Oramix – Sistemas de Informação, S.A., (hereinafter Oramix), as an organization that deals with personal data on a daily basis, considers itself committed to all matters regulated and the obligations imposed by the European legislation on data protection constituted, in particular, by Regulation (EU) 2016/679 of the Parliament and Council (on the protection of individuals with regard to the processing of personal data and on the free movement of such data), hereinafter called GDPR, transposed into the national legal order through Law 58/2019 of August 8.
In this sense, the present Personal Data Protection Policy is approved to reinforce the organization’s commitment and respect for the rules of privacy and the protection of personal data.
SCOPE
This Personal Data Protection Policy applies exclusively to the processing of personal data by Oramix. Oramix adheres to the following principles, identifying, but not limited, in its personal data processing:
- Lawfulness: personal data is processed insofar as at least one of the conditions laid down for lawful processing is met (i) when consent is given by the Data Subject (ii) in the context of the contractual relationship (iii) for compliance with legal obligations (iv) and in furtherance of the legitimate interest of Oramix or a third party;
- Minimization and limitation of storage: only the personal data that are adequate for the purposes of the processing and for the time necessary for these purposes will be processed;
- Transparency: data subjects will be informed in a transparent manner about the main features and measures of personal data protection, including the purposes of processing and possible transmission to third parties;
- Need for access: only employees, collaborators and partners whose functions require it will have access to the personal data processed by Oramix.
The provision of personal data by the data subject implies knowledge and acceptance of the conditions contained in this Privacy Policy.
The data subject can find detailed information regarding the Privacy Policy and Cookie Policy in the following points:
Personal Data
For the purposes of this Personal Data Policy, “Personal Data” shall mean information relating to an identified or identifiable natural person (“data subject”).
Accordingly, an identifiable natural 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, or electronic identifiers – or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The Data Controller
The entity responsible for the collection and processing of personal data is Oramix, which in this context decides which data is collected, the means of processing, the period of conservation and the purposes for which it is used.
Collection of personal data
Oramix collects personal data in person, by telephone, in writing or through computer systems. The personal data collected is processed, either by non-automated means (e.g. manual files), or by computer and in strict compliance with the personal data protection legislation, and is stored in specific databases created for this purpose. Under no circumstances will the data collected be used for a purpose other than that for which consent has been given by the data subject or the condition of the legitimacy of the processing permits.
On the lawfulness of personal data processing
The processing of personal data depends on verification of the conditions of legitimacy and on verification of the lawfulness of the purpose of such processing, as well as on compliance with the principle of proportionality sensu lato.
Specifically, all processing of personal data at Oramix will only occur provided that:
- the holder has given prior consent in a free, specific, informed and unequivocal manner;
- for the pursuit of Oramix’s legitimate interests;
- for the execution of a contract or pre-contractual steps;
- for compliance with any legal or regulatory obligation to which the controller is subject;
- for the protection of vital interests of the data subject or of another natural person.
About the purposes of processing personal data
Information on the processing of personal data is provided to the data subject at the time of collection, or, if the personal data have been obtained from another source, within a reasonable time, depending on the circumstances.
When collecting data, Oramix, as the controller, provides the data subject with more detailed information on how the personal data will be used, in particular:
- The identity and contact details of the data controller;
- The contact details of the data protection officer;
- The purposes for which the personal data is being processed, as well as the legal grounds for the processing;
- The recipients or categories of recipients of the personal data;
- The rights of the data subject;
- The data retention period or the criteria used to define this period;
- Which data you are required to provide, which are optional.
Communication of Personal Data to Third Parties
The personal data processed by Oramix, may be transmitted or given access to them for third parties legitimately when there is the fulfilment of purposes directly related to the legitimate functions of the data holder or controller.
When this happens, Oramix takes steps to ensure that the entities that have access to the personal data provide adequate guarantees for the protection of your personal data.
Where personal data can be legitimately transferred to another recipient, the data subject shall be informed prior to the communication of personal data to a third party and, where justified, may request that his/her personal data not be transferred, provided that this does not hinder the vital and legitimate interest of one of the parties or the public interest.
Where Oramix has the intention or need to process personal data for a purpose other than that for which it was collected, it will provide the data subject in advance with information about that purpose and other necessary information and will seek consent for the new purpose where there is no associated legal basis. When it is not possible to inform the data subject of the origin of the personal data held by Oramix, due to the use of various sources, he/she shall be provided with all the information on this origin.
Oramix safeguards the possibility of providing your personal data in situations where this is required by law or by competent authorities.
Subcontracting
The processing of the data subject’s data may be carried out by a reputable service provider contracted by Oramix. The said service provider will exclusively handle the data for the purposes established by Oramix and in compliance with the instructions issued by the latter, strictly complying with the legal regulations on personal data protection, information security and others.
Data Sharing between Companies of Oramix Group
Oramix may communicate your personal data to companies of the Oramix Group, ensuring that they process the said personal data solely and exclusively for the fulfilment of the purposes indicated. The data subject is informed prior to the communication of personal data and, where justified, may demand that his/her personal data not be transferred, provided that this does not harm the vital and legitimate interest of one of the parties or the public interest.
Term of conservation of personal data
Oramix only keeps and processes your personal data for the period of time that is necessary or mandatory for the fulfilment of the purposes of the processing, applying information retention criteria appropriate to each processing and in line with applicable legal and regulatory obligations.
