Privacy Policy

Our Commitment to privacy protection.

Saphety is always committed to comply with the applicable laws related, namely, to Data Protection, Privacy and Information Security, in order to protect your personal data that Saphety may process as Data Processor and with the intent of providing a better customer service and user experience.
For Saphety to be able to provide you with the full range of its services, complete experience on the website, as well as a better customer service and user experience, Saphety will sometimes need to collect and use your personal information.
As such, the goal of this Data Protection, Privacy and Cookies Policy ("Privacy Policy") is to inform and explain the following:

- The type of information that Saphety can collect about you;
- How will Saphety use the information collected about you;
- When will Saphety use your data to contact you;
- If and on which terms Saphety will disclose its data to third parties;
- Your choices and rights regarding the personal data you provide to Saphety;
- The use of cookies on Saphety websites and how you can manage those cookies.

Saphety’s websites include social networking features, including the "share" or "follow" button from Facebook, Twitter, LinkedIn, Google Plus and YouTube.
These features may collect your IP address and the page you are visiting on our websites and may set/install a cookie to allow its feature to run properly. Your interactions with these features are governed by the privacy policy of the company that provides these services.
Our websites also include links to other websites whose privacy practices may differ from Saphety’s practices. If you provide personal data on any of these websites, your personal data will be processed in accordance with the privacy policies of those websites. In this case, Saphety is in no way responsible for the processing of your personal data outside our websites.

1. Who are we
Saphety Level - Trusted Services, S.A. (“Saphety”), a commercial company under Portuguese law, based in Lugar do Espido, Via Norte, 4470-177 Maia, Portugal, registered on the Commercial Registry of Maia under number 507957547, is the company responsible for providing the relevant services and the website www.saphety.com, whereby users and/or customers have access to information regarding Saphety's services and product presentations, as commercialized or delivered over time, and Responsible for the Processing of personal data for the purposes of this Policy. 

2. Collection and Processing of Personal Data 
Your personal information can be requested by Saphety when you subscribe our newsletter, download Saphety’s documentation, request a Saphety contact – namely, for a demonstration or business meeting with Saphety -, registration and participation in events organized by Saphety, and may still be processed within the scope of Saphety's services.
Your browsing in Saphety’s website can also be monitored for statistical purposes.
Saphety may also collect information about your computer hardware and software. This information may include your IP address, browser type, domain names, access times, and referring website addresses. 
The personal data categories Saphety may collect and process for the purposes set out below are as follows:

- Name;
- Email;
- Address;
- Phone number;
- Information about your company, such as your name and position in the company
- IP address;
- Browser type;
- Domain name;
- Access time;
- Reference websites/domain websites;
- Photos, videos and audio recordings (strictly related to your participation in Saphety events);
- Academic education;
- Professional experience.

3. Use and Purposes of the Personal Data Collected 
Saphety can process your personal data to:

(i) provide services and/or perform its social activity, including:

- Provide and carry out services;
- Process and complete transactions, as well as sending related information, including confirmations of transactions and invoices;
- Manage the use of Saphety’s services by its customers, answer information requests and comments, as well as provide customer service and support;
- Send technical alerts, updates, security notifications and general communications to customers;
- Investigate and prevent fraudulent activities, unauthorized access to services or other illegal activities.

The legal basis for such processing shall be (a) the performance of the relevant contract, (b) the fulfillment of a legal obligation to which Saphety is subject, or (c) the need for the legitimate interests pursued by Saphety or a third party.

(ii) communicate with you about products, services, offers, promotions we believe you may be interest or send you our newsletter, if it is in accordance with your marketing communications preferences. However, you can always choose to stop receiving these communications at any time through the means available for this purpose in all the sent communications, by contacting us through the following email: dataprotection@saphety.com or by managing your preferences through the unsubscribe option in the newsletter itself.

For these purposes, Saphety may contact you:
- regarding any Saphety service, activity or online content that has been subscribed, to ensure that Saphety can properly provide the services in question;
- regarding any correspondence that Saphety receives from you or any comments you may communicate to Saphety about Saphety’s products or services;
- regarding any customized Saphety service you are using;
- to invite you to participate in surveys about Saphety’s services (participation is always voluntary);
- to update you on any material changes to Saphety's policies and practices; and
- with the purpose of sending direct marketing communications.

We may adjust the content of the communications addressed to you by Saphety based on the information you have given us.
The legal basis for such processes is the need for the legitimate interests pursued by Saphety or a third party, considering the interest of the parties involved in maintaining business relations and contacts, as well as generating potential commercial relationships.

