Definitions on data processing:
- “CNPD”: National Data Protection Commission;
- “Consent of the data subject”: any freely given, specific and informed indication of the data subject’s wishes by which he or she agrees to the processing of his or her Personal Data;
- “Personal Data”: any information of any nature and regardless of its medium, including sound and image, 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 identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;
- “Sensitive Data”: Personal Data concerning philosophical or political beliefs, trade union membership, religious faith, private life and racial or ethnic origin, as well as the processing of data concerning health and sex life, including genetic data;
- ‘interconnection of data’ means a form of processing consisting in linking data from one file with data from another file kept by another controller, or data from a file kept by the same controller for a different purpose;
- “Personal Data Protection Legislation – PDPL”: Regulation (EU) 2016/679 of 27 April 2016;
- “GDPR”: Regulation (EU) 2016/679 of April 27, 2016;
- “Controller”: the (name of the Company) or another company of the Group which determines the purposes and means of the processing of Personal Data;
- “Processor”: the natural or legal person who processes the Personal Data in the name and on behalf of the Controller;
- “Third Party”: the natural or legal person, public authority, agency or any other body to whom the Controller transmits Personal Data;
- “Data Subject”: the identified or identifiable natural person whose Personal Data is processed by ZT Mobility, Lda, or by another Controller;
“Processing of Personal Data” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA
This Personal Data Processing governs the collection and processing of your Personal Data, as well as the exercise of your rights in relation thereto, under the terms of the Personal Data Protection Legislation.
The Processing of Personal Data shall be carried out in accordance with the following principles:
- Lawfulness and fairness;
- Adequacy, relevance and proportionality;
- Security; and
The Personal Data collected will be processed and stored by ZT Mobility, Lda, or by the entities subcontracted by it, for the purpose of managing the relationship between ZT Mobility, Lda and the Data Subject for the purpose of performing services.
Collection, processing and storage of Personal Data
ZT Mobility, Lda, will only process Personal Data if they are necessary for the pursuit of its activity, compliance with legal or contractual obligations or for the pursuit of the purposes indicated above.
ZT Mobility, Lda, assumes that the data collected was inserted / made available by the respective holder and that its insertion / availability to ZT Mobility, Lda, was authorized by the same, being the Personal Data in question true and accurate. Without prejudice, ZT Mobility, Lda will take appropriate measures to ensure that inaccurate or incomplete data are erased or rectified, taking into account the purposes for which they were collected or for which they are further processed.
The Personal Data collected will be kept in a form that allows its identification only for the period necessary for the pursuit of the purposes of collection or further processing, after which it will be permanently deleted without the possibility of recovery.
The Personal Data we collect includes names, shipping information, addresses, email addresses and telephone numbers. Some of the information collected by ZT Mobility, Lda consists of data relating to an identifiable natural person.
Cross-border flows of personal data
Communication to Third Parties
ZT Mobility, Lda may communicate Personal Data to third parties, within the scope:
- The fulfillment of a legal obligation, a resolution of the CNPD or a court order;
- When the communication of data is carried out to protect the vital interests of the holder of the Personal Data;
- In the context of a sale, assignment or other transfer of the business to which the Personal Data relates; or
- Any other legitimate purpose provided for in the GDPR.
ZT Mobility, Lda, may communicate Personal Data to entities subcontracted by it for the purpose of processing them, on behalf of and under the instructions of ZT Mobility, Lda, as the Responsible entity.
Interconnection of Personal Data
ZT Mobility, Lda, will not carry out any Personal Data interconnection operation without the prior authorization of the CNPD for this purpose.
The Personal Data interconnection operations carried out by ZT Mobility, Lda, will comply with the following requirements:
- Suitability for the pursuit of its legal or statutory purposes and legitimate interests;
- Non-discrimination or diminution of the rights, freedoms and guarantees of data subjects,
- use of appropriate security measures; and
- taking into account the type of data being interconnected.
Rights of Data Subjects
Under the terms of the LPDP, Data Subjects are guaranteed the right to access, update and rectify their Personal Data, as well as the right to object to the processing thereof, under the terms declared by them, and such exercise must be carried out in person by the data subject.
As you navigate through our website, certain information may be collected without you realizing it. We use various technologies and means, such as Internet Protocol addresses, cookies, web tags and browsing data collection for this purpose.
Our website uses internet protocol (IP) addresses. An IP address is a number assigned to your computer by your internet service provider so that you can access the internet.
We use your IP address to diagnose problems with our server, to determine the fastest route for your computer to use when connecting to our website and for visit statistics and improving our website.
If you are a contractual customer of ZT Mobility, Lda, you may at any time log in to your Customer Area and edit your personal data.
You may also request these same changes from us to update or correct the personal information we hold.
Our website may contain links or references to other websites.
ZT Mobility, Lda, implements technical and organizational measures necessary to protect Personal Data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access, in particular when the processing involves its transmission over a network, as well as against any other form of unlawful processing thereof, and such measures must be complied with by its employees.
These measures will ensure, taking into account the technical expertise available and the costs resulting from their application, an adequate level of security in relation to the risks presented by the Processing of Personal Data and the nature of the Personal Data to be protected.
ZT Mobility, Lda, will adopt special security measures when processing Sensitive Data.
Your right to complain
If you have a complaint regarding our use of your personal data, you can make it directly to the Portuguese supervisory authority, in this case the National Data Protection Commission, through the website https://www.cnpd.pt/bin/duvidas/queixas_frm.aspx or by writing to its address at Rua de São Bento, 148, R/C, 1200-821 Lisboa.