APREN – Associação Portuguesa de Energias Renováveis, is a non-profit association, established in October 1988, with the mission to coordinate and represent common interests of its Associates concerning the promotion of Renewable Energies on the electricity sector.
In APREN we are committed to only process your data to purposes clearly defined and, at the same time, we have adopted several security measures, technical and organizational, to guarantee the protection of personal data, against its distribution, loss, unlawful use, amendments, unauthorized process or access, or any other way of illicit processing of personal data.
1. Data Controller
APREN - Associação Portuguesa de Energias Renováveis with registered office in Av. Sidónio Pais nº18 r/c Esq. 1050-215 Lisboa – Portugal, is the controller, i.e., the entity that defines which data is collected, which means are used for the processing of your personal data and to which purpose is it processed.
If you wish to clarify any kind of information or present a complaint, you can do it to the following email address: firstname.lastname@example.org.
APREN also informs you that you have the right to present a complaint to the supervisory authority Comissão Nacional de Proteção de Dados (CNPD) concerning the processing of your personal data by APREN.
2. Personal Data, data subjects, data categories and means of collection of personal data
2.1. What is personal data?
By personal data we mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, 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 a natural person.
2.2. Who are the data subjects?
Any interested, single person, to whom the data concern, and that enjoys, or intends to enjoy of the services made available by APREN.
The representative/employee or point of contact of our Associates, in case of collective persons, within the scope of APRENs’ activity.
2.3. Which data categories are processed in APREN?
Identification data: see examples below.
Personal and Contact Information: Civil and/or fiscal identification data, data needed for the payment of the services, address, date of birth, mobile number and email.
2.4. How and when is your personal data collected?
APREN collects your personal data:
- To process information requests;
- To send you information and invitations concerning events that might be of your interest (newsletter and brochures);
- To acquire knowledge about our associates and users, with the purpose to improve the website and to adequate its content to the purposes defined.
In some cases, it will be mandatory to give us certain personal data and, in that case, if you don’t provide us with such data or such is incomplete, APREN won’t be able to provide the service requested. We will inform you of the mandatory nature of the data, when necessary.
The personal data collected is informatically processed within the strict compliance of the adequate legislation regarding protection of personal data, being stored in specific data basis, created for such purpose and, in any situation, the data collected will not be used to other purpose than the one consented.
3. Processing children personal data
Where the child is under 18, processing personal data is only lawful when and if the consent is given by the holder of parental responsibility over the child or by his/her legal representative.
4. Legal Basis, Purposes and Duration of the Process of Personal Data
The Legal basis for processing personal data in APREN are the following.
- Consent: your personal data may be processed by means of a freely given, specific, informed and unambiguous indication of your, the data subject, wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her, by APREN.
- Necessary for the performance of a contract: your personal data may be necessary for the performance of a contract to which you are a part of with APREN, namely in order to clarify doubts and to execute and manage the relation between APREN and the associate.
- Compliance with a legal obligation: your personal data may be necessary for the compliance with a legal obligation to which the controller, APREN, is subject.
- Legitimate interest: your personal data may be needed for carrying out certain activities by APREN, notwithstanding when your privacy and data protection rights prevail.
APREN will process your personal data, according to the following (legal bases and purposes):
- Consent: APREN processes personal data of anyone that is interested, non-associates, to the activities of the association on the basis of consent, in order to promote events, actions, training, conferences and other activities.
- Pre-contractual diligencies or for teh eprformance of teh contract compliance with legal obligations: APREN processes personal data for the purposes of celebrating, executing and managing the contract signed between APREN and the associate.
- Legitimate Interest: When your personal data is needed for the compliance with legal obligations to which APREN is subject, your data will be transmitted to administrative and fiscal entities, namely for purposes of invoicing, answering and solving eventual complaints registered in the Complaint Book, among others.
APREN may process personal data on the basis of legitimate interest in order to manage in a more efficient way its attributions as well to answer contact requests by non-associates, among others.
When APREN associates are collective persons and, in order to fulfil its statutory obligations, APREN needs to collect personal data (name, email and mobile number) of the representative or employee of such company, for the exclusive purpose of carrying out APREN attributions.
In such case, the associate, whether collective or individual person, must ensure that the data collected of its representatives and/or employee are collected and transmitted to APREN lawfully, based on one of the lawful basis of process. It must also ensure that the data subject, the representatives or employee, is completely informed about the process of his/her personal data.
4.1. Period for which the personal data will be stored
APREN will keep your personal data only during the period strictly necessary for the purpose by which they were collected.
In some cases, legislation provides for a mandatory deadline to store the data, namely, data that needs to be communicated to the Tax Authority, which will be stored for 10 years, according to the applicable law.
