these cookies is anonymous.
| Cookie | Designation of cookie | Purpose | Nature of the cookie | Duration |
|---|---|---|---|---|
| _ga | Records a unique ID that is used to generate statistical data on how the visitor uses the site | Third Party | 2 years | |
| _ga_# | Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. | Third Party | 2 years |
Functionality cookies allow the website to provide enhanced functionality and customization, such as remembering the language in which you want to see the website in your next visit. If you do not allow these cookies some of these features, or even all of them, may not act correctly.
| Cookie | Designation of cookie | Purpose | Nature of the cookie | Duration |
|---|---|---|---|---|
| _GRECAPTCHA | Allows to distinguish between humans and bots. It is necessary for reports of use of the site to be reliable | Third Party | 179 days | |
| rc::a# | Allows to distinguish between humans and bots. It is necessary for reports of use of the site to be reliable | Third Party | Persitent | |
| rc::c | This cookie is used to distinguish between humans and bots. | Third Party | Session | |
| api.itjobs.pt | itjobs_pt | Pendent | Third Party | 30 days |
The user may, at any time, revoke or change the preferences of consents previously granted. To do this, simply access the tool Cookies Management.
The use of cookies can also be defined in the preferences of your browser (browser), namely in the privacy options. For this purpose, we recommend that you refer to the help section/menu of your browser or visit the respective provider’s web pages.
Although the existence of SOWIN, S.A. commitment to resolve any type of situation. The Data Subject has the right to file a complaint to the competent authorities (CNPD) if any of the rights is denied.
From the competent authority:
Comissão Nacional de Proteção de Dados
Av. D. Carlos I, No. 134 - 1.º
1200-651 Lisboa / Portugal
Tel: +351 213928400 / Fax: +351 213976832
www.cnpd.pt
SOWIN, S.A. reserves the right to change this Privacy Policy at any time, being that change duly published here.
In any case, we suggest that you review this Policy regularly so that, in the event of changes or updates being introduced, you can always be properly informed about them.
The privacy policy as well as the collection, processing or transmission of data from customers, employees and partners are governed by the provisions of regulation (EU) 2016/679, of the European Parliament of the Council, of April 27, 2016 and by the applicable legislation and regulations. In Portugal, namely Law No. 58/2019 of 8 August.
Any Disputes arising from the validity, interpretation, or execution of the Privacy Policy, or that are related to the collection, processing, or transmission of Customer data, must be submitted exclusively to the jurisdiction of the judicial courts of the District of Lisbon, without prejudice to the legal imperatives rules applicable.
If you have any doubts, wish to exercise your rights, suggestions or complaints regarding Data Protection and this Privacy Policy, you can contact us at our email address: gdpr@sowin.pt .