This information is proprietary to Wakaru® Consulting and may not be disclosed without the permission of Wakaru® Consulting. This document is part of Wakaru® Consulting’s management system and Water Wise System®.1.INTRODUCTION OBJECTIVE
This text presents a general overview of how WAKARU® processes personal data at its disposal in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council - General Data Protection Regulation (GDPR) - and other applicable legislation on privacy and data protection, including local legislation supplementing the GDPR, such as the Decree Law Decreto Lei n.º 58/2019. Whenever personal data are required, the use of such data is described in terms of this document and with respect to data protection legislation.
Pólo Tecnológico de Lisboa
Rua António Champalimaud Lote 1 Sala 0.16
+351 210 518 880
(from 9 am to 12 noon and 2 pm to 6 pm) 3. POLICY STATEMENT WAKARU®
Wakaru® is a technology-based company, focused on developing Big Data solutions to manage, analyse and process complex events in real time; the creation of 100% digital customer experience ecosystems; software development services or tailor-made integration, innovation and R&D, talent outsourcing, auditing, and consulting in management systems and information technologies. We leverage our innovation capacity to develop new products with a strong SAP® consulting practice specialized in customer and asset management and, logistics automation. GDPR Definitions
Personal Data - is any information related to the data subject and that allows him/her to be identified.
Data Subject - any identified or identifiable natural person to whom the Personal Data is associated. The natural person may be directly or indirectly identifiable or identified, including by name, civil or tax identification number, location data, online identifiers (such as IP addresses and logs). Identification can also be made through factors of physical, physiological, genetic, mental, economic, cultural, or social identity. The user of the website, applications and digital platforms is considered as Data Holder in relation to company.
Processing- any operation or set of operations which are performed on personal data or on personal data sets, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Processing of Personal Data WAKARU® only collects the personal data considered essential, making the necessary processing according to its purpose.
The collection of your data, including personal data, takes place in the interactions with WAKARU®, namely:
General requests for information;
Customer management process;
Accounting, tax and administrative management;
Compliance with legal and regulatory obligations;
Human resources management process;
Marketing and event management (on-site and/or online);
Information security control;
Other data that are in the documentation delivered to the company or obtained as a result of the relationship established. Depending on the nature of the interaction, and only when necessary, WAKARU® may request certain personal data, such as:
Name, email address, address / location, telephone, mobile phone, citizen / passport card number, physical and digital), date of birth, nationality, marital status, academic qualifications, profession, bank data, and, in general, any documentation and information of the contacts maintained with the client by different means, including marketing campaigns. Data processing for marketing purposes will be done according to the consent option stated by the data subject. Consent must be prior, free, informed, specific and unambiguous, expressed in a written statement, oral or through the validation of an option. The data subject may object to the processing of data for marketing purposes at any time and by any means. Optionally, the data subject may authorize the collection of complementary data that may assist WAKARU® in providing a better and more personalized service. Purpose of Processing Personal Data
The personal data provided by the data subject or generated in relation to the service provided will be processed and stored in a digital way and will be used by WAKARU®. WAKARU® collects and processes the strictly necessary data, which is only requested when related to the purpose in question, and for legitimate purposes, such as:
Provide an adequate and targeted response to information/proposal requests;
Communicate better with the data subject, for relevant issues and only as often as necessary, according to the characterization of their data and their preferences;
Comply with business purposes, namely, statistical data to improve the performance of the various services provided;
Comply with the human resources management assumptions;
Comply with legal or regulatory requirements, which depend on the validity of the certificates of some of the services provided, namely, training actions; services and/or products invoicing. Personal data are processed by WAKARU® only for the period of time necessary to achieve the defined purpose. WAKARU® collects and processes the strictly necessary data, which is only requested when related to the purpose in question, and for legitimate purposes, such as: Human Resources Management. It includes the processing of data necessary for the celebration, fulfilment and termination of a work contract, work time management, absences and holidays, processing of salaries and other benefits or employer obligations, relationship with the Tax Administration and Social Security, promotions and career development, training, evaluation, expenses validation and reimbursement, internal communication and the exercise of