We are very pleased that you have shown an interest in our company. Data protection is a particular priority for Serro & Andrade, Lda (S&A). The use of the internet pages of S&A is possible without any indication of personal data; however, if a data subject wishes to use special services via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we obtain the consent of the data subject.
The processing of personal data - such as the name, address, e-mail address, or telephone number - of a data subject must always comply with the General Data Protection Regulation (GDPR)and in accordance with the country-specific data protection regulations applicable to S&A. By means of this data protection declaration, our company would like to inform the general public about the nature, scope, and purpose of the personal data we collect, use, and process. In addition, data subjects are hereby informed by this data protection statement of their rights.
As a controller, S&A has implemented various technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may, in principle, have security gaps, and therefore absolute protection may not be guaranteed. For this reason, each data subject is free to transfer personal data to us by alternative means, for example by telephone. You can find a list of the various ways of contacting us here.
Please note that S&A cannot guarantee that all URLs in this document are functional at the time of reading this document. All URLs in this data protection statement are verified as correct and active at the time of this writing; however, S&A cannot guarantee that URLs to external websites will remain functional over time as such URLs are subject to change at the discretion of the external website owner.
This data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration must be readable and understandable for the general public as well as for our customers and business partners. To ensure this, we would like to start by explaining the terminology used.
In this data protection statement, we use, inter alia, the following terms:
- Personal details
Personal data means any information relating to an identified or identifiable natural person ("data subject"). 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.
- Data subject
The data subject is any identified or identifiable natural person whose personal data are processed by the controller responsible for processing.
Processing is any operation or set of operations which is performed on personal data or sets of personal data (whether or not by automated means), such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, erasure, or destruction.
- Treatment restriction
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that person's work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.
Pseudonymisation is the processing of personal data in such a way that personal data can no longer be attributed to a specific data subject without recourse to further information, provided that such further information is kept separately and is subject to technical and organisational measures to ensure that personal data cannot be attributed to an identified or identifiable natural person.
- Data Controller or Controller or Controller responsible for processing
Data Controller or Controller or Controller responsible for processing is the natural or legal person, public authority, agency or other body which (alone or jointly with others) determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its appointment may be indicated by Union or Member State law.
- Data Processor or Processor or Subcontractor
Data Processor or Processor or Subcontractor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
A recipient should be a natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law should not be regarded as recipients; the processing of such data by those public authorities should be in compliance with the applicable data protection rules according to the purposes of the processing.
The third party is a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or the processor, are authorised to process personal data.
Data subject consent is any freely given, specific, informed, and unambiguous indication of the data subject's wishes - by means of a statement or by a clear affirmative action - in which he/she expresses agreement to the processing of personal data relating to him/her.
The controller, for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws in the Member States of the European Union and other provisions relating to data protection, is:
Serro & Andrade, Contabilidade e Consultoria, Lda.
Rua Eugénio de Castro, 248 2 S237
Telephone: +351 226001265
E-mail: [email protected]
The Data Protection Officer of the controller is::
António Alexandre Serro
Serro & Andrade, Contabilidade e Consultoria, Lda.
Rua Eugénio de Castro, 248 2 S237
Telephone: +351 226001265
E-mail: [email protected]
Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions regarding data protection.
By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us, as mentioned above, to recognise the users of our website. The purpose of this recognition is to make it easier for users to navigate our website. The user of the website using cookies, for example, does not need to enter access data each time the website is accessed, because this is assumed by the website, and the cookie is stored in the user's computer system. Another example is the cookie from a shopping cart in an online shop: the online shop records the items that a customer has placed in the virtual shopping cart by means of a cookie.
The data subject may at any time prevent the setting of cookies on our website by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. In addition, cookies that have already been set can be deleted at any time using an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the cookie setting on the Internet browser used, not all of the functionalities of our website may be fully usable.
The S&A website collects some general data and information when a data subject or automated system accesses the website. This general data and information is stored in server log files. The data collected may consist of (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website through which the system arrives at our website (the so-called referrer), (4) the subwebsites, (5) the date and time of access to the Internet website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the system that accesses the website and (8) any other similar data and information that can be used in the event of an attack on our information technology systems.
