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Privacy Policy

Personal Data Protection Policy

1. introduction

Wellow™ respects the privacy and protection of personal data, including that of our candidates, employees, trainees and trainers in development projects, users of our websites and social media, as well as suppliers and customers and, in the case of legal entities, their representatives.

The data provided by the different users are treated confidentially by Wellow™ in accordance with the provisions of Law 58/2019 of 8 August, the recommendations and directives issued by the National Commission for Data Protection and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

The monitoring of compliance with this Policy will be ensured through the measurement of control evaluation indicators and/or audits (internal or external), at regular intervals or when significant legislative or regulatory changes occur.

Wellow™ undertakes to respect the best practices in the field of security and protection of personal data, and to that end has approved a program capable of ensuring the protection of the data provided to us by all those who, in any way, have a relationship with it.

This Privacy Policy applies to the collection and processing of personal data by Wellow™ and is intended for the general public and sets out obligations for all employees.

2. Definitions

Personal Data - All information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, electronic identifiers, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special Categories of Personal Data - Personal data revealing a natural person's racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health or data concerning sex life or sexual orientation.

Treatment - It is the operation or set of operations performed on personal data or on sets of personal data, by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction.

Responsible for Treatment - The natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for his nomination may be provided for by Union or Member State law.

Personal Data Breach - A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.

Subcontractor - It is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Third - It is a natural or legal person, public authority, service or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorised to process the personal data.

Control Authority - An independent public authority established by a Member State.

CNPD - National Data Protection Commission.

3. Collection and Processing of Data from the Data Subject

This Policy applies to all personal data of users that are collected by Wellow™ for (i) recruitment and selection activities, as well as all issues associated therewith including the dissemination of new job offers, professional training and institutional information, (ii) information to customers and potential customers (iii) information on the existence of promotions or marketing campaigns, (iv) contractual or pre-contractual management (whether of a labour, commercial or other nature) or (v) to comply with legal obligations. As part of the activities developed by Wellow™, users may be contacted for the purposes described above.

The types of personal data collected, processed and stored by Wellow™ are those necessary to carry out (i) recruitment and selection processes for employment and training opportunities or those necessary to fulfil other requirements when acting as an employer or employment agency, (ii) the provision of services to clients, on an outsourcing or other basis, and (iii) the fulfilment of legal, contractual and pre-contractual requirements arising from the respective activity.

Such information may include:

  • Full name
  • Contact details (address, telephone number, e-mail address)
  • Date of birth
  • Driving licence number and details
  • Academic and professional training qualifications
  • Professional experience and skills
  • Professional credentials, certificates or licences
  • Membership of professional organisations
  • Any other information contained in the curriculum
  • Citizenship status and work permit
  • Data related to health or disabilities
  • Information from and related to public access profiles you have created on employment-related social media platforms and job portals (such as LinkedIn, Facebook, Sapo Emprego or Indeed, among others)
  • Information collected by professional reference check
  • Career management interests and preferences
  • Employee, customer and/or supplier registration
  • User ID and password or PIN, if registering via the Wellow™ website.

Additionally, Wellow™ may request types of personal data deemed "sensitive":

  • National ID or tax number/social security number
  • Financial or bank account details
  • Information related to tax situation
  • Criminal record information
  • Information on health insurance and pension plans
  • Health data (e.g. concerning medical examinations or accidents at work)
  • Trade union membership
  • Information contained in the employee's Wellow™ personnel file, such as performance reviews, disciplinary action and payroll processing
  • Finally, interactions with Wellow™ mobile and web applications may result in the collection, processing and storage of geolocation data
  • Other information you may provide to us, for example through surveys, interactions with social profiles (LinkedIn, Facebook, Instagram, Twitter, Youtube, among others), as well as through other channels used to contact Wellow™.

The provision of this type of information will be voluntary unless required by law. If it is not provided, this will not prejudice your employment or training opportunities, for example.

4. Subcontracted Entities

When processing the data of the data subject, Wellow™ uses or may use third parties subcontracted by it to process the data of the data subject on its behalf and in accordance with its instructions, in strict compliance with the provisions of the law and this Privacy Policy.

These subcontracted entities shall not transmit the data of the data subject to other entities without Wellow™ having previously given written authorisation for that purpose, and they are also prevented from contracting other entities without authorisation for that purpose.

