Updated date: 24.09.2019
- Name and address of the person responsible
- Quality policy
- General information on data protection policy and processing
- Provision of the website and creation of log files
- Contact form and e-mail contact
- Web analytics by Google Analytics
1. Name and address of the person responsible
Responsible in the sense of the basic data protection regulation and other national data protection laws of the member states as well as other data protection regulations is:
Consenso Global – Serviços de Tradução, Unipessoal, Lda.
Praceta Calouste Gulbenkian, 4
2560-291 Torres Vedras
Phone: +351 261 317 092
Represented by: Pedro Santos
3. Quality policy
The company’s management, aware of the strategic relevance that its customers have for its business, through the acquisition of the services it offers and provides, from the context of
organization and its strategic orientation, established its Quality Policy based on the following principles:
- Satisfaction of customer needs and expectations, meeting their requirements;
- Compliance with applicable legal and contractual requirements;
- Development of employee skills through education, continuing training and experience;
- Continuous improvement of the services provided and the effectiveness of the quality management system implemented and periodically reviewed.
3. General information on data protection policy and processing
3.1 Scope of the processing of personal data
In principle, we process personal data of our users only to the extent necessary for the provision of a functional website and our content and services. The processing of personal data of our users takes place regularly only with the consent of the user. An exception applies to cases in which prior consent is not possible for reasons of fact and the processing of the data is permitted by law.
3.2 Data Protection Policy
The Consenso Global Management determines that data processing should be subject to the following principles (data protection policy):
- determination, prior to data collection, of the objectives for their use and their conservation and disposal
- identification of data subjects (personal and non-personal) and determination of their interests and rights
- providing information to data subjects about specific purposes for the use, limitation and discontinuation of use, rectification and retention, data deletion and right of opposition when data subjects are unaware of the information
- obtain authorization from the data subject to use it, particularly when it comes to or may be used for the purpose of offering goods and services, even free of charge, or for analyzing and controlling their behavior
- interruption of processing of data which no longer meets the purposes for which they were collected or when requested by their holders
- deletion of data when not in use or at the request of the data subject, subject to applicable legal / tax permissions
- Data protection through logical, physical and other security measures
These principles apply to data collected by direct (personal and telephone contacts) or indirect (postal correspondence, own websites and social networks) or verbal and / or written forms (registration / information sheets; advertising, emails, posts and others).
The Consenso Global Management determines that all data held and retained by the organization shall be subject to lawful, fair and transparent treatment within the principles of security and accountability defined internally.
The company does not designate any Data Protection Officer, as there is no need for regular and systematic control of data based on the nature, scope and purpose of the data, as well as the small scale of the data collected and retained.
3.3 Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (DSGVO) as legal basis. In the processing of personal data necessary for the performance of a contract of which the data subject is a party, Art. 6 para. 1 lit. b DSGVO as legal basis. This also applies to processing operations required to carry out pre-contractual measures. Insofar as the processing of personal data is required to fulfill a legal obligation that our company is subject to, Art. 6 para. 1 lit. c DSGVO as legal basis. In the case, that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis. If processing is necessary to safeguard the legitimate interests of our company or a third party, and if the interest, fundamental rights and fundamental freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f DSGVO as legal basis for processing.
3.4 Data deletion and storage duration
The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage is deleted. In addition, it may be stored if provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. A blocking or deletion of the data takes place even if a storage period prescribed by the mentioned standards expires, unless there is a need for further storage of the data for a conclusion of contract or a fulfillment of the contract.
4. Provision of the website and creation of log files
4.1 Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the calling computer. The following data is collected here:
- Information about the browser type and version used
- The user’s operating system
- The user’s Internet service provider
- The user’s IP address
- The date and time of access
- Web sites from which the user’s system accesses our website
- Websites that are accessed by the user’s system through our website
The data is also stored in the log files of our system. A storage of this data together with other personal data of the user does not take place.
4.2 Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.
4.3 Purpose of the data processing
The temporary storage of the IP address by the system is necessary to allow delivery of the website to the computer of the user. To do this, the user’s IP address must be kept for the duration of the session. Storage in log files is done to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. For these purposes, our legitimate interest in the processing of data according to Art. 6 para. 1 lit. f DSGVO.
4.4 Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. In the case of collecting the data for providing the website, this is the case when the respective session is completed. In the case of storing the data in log files, this is the case after one month at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
4.5 Opposition and removal option
The collection of data for the provision of the website and the storage of the data in log files are essential for the operation of the website. There is consequently no contradiction on the part of the user.
a) Description and scope of data processing
The following data are stored and transmitted in the cookies:
- Language Settings
- Session ID
In this way, the following data can be transmitted:
- Search terms entered
- Frequency of page views
- Use of website functions
The data of the users collected in this way are pseudonymised by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data will not be stored together with other personal data of the users.
b) Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is the consent of the user Art. 6 para. 1 lit. a GDPR.
c) Purpose of the data processing
We require cookies for the following applications:
- Applying language settings
- Remembering search terms
The user data collected by technically necessary cookies will not be used to create user profiles.