By using this general data and information, S&A does not draw any conclusions about the data subject. Instead, this information is necessary to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with information necessary for criminal prosecution in the event of a cyber attack. Therefore, S&A analyses the collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we handle. Anonymised data from server log files is stored separately from all personal data provided by a data subject.
On the S&A website, visitors have the opportunity to subscribe to the newsletter of our company. The input mask used for this purpose determines which personal data is transmitted, as well as when the newsletter is requested from the controller.
S&A regularly informs its customers and business partners by means of a newsletter about company offers. The company newsletter can only be received by the data subject if (1) he/she has a valid e-mail address, and (2) he/she registers for the receipt of the newsletter. For legal reasons, a confirmation e-mail will be sent to the e-mail address first registered by the data subject for the sending of newsletters, in a procedure commonly known as "double registration". This confirmation e-mail is used to check whether the owner of the e-mail address - as data subject - wishes to receive the newsletter.
During registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the (possible) misuse of a data subject's e-mail address at a later date and thus serves the purpose of legal protection of the controller.
Personal data collected as part of a newsletter registration will only be used to send our newsletter. In addition, newsletter subscribers may be informed by e-mail, insofar as this is necessary for the operation of the newsletter service or a registration in question, as could be the case with changes in the newsletter offer, or the change of technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter can be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject provided to send the newsletter, can be revoked at any time. For the purpose of revoking consent, a corresponding address can be found in each newsletter. The data subject may also unsubscribe from the newsletter by communicating this wish to the controller.
S&A's newsletter contains so-called tracking pixels. A tracking pixel is a thumbnail graphic embedded in such emails, which are sent in HTML format to allow for log file recording and analysis. This enables a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, S&A can see if and when an email has been opened by a data subject and which addresses in the email have been invoked by data subjects.
Such personal data collected in the tracking pixels contained in the newsletter are stored and analysed by the controller in order to optimise the sending of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. The data subject has at any time the right to revoke the respective declaration of consent issued by means of the double registration procedure. Following a revocation, such personal data shall be deleted by the controller. S&A automatically considers a withdrawal from the receipt of the newsletter as a revocation.
The website of the S&A contains information which enables a quick electronic contact to our enterprise as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are stored automatically. Such personal data voluntarily transmitted by the data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of such personal data to third parties.
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the storage, or to the extent that this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the purpose of storage is not applicable, or if a storage period prescribed by the European legislator or other competent legislator has expired, personal data is routinely blocked or deleted in accordance with legal requirements.
Right to be informed
Each data subject has the right - granted by the European legislator - to know how the personal data provided by him or her will be used by the controller or processor.
This data protection statement explains how all personal data collected by S&A may be used. If a data subject has any questions about how his/her personal data will be used, he/she may at any time contact our Data Protection Officer or another employee of the controller directly.
Right of confirmation
Every data subject has the right - granted by the European legislator - to obtain confirmation from the controller as to whether or not personal data concerning him/her is being processed. If a data subject wishes to avail himself/herself of this right of confirmation, he/she may at any time directly contact our Data Protection Officer or another employee of the controller.
Right of access
Each data subject has the right - granted by the European legislator - to obtain from the controller, at any time and free of charge, information about their stored personal data and a copy of this information. In addition, European directives and regulations grant the data subject access to the following information:
The aims of the treatment;
The categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
if possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
The existence of the right to request the controller to rectify or erase personal data, or to restrict the processing of personal data concerning the data subject, or to object to such processing;
The existence of the right to lodge a complaint with a supervisory authority;
Where personal data is not collected from the data subject, any available information on its origin;
The existence of automated decision-making, including profiling, referred to in Articles 22(1) and (4) of the GDPR and - at least in such cases - meaningful information on the logic involved as well as the significance and intended consequences of such processing for the data subject.
Furthermore, the data subject has the right to obtain information on whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject has the right to be informed of the appropriate safeguards concerning the transfer.