disciplinary power. Internal and Business Management. It includes activities such as project planning, work time registration, company assets management, provision of core services to increase the efficiency of operations, conducting audits and investigations, implementing management controls, using internal databases, file management, insurance, prevention, preparation and conflict management. Health and Safety. It includes activities related to health and safety at work, workers’ protection and safeguard of company assets, worker authorization, authentication and access management. Analysis and Management. It includes activities such as internal or external satisfaction questionnaires, merger process management, business unit acquisitions and sales, and the processing of employee data for reporting and analytic purposes. Compliance with Legal Obligations. It includes the processing of personal data strictly necessary for the fulfilment of its legal obligations, such as the disclosure of data following judicial mandates, collaboration with regulators and the defence of the legitimate interests of WAKARU®. Protection of Vital Interests. The processing of personal data for the protection of the vital interests of workers and partners. Recruitment. It includes recruitment activities such as research and selection as well as related activities. In this context, data related to salary processing and human resources management will also be processed. Execution of Contracts. It includes activities such as entering into contracts with clients and partners, as well as communication with third parties involved in contracts (insurance companies, beneficiaries, intermediaries). Development and Improvement of Services. It includes activities necessary for the development and improvement of the services provided by WAKARU®, activity analysis and processing for statistical and scientific purposes. Automated Decisions
In order to justify and execute the business relationship, WAKARU® generally does not use decision-making procedures solely on the basis of automated processing, as provided in the GDPR. If we have or will use this procedure, the data owners will be informed. Access and Sharing of Personal Data
Within WAKARU®, employees who need to comply with contractual/pre-contractual and legal procedures or obligations, or processing for which there is specific, informed and unambiguous consent, have access to the data. The data can be used by WAKARU® in the context of the provision of shared services between partners and for the purpose of internal reporting, always preserving the principle of the lawfulness of the processing. They may also be made available to suppliers and other sub-contractors who, under the terms of the GDPR, can access the data for these specific purposes, but subject to data protection guarantee measures and always acting in the name and on behalf of WAKARU®. In certain circumstances, certain personal data may need to be communicated to public authorities, such as the Working Conditions Authority, Health Regulatory Authority, Courts and Security Forces. The data transfers to a third country (outside the European Union) or an international organisation only occurs if the data subject has given an express authorization for this purpose or if this is mandatory by a legal requirement. Where third-country service providers are required, they will be obliged to comply with the written instructions in order to comply with the level of data protection applicable in the European Union. Data Retention Time
Personal data are kept for different periods of time, depending on the purpose for which they are intended and taking into account legal criteria, the need for and the minimal of conservation time, or for periods legally defined for investigation and prosecution of a criminal or criteria. After the retention period, the personal data is destroyed. Rights of the Owners of Personal Data
WAKARU® guarantees all the rights of the data subjects in relation to the treatment of their data and at any time. To know:
Lawfulness of processing and conditions applicable to consent (Article 6 and Article 7)
Right of access of the data subjects (Article 15)
Right of rectification (Article 16)
Right to erasure (Article 17)
Right to limit processing of data (Article 18)
Right of opposition (Article 21)
Portability (Article 20) In addition, without prejudice to the possibility of complaining to WAKARU®, the data subject may submit a complaint directly to the Data Protection Supervisory Authority using the following channels:
+351 213 928 400
Comissão Nacional de Proteção de Dados | CNPD
Av. Carlos I, 134 – piso 1
1200-651 Lisboa At any time, employees, customers, or prospective customers of WAKARU®, as data subjects, may withdraw previously given consents and exercise any of the aforementioned rights. The exercise of rights can be requested through:
LISPOLIS Pólo Tecnológico de Lisboa
Rua António Champalimaud Lote 1 Sala 0.16
+351 210 518 880 Obligation to Provide Personal Information
In the commercial relationship, data subjects will have to present the personal data necessary to establish and create a commercial relationship and to fulfil the contract and contractual obligations and diligences, as well as those legally required to collect. Without these data, WAKARU® will generally refuse to conclude the contract or, furthermore, it will not be able to maintain the contract and have to resolve it. Security of Personal Data
WAKARU® protects your personal data against destruction, loss, accidental or unlawful changes and unauthorized disclosure or access.