Data Protection and Privacy Policy

Turimagri – Sociedade Agrícola e Imobiliária S.A., (hereinafter “Turimagri S.A.”) is committed to respecting your personal data and privacy.

This Data Protection and Privacy Policy aims to explain in a clear and concise manner how Turimagri S.A. treats your personal data and ensures your privacy in the development and conduct of its activities, namely:

1. Person responsible for handling your Personal Data
2. Principles applicable to the protection of your Personal Data
3. Personal Data, Processing of Personal Data and Data Subject
4. Category of Personal Data which Turimagri S.A. handles
5. Purposes for which your Personal Data is processed
6. Grounds for Lawfulness
7. Term of conservation of your Personal Data
8. Sharing of Your Personal Data
9. Your rights and how to exercise them
10. Security of your Personal Data
11. Confidentiality
12. Cookies
13. Contacts
14. Changes to this Data Protection and Privacy Policy

1. RESPONSIBLE FOR THE TREATMENT OF YOUR PERSONAL DATA

Turimagri S.A. is responsible for the treatment of your Personal Data, determining, for this purpose, without limitation:

  • The Personal Data to be processed in the context of the provision of services and/or supply of products;
  • The Purposes for which your Personal Data are processed; and,
  • the means to be applied to the processing of your Personal Data.


2. PRINCIPLES APPLICABLE TO THE PROTECTION OF YOUR PERSONAL DATA

In the context of the relationship established with you, the Treatment of your Personal Data is carried out by Turimagri S.A. in accordance with the general principles set out in the General Data Protection Regulation (“RGPD”), namely:

  • Ensures that your Personal Data will be processed lawfully, fairly and transparently (“Principle of lawfulness, fairness and transparency”);
  • collects your Personal Data for specified, explicit and legitimate purposes and does not further process the same Data in a way incompatible with those purposes (“Purpose limitation principle”);
  • ensures that only Personal Data that are adequate, relevant and limited to what is strictly necessary for the purposes for which they are processed are processed (“principle of data minimization”);
  • Take appropriate steps to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“Principle of accuracy”);
  • keeps Personal Data in a form which permits their identification only for as long as is necessary for the purposes for which they are processed (“Principle of storage”);
  • Ensures that your Personal Data is processed in a manner that ensures its security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures (“Principle of integrity and confidentiality”).

Additionally, and although not expressly stated in the GDPR, Turimagri S.A. processes your data through the application of technical and organizational measures that ensure Data Protection by Design and by Default, so that your Personal Data is treated in accordance with best practices from the time of collection until its destruction.

3. PERSONAL DATA, PROCESSING OF PERSONAL DATA AND DATA SUBJECT

Personal Data is all information and/or elements that, regardless of their support, can identify you or make you identifiable, directly or indirectly, to Turimagri S.A., in particular by reference to an identifier, such as a name, an identification number, your location data and/or electronic identifiers or to one or more specific elements of your physical, physiological, genetic, mental, economic, cultural or social identity.

Processing of Personal Data means the operation or set of operations carried out on Personal Data of Data Subjects using automated or non-automated means, from the collection of information to its destruction. Within this cycle, among others, are included recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, limitation, erasure. The concept of Personal Data Processing is quite broad and will apply to all operations or set of operations carried out by Turimagri S.A. with reference to your Personal Data.

In the context of the activities performed by Turimagri S.A., the Data Subject is, without limitation, the customer and/or former customers, potential customers, investors, partners, job applicants, employees and former employees, employees of partners, suppliers and service providers and their employees, claimants and complainants and/or all those individuals who have a relationship with Turimagri S.A. and to whom the Personal Data relates.

Turimagri S.A. will only process the personal data of minors in strict compliance with personal data protection legislation and other applicable legislation, or when provided by parents or a legal guardian who expressly consents to such collection. Should Turimagri S.A. discover that it has inadvertently collected the personal data of a minor under the age of 18, it will immediately delete the records containing the personal data of that minor. If you are the holder of parental responsibilities of a child and become aware that the child has provided us with information, please contact us by the means detailed below, so that Turimagri S.A. can, together with you, resolve the issue.