Wellow™ undertakes to subcontract only entities that provide sufficient guarantees of implementation of appropriate technical and organisational measures, in order to ensure the defence of the rights of the holder.

All subcontracted entities shall be bound by a written agreement in which the subject matter, duration of processing, nature, purpose of processing, type of personal data, categories of data subjects and rights and obligations of the Parties are regulated.

When collecting personal data, Wellow™ provides the data subject with information about the categories of subcontractors that may carry out data processing on behalf of Wellow™.

5. Data Collection Channels

Wellow™ may collect data directly (i.e., directly from the data subject) or indirectly (i.e., through partner entities or third parties). The collection may be done through the following channels:

  • Direct collection: in person, by telephone or e-mail or via the Internet
  • Indirect collection: through partners, external companies or Group companies and official entities

6. General Principles Applicable to the Processing of Data of the Data Subject

In terms of general principles regarding the processing of personal data, Wellow™ undertakes to ensure that:

  • The object of lawful, fair and transparent processing in respect of the data subject
  • collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes
  • Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
  • accurate and up-to-date where necessary, with every reasonable step being taken to ensure that inaccurate data, having regard to the purposes for which they are processed, are erased or rectified without delay
  • kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data are processed
  • processed in a manner that ensures their security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, with appropriate technical or organisational measures being taken

Data processing carried out by Wellow™ is lawful when at least one of the following situations is present:

  • the data subject has given his/her explicit consent to the processing of the data subject's data for one or more specific purposes
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
  • processing is necessary for compliance with a legal obligation to which Wellow™ is subject
  • processing is necessary in order to protect the vital interests of the data subject or of another natural person
  • processing is necessary for the purposes of the legitimate interests pursued by Wellow™ or a third party (except where the interests or the fundamental rights and freedoms of the data subject require protection of personal data)

Wellow™ undertakes to ensure that the processing of the data subject's data is only carried out under the conditions listed above and with respect for the aforementioned principles.

Where processing of the data subject's data is carried out by Wellow™ based on the data subject's consent, the data subject shall have the right to withdraw his or her consent at any time. Withdrawal of consent shall not, however, affect the lawfulness of processing carried out by Wellow™ on the basis of the consent previously given by the data subject.

The period of time for which data is stored and retained varies according to the purpose for which the information is processed.

In fact, there are legal requirements that require data to be kept for a minimum period of time. Therefore, and whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that motivated their collection or their subsequent processing, after which they will be deleted.

7. Use and Purposes of Data Processing of the Data Subject

In general terms, Wellow™ uses the data of the data subject for various purposes, including billing and collection, for marketing purposes and for human resource management and employee recruitment, among others.

The data of the data subject collected by Wellow™ shall not be shared with third parties without the consent of the data subject, with the exception of the situations mentioned in the following paragraph. In the event that the data subject contracts Wellow™ for services provided by other entities responsible for processing personal data, the data subject's data may be consulted or accessed by these entities, to the extent necessary for the provision of such services.

Under applicable legal terms, Wellow™ may transmit or communicate the data subject's data to other entities in the event that such transmission or communication is necessary for the performance of the contract established between the data subject and Wellow™ or for pre-contractual diligences at the request of the data subject, in the event that it is necessary for the fulfilment of a legal obligation to which Wellow™ is subject or in the event that it is necessary for the purpose of pursuing the legitimate interests of Wellow™ or a third party.

In the event of data being passed from the data subject to third parties, reasonable efforts will be made to ensure that the recipient uses the data in a manner consistent with this Privacy Policy.

8. Technical, Organisational and Safety Measures Implemented

To ensure the security of the holder's data and the utmost confidentiality, Wellow™ treats the information he/she has provided us with absolutely confidentially, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated as necessary, as well as in accordance with the terms and conditions legally provided.

Depending on the nature, scope, context and purposes of the data processing, as well as the risks arising from the processing for the rights and freedoms of the data subject, Wellow™ undertakes to implement, both when defining the means of processing and when processing itself, the necessary and appropriate technical and organisational measures for data protection and compliance with legal requirements.

It further undertakes to ensure that only data that is necessary for each specific purpose of the processing is processed and that such data is not made available to an indefinite number of persons.