Data Subject Rights
Under the terms of the applicable law, the data subject may at any time request access to personal data concerning him or her, as well as their rectification, erasure, limitation of processing, data portability, oblivion or objection to their processing.
The data subject also has the Right to withdraw his or her consent, not to be subject to automated individual decisions exclusively, and to lodge complaints with the supervisory authority.
Under the terms of the law, the data subject is also guaranteed the right to withdraw his or her consent to the processing of data for the purposes indicated, without invalidating; however, the processing carried out up to that date based on the consent previously given.
To exercise any of the above rights, the data subject must submit a written request to the following contacts:
- Address: Oramix, Sistemas de Informação SA
A/C GDPR,
Lagoas Park | Edifício 8, Piso 1 | 2740-244 Porto Salvo
Duties of the Data Subject
The data subject undertakes to update his information whenever there is a change in his personal data.
Why We Collect Data
Depending on the nature of the interaction and only when necessary, Oramix may collect some personal data such as name, email, address/location, telephone, civil identification number/tax identification number, date of birth, gender, nationality, academic qualifications, professional status and/or bank/payment details.
Oramix collects and processes your data in accordance with the principle of what is strictly necessary, being requested only when related to the purpose in question, in accordance with your consent and for legitimate purposes, such as:
Website Management
- When you visit our Website, we process your Personal Navigation Data. This Personal Data is essential to communicate with your browser and display our Website on your device. Within this scope, we process data such as your electronic identifier, date/time of connection start and connection end, place of origin of the web navigation session, visited URLs, and social network address.
Contact management
- Oramix collects data such as name, contact and email address when contacted through its website to respond to questions, complaints or other matters for which the data subject contacts it. The processing of personal data in this case will be based on the unambiguous consent given by the data subject when submitting the form and contacting Oramix.
Recruitment and Selection Process
- Oramix may collect personal data from the data subject when he/she submits a spontaneous application form for our analysis or intends to apply for an internal Recruitment and Selection process promoted by Oramix. We may process your Personal Data such as your application date, curriculum vitae or certificate of qualifications, cover letter and interview results. This personal data is processed by Oramix on the basis of your unambiguous consent when you submit your application.
- During an internal Recruitment and Selection process promoted by Oramix, if the data subject is not selected, Oramix may continue to process your personal data in a compatible manner, for the purposes of the remaining internal Recruitment and Selection processes and/or for opportunities that may arise in the future.
Commercial Activity and Marketing
- In the context of the commercial and marketing activities of Oramix, personal data may also be collected and processed, particularly in situations where you subscribe to our newsletter to receive information about our services or events and/or within the scope of contacts established in the course of commercial and marketing activities. This personal data will be collected and processed on the basis of express consent. And depending on the fulfilment of such purposes, it will be possible to collect your telephone/mobile phone number, e-mail address, date/time of contact, place of origin of the contact or preferred contact.
In addition to these processing purposes, other personal data flows exist internally at Oramix:
Hiring and Human Resources Management
- Oramix is the entity responsible for the collection, processing, use, storage and preservation of the personal data of its employees, processed within the scope of the employment relationship established.
Services Rendered
- Oramix may have access, as a subcontractor, during the provision of services and realization of projects to personal data that are the responsibility of its customers. To this end, it implements all the technical and organizational measures necessary for the proper protection of personal data that may be accessed.
Security Measures
Oramix develops its best efforts to guarantee the protection of the personal data made available to it, against unauthorized accesses. To this end, it uses security systems, rules and other procedures to ensure the protection of personal data, as well as to prevent unauthorized access to data, improper use, disclosure, loss, destruction or any other form of unlawful processing.
It is, however, the responsibility of Users to ensure that devices and equipment used to access the Site are adequately protected against harmful software, computer viruses and worms.
If Oramix subcontracts the provision of services involving the transfer of personal data to other entities, such entities shall be obliged to adopt the necessary technical and organizational measures to protect personal data against destruction, loss, alteration, unauthorized disclosure, access or any other unlawful forms of processing.
Cookies
Cookies are small text files that identify the user’s computer to the Oramix server. The cookies themselves do not identify the individual user, only the computer used. Cookies are not used to collect personal data.
The Oramix site uses cookies to help determine the usefulness, interest, and number of accesses to the site, allowing for faster and more efficient site navigation, and eliminating the need to repeatedly enter the same information. In this way, Oramix will be able to provide a more personalized and tailored service to the data subject.
The data subject can configure cookies in the browser’s “options” or “preferences” menu. To learn more about cookies, including how you can manage and delete cookies, you can refer to our Cookie Policy.
Please note, however, that disabling cookies may partially or totally affect your browsing experience on the Oramix Website.
Complaints
Without prejudice to any other administrative or judicial remedy, the data subject has the right to lodge a complaint with the competent supervisory authority under the law, if he or she believes that the processing of his or her data by Oramix violates the legal regime in force at any given time.
Questions and suggestions
The data subject may contact Oramix, on all matters relating to the processing of their personal data and the exercise of the rights conferred on them by applicable law and in particular, referred to in this Policy, by written communication, through the following contacts:
- Email: [email protected]
- Address: Oramix, Sistemas de Informação SA
A/C GDPR,
Lagoas Park | Edifício 8, Piso 1 | 2740-244 Porto Salvo
Revisions to the Privacy Policy
Oramix reserves the right to make changes or revisions to this Privacy Policy at any time, and any such changes or revisions will be duly posted and communicated at www.oramix.pt .
Date of last update: 19/09/2022