If a data subject wishes to take advantage of this right of access, he/she may, at any time, contact our Data Protection Officer or another employee of the controller directly.
Right of rectification
Every data subject has the right - granted by the European legislator - to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him/her. Taking into account the purposes of the processing, the data subject has the right to complete incomplete personal data, including by submitting a supplementary statement.
If a data subject wishes to take advantage of this right of rectification, he/she may, at any time, contact our Data Protection Officer or another employee of the controller directly.
Right of erasure (Right to be forgotten)
Each data subject has the right - granted by the European legislator - to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller has the obligation to erase personal data without undue delay when one of the following grounds applies, provided that the processing is not necessary:
The personal data is no longer necessary in relation to the purpose for which it was collected or otherwise processed.
The data subject withdraws the consent on which the processing is based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal ground for the processing.
The data subject objects to the processing under Article 21(1) of the GDPR and there are no legitimate grounds for the processing, or the data subject objects to the processing under Article 21(2) of the GDPR.
Personal data has been unlawfully processed.
Personal data shall be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data has been collected in connection with the provision of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and the data subject wishes to request the erasure of personal data stored by S&A, he/she may at any time directly contact our Data Protection Officer or another employee of the controller. The S&A Data Protection Officer or other employee shall promptly ensure that the erasure request is complied with immediately.
If S&A has made personal data available and is responsible for the deletion of personal data in accordance with Article 17(1), S&A - taking into account available technology and implementation costs - shall take reasonable steps, including technical measures, to inform other controllers handling the published personal data that the data subject has requested the erasure by those controllers of any links, or copies or replication, of such personal data, unless the processing is necessary. The S&A Data Protection Officer or other employee will arrange the necessary measures in individual cases.
Right to restriction of treatment
Each data subject has the right - granted by the European legislator - to obtain restriction of processing from the controller if one of the following conditions applies:
The accuracy of the personal data is challenged by the data subject, for a period that allows the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject objects to the erasure of the personal data and requests the restriction of its use.
The controller no longer needs the personal data for processing purposes, but they are required by the data subject for the establishment, exercise, or defence of legal claims.
The data subject has objected to the processing under Article 21(1) of the GDPR, and it is not yet clear whether the legitimate reasons of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by S&A, he/she may at any time directly contact our Data Protection Officer or another employee of the controller. The S&A Data Protection Officer or other employee will arrange the restriction of processing.
Right to data portability
Each data subject has the right - granted by the European legislator - to receive the personal data concerning him/her, which have been provided to a controller, in a structured, commonly used and machine-readable format. He/she has the right to transmit such data to another controller without hindrance from the controller to which the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, or a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
In addition, when exercising their right to data portability under Article 20(1) of the GDPR, a data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and where doing so does not adversely affect the rights and freedoms of others.
To secure the right to data portability, the data subject may at any time contact our Data Protection Officer or another employee of the controller directly.
Right to object
Every data subject has the right - granted by the European legislator - to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling on the basis of these provisions.
S&A shall no longer process personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defence of legal claims.
If S&A processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him/her for such marketing. This also applies to profiling insofar as it relates to such direct marketing. If the data subject contacts us to object to the processing for direct marketing purposes, we will no longer process the personal data for those purposes.
In addition, the data subject shall have the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her by S&A for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may at any time directly contact our Data Protection Officer or another employee of the controller. Furthermore, the data subject is free - in the context of using information society services and notwithstanding Directive 2002/58/EC - to use his or her right to object by automated means, using the technical specifications.
Automated individual decision making, including profiling
Every data subject has the right - granted by the European legislator - not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion, or performance of a contract between the data subject and a data controller, (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for the conclusion, or performance, of a contract between the data subject and a data controller, or (2) is based on the data subject's explicit consent, the controller shall implement reasonable measures to safeguard the data subject's rights and freedoms and legitimate interests, including at least the right to obtain human intervention by the controller, to express its point of view, and to contest the decision.
If a data subject wishes to avail himself/herself of his/her rights concerning automated individual decision-making, he/she may, at any time, contact our Data Protection Officer or another employee of the controller directly.