(iii) manage and advertise events organized by Saphety, including the invitation to participate, registration, participation and internal and external disclosure of the event in question. The legal basis for such processing is the need for the legitimate interests pursued by Saphety or a third party and/or consent (prior consent will be required in case of collection and registration of images, video or audio of the participants in the event).

(iv) ensure that our websites are suited to your needs and to help us create content that we believe you may be interested in, including:

- To manage our websites, including problem solving, data analysis, testing, statistics and surveys;
- To improve our websites ensuring the content is presented as effectively as possible;
- Analyze the use of our websites by customers to provide general statistics, including for trend monitoring, marketing and advertising purposes;
- For the purposes identified when submitting information to Saphety on our websites - for example, to answer to a demonstration request or to provide you the requested information about our services and/or products; and
- As part of our efforts to keep our websites protected.
The legal basis for such processes is the need for the legitimate interests pursued by Saphety, regarding the purposes identified above.

(v) recruitment and selection processes, which includes applications and analysis of CV’s sent or collected, within the scope of the internal selection process according to the needs identified by Saphety.
The legal basis for such processing is (a) the need for pre-contractual arrangements developed at the request of the personal data subject, and (b) the need for the legitimate interests pursued by Saphety to review the applications and submit the candidates for an internal selection process, according to the previously defined criteria.

4. Lawfulness of the Processing of Personal Data
As mentioned, all personal data processing operations carried out by Saphety have a legal basis either (i) on the basis of their consent to the processing of the personal data for the respective purposes, or (ii) is deemed necessary for the execution of a contract with Saphety of which the subject of the personal data is party or for pre-contractual procedures at the request of the latter, or (iii) because the processing is necessary to fulfill a legal obligation to which Saphety is subject, or (iv) because the processing is necessary for the legitimate interests pursued by Saphety or by third parties.

5. Retention Period of Personal Data
Saphety will retain your personal data as long as necessary for the relevant activity or purpose, namely, to provide you with the services in question and in any case respecting any applicable retention period defined by the applicable law.
If you want to change your personal data or request that we stop using it, according to the applicable law, contact us through the following email: 
dataprotection@saphety.com.

6. Cookies Policy 
What are cookies? 
Cookies are small text files stored in your browser when you visit a website. Most websites use them to improve their user experience and the website’s performance.

How does Saphety use cookies? 
Saphety uses cookies to register details about all your current sessions, language preferences, and to collect statistics to optimize the functioning of the website and provide content according to your interests. Some features of the website may not work properly if you do not enable the use of cookies.

What types of cookies does Saphety use? 
Saphety uses the following types of cookies:

– Functional cookies (strictly necessary)
Used to store each session setting, namely, your language preferences.

– Analytical cookies 
Used to measure the website’s speed performance and to collect information related to which pages on the site have more or less views in order to help improve content for all users of the website in general.

– Segmentation cookies 
Cookies that register the user's visit to our website, the pages visited and the links followed.

Saphety websites use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies in a way that allows Saphety to analyze how you use Saphety’s websites. The information generated by the cookies about how the websites are used (including the IP address) may be transmitted to Google and stored by Google, and Google will use the information in question to evaluate the use of the websites by the user, create traffic reports for each page of the websites to the operators of the websites and to provide other services related to the traffic of the websites and the use of Internet. Google may also transmit this information to third parties in compliance with a legal obligation applicable to you or in the case that such third parties treat the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You can disable these cookies by selecting the appropriate preferences in your browser ("browser").

You may find more information about Google Analytics on the following link:
https://www.google.com/analytics/terms
If you'd like to deactivate Google Analytics services, you can do it by using the following link:
https://tools.google.com/dlpage/gaoptout?hl=en

You can find more information, about the cookies used, here:
AdWords Remarketing - https://policies.google.com/privacy
LinkedIn - https://www.linkedin.com/legal/privacy-policy
Twitter - https://twitter.com/en/privacy
Facebook - https://www.facebook.com/legal/FB_Work_Privacy
Google Plus & YouTube - https://policies.google.com/technologies/cookies?hl=pt-PT

How can you manage your cookies?
You can manage your cookies through your cookies preferences or through your browser's features regarding cookies. However, disabling cookies may prevent some services from working properly, affecting, total or partially, the browsing on Saphety’s websites.
You can choose not to activate all the cookies categories (except for the strictly necessary cookies) by accessing your browser's cookie preferences:

Firefox:
Gerir Cookies no Firefox

Chrome:
Gerir Cookies no Google Chrome

Internet explorer:
Gerir Cookies no Internet Explorer

All about Cookies:
www.aboutcookies.org

7. Transmission of Data to Third Parties
Saphety does not transfer your personal data to third parties, except when necessary for the provision of contracted services and/or to fulfill legal obligations applicable to Saphety.
Such transmission to third parties is, in any case, carried out in accordance with the applicable data protection law, and within the scope of legal and established purposes.
Saphety may share your personal data, to the extent strictly necessary, with the following entities:

- Parties involved in the business relationship, including, for the purpose of providing services by Saphety;
- Public entities, within what is necessary to fulfill the legal obligations applicable to Saphety;
- Saphety economic group companies for internal administrative purposes;
- Service providers that provide services to Saphety within the framework of the purposes defined above.

The provision of information or services by Saphety to its users and/or customers, namely, through its websites, may involve the use of subcontracted third party services, which may imply access by those third parties to your personal data.
In this case and whenever necessary, Saphety shall only use subcontracted entities which provide enough guarantees as to the appropriate technical and organizational measures for the processing in question, so that it complies with the requirements of the applicable legislation, and such guarantees shall be established by signed contract between Saphety and each of these third parties.

8. Transmission of Personal Data to Third Countries or International Organizations
Saphety may have to transmit the personal data collected to a third country outside the European Union and not included in the list of countries the European Union considers to comply with the adequate levels of protection of personal data. In this case, Saphety will ensure that such transfers of personal data are performed in strict accordance with the applicable legal standards and that such transfers are the result of the applicable data protection laws, namely, the GPDR.

9. Security of your Personal Data
Considering the most advanced techniques, application costs and the nature, scope, context and purpose of the processing, as well as the risks, of probability and variable severity for your personal data, Saphety and all subcontracted entities shall apply technical and organizational measures to ensure a level of safety appropriate to the risk involved.
Saphety has implemented a set of security procedures to protect your personal data against unauthorized access, use or disclosure.
Saphety guarantees that the personal data provided and stored by Saphety on the servers is in a controlled, secure and protected environment from unauthorized access, use or disclosure.
If Saphety requires to subcontract services from a third party that may have access to your personal data, Saphety’s subcontractors shall take the necessary technical and organizational measures that may be necessary to protect the confidentiality and security of your personal data.

10. Your Rights as the Personal Data Subject
 In accordance with and under the terms of the General Data Protection Regulation ("GPDR"), as the Personal Data Subject and regarding your personal data processed by Saphety, you have the right to request Saphety to access, rectify or eliminate your personal data, the right to limit the processing of your personal data, and the right to the portability of the personal data you have provided to Saphety.
Saphety will make the appropriated efforts, within the scope of its legal obligation, to provide, rectify or eliminate your personal data in Saphety’s archives.
For the exercise of such rights, please contact us through the following email address: dataprotection@saphety.com.
If the request in question is manifestly groundless or excessive, in particular due to its repetitive nature, Saphety shall be entitled to:

a) require the payment of a reasonable fee considering the administrative costs of providing the information or the communication, or taking the requested action; or
b) refuse to comply with the request.

When the process is based on your consent, you have the right to withdraw the consent at any time without compromising the lawfulness of the process made which is based on the previously given consent.
Without prejudice to all communication channels you have available with Saphety, you shall in any case have the right to complain to a supervisory authority.

11. Incident Response
Saphety has implemented an incident management system related to data protection, privacy and security of the information.
Saphety makes every effort to maintain threat detection technologies to help identify and respond to security or privacy incidents (including any personal data breach within the GDPR) without delay, and Saphety is always committed to implement the technical and organizational measures that ensure an adequate level of security regarding the nature and characteristics of the personal data processed by Saphety.

12. Changes to this Privacy Policy
This Privacy Policy may be subject to updates, so we suggest you check it regularly.
In any case, if material or relevant changes are made to this Privacy Policy, i.e., affecting how we would like to process your personal data, you will be clearly notified, namely by email or through a warning when accessing Saphety’s websites.

13. Saphety’s contacts
In order to exercise your rights as a Personal Data Subject or for any matter related to data protection, privacy and information security, you may contact Saphety at the following email address: dataprotection@saphety.com, describing the subject of the request and indicating an email address, a phone contact or an address for reply.

For your information, Saphety's general contacts are the following:
Website: www.saphety.com
Email: info@saphety.com

Check our Declaration of Commitment.