In terms of general measures, Wellow™ adopts the following:

  • Regular audits to assess the effectiveness of technical and organisational measures implemented
  • Raising awareness and training staff involved in data processing operations
  • Pseudonymisation and encryption of personal data, where justified
  • Mechanisms to ensure the ongoing confidentiality, availability and resilience of information systems
  • Mechanisms to ensure the timely restoration of information systems and access to personal data in the event of a physical or technical incident

9. Transfer of Data Outside the European Union

The personal data collected and used by Wellow™ are not made available to third parties established outside the European Union. If, in the future, such a transfer takes place, Wellow™ undertakes to ensure that the transfer complies with applicable legal provisions, in particular as regards the determination of the suitability of such country with regard to data protection and the requirements applicable to such transfers.

10. Rights of Data Subjects

a. Right to Information

The information contained in this document shall be provided in writing (including by electronic means) by Wellow™ to the data subject prior to the processing of the personal data in question. In accordance with applicable law, Wellow™ is under no obligation to provide the data subject with this information when and insofar as the data subject is presumed to be already aware of it.

The information is provided by Wellow™ free of charge.

b. Right of Access to Personal Data

Wellow™ ensures the means to allow access, by the data subject, to his/her personal data.

The data subject shall have the right to obtain from Wellow™ confirmation as to whether or not personal data concerning him or her are being processed and, where applicable, the right to access his or her personal data and the following information:

  • The purposes of data processing
  • The categories of personal data concerned
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or belonging to international organisations
  • if possible, the storage period of the personal data
  • The existence of the right to request Wellow™ to rectify, erase or limit the processing of personal data or the right to object to such processing
  • Right to lodge a complaint with the CNPD or another supervisory authority
  • where the data have not been collected from the data subject, the information available on the origin of such data
  • the existence of automated decisions, including profiling and information concerning the logic involved, as well as the significance and expected consequences of such processing for the data subject
  • Right to be informed about the appropriate safeguards associated with the transfer of data to third countries outside the EU or international organisations

Upon request Wellow™ will provide the data subject, free of charge, with a copy of his/her data undergoing processing. The provision of other copies requested by the data subject may entail administrative costs.

c. Right to Rectification of Personal Data

The data subject shall have the right to request at any time the rectification of his/her personal data as well as the right to have his/her incomplete personal data completed, including by means of an additional declaration.

In the event of rectification of data, Wellow™ shall communicate to each recipient to whom the data have been transmitted the rectification thereof, unless such communication proves impossible or involves a disproportionate effort for Wellow™.

d. Right to erasure of personal data ("Right to be forgotten")

The data subject has the right to obtain, from Wellow™, the erasure of his/her data where one of the following grounds applies:

  • the data subject's data are no longer necessary for the purpose for which they were collected or processed
  • the data subject withdraws the consent on which the processing of the data is based and there is no other legal ground for the processing
  • the data subject opposes the processing pursuant to the right to object and there are no overriding legitimate interests justifying the processing
  • If the data subject's data are processed unlawfully
  • If the data subject's data must be deleted in order to comply with a legal obligation to which Wellow™ is subject

Under applicable legal terms, Wellow™ is under no obligation to erase the data subject's data to the extent that the processing is necessary to comply with a legal obligation to which Wellow™ is subject or for the purposes of asserting, exercising or defending a right of Wellow™ in legal proceedings.

In the event of erasure of data, Wellow™ shall communicate to each recipient/entity to whom the data have been transmitted the erasure thereof, unless such communication proves impossible or involves a disproportionate effort for Wellow™.

Where Wellow™ has made public the data of the data subject and is obliged to erase them pursuant to the right to erasure, Wellow™ undertakes to ensure that reasonable steps, including technical measures, taking into consideration available technology and the cost of their implementation, are taken to inform the actual controllers of the personal data that the data subject has requested them to erase the links to, and copies or reproductions of, those personal data.

e. Right to Limitation of Processing of Personal Data

The data subject shall have the right to obtain from Wellow™ the limitation of the processing of his/her data if one of the following situations applies (limitation may consist of inserting a mark in the personal data retained with the aim of limiting its processing in the future):

  • If you contest the accuracy of the personal data, for a period that allows Wellow™ to verify its accuracy
  • if the processing is unlawful and the data subject opposes their erasure and instead requests limitation of their use
  • If Wellow™ no longer needs the data subject's data for the purpose of processing, but such data are required by the data subject for the establishment, exercise or defence of legal claims
  • Where the data subject has opposed the processing, until it is established that the legitimate reasons of Wellow™ prevail over those of the data subject

Where the data subject's data are subject to limitation, they may, with the exception of storage, only be processed with the consent of the data subject or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person, or for reasons of public interest as provided by law.

