PT EN ES FR DE IT RESERVED AREA Privacy and Protection of Personal Data Policy Customers / Suppliers INVESTWOOD’S Commitment INVESTWOOD respects your privacy and undertakes to protect it. Protecting privacy and personal data is an essential commitment of INVESTWOOD in relation to our Customers (“Customers”) and Suppliers (“Suppliers”), its services and products. The Privacy and Protection of Personal Data Policy is applied generically to the processing of personal data supplied by the users who visit this website, namely the data collected through forms, documents or other means of contact with INVESTWOOD. The information supplied to us, including information sent through our Internet site, by e-mail or any other means, shall be processed with the utmost confidentiality and in compliance with applicable European or national law. Only personal data required for the purposes for which they are collected shall be requested, namely for processing orders, deliveries and the respective technical and business contacts, as well as for other legitimate reasons in the business relationship between the two parties. Customers/Suppliers may also actively authorise the use of the personal data previously supplied or other data provided or modified for other duly identified purposes, such as for sending newsletters or other kinds of commercial contacts. INVESTWOOD may process your data to send you information about its products and services. This data processing will be carried out only after obtaining your consent. If you grant this consent, you shall receive marketing information by e-mail. If you do not supply your personal data (name and e-mail) INVESTWOOD cannot send you commercial information. You may oppose this processing of data at any time. Data shall be stored for this purpose until the data subject exercises his/her right to opposition. INVESTWOOD recommends reading this Privacy Policy and the respective updates. If the Privacy Policy is modified, the date of the last alteration, available at the end of this page, is also updated. If the alteration is substantial, a notice may also be put on the website. The Privacy Policy, and the processing of Personal Data, are governed by the applicable laws of the Republic of Portugal. Any litigation should be submitted exclusively to the Lisbon district judicial courts, notwithstanding the imperative legal regulations that are applicable. Data controller and data protection officer The controller in charge of collecting and processing your personal data is INVESTWOOD – ESTUDOS E CONSULTORIA EMPRESARIAL, S.A. (abbreviated to INVESTWOOD), a commercial company registered at Lisbon Commercial Registry Office under the single registration and tax number 504603183, with share capital of EUR 600,000.00, with head office at Avenida Infante Dom Henrique, no. 337, 3º. Piso, 1800 – 218 Lisbon, which provides the service or supplies the product / or who acquires the service or product from you and within this scope decides, in compliance with the current laws, what data are collected, the processing means and the purposes for which the data shall be used. Personal data, personal data subjects and personal data categories What are personal data? Personal data means any information, of any nature and in any form, relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, such as a name, an identification number, location data, an online identifier or other factors that enable the identification of that natural person. Who are the owners of the personal data (data subjects)? Customers/Suppliers or natural persons to whom the data pertains and who use the INVESTWOOD services or products, or supply services or products to INVESTWOOD. Potential customers are those who are the target of INVESTWOOD advertising campaigns or promotions, and who request information about products and services commercialised by INVESTWOOD and provide personal data for this purpose voluntarily or upon request from INVESTWOOD. INVESTWOOD actively protects personal data and respects its Customers’ rights. Why and how are the Personal Data collected? When visiting our site, you can supply us with your Personal Data. Therefore, it is likely that INVESTWOOD collects your Personal data using the following means: When you navigate through our site (i.e. technical information such as IP addresses or logs collected through cookies or similar technologies); When you contact the customer care service or upload information in your contact with us (e.g. complaints, suggestions or information); When you establish a relationship with us as part of Investwood’s business activity; When you subscribe to the INVESTWOOD newsletter; When you take part in a competition, marketing programme, test or survey; When you apply for a job; When you leave a comment or image on our social network pages; When you send us personal information in another way. The information collected may be processed within the commercial relationship between INVESTWOOD and the Data Subject, in compliance with the regulations and/or laws that protect the rights, interests, property and security of INVESTWOOD, its employees or other people the company collaborates with. What categories of personal data do we process? PERSONAL DATA CATEGORIES IDENTIFICATION Name Identification document number, when indispensable Tax identification number Customer number CONTACTS Address Telephone number E-mail address PROFILE Country of Residence ELECTRONIC INTERACTIONS IP address Device Identifiers Cookies Grounds, Purposes and Duration of the Personal Data Processing For what reasons may INVESTWOOD process your personal data? Consent: when you grant your express and prior consent – in writing, verbally or upon validation of an option – and provided this consent is voluntary, informed, specific and unequivocal. Examples of granting your consent are for the delivery of direct marketing messages, profiling, sharing data with other entities; or Implementation of a contract and