4. CATEGORY OF PERSONAL DATA PROCESSED BY TURIMAGRI S.A.

In the course of its activities, Turimagri S.A. processes Personal Data of a significant number of categories of Data Subjects. The Personal Data that Turimagri S.A. collects always depends on the nature of the interaction, but may include the following:

a) Personal Contact Data: first name, last name, postal address, telephone or cell phone number, fax number, email address or other similar contact information.
b) Commercial data for the provision of services: data related to the provision of services or supply of products, billing data, payment data and/or information in the context of responding to any questions, requests or complaints.
c) Payment data: credit/debit card numbers, security code numbers or other related billing information.
d) Account data: How you purchase services, your transaction, billing and support history in the context of the Turimagri S.A. services you use, or any other related information.
e) Demographic data: Country, gender, age, preferred language, general education and work history, as well as, general interest data about your work.
f) Preference Data: Information about the holder’s preferences and interests as they relate to the services and how he or she prefers to receive communications.
g) Social network data: Information shared on social networks in interaction with Turimagri S.A., where transparency is guaranteed through the existence of appropriate privacy policies.
h) IT usage data: User ID, functions, rights, login times, computer name and IP address.

We emphasize that you will not be obliged to share your Personal Data with Turimagri S.A. However, if you choose not to share your personal information, in some cases Turimagri S.A. may not be able to provide the services or products you want, provide certain specialized features or respond effectively to any questions you may have.

5. PURPOSES FOR THE PROCESSING OF YOUR PERSONAL DATA

By reference to the “Purpose limitation principle”, the development and performance of the various activities pursued by Turimagri S.A. mean the existence of a relevant set of purposes for the processing of your Personal Data, such as:

a) Accounting, Fiscal and Administrative Management: customer management, supplier management, administrative management and economic and accounting management;
b) Commercial Activity and Marketing: contact management, client management for the provision of services, marketing activities and opinion polls and surveys;
c) Creation and Analysis of Profiles;
d) Human Resources Management: personnel selection and recruitment;
e) Electronic Communications Management: management of website usage and traffic data retention;
f) Compliance with Legal Obligations: transfer of data to Third Parties.

6. GROUNDS OF LAWFULNESS

By reference to the “Lawfulness Principle”, in the development and conduct of its activities, Turimagri S.A. only processes your personal data when there is a legal basis that legitimizes the processing, namely:

Consent: Turimagri S.A. will only process your Personal Data if you consent to the respective Treatment through a free, specific, informed and explicit manifestation of will, by which you accept, through a declaration (in writing or orally) or an unequivocal positive act (by filling in an option), that your Personal Data be subject to Treatment.

Pre-contractual procedures or performance of a contract: Turimagri S.A. may process your Personal Data if they are necessary, but not limited, to the performance of a contract for the provision of services to which you are a party as an employee, customer and/or supplier, or to carry out pre-contractual procedures at your request.

Compliance with a legal obligation: Turimagri S.A. may process your Personal Data to ensure and guarantee compliance with legal obligations to which it is subject under the legislation of a Member State and/or the European Union.

Defense of vital interests of the Data Subject: Turimagri S.A. may process your Personal Data to ensure the defense of your vital interests, in particular when the same Treatment is essential to your life.

Legitimate Interests: Turimagri S.A., other Responsible Parties or Third Parties, may process your Personal Data provided that such Treatment does not prevail over your interests or fundamental rights and freedoms.

7. TERM OF CONSERVATION OF YOUR PERSONAL DATA

By reference to the “Principle of conservation”, Turimagri S.A. keeps your Personal Data only for the period of time necessary for the execution of the specific purposes for which they were collected. However, Turimagri S.A. may be required to retain some Personal Data for a longer period, taking into account factors such as:

  • Legal obligations, under the laws in force, to retain Personal Data for a certain period;
  • Statute of limitations under applicable law;
  • (possible) Litigation; and,
  • Guidance issued by the relevant data protection authorities.
  • During the period of Treatment of your Personal Data, Turimagri S.A. ensures that they are treated in accordance with this Data Protection and Privacy Policy. As soon as your Data is no longer required, Turimagri S.A. will dispose of it in a secure manner.


8. SHARING OF YOUR PERSONAL DATA

Subcontractors: Your Personal Data may be shared with companies entrusted with the provision of services by Turimagri S.A.. These companies are bound by a written contract and may only process your Personal Data for the purposes specifically established and are not authorized to process your Personal Data, directly or indirectly, for any other purpose, for their own benefit or for the benefit of a third party.

Other Responsible Parties and/or Third Parties: Your Personal Data may be shared internally with other Turimagri S.A. companies, which will comply with the applicable data protection rules according to the purposes assigned to the Processing performed.

At your request and with your consent, your Personal Data may be shared with other entities.

In compliance with legal and/or contractual obligations, Personal Data may also be transmitted to judicial, administrative, supervisory or regulatory authorities and also to entities that lawfully carry out data compilation, fraud prevention and combat actions, market or statistical studies.