The data subject who has obtained the limitation of the processing of his/her data in the above cases shall be informed by Wellow™ before the limitation on processing is lifted.

In case of limitation of data processing, Wellow™ will communicate to each recipient to whom the data have been transmitted the limitation, unless such communication proves impossible or involves a disproportionate effort for Wellow™.

f. Right to Personal Data Portability

The data subject shall have the right to receive the personal data concerning him/her that he/she has provided to Wellow™, in a structured, commonly used and machine-readable format, and the right to transmit such data to another controller, if:

  • the processing is based on consent or on a contract to which the data subject is party
  • the treatment is carried out by automated means

The right of portability does not include inferred data or derived data, i.e. personal data that are generated by Wellow™ as a consequence or result of the analysis of the data undergoing processing.

The data subject shall have the right to have personal data transmitted directly between controllers, where technically possible.

g. Right to object to the treatment

The data subject shall have the right to object at any time, on grounds relating to his/her particular situation, to processing of personal data concerning him/her that is based on the exercise of legitimate interests pursued by Wellow™ or when the processing is carried out for purposes other than those for which the personal data were collected, including profiling or when the personal data are processed for statistical purposes.

Wellow™ shall cease processing the data subject's data, unless it provides compelling legitimate grounds for such processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of a right of Wellow™ in legal proceedings.

Where the data subject's data are processed for the purposes of direct marketing (marketing), the data subject shall have the right to object at any time to the processing of data concerning him or her for the purposes of such marketing, which includes profiling to the extent that it is related to direct marketing. Where the data subject objects to the processing of her or his data for the purposes of direct marketing, Wellow™ shall cease processing the data for that purpose.

The data subject shall also have the right not to be subject to a decision taken solely on the basis of automated processing, including profiling, which produces legal effects concerning him/her or significantly affects him/her in a similar manner, unless the decision:

  • it is necessary for the conclusion or performance of a contract between the holder and Wellow™
  • is authorised by legislation to which Wellow™ is subject
  • it is based on the explicit consent of the data subject

h. Procedures for the Exercise of Rights by the Holder

The right of access, the right of rectification, the right of erasure, the right of limitation, the right of portability and the right to object may be exercised by the data subject by contacting  privacidade@wellowgroup.comThe address is Rua do Proletariado n.º 2-A 2794-063 Carnaxide or through the telephone number 214139480.

Wellow™ will respond in writing (including by electronic means) to the holder's request within a maximum period of one month from receipt of the request, except in cases of particular complexity, where this period may be extended to two months.

If the requests submitted by the holder are manifestly unfounded or excessive, in particular because of their repetitive nature, Wellow™ reserves the right to charge administrative costs or refuse to act on the request.

i. Personal Data Breaches

In the event of a data breach and insofar as such breach is likely to result in a high risk to the rights and freedoms of the data subject, Wellow™ undertakes to communicate the personal data breach to the data subject concerned without undue delay.

In legal terms, the communication to the holder is not required in the following cases:

  • Where Wellow™ has applied appropriate protective measures, both technical and organisational, and those measures have been applied to the personal data affected by the personal data breach, especially measures that render the personal data unintelligible to any person not authorised to access that data, such as encryption
  • Where Wellow™ has taken subsequent measures which ensure that the high risk to the rightholder's rights and freedoms is no longer likely to materialise
  • In the event that the communication to the data subject would involve a disproportionate effort for Wellow™. In such a case, Wellow™ shall make a public communication or take a similar measure whereby the rightholder shall be

II. Consent to Call Recording

The contracted employees provide their express CONSENT for the recording of calls in which they are involved in the execution of the respective activity, namely for the purposes of internal auditing, quality control and eventual proof of a commercial transaction, of Wellow™ itself or of the respective Client.

III. Website Use Policy

This website provides users with access to information, services and content, and the user assumes responsibility for its correct use, as well as for the registration process required to access certain services or content.