APREN will also store your personal data during the period that you keep a relation within the scope of our activities until such is ceased. However, we can keep your personal data for longer periods than that of the duration of the service provided, based on your consent, to guarantee rights and duties linked to the service or if there’s a legitimate interest of APREN, always respecting the adequate period for the purpose of the collection of such data.
When there’s no legal storage period defined, your data will be processed only during the period needed for the purpose of its collection and also while there is a valid legitimate interest of APREN to keep such data.
As a general rule, your personal data, when needed for purposes of marketing, will be stored for a period of 5 years, counted since the collection of your consent or from the last contact made with you (according to which happens latest) and only if you don’t withdraw your consent. Once reached the maximum deadline defined, your personal data will be rendered anonymous in an irreversible way, which can be kept by APREN, or safely destroyed.
5. Transfer of personal data
APREN guarantees to only transfer your personal data when deemed necessary for the purposes described above, namely for the provision of services as requested by you. APREN may share your personal data, fur such purpose, with other companies, in order to assure the adequate provision of our services.
Companies that provide services to APREN, are contractually subject to the same terms and conditions for processing personal data. Such entities are responsible for the implementation of the adequate security measures as enshrined in the GDPR.
APREN may transfer your personal data to event planning companies and to administrative and fiscal authorities, only when deemed necessary to the development of the activities carried out by such entities.
Your personal data may also be transferred to entities to which the data have to be legally communicated, for example, the Tax Authority. Personal data won’t be transferred to entities outside of the European Union territory.
6. Links to other websites
7. Rights of the data subject
APREN guarantees the applicability of all the rights of the data subject as prescribed in the GDPR and in the national legislation.
- Right to access: You have the right to obtain, from APREN, the confirmation that your personal data is or not subject of processing and, if such is the case, the right to access to your personal data and to the information concerning such processing. For example, you may request an exact copy of your data compilation and request additional information about the process of your data.
- Right to rectification: You have the right to obtain, within due time, by APREN, the rectification of your inexact personal data, namely, the right to correct or complete it.
- Right to erasure (“Right to be forgotten”): You can request the erasure of your personal data, by APREN, within due time, as long as: your personal data is no longer necessary for the purpose that motivated its processing; when you withdraw your consent and there’s no other valid ground for its storage; when you oppose to the treatment and there’s no legitimate interest prevailing by APREN, or in other situations stipulated in the GDPR.
- Right to Portability: You have the right to request and receive your personal data collected by APREN, in a structured format, of current use and of automatic reading, as well the right to transfer such data to any other controller (if technically possible) without APREN preventing it, and if the process is based on consent or in a contract, and if the process is done by automated means.
- Right to withdraw Consent: You can, at any time, change your consent, limit it to certain types of processing or to withdraw it. However, withdrawing consent does not compromise the legality of the processing based on your previously given consent.
- Right to object: You can object, at any time, to the processing of your personal data, unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Also, you have the right to object, at any time, to the processing of your personal data for direct marketing purposes. In this case, APREN will immediately cease the processing for such purpose.
- Right to the restriction of processing: You have the right to obtain, from APREN, the restrictions of the processing of your personal data, namely if the accuracy of the personal data is contested for you, in a period that enables APREN to verify the accuracy of the personal data, when APREN no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, as well in other cases as stipulated in the GDPR.
- Right to not to be subject to a decision based solely on automated processing: APREN does not make decisions based on automated processing. Still, you have the right to not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects the data subject.
7.1. Exercise of your rights
You can exercise your rights, with no charges applicable, except if it’s a manifestly excessive and an unfounded request which, in such case, will be charged a fee adequate to the costs of your request.
APREN will answer to your requests within 30 days max., except when such request is to be considered complex.
You can exercise your data subject rights to:
- Letter: Av. Sidónio Pais nº18 r/c Esq. 1050-215 Lisboa, Portugal
- E-mail: email@example.com
- Phone: (+351) 213 151 621
Still, and if you’re not satisfied with the answer given to you after the exercise of any of the rights mentioned above, you have the right to present a claim to the CNPD.
8. Procedural and Technical Security measures
APREN has adopted several security measures, technical and organizational, in order to guarantee the protection of personal data, against its distribution, loss, unlawful use, amendments, unauthorized process or access, or any other way of illicit processing of personal data.
APREN uses adequate technology to protect your personal data of unduly uses, guaranteeing that only authorized persons have access to your data and that eventual APREN partners will deal with your personal data in strict confidentiality. The storage and remitting of your data through Internet will be safeguarded by updated technological means.
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