SISTRADE PERSONAL DATA PROTECTION POLICY

  1. Introduction
  2. Who we are
  3. Company identification
  4. For what purposes we use your personal information
  5. How we got information about you
  6. What is the legal basis for processing your data
  7. Your data will be communicated to other parties
  8. International data transfer
  9. Hyperlinks to third-party websites
  10. Personal data storage period
  11. How you can exercise your rights
  12. How we protect your personal data
  13. Modifications to this data protection information
  14. Contact
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1. Introduction
Processing of personal data
At SISTRADE, we are concerned with the security and protection of personal information provided by our customers. Therefore, in order to process your data in a lawful, fair and transparent manner, in accordance with national and European legislation, both in the collection and in any subsequent processing of your personal data, we have updated and adapted our data protection policy, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, known as the General Data Protection Regulation (GDPR) and now in force.
In addition to the principles of lawfulness, loyalty and transparency in the processing of personal data, this Privacy Policy will pay particular attention to the principles of data minimization, accuracy, storage purpose and period limitation to what is strictly necessary, as well as the principles of integrity and confidentiality of information and, in general, to the principle of proactive accountability.
In this document we intend to explain for what purposes we use your personal information, the legitimacy for this processing, that is, the reasons that lead us to carry out such processing, how and why we collect and use your data, your rights, and the processes that we use so that your privacy is protected at all times. By providing us with your personal information and when using our website, we assume that you have read and understood the terms related to the personal data protection that we provide. In any case, we are at your disposal for any clarification that you deem necessary regarding this matter.

2. Who we are
SISTRADE is an international information systems engineering and consulting company, with offices and branches in various countries. SISTRADE has always bet on software for vertical markets, and currently has customers in more than 24 countries on 4 continents. SISTRADE is a company certified in ISO 9001 and NP 4457 standards (Quality and innovation).
SISTRADE has a team specialized in the software development and with knowledge about different business processes. These competencies enable us to develop and implement solutions with real added value in organizations.

3. Company identification
- Company name: Sistrade – Software Consulting, S.A.
- Registered office: Travessa da Prelada, 511, 4250-380 Porto, Portugal.
- Phone: 226153600.
- VAT no.: 504785621
- Website: www.sistrade.com.

4. For what purposes we use your personal information
At SISTRADE we respect privacy, therefore we process the data provided to us by companies that have expressed their desire to receive information about our software solutions products, by companies that acquired our solutions or participated in our promotional activities, all this in order to respond to your requests, to manage the sending of the information and/or products that you have requested, to present offers of products and services from our portfolio and to provide a service with the levels of quality and guarantee expected from us.
In this sense, your business information is processed in order to manage the contractual relations established with us, and the requests directed to us through the different channels that exist at any moment in our offers, for example through the mail, press, websites or applications, telephone, email or in our premises, or stands, and also to channel your suggestions, doubts and complaints to the respective management and resolution. The processing of such data is necessary, and without it will not be possible to maintain the desired relationship between the parties or to respond to your requests.
Likewise, if you do not object, we will maintain the business relationship with you through postal mail, telephone, sms, email, push notifications or other electronic means, so that you are informed of offers and promotions of SISTRADE products and services (www.sistrade.com). You may request and opt at any time to stop receiving our or third-party advertising if you have authorized them. In this case, and in order to be able to respond to your request, the essential data for that request will be included in a listing for the sole purpose of reducing the advertising you receive.

5. How we got information about you
We collect your personal information through a variety of means, namely when you contact us and provide us with your information in order to contact us or to obtain more information about a product or service, and for such a purpose you call us by telephone, register on our website, send us an email, fill out or respond to a questionnaire, participate in one of our fairs, workshops, etc.
Generally, the personal information you give us is limited to your name and surname, job title, company address, business email address, contact telephone number in the company.  
SISTRADE services, promotional offers and web pages are usually directed at companies.

Information we collect from your visits to our website
In each website you access, you will be able to know the existing cookies policy. The information obtained is completely anonymous and cannot be associated to a specific and identified user, except in the cases specifically indicated there.
In general, by using cookies we may collect and store various personal information and non-customized general statistics.
On this website we only obtain and keep the following information about our visitors:
1. The domain name of the internet service provider (ISP) and/or the IP address that gives them access to the network. In this way we can compile statistics about the servers that visit our website more frequently.
2. The number of daily visitors of each section. This allows us to know the areas with the most success and to increase and improve our content, in order that the users obtain a more satisfactory result.
3. The data of those visitors who, voluntarily, submit their forms with requests for information. The sole purpose of this information record is to be able to process within our organization the request received, so that we can then transmit to the user the information requested.

Communication through social networks 
We can also contact you through the different social networks in which we are present.
The information we collect through social networks sometimes includes personal information that is available online and to the public. We always make sure that all the information we use is correctly attributed to its source or that it is made anonymous.
Social networks have their own privacy policies, which we encourage you to read and analyse before sharing your information.

6. What is the legal basis for processing your data
The use of personal data is needed to pursue such formalities arising from commercial and/or contractual relationship with the customers who were interested or who have purchased any of our products or services because without this information we could not provide a proper service. In particular, the prospective offer of products and services is also based on the legitimate interest of the company in keeping its customers informed of the offers, advantages and promotions of its products and services. Of course, one may at any time express the opposition to the use of one’s data for commercial purposes, without affecting the performance of the contract that has been signed..
If you have never had contact with us and wish to be informed of our offers, advantages and promotions you may request and give us your consent by sending us an email to inov@sistrade.com or by calling the Marketing Department at +351226153600.

