Data protection policy

Sol sem Fronteiras – Associação de Solidariedade Jovem Sem Fronteiras, registered as a Non-Governmental Organisation for Development (NGDO), hereafter referred to as Sol sem Fronteiras or Solsef, has as one of its priorities the respect and safeguarding of the data provided by its associates, volunteers, friends and clients, namely regarding its personal data protection and treatment policy. With the entry into force of the General Data Protection Regulation (GDPR), we want to let all our contacts know how their data is treated and protected under our Privacy Policy.

 

WHAT IS PROVIDED FOR IN THE GENERAL DATA PROTECTION REGULATION (GDPR):

The GDPR aims to update existing data protection rules. Thus, it reformulates concepts and introducing new principles, premises, and rights. The GDPR requires entities that process personal data to implement new measures that will increase trust in the relationship between those who provide the data and those who process it.

 

PRINCIPLES, PREMISES AND RIGHTS TO BE RESPECTED: [1]

Lawfulness, fairness, and transparency:

It must be clear, what the personal data is requested for and who is requesting it.

Purpose limitation

It must be clear that the data will not be used for any purpose other than that consented to by the data subject.

Minimisation of data

Only the data necessary for the purpose should be requested.

Accuracy

It must be ensured that the data is kept up to date.

Integrity and confidentiality

Data security must be ensured by means of appropriate technical and organizacional measures.

Restriction of storage

The data must be kept as short time as possible, considering the purpose and any legal obligations.

Accountability

The responsible organisation shall demonstrate that it ensures compliance with the GDPR.

 

RIGHTS OF THE HOLDERS OF PERSONAL DATA AND RESPONSE TO THEIR REQUESTS

Sol sem Fronteiras guarantees the applicability and compliance with all the rights of the personal data subject provided for in the General Data Protection Regulation, and in accordance with the national legislation in force, such as:

Right of Access

You have the right to obtain from Sol sem Fronteiras confirmation as to whether or not personal data concerning you are being processed and, if so, the right to access your personal data and information regarding such processing. In this regard, for example, you can request an exact copy of your compilation and request additional information about the processing we carry out.

Right of Rectification

You also have the right to obtain, without undue delay, from Sol sem Fronteiras, the rectification of inaccurate personal data concerning you, in particular the right to correct or complete your personal data.

Right to data erasure (“right to be forgotten”)

You may exercise your right to have your personal data erased by Sol sem Fronteiras without undue delay if the data is no longer necessary for the purpose for which it was processed; when you withdraw your consent and there are no other valid reasons for storing it; when you object to the processing and there are no overriding legitimate interests on the part of Sol sem Fronteiras or in the other cases provided for by law.

Right to Data Portability

You have the right to receive the personal data concerning you that you have provided to Sol sem Fronteiras in a structured, commonly used and machine-readable format. You also have the right to transmit such data to another controller (if technically possible), if the processing is based on consent or on a contract, and if the processing is carried out by automated means.

Right to withdraw consent

You may at any time change your consent, limit it to certain types of processing or withdraw it. However, withdrawal of consent does not compromise the lawfulness of the processing carried out on the basis of the consent previously given.

Right of Opposition

You may also object at any time to the processing of personal data concerning you where there are no compelling legitimate grounds for the processing which override your interests, rights and freedoms. The same applies for the establishment, exercise or defense of legal claims.

It should also be added that you have the right to object at any time to the processing of your data for the purposes of direct marketing. In this case, Sol Sem Fronteiras undertakes to cease processing the data for such purposes.

Right to Limitation of Processing

In certain situations, you have the right to obtain from Sol sem Fronteiras the restriction of the processing of your data, particularly if you contest the accuracy of your personal data for a period that allows Sol sem Fronteiras to verify its accuracy. It also applies in cases where the data is no longer necessary for the purposes of the processing but is required by the data subject for the establishment, exercise or defense of a right in legal proceedings. It is also applicable when you oppose the processing until it is established that the legitimate interests of Sol sem Fronteiras outweigh your own, as well as in the other cases provided for by law.

Right not to be subject to any automated decision

You have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar manner.

 

WHAT TYPE OF DATA DOES SOL SEM FRONTEIRAS COLLECT?

Sol sem Fronteiras collects data such as full name, tax number, ID number, date of birth, telephone contacts, e-mail address, address, and other personal details. The collection of this data applies whether in the context of strengthening relations with your contacts (members, volunteers, collaborators, beneficiaries, donors, clients, suppliers or other general contacts), or in the context of issuing accounting documents, or in the context of collecting information for needs assessment in the context of our projects or in the context of contact with our clients through the Prenda Solidária trademark.

 

HOW AND WHEN IS YOUR PERSONAL DATA COLLECTED?

Your personal data may be collected in the following circumstances:

  1. For the purpose of concluding and executing a contract, namely when purchasing or acquiring a product and/or service from Sol sem Fronteiras, if the option is made available by the NGOD.
  2. Through the Sol sem Fronteiras websites (solsef.org or prendasolidaria.org), if the option is available, when you: a.- fill in the member application form; b.- purchase any item through the Solidarity Store; c.- subscribe to the Sol sem Fronteiras newsletter and other institutional information; d.- fill in the volunteer form; e.- provision personal data when making a donation through the available channels.
  3. When you come to the headquarters as a potential associate, volunteer, collaborator or customer and give us your personal data.
  4. When you subscribe to our newsletters and other institutional information by giving us your consent.
  5. When you participate in events organised by Sol sem Fronteiras and, upon expressed consent, making your personal data available to us.