pre-contractual formalities: when personal data has to be processed to complete, implement and manage a contract made with INVESTWOOD, such as for information requests, preparation of a proposal for service provision or sale of merchandise, management of contacts/complaints, billing/collection/payments; or Compliance with legal obligations: when the processing of personal data is necessary to comply with a legal obligation that INVESTWOOD is subject to, such as communication of data to police, judicial, taxation or regulatory authorities; or Legitimate interest: when the processing of personal data comprises a legitimate interest of INVESTWOOD or a third party, such as to improve the quality of service, detect fraud or when the reasons for its use take precedence over the rights of the data subjects. For what purposes and for how long will INVESTWOOD process your personal data? Your personal data shall be processed by INVESTWOOD only for as long as required to carry out the defined purpose, or depending on what is applicable, until you exercise your right of opposition, right to be forgotten or you withdraw your consent. After the respective storage term has elapsed, INVESTWOOD shall erase or anonymise the data whenever they no longer need to be stored for any valid purpose. CATEGORY OF PURPOSES MARKETING Marketing or sale of new services or products CUSTOMER MANAGEMENT AND SERVICE PROVISION Management of contacts, information or requests Management of complaints Management of billing, collection and payments ACCOUNTANCY, TAX AND ADMINISTRATIVE MANAGEMENT Accountancy, billing Management of commissions Tax information, including delivery of information to the tax authorities LITIGATION MANAGEMENT Judicial and extrajudicial debt collection Management of other conflicts PHYSICAL CONTROL SECURITY CCTV of premises What are the time periods for the processing and storage of personal data? INVESTWOOD processes and stores your personal data in line with the purposes for which they are collected. In certain cases, the law requires the processing and storage of data for a minimum period of time, namely for 10 years for data needed to inform the Tax Authorities for accountancy or tax purposes relating to commercial bookkeeping, and 7 years for the purpose of fighting against money laundering and financing of terrorism. INVESTWOOD will process and store your personal data for the terms its contractual relationship with you is in force. However, when no specific legal obligation is in place, the data shall be processed only for the period needed to comply with the purposes for which they were collected and stored, and always in compliance with the law, guidelines and decisions of the CNPD (National Data Protection Authority). With respect to CCTV on its premises, INVESTWOOD shall only store the images and respective personal data for a maximum of 30 days. INVESTWOOD can keep other personal data for longer periods than the contractual relationship, whether based on your consent, or to ensure the rights and duties related to the contract, or owing to legitimate interests, but always for the period strictly necessary to carry out the respective purposes and in accordance with the guidelines and decisions of the CNPD. Examples include contacts for marketing and sales purposes, storage of data within the scope of billing complaints, exercising guarantees or pending judicial litigation. Form and moment of personal data collection When and how do we collect your personal data? We collect your personal data upon when you grant your express consent to do so, or when you acquire INVESTWOOD services or products or you supply services or products to INVESTWOOD. The data may be collected verbally, in writing or through the INVESTWOOD website. Your personal information may also be collected from other sources, namely our agents / brokers, who are equally responsible for protecting the data and the security of the information. Rights of the personal data subjects What are your rights? Right of Access – right to obtain confirmation as to which personal data are being processed and information about them such as the purposes of the processing, the terms for which they will be stored, among others. Right to Rectification – right to request rectification of your personal data that is inaccurate or request that incomplete personal data be completed, such as the address, NIF (tax number), e‑mail, telephone contacts, or others. Right to Erase data or “right to be forgotten” – right to erase your personal data, provided there are no valid reasons for their storage, such as cases in which INVESTWOOD has to store the data to comply with a legal requirement or because a judicial process is ongoing. Right to Portability – right to receive data that you supplied to us in commonly used and machine-readable format or request for direct transmission of your data to another entity that will be the new controller of your personal data, but in this case only if technically possible. Right to Withdraw Consent or Right to Opposition – right to opposition or to withdraw consent, at any time in relation to the data processing, such as in the case of processing data for marketing purposes, provided there are no legitimate interests that prevail over your interests, rights and freedoms, such as upholding a law in a judicial process. Right of Limitation – right to request limitation in the processing of your personal data, in the form of: (i) suspension of the processing, or (ii) limiting the scope of processing to certain categories of data or processing purposes. Right to complaint – right to lodge a complaint to the supervisory authority, the CNPD, or to INVESTWOOD itself. How can you exercise your rights? You may exercise your rights free of charge, unless it is an evidently groundless or excessive request, in which case a reasonable fee may be charged to cover costs. In order to exercise your rights, please visit INVESTWOOD’S head office at the following address: