Associação Fraunhofer Portugal Research (hereinafter referred to as "Fraunhofer Portugal") made the commitment to comply with the obligations imposed by the new General Data Protection Regulation, established by the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “GDPR”). This privacy and personal data protection policy (hereinafter referred to as “Policy") is approved with the aim to reinforce the organisation's commitment and respect towards the privacy and personal data protection regulation.
This Policy applies exclusively to personal data treatment by Fraunhofer Portugal.
This Policy regulates the treatment of personal data of users (hereinafter referred to as "User" or "Users"), collected in the course of the activities, developed by Fraunhofer Portugal, as entity that determines the purposes and means of the processing of personal data (“Controller”).
The providing of personal data involves knowledge and acceptance of the conditions present in this Policy.
For the purposes of this Policy, '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.
Responsible for the personal data treatment
The Controller is Fraunhofer Portugal who, in this context, decides what data to be collected, treatment means to be used, data storage period and purposes for collection.
Personal Data collection
Fraunhofer Portugal collects personal data directly, by telephone, in writing or through computer systems. Collected personal data are treated either by non-automatised means (e.g. manual files), or digitally complying with personal data protection law, being stored in specific databases created for that purpose. Under no circumstances shall collected data be used for any other purpose than the one for which consent has been given by the data subject or when required by law.
Lawfulness of processing personal data
The processing of personal data depends on the legitimate and lawful conditions for that processing as well as the compliance with the proportionality principle lato sensu.
Specifically, any treatment of personal data at Fraunhofer Portugal will only take place as long as:
> The data subject has granted the corresponding consent;
> It is necessary for pursuing legitimate interests;
> It is necessary for the performance of a contract or for the compliance of any legal obligation to which the Controller is bound;
> It is necessary for the protection of the data subject’s or any other natural person`s vital interests;
> It is necessary for the pursuit of the legitimate interests of the Controller or third party to whom the data are disclosed, as long as the interests or rights, freedoms and guarantees of the data subject do not prevail.
About the purpose of personal data treatment
Information about personal data treatment is given to the data subject at the time when personal data are collected. If personal data have been obtained from another source, the information will be given within a reasonable time-line, depending on the circumstances.
Personal data treated by Fraunhofer Portugal can be legitimately sent to third parties when the compliance with the purpose of the treatment is verified.
Whenever personal data are likely to be legitimately transferred to another recipient, the data subject shall be previously informed. The data subject can demand that his/her personal data are not transferred as long as it does not harm any legitimate interest of any party involved or the public interest.
Whenever Fraunhofer Portugal has the intention or need to treat personal data for any other purpose than for which the data have been collected, it shall previously provide to the data subject the necessary information about that purpose and any other necessary information. In case it is not possible to inform the data subject of the source of the personal data that Fraunhofer Portugal holds, the data subject shall be given all existing information about that same source.
Personal data storage period
The period during which the data is stored varies according to its treatment purpose. Personal data will be kept for a period of 8 years as from the date of the data collection, unless another storage period derives from the applicable law.
In accordance with the applicable law, the User reserves the right to, at any time, access his/her personal data, as well as to change, delete, limit the data treatment, data portability, or object to the data treatment.
Pursuant to the terms set out in the applicable law, the User has the right to withdraw his/her consent for data treatment for the purposes indicated previously, through the means listed above. However, this does not invalidate the data treatment that has already been done until that date, based on the prior consent given.
For the use of any of the above mentioned rights, the User must submit a written request to the following email address: firstname.lastname@example.org.
Why do we collect data
Based on each situation and only when necessary, Fraunhofer Portugal may request some personal data, such as: name, email, address/place, phone number, id / tax number, date of birth, gender, nationality, education, employment status.
Fraunhofer Portugal collects and processes the personal data that are strictly necessary and that are requested for that specific purpose, in accordance with the consent given and for legitimate purposes such as:
> To provide an appropriate and targeted response to the information and proposal requests;
> To better communicate, for relevant issues and only as often as necessary, according to your data characterisation and preferences.
Fraunhofer Portugal may communicate your personal data to third party entities, ensuring that those personal data are only and exclusively used for the compliance of the indicated purpose.
When applicable, your personal data will be shared with:
> Partner entities for purposes of activity execution as included in the collaboration agreements;
> Regulatory Entities for verification of the compliance of activities performed by Fraunhofer Portugal;
> Public Entities.
Data may be managed by a reliable service provider, hired by Fraunhofer Portugal (“Processor”). The Processor will treat the data exclusively for the defined purposes and in compliance with the instructions set by Fraunhofer Portugal, in strict compliance with the applicable laws on personal data protection, data security and other applicable rules.
Fraunhofer Portugal does its best to protect the User`s personal data against unauthorised access. For this purpose, it uses security systems, rules and other procedures in order to ensure the protection of personal data, as well as to prevent unauthorised access to data, data misuse, leak, loss or destruction.
Notwithstanding other administrative or judicial appeals, the User has the right to submit a complaint to the competent authority in accordance with the law, in case he/she considers that his/her data treatment by Fraunhofer Portugal goes against the legal regime in force at any time.
Questions and suggestions
The User may contact Fraunhofer Portugal for any question related to his/her personal data treatment and exercise the rights given by the applicable law and, in particular, referred in this Policy, through the following contacts:
Associação Fraunhofer Portugal Research
Rua Alfredo Allen, 455/461, 4200-135 Porto, Portugal
Telefone: + 351 220 430 300
Fax: +351 226 005 029
Last update 14/06/2019