Right to withdraw consent to data processing
Every data subject has the right - granted by the European legislator - to withdraw their consent to the processing of their personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, he/she may, at any time, contact our Data Protection Officer or another employee of the controller directly.
The data controller will collect and process the applicants' personal data for the purpose of processing the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant sends the corresponding application documents by e-mail or via a form on the website to the controller.
If the data controller concludes an employment contract with an applicant, the data submitted will be stored for the purpose of processing the employment relationship in accordance with legal requirements.
If no employment contract is concluded with the applicant by the data controller, the application documents will be automatically deleted within two months after the notification of the refusal decision, provided that (1) no other legitimate interests of the controller - such as the burden of proof in legal proceedings - oppose the deletion, or (2) the data subject explicitly expresses his/her wish for the controller to retain the personal data. A typical example of such a wish of the data subject is when he/she wishes the controller to retain a Curriculum Vitae (i.e. personal data) for future contact when a suitable employment opportunity arises.
On this website, the controller has integrated the Google Analytics component (with anonymisation functionality). Google Analytics is a web analytics service. Web analytics is the collection, aggregation, and analysis of data about visitor behaviour on websites. A web analytics service collects, inter alia, data about the website from which a person came (so-called referrer), which pages were visited, or how often and for what duration a page was viewed. Web analytics are mainly used for the optimisation of a website and to perform a cost-benefit analysis of internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Anphitheatre Parkway, Mountain View, CA 94043-1351, United States of America.
For web analytics through Google Analytics, the controller uses the "anonymizeIp" feature. Through this feature, the IP address of the data subject's internet connection is obtained by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website and to provide online reports, which show the activities on our websites and to provide us with other services about the use of our website on the Internet.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the cookie setting, Google is able to analyse the use of our website. With each call to one of the individual pages of this Internet website, which is operated by the controller and in which a Google Analytics component has been integrated, the Internet browser in the data subject's information technology system will automatically send data via the Google Analytics component for the purposes of online advertising and commission settlement to Google. In the course of this technical procedure, the Google enterprise gains knowledge of personal information, such as the data subject's IP address, which enables Google, among other things, to understand the origin of visitors and clicks and subsequently to set commissions.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our website, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on personal data collected through this technical procedure to third parties.
The data subject can, as indicated above, prevent the setting of cookies on our website at any time by means of a corresponding setting of the web browser used and thereby permanently deny the setting of cookies. This browser setting will also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already used by Google Analytics can be deleted at any time via the web browser or other software programs.
Further information and the applicable data protection provisions of Google can be found at www.google.com/intl/en/policies/privacy and at www.google.com/analytics/terms/us.html. Google Analytics is explained at www.google.com/analytics.
Article 6(1)(a) of the GDPR serves as a legal basis for processing operations for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which the data subject is a party - as is the case, for example, where the processing operations are necessary for the supply of goods or to provide any other service - the processing is carried out on the basis of Article 6(1)(b) of the GDPR. The same applies to processing operations necessary for the performance of pre-contractual measures, for example in the case of consultations about our products or services.
If our company is subject to a legal obligation by which the processing of personal data is required - such as compliance with tax obligations - the processing is based on Article 6(1)(c) of the GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor was injured at our company and their name, age, health insurance details, or other vital information would need to be passed to a doctor, hospital, or other third party. In that case, the treatment would be based on Article 6(1)(d) of the GDPR.
Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal grounds, if the processing is necessary for legitimate interests exercised by our company or a third party, except where these interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring protection of personal data. Such processing operations are particularly permitted because they were specifically mentioned by the European legislator, who considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 of the GDPR).
Where our processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the conduct of our business for the welfare of all our employees and shareholders.
The criteria used to determine the storage period of personal data are the respective statutory retention period. After the expiry of this period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment of the contract or the initiation of a contract.
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner).
Sometimes, in order to close a contract, it may be necessary for the data subject to provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide personal data when our company signs a contract with him/her. Failure to provide personal data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer will inform the data subject as to whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of failure to provide the personal data.
As a responsible company, we refrain from automatic decision making or profiling.