The user undertakes to make appropriate use of the information, contents and services of this website and, specifically, not to carry out any action that may cause physical or logical damage to the system, as well as not to access it fraudulently through the use of unauthorised access data.

The content of this website may not be modified or reinterpreted so as to be protected under any other copyright, patent, trademark or intellectual property registration that does not belong to Wellow™.

The information provided on the website may contain some technical inaccuracy or typographical error. Consequently, Wellow™ accepts no responsibility, in any form, for any direct, indirect, incidental or collateral damage resulting from the visit to its pages, including loss of data, loss of revenue or other income, and interruption of business processes derived from the use or inability to use the information on this website. Wellow™ furthermore declines any responsibility for the content of third party websites that contain links to this website and/or that can be accessed from this website.

All elements contained in this website, namely texts, photos, illustrations and others are protected by law, under the Code of Copyright and Related Rights.

It is expressly forbidden to copy, reproduce and disseminate the texts, photos, illustrations and other elements contained in this electronic edition without the express permission of Wellow™, regardless of the means used for such, with the exception of the right to quote defined by law.

The commercial use of the elements contained in the electronic edition of Wellow™, namely texts, photos, illustrations and others, is expressly prohibited.

Wellow™ reserves the right to take legal action against the authors of any unauthorised copy, reproduction, diffusion or commercial exploitation of the elements contained in this website, namely texts, photos, illustrations and others.

IV. Cookies Policy

A "cookie" is a file that is imported into your computer or other device when you access certain web pages collecting information about your browsing on these web pages. In some cases, cookies are necessary to facilitate navigation and enable information about a user's browsing habits or equipment to be saved and recovered, among other things, and depending on the information they contain and the way in which you use your equipment, they may be used to recognise you.

The cookies used on this website can be classified as follows:

  • Own cookies:are those which are sent to the user's terminal equipment from a device or domain managed by the publisher itself and from which the service requested by the user is provided
  • Third party cookies:are those that are sent to the user's terminal equipment from a device or domain that is not managed by the publisher, but by another entity that processes the data collected through the cookies
  • Session cookiescollect and store data when the user accesses a web page
  • Technical cookiesallow the user to navigate through a web page, platform or application and use the different options or services available on it
  • Personalisation Cookies: they allow the user to access the service with some characteristics of a general nature predefined according to a series of criteria in the user's terminal, such as language, the type of browser through which the service is accessed, the regional configuration of the place from where the service is accessed, etc.
  • Analytics CookiesThese cookies allow the person responsible for them to monitor and analyse the behaviour of the users of the websites to which they are linked. The information collected through this type of cookies is used to measure the activity of the websites, application or platform and to draw up navigation profiles of the users of these websites, applications and platforms, with the aim of introducing improvements in the analysis of the data on the use of the service users.

To find out which cookies your browser has saved, you can use the tools available in your browser.

We use social media buttons to enable our users to share websites or select them as favourites. These are buttons for external social networking websites. These sites may record information about your activities on the Internet, including our website. You can review the terms of use and privacy policies of these websites to learn exactly how they use the information and to learn how you can delete or erase this information.

We sometimes use external web services to display content within our web pages. For example, to show virtual tours, images, videos, graphics, infographics, maps or to conduct surveys. As with social media buttons, we cannot prevent these external websites or domains from collecting information about the use made of this embedded content.

Wellow™ accepts no responsibility for legal or technical problems caused by the user's failure to comply with the recommendations indicated. This communication is intended for the knowledge and use of users and, therefore, should not be used for any other purpose. Wellow™ is also not responsible for the content and veracity of third party privacy policies included in this cookie policy.

If you have any questions about this cookie policy, please contact us at privacidade@wellowgroup.com

V. Final Part 

1. Changes to the Privacy Policy

Wellow™ reserves the right to change this Privacy Policy at any time. If the change is substantial, a notice will be posted on the website.

2. Applicable Law and Jurisdiction

The Privacy Policy, as well as the collection, processing or transmission of data from the data subject, are governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and by the legislation and regulations applicable in Portugal.

Any disputes arising from the validity, interpretation or execution of the Privacy Policy, or which are related to the collection, processing or transmission of the owner's data, shall be submitted exclusively to the jurisdiction of the judicial courts of the district of Lisbon, without prejudice to the applicable mandatory legal rules.

Download here the Privacy and Personal Data Protection Policy.