Avenida Infante Dom Henrique, no. 337, 3º. Piso, 1800 – 218 Lisbon. Exceptionally and in relation to withdrawing your consent/opposition, whereby the consent in question may have been provided digitally, this right may be exercised using the e-mail address shown below. All requests shall be answered within a maximum of 30 days, unless it is an especially complex request. With regard to exercising of these rights, the controller as regards data protection is INVESTWOOD, to whom the respective request should be presented using the following e-mail address: geral.rgpd@investwood.pt. You also have the right to make a complaint to the National Data Protection Authority https://www.cnpd.pt/ Transmission of Personal Data Based on your consent, your data may be disclosed to other companies belonging to the INVESTWOOD group for the purposes of institutional communication. The INVESTWOOD Group is made up of, directly or indirectly, the following entities: INVESTWOOD – ESTUDOS E CONSULTORIA EMPRESARIAL, S.A., VIROC PORTUGAL-INDUSTRIAS DE MADEIRA E CIMENTO S.A., VALBOPAN-FIBRAS DE MADEIRA, S.A. and I.F.M. – INDÚSTRIA DE FIBRAS DE MADEIRA, S.A., as well as any entity in whose share capital INVESTWOOD gains a controlling position of, together referred to as “INVESTWOOD Group”. Your data may be transmitted to subcontractors for them to process on behalf of INVESTWOOD. In this case, INVESTWOOD shall take the contractual measures required to guarantee that the subcontractors respect and protect the personal data of the Customer / Supplier. These companies are supplied with only the personal data necessary to provide the service in question. The personal data may also be accessed by INVESTWOOD’S internal and external auditors, with a guarantee that they shall be kept confidential and shall not be used for purposes other than the auditing. Your data shall be processed inside the European Union area. The data may also be transmitted to third parties – entities unconnected to INVESTWOOD or the subcontractors – if the data subject grants consent to do so, or entities to whom the data have to be communicated by law. Security and Confidentiality We make every effort to keep your data safe, implementing appropriate security measures to ensure the protection of your personal data and prevent access to non-authorized people. We submit our security policies and systems to regular analyses to guarantee that the data are safe and protected. However, the transmission of information through the Internet is not completely safe, and we cannot absolutely guarantee the security of the information transmitted through our site. We also respect the confidentiality of your information. As such, we shall not sell, distribute or in any way commercially supply your information to any third party. INVESTWOOD undertakes to keep your information confidential in line with this Privacy Policy and applicable laws. Cookies Policy What are cookies? “Cookies” are small software tags that are stored in your computer through the browser, retaining only information related to your preferences, not including, as such, your personal data. What are Cookies for? Cookies are used to help determine the usefulness, interest and number of times you use websites, allowing for faster and more efficient navigation, eliminating the need to repeatedly enter the same information. What kind cookies are there? Two kinds of cookies may be used: Permanent cookies – cookies that are stored at the browser level on your device (PC, mobile phone or tablet) and are used whenever you make a new visit to one of our websites. They are generally used to direct navigation to the user’s interests, allowing us to provide a more customised service. Session cookies – temporary cookies that remain in your browser’s cookie file until you leave the website. The information obtained by these cookies is used to analyse traffic patterns on the web, allowing us to identify problems and provide a better browsing experience. What are the purposes of the cookies we use? Strictly necessary cookies – Allow you to browse the website and use its applications, as well as access secure areas of the website. Without these cookies, the services you have requested cannot be provided. Analytical cookies – Used anonymously for the purpose of creating and analysing statistics, in order to improve the functioning of the website. Functionality cookies – Store the user’s preferences regarding the use of the website, so that it is not necessary to reconfigure the website each time you visit it. Third-party cookies – Measure the success of applications and the effectiveness of third-party advertising. They can also be used to customise a widget with user data. Advertising cookies – Direct advertising according to the interests of each user, and in addition, they limit the number of times a user sees an advertisement, helping to measure the effectiveness of advertising and the success of the website organisation. How can you manage cookies? All browsers allow the user to accept, refuse or erase cookies, namely by selecting the appropriate settings on the respective browser. The cookies can be configured on the “options” or “preferences” menu of your browser. It is pointed out, however, that when disactivating cookies, you may prevent some web services from working properly, affecting the navigation on the website partially or totally. Notification of Security Breaches All security breaches that put the data subjects’ rights at risk shall be immediately reported to the respective authorities, as well as to the data subjects themselves. Changes to the Privacy Policy INVESTWOOD reserves the right, at any time, to make adjustments or changes to this Privacy Policy, and these changes will be published on this website and communicated as INVESTWOOD deems appropriate. Lisbon, 1st June 2020. CORPORATE CONTACTS NEWS DOCUMENTS PRIVACY POLICY TERMS & CONDITIONS © INVESTWOOD 2020, ALL RIGHTS RESERVED. OFFICIAL WEBSITE SOCIAL NETWORKS