The use of the analysis cookies is for the purpose of improving the quality of our website and its contents. Through the analysis cookies we learn how the website is used and thus can constantly optimize our offer and the portfolio of our services. For these purposes, our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f DSGVO.
e) Duration of storage, objection and disposal options
6.1 Description and scope of data processing
On our website, you can subscribe to a free newsletter. When registering for the newsletter, the following data from the input mask will be sent to us:
- Last name
- E-mail address
- Company name
In addition, the following data will be collected upon registration:
- IP address of the calling computer
- Date and time of registration
In connection with the processing of data for the sending of newsletters, the data is forwarded to our newsletter service provider Act-On. The data will be used exclusively for sending the newsletter.
6.2 Legal basis for data processing
Legal basis for the processing of the data after the application for the newsletter by the user is in the presence of a consent of the user Art. 6 para. 1 lit. a GDPR.
6.3 Purpose of the data processing
The collection of the user’s e-mail address serves to deliver the newsletter.
The collection of other personal data as part of the registration process is intended to prevent misuse of the services or the e-mail address used.
6.4 Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection. The e-mail address of the user is therefore stored as long as the subscription to the newsletter is active.
The other personal data collected as part of the registration process will normally be deleted after a period of 30 days.
6.5 Opposition and removal option
Subscription to the newsletter may be terminated at any time by the user concerned. For this purpose, there is a corresponding link in each newsletter.
This also allows a revocation of the consent of the storage of the personal data collected during the registration process.
7. Contact form and e-mail contact
7.1 Description and scope of data processing
On our website is a contact form available, which can be used for electronic contact. If a user realizes this option, the data entered in the input mask will be transmitted to us and saved. These data are:
- First name
- Last name (required)
- E-mail (required)
- Message (required)
At the time of sending the message, the following data is also stored:
- The IP address of the user
- Date and time of transmission
Alternatively, contact via the provided e-mail address is possible. In this case, the user’s personal data transmitted by e-mail will be stored.
We use the data you provide as part of our customer and prospect management with the use of marketing tools (Act-On and Vtiger) to initiate and conduct contractual relationships with you. In this context, there is the possibility of the third parties taking note of the data
7.2 Legal basis for data processing
Legal basis for the processing of the data is in the presence of the consent of the user Art. 6 para. 1 lit. a GDPR.
The legal basis for the processing of the data transmitted in the course of sending an e-mail is Article 6 (1) lit. f DSGVO. If the e-mail contact aims to conclude a contract, then additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO
7.3 Purpose of the data processing
The processing of personal data from the input mask is only used to process the contact for B2B services. In the case of contact via e-mail, this also includes the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
7.4 Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection. For the personal data from the input form of the contact form and for those who have been sent by e-mail, this is the case when the respective conversation has ended in connection with the request.
7.5 Opposition and removal possibility
The user has the opportunity to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he may object to the storage of his personal data at any time. In such a case, the conversation can not continue.
8. Web analytics by Google Analytics
8.1 Scope of processing of personal data
On our website we use the open source software tool Google Analytics to analyze the surfing behavior of our users. The software sets cookies on the user’s computer (for cookies, see above). The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
If individual pages of our website are called, the following data is stored:
- the IP address of the user’s calling system
- the website called up
- the website from which the user accessed the accessed website (referrer)
- the subpages that are accessed from the website accessed
- the time spent on the website
- the website Frequency of calling the website,
Only the first half of the IP address is transmitted. The IP anonymisation has been activated on the website, so that your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google uses this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator.
In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading the browser plug-in available under the following link and install: http://tools.google.com/dlpage/gaoptout
8.2 Legal basis for the processing of personal data
The legal basis for the processing of users’ personal data is the consent pursuant to Art. 6 para. 1 lit. a GDPR.
8.3 Purpose of the data processing
The processing of users’ personal data enables us to analyze the surfing behavior of our users. By analyzing the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. With regard to the consent of the user to be granted, this agrees with the purposes of data processing. The further anonymization of the IP address also takes into account the interest of users in their protection of personal data.
8.4 Opposition and removal possibility
In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google.
Consenso Global stores personally identifiable information, such as your name and email address, but only to respond to the matter addressed by your website visitor.
page and in accordance with the General Data Protection Regulations. Consenso Global does not share or provide information collected to third parties, except with the express permission of its holder. The personal data collected in the communication initiated by the page visitor is kept for the time necessary for the resolution of the addressed subject or until the request of its removal by its owner. Records of electronic or postal correspondence exchanged between the parties shall be kept on file, where relevant, for a maximum of 10 years.