9. YOUR RIGHTS AND HOW TO EXERCISE THEM

As the Holder of Personal Data processed by Turimagri S.A., you have the right to access, rectification, limitation, portability, erasure and the right to object to the Processing of Personal Data, in certain circumstances, which may be exercised under the terms of this chapter of the Data Protection and Privacy Policy.

Right to information: You have the right to obtain clear, transparent and easily understandable information about how Turimagri S.A. uses your Personal Data and what your rights are.

Right of access: You have the right to obtain information about what Personal Data Turimagri S.A. processes (if it is processing it) and certain information (similar to that provided in this Data Protection and Privacy Policy) about how that Data is processed.
This right allows you to be aware and confirm that we use your Data in compliance with data protection laws.

Turimagri S.A. may refuse to provide the information requested where to do so would require Turimagri S.A. to disclose another person’s Personal Data or the information would adversely impact another person’s rights.

Right to rectification: If your Data is incorrect or incomplete (for example, if your name or address is wrong), you may ask Turimagri S.A. to take reasonable steps to correct it.
Right to erasure of data: This right is also known as the “right to be forgotten” and, in simple terms, allows you to request the erasure or deletion of your data, provided that there are no valid grounds for Turimagri S.A. to continue using it or its use is unlawful. This is not a general right to erasure, as exceptions are allowed (for example, where such data is necessary for the defense of a right in legal proceedings).

Right to restriction of processing: You have the right to “block” or prevent further use of your Data while Turimagri S.A. assesses a request for rectification or as an alternative to erasure. Where Processing is limited, Turimagri S.A. may still store your Data, but may not use it further. Turimagri S.A. keeps a list of the data subjects who have requested “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 personal data that you have provided to Turimagri S.A. and which Turimagri S.A. processes with your consent and those that are processed by automated means.

Right to object: You have the right to object to certain types of processing, for reasons relating to your particular situation, at any time when such processing is carried out, for the purposes of the legitimate interests of Turimagri S.A. or third parties. Turimagri S.A. may continue to process such data if it can prove “compelling legitimate grounds for the processing which override its interests, rights and freedoms” or if such data is necessary for the establishment, exercise or defence of legal claims.

Right to lodge a complaint: You have the right to lodge a complaint with the competent supervisory authority, the Comissão Nacional de Proteção de Dados – CNPD (National Commission for Data Protection), if you consider that the Processing carried out on your personal data violates your rights and/or the applicable data protection laws

You may at any time, in writing, exercise the rights enshrined in the applicable legislation on the protection of personal data through the email address [email protected]

10. SECURITY OF YOUR PERSONAL DATA

Your Personal Data will be processed by Turimagri S.A., in the context of the purposes identified in this Policy, in accordance with the policy and internal rules of Turimagri S.A. and using appropriate technical and organizational measures to promote their security and integrity, particularly in relation to unauthorized or unlawful processing of your personal data and their accidental loss, destruction or damage.

Without limitation, Turimagri S.A. uses logical and physical security requirements and measures to ensure the protection of your Personal Data by preventing unauthorized access, ensures that information is stored on secure computers in a closed information center and implements control procedures to ensure compliance with Turimagri S.A.’s security policies.

However, since the transmission of information over the Internet is not completely secure, Turimagri S.A. cannot guarantee the security of its Data when transmitted over an open network.

11. CONFIDENTIALITY

Turimagri S.A. recognizes that the information you provide to us may be confidential. Turimagri S.A. does not sell, rent, distribute, or make available commercially or otherwise the Personal Data to any third party, except in cases where it needs to share information with Service Providers for the purposes set out in this Data Protection and Privacy Policy. Turimagri S.A. preserves the confidentiality and integrity of your Data and protects it in accordance with this Data Protection and Privacy Policy and all laws in force.

12. COOKIES

Turimagri S.A. uses cookies to collect information about the use of the website. Whenever you use the website, Turimagri S.A. treats your Personal Data collected through the use of cookies in accordance with our Cookie Policy.
For more information about the use of cookies, we advise you to read and review the Cookies Policy and consult it regularly to check for the most up-to-date versions.

13. CONTACT

If you have any questions or would like more information about how we treat your Personal Data, and what our information security practices are, please feel free to contact us at the following addresses:

Email: [email protected]
Address: R. Latino Coelho, nº1 bloco A3 19esq. 1050-132. Lisbon, Portugal.

14. CHANGES TO THIS DATA PROTECTION AND PRIVACY POLICY

Turimagri S.A. may periodically update this Data Protection and Privacy Policy, as well as any other specific data protection and privacy statement. When making changes to this Data Protection and Privacy Policy, a new date will be added at the end of the Data Protection and Privacy Policy.

May 2022