Effective date: 27 October 2023
Sintagma Traduções Lda.
- Who are we?
- What is personal data?
- What data does Sintagma process?
- For what purpose and with what lawful justification?
- How long do we keep personal data?
- Transfer of personal data
- Safeguarding measures
- Rights of data subjects
- International transfer of personal data
- How can you exercise your rights?
1. Who are we?
SINTAGMA TRADUÇÕES UNIPESSOAL LDA. is a sole ownership limited liability company, with legal person identification no. 503 018 597, registered at the Cascais Company Registry Office under the same number, with a share capital of 5000.00 EUR and with registered office at Rua José́ Régio, n.º 9 – 3.º Direito, Quinta das Palmeiras, 2780 - 129 Oeiras
Sintagma can be contacted via the following email: email@example.com or by mail to the address above.
Sintagma is the Data Controller.
2. What is personal data?
Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.
3. What data does Sintagma process?
Sintagma may process the following categories of personal data, depending on the relationship that it establishes with the data subject:
- Identification data (e.g. name, citizen identity card, passport and taxpayer number data, nationality);
- Data in relation to education and work experience (e.g. education, qualifications, certifications, languages, curricula vitae);
- Professional data (e.g. position, duties, job description, company, office address);
- Expenses and invoicing data (e.g. fees, expenses); and
- Sound and image registration data (e.g. photographs and video).
The data subjects are the natural persons that the data relates to.
Sintagma collects your personal data when you send us an email or when you insert your data on our website’s online form, when you provide services or, furthermore, when you engage our services.
4. For what purpose and with what lawful justification?
Sintagma can process your personal data for the following purposes and with the following lawful justification:
a) For the provision of translation, subtitle and training services, which may include:
Registration of service proposals submitted;
Communication with the client, with other parties and/or public entities
The lawful justification, in this case, is the performance of the contract.
b) For communications and sending information, including disclosure of information of legal nature (e.g. newsletters).
The lawful justification is the legitimate interest.
c) Respond to the requests submitted by subscribers of online forms on Sintagma’s website, communicating in an appropriate manner;
The lawful justification is the legitimate interest.
d) For Invoicing and accounting management, which includes:
Expenditure accounting, costs control and reimbursements (e.g. communication and travel expenses);
Invoicing and current account management; and
Accounting records and support documentation archive maintenance.
The lawful justification is the performance of the contract and compliance with a legal obligation.
e) For recruitment and selection, which includes candidate and CV analysis, as well as the internal employee selection process according to the needs identified.
The lawful justification is pre-contract due diligence requested by the data subject and the legitimate interest.
Sound and image recording, photographs:
The lawful justification is the consent of the data subject.
5. How long do we keep personal data?
Sintagma keeps your data for as long as is necessary in order to achieve the purposes defined in this Policy or during the period required according to the applicable laws and regulations, for example with regard to Tax.
Personal data, according to the purpose they are processed, is kept for the following periods:
Communications and expedition of image and voice information and data: Until the data subject expresses their opposition.
Invoicing and accounting management: 10 years.
Recruitment and selection: 2 years, counted from the delivery of the candidature or the CV, if the candidate is not selected; and
During the period that a professional relationship with Sintagma stays in effect, in the remaining cases.
6. To whom does Sintagma transfer the personal data?
Sintagma does not transfer your personal data to third parties, unless this is necessary in order to provide the services under contract, or in order to comply with legal obligations that Sintagma is subject to.
The transfer of data to third parties is performed according to the applicable law in terms of personal data protection and limited to the purposes for which they are processed and the lawful justification defined in this Policy.
Sintagma may share personal data with the following entities:
Public authorities, within the scope of legal obligations;
Service providers that provide services to Sintagma, within the scope of the purposes described above, such as, for example, IT providers, communications services, translation services. Under these circumstances, a Personal Data Protection Agreement shall be executed for the purposes of governing confidentiality and matters regarding duties of data protection.
When the transfer of personal data to the entities referred to above involves a cross-border transfer of personal data (i.e. outside the European Economic Area), Sintagma will comply with that set forth in articles 49 et seq. of the General Data Protection Regulation.
7. Safeguarding Measures
Sintagma has implemented a rigorous protection policy, from a technical and organisational perspective, in order to protect personal data against the destruction, loss, alteration, disclosure or unauthorised access and any other form of unlawful processing or misuse.
8. What are the rights of the data subject?
Right of access
You have the right to obtain confirmation from Sintagma as to whether or not personal data concerning you is being processed, access to the personal data and information about its processing.
You can also obtain a copy of the personal data subject to processing.
Right to rectification
If your personal data is inaccurate or incomplete, you can request its rectification or completion.
Right to erasure
Under certain circumstances, you are entitled to request the erasure of your personal data.
This right can be restricted under certain circumstances, such as, for example, when the data processing is necessary in order to comply with legal obligations to which Sintagma is bound, or when such processing is necessary for the establishment, exercise or defence of legal claims.
Right to restriction of processing
Under certain circumstances, you can request that Sintagma restrict access to personal data or to suspend the processing.
Right to data portability
When the data processing is based on a contract you are party to or the processing is based on your consent, you can demand that Sintagma deliver the personal data that was provided in a structured, commonly used and machine-readable format, to you. You can also ask Sintagma, where technically feasible, to transmit that data to another controller.
Right to object
When the data processing is based on the legitimate interests of Sintagma or when it is performed for reasons other than those that the personal data was originally collected for, even if compatible with these reasons, you have the right to object to the processing of personal data concerning you on grounds relating to your particular situation.
Right to withdraw consent
When data processing is based on your consent, you can withdraw your consent at any time.
If you withdraw your consent, your personal data will no longer be processed, unless another lawful justification exists that permits such processing.
Right to submit complaints to the supervisory authority
You have the right to submit complaints to the appropriate supervisory authority, with regard to matters related to the processing of your personal data.
In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados [National Data Protection Commission]. If you require further information, please consult www.cnpd.pt.
Sintagma does not make automated individual decisions, including profiling, that produce legal effects concerning you or that similarly significantly affect you.
9. International transfer of personal data
Sintagma's website is hosted on the Webflow platform which, in turn, is hosted on a server in the United States of America.
Sintagma complies with that set forth in article 49 of the General Data Protection Regulation relating to such transfer, in particular by requesting your prior consent before collecting your personal data
10. How can you exercise your rights?
You can exercise your rights using either of the following channels:
E-mail: you can exercise your rights by email sent to firstname.lastname@example.org; or
Letter: you can exercise your rights by sending a letter to Sintagma Lda, mailing it to the address stated above.
You can exercise your rights free of charge.
Lisbon, 27 October 2023