7. Your data will be communicated to other parties
In some cases, in order to comply with our obligations to you, it is necessary to communicate to third parties the information you have provided us, in order to be able to send you the product or provide the requested service, delivery, transportation, assembly, logistics, collection of payments, etc. 
Likewise, there are companies that provide us with other types of services, such as: information technology (information storage and processing), security services, financial services, auditing services, etc. These third-party companies act as subcontractors of the processing and only have access to the personal information they need to perform such services. In addition, your personal information will be available to the Public and Judicial Administration Authorities for the resolution of possible liability generated from the processing.

8. International data transfer
The personal information we collect is located in Portugal. In case we are contracting services in Cloud Computing, by making international data transfer, we will take the appropriate guarantees to protect your information. About these guarantees you can obtain additional information by sending an email to the address: inov@sistrade.com.

9. Hyperlinks to third-party websites
In the event that we provide hyperlinks to websites that are not operated or controlled by SISTRADE, you will be informed promptly, since SISTRADE does not have any control over such websites, nor is responsible for the contents thereof or even has control how third parties collect and use your personal information. In addition, SISTRADE is not responsible nor makes any kind of statement about the websites of third parties. Usually, these websites have their own privacy policies, in which they explain how they use and share your personal information. We recommend that you carefully review the privacy policies of these websites before using them to ensure that they comply with the way your personal information is collected and shared. 

10. Personal data storage period
We only store your personal information to the extent that we need it to be able to use it according to the purpose which it was collected for, and according to the legal basis for its processing, under applicable law. This way, we will keep your personal information, while there is a contractual and/or commercial relationship between us, and also for the purpose of keeping you informed about our offers, advantages and promotions, whenever you do not exercise your rights of opposition, deletion and/or limitation to the processing of your data.

11. How you can exercise your rights
The rights to your personal information are of your sole ownership and therefore the control over these data is yours. In addition to our duty to ensure that this information is accurate and truthful at all times, your control over your personal data is further ensured by the following rights recognized by law:
- Right to access:: any person has the right to confirm that SISTRADE is processing personal data concerning him or her and to access them.
- Right to rectification and deletion: the data holder has the right to request the rectification of inaccurate data or, if applicable, to request their deletion where, among other reasons, one considers that they are no longer necessary for the purposes for which they were collected.
- Right of objection: under certain circumstances, and for the reasons related to your situation in particular, you can object to the processing of your data. In this case, your personal information will no longer be processed for the purposes to which you have expressed your objection, unless for compelling legitimate reasons, or in the performance or defence of possible complaints, we shall keep them duly blocked during the corresponding periods, as long as legal obligations remain.
- Right to limitation: likewise, the data holder may obtain the limitation of the personal information processing, without prejudice of the storage of information, while proving the accuracy or legality of the data processing, for the exercise or judicial defence of the rights, or until it is ascertained that the legitimate reasons given for processing as a result of the objection prevail over the rights and interests.
- Right of objection to the sending of publicity: in accordance with the current regulations, if you do not wish your data to be processed for the purpose of commercial prospecting, which we consider qualifying as a legitimate interest of our activity; you can communicate this intention to us. In all our communications, we provide you with the information for you to be able to exercise your rights.
- Right to portability: under certain circumstances, the data holder can request the portability of the data that one has provided to us, to another controller responsible for the processing.
- If you have given us your consent for any processing, you can revoke that at any time, without affecting the lawfulness of the processing based on the aforementioned consent when signing the contract and its legal consequences.

You can also exercise your rights free of charge, and you shall have the right to receive a response within the time limits provided for in the data protection legislation in force. To exercise your rights you can choose between the following means:
- Written and signed request, addressed to SISTRADE, Travessa da Prelada, 511, 4250-380 Porto, with the legally admitted proof of your identity.
- Request by e-mail, addressed to the email inov@sistrade.com, with the legally admitted proof of your identity.

However, you may still file a complaint with the National Data Protection Commission, especially if you are not satisfied with the response regarding the exercise of your rights. For more details you can consult the website: www.cnpd.pt

12. How we protect your personal data
At SISTRADE we are committed to protecting your privacy and your personal information by employing appropriate technical and organizational measures, which are periodically reviewed. For adequate protection of your information, we take care of both the physical security of our installations and our servers, and of virtual security, including the implementation of access controls that restrict and manage the way your information and personal data are processed and managed. We also make sure that our staff is properly trained to protect your information and to process it only to the extent necessary. In this regard, and in the interest of privacy, we may deny you the supply of your own data if we do not have a valid proof of identity that proves that we are actually speaking to you or to someone duly authorized by you.

We also want Internet browsing to be secure, and for this, in all e-commerce transactions, we ensure that our operations comply with the principles of:
Authentication, to guarantee the identification of the person with whom we communicate.
- Integrity, to ensure that the content of the communication between the two parties cannot be modified.
- Confidentiality, so that nobody who is not authorised can know the content of the communication.

13. Modifications to this data protection information
We will review and update the data protection information periodically and especially when there are modifications in the legislation or in some of the procedures for processing personal information, indicating the date of the last update, content and date. If we have your email address or mobile phone, we can also inform you of the changes by sending an email. If necessary, we may ask you to renew your consent to confirm that you agree to these changes. 
This data protection information was last reviewed and updated in May, 2018.

14. Contact
If you have any questions, comments or concerns, or if you would like to make a suggestion about how we process your personal information, you can send us a communication to: SISTRADE – Software Consulting, S.A., Travessa da Prelada, 511, 4250-380 Porto or by email to: inov@sistrade.com.