If personal data is processed by you, you are i. P. D. DSGVO and you have the following rights to the person responsible
9.1 Right to information
You may ask the person in charge to confirm if personal data concerning you is processed by us. If such processing is available, you can request information from the person responsible about the following information:
- the purposes for which the personal information is processed;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom the
personal data relating to you have been disclosed or are still being disclosed;
- the planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;
- the right of rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- all available information on the source of the data if the personal data is not collected from the person concerned;
- the existence of automated decision-making including profiling according to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved, as well as the scope and intended impact of such processing on the person concerned.
You have the right to request information about whether the personal data relating to you are transferred to a third country or an international organization. In this regard, you can request the appropriate warranties in accordance with. Art. 46 GDPR to be informed in connection with the transfer.
9.2 Right to rectification
You have a right to rectification and / or completion to the controller, if the personal data you process is incorrect or incomplete. The person in charge must make the correction without delay.
You may request the restriction of the processing of your personal data under the following conditions:
- if you deny the accuracy of your personal information for a period of time that enables the controller to verify the accuracy of your personal information;
- if the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of personal data;
- if the person responsible no longer requires the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or
- if you object to the processing pursuant to Art. 21 (1) GDPR and not yet It is clear whether the legitimate reasons of the person responsible outweigh your reasons.
If the processing of personal data concerning you has been restricted, this data may only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest Union or a Member State.
If the processing restriction has been restricted in accordance with the above conditions, the person responsible informs you before the restriction is lifted.
9.4 Right to cancellation
a) Obligation to delete
You may require the controller to delete your personal information without delay, and the controller is required to delete that information immediately if one of the following is true:
- Your personal information is no longer necessary for the purposes for which it was collected or otherwise processed.
- You revoke your consent, to which the processing acc. Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
- You place according to Art. 21 para. 1 DSGVO objection to the processing and there are no prior justifiable reasons for the processing or you submit gem. Art. 21 para. 2 DSGVO objection to processing.
- Your personal information has been processed unlawfully.
- The deletion of personal data concerning you is required to fulfill a legal obligation under Union or national law to which the controller is subject.
- The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
- Information to third parties
If the person responsible has made the personal data relating to you public and is in accordance with. Article 17 (1) of the GDPR, it shall take appropriate measures, including technical ones, to inform data controllers who process the personal data that you have been identified as being affected, taking into account available technology and implementation costs Person requested by them to delete all links to such personal data or to make copies or replicas of such personal data.
The right to erasure does not exist if the processing is necessary
- to exercise the right to freedom of expression and information;
- to fulfill a legal obligation required by the law of the Union or of the Member States to which the controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the controller;
- for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 (3) GDPR;
- for archival purposes of public interest, for scientific or historical research purposes or for statistical purposes acc. Article 89 (1) GDPR, to the extent that the right referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
- to assert, exercise or defend legal claims.
9.5 Right to information
If you have the right of rectification, erasure or restriction of the processing to the controller, he / she is obliged to notify all recipients to whom the personal data concerning you have been corrected or deleted or processing restricted, unless: this proves to be impossible or involves a disproportionate effort.
You have the right to be informed about these recipients.
9.6 Right to Data Portability
You have the right to receive personally identifiable information you provide to the controller in a structured, common and machine-readable format. You also have the right to submit this information to another person without hindrance by the controller to whom the personal information has been provided, provided that
- the processing is based on a consent acc. Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a DSGVO or on a contract acc. Art. 6 para. 1 lit. b DSGVO
- the processing is carried out using automated procedures
In exercising this right, you also have the right to obtain that your personal data relating to you are transmitted directly from one person to another, as far as this is technically feasible. Freedoms and rights of other persons may not be affected.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the controller.
9.7 Right to object
For reasons arising from your particular situation, you have the right at any time against the processing of personal data relating to you, which pursuant to Art. 6 para. 1 lit. e or f DSGVO takes an objection; this also applies to profiling based on these provisions.
The controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purposes of asserting, exercising or defending legal claims.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
Regardless of Directive 2002/58 / EC, you have the option, in the context of the use of information society services, of exercising your right to opt-out by means of automated procedures that use technical specifications.
9.8 Right to revoke the data protection consent declaration
You have the right to revoke your data protection consent declaration at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.
9.9 Automated decision on a case-by-case basis including profiling
You have the right not to be subjected to a decision based solely on automated processing – including profiling – that will have legal effect or similarly affect you in a similar manner. This does not apply if the decision
- is required to conclude or perform a contract between you and the
- is permitted by Union or Member State legislation to which the controller is subject, and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests , or
- with your express consent.
However, these decisions may not be based on special categories of personal data under Art. 9 (1) GDPR, unless Art. 9 (2) lit. a or g DSGVO applies and reasonable measures have been taken to protect the rights and freedoms as well as your legitimate interests.
With regard to the cases mentioned in (1) and (3), the person responsible shall take appropriate measures to uphold the rights and freedoms and their legitimate interests, including at least the right to obtain the intervention of a person by the controller, to express his / her own position and heard on challenge of the decision.
8.10.Right to appeal to a regulator
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data concerning you is against the DSGVO violates.
The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.