 

WHO IS THE DATA PROTECTION OFFICER (DPO) OF SOL SEM FRONTEIRAS?

The administrative technician and the member of the Board of Directors responsible for members’ affairs are the Data Protection Officers (DPOs) of Sol sem Fronteiras.

Their duties are

  1. Supervise and advise the controller on the obligations under the rules of privacy and protection of personal data;
  2. Cooperate with the Supervisory Authority;
  3. Be the point of contact with the customer, or potential customer, to clarify possible questions about the data processing done by Sol Sem Fronteiras.

Should you have any questions or complaints, you may contact the Data Protection Officer of Sol Sem Fronteiras at the following e-mail address – info@solsef.org.

 

GROUNDS, PURPOSES AND DURATION OF PERSONAL DATA PROCESSING

The grounds on which Sol sem Fronteiras may process your personal data are as follows:

Consent: your personal data may be processed by freely given, specific, informed, and explicit manifestation of will, by which you accept, through a declaration or unequivocal positive act, that your personal data can be processed.

Pre-contractual procedures and/or execution of the contract: your personal data may be required for the clarification of questions, to make you an offer, for the conclusion, execution and management of the contract concluded with Sol sem Fronteiras.

Compliance with legal obligation: your data may required to comply with a legal obligation to which the controller, in this case Sol sem Fronteiras, is subject to.

Legitimate interest: your data may be necessary to carry out certain operations related to the institutional activity of Sol sem Fronteiras, except in cases where your privacy and data protection rights should prevail.

 

RETENTION PERIOD OF PERSONAL DATA

Sol sem Fronteiras keeps personal data for a period that is strictly necessary for the purpose for which it was collected.

In certain cases, the law requires data to be kept for a specific period, particularly in the case of data required for information to the Tax Authority, which will be kept for 10 years in accordance with current legislation.

We will also retain your data for as long as you maintain a contractual relationship with Sol sem Fronteiras. However, we may keep your personal data for periods longer than the duration of the contract, based on your consent, to ensure contract-related rights and obligations or in situations where there is a legitimate interest of Sol sem Fronteiras, always respecting the period necessary for the purpose for which they were collected.

In the absence of a specific legal obligation, your data will be processed only for the period necessary to fulfil the purposes for which they were collected and for as long as there are legitimate grounds for Sol sem Fronteiras to retain them.

Once the maximum storage period has elapsed, personal data will be irreversibly anonymized (anonymized data may be retained) or securely destroyed.

 

TRANSMISSION OF YOUR PERSONAL DATA

Sol sem Fronteiras only provides your personal data when necessary for the purposes described above, namely, to provide the services requested by you.

Suppliers and/or service providers and/or partners of Sol Sem Fronteiras are contractually subject to the same terms and conditions of personal data processing as Sol Sem Fronteiras and are prohibited from using, transferring, disclosing, or recording your personal data for any purpose other than that for which they were specifically hired (or without your consent, as applicable).

Sol sem Fronteiras may transmit your personal data, depending on the purpose for which they were collected, to the following categories of recipients: partner entities, insurers, brokers/dealers, credit and financial institutions, when requested by you, and only the data necessary for the development of the activity pursued by these entities shall be transmitted.

Your personal data may also be transmitted to entities to whom the data must be communicated by law, such as the Tax Authority.

 

HYPERLINK TO OTHER WEBSITES

Please note that Sol sem Fronteiras is not responsible for the privacy practices of third parties whose websites are hyperlinked to our websites and cannot therefore guarantee the accuracy or authenticity of the information contained therein. We advise you to read the privacy policies of any other website that is linked to the Sol sem Fronteiras website.

Sol sem Fronteiras does not guarantee the accuracy, completeness or authenticity of information contained in any hyperlink or other website. Any personal data inserted in other websites that are linked to the Sol Sem Fronteiras website shall be your sole responsibility.

 

USE OF CONTENTS OF SOL SEM FRONTEIRAS’ WEBSITES

Regarding the use of the materials present on the Sol sem Fronteiras website (solsef.org and prendasolidaria.org), information, text, figures, or graphics contained therein, the same may only be used for your personal use and never for commercial purposes, nor may you reproduce, modify, transmit, authorise or publish such information, text, figures or graphics, in whole or in part, for any purpose without the prior written authorisation of Sol sem Fronteiras.

Regarding the use and risk of your use, Sol sem Fronteiras specifically disclaims any liability for direct, indirect, accidental, consequential, or special damages arising out of or in any way connected with your access to or use of its websites, affecting your equipment or your confidence in the information obtained through the Sol sem Fronteiras websites.

The material contained in the websites is intended for information purposes only. Despite Sol sem Fronteiras’ efforts to keep content up to date and reliable, it may contain inaccuracies, typographical errors or be out of date and may be changed at any time without Sol sem Fronteiras being obliged to give prior notice.

 

UPDATING OF PRIVACY POLICY

Sol sem Fronteiras reserves the right to update this policy at any time, according to legal requirements and/or institutional activity needs. You are hereby invited to visit this page to check our policy.

 

APPLICATION OF THE RGPD:

Target group
Members Volunteers Collaborators Beneficiaries Donors Suppliers Customers of the shop General contacts
Who are the data collectors?
Social Direction, Executive Team, or the members themselves when they register as members on the site Social Direction and Executive Team Social and Technical Administrative Direction Field project technician, field project partner Social Direction, Administrative Technician, and volunteers Social and Technical Administrative Direction Social Management, Executive Team or the customers themselves when the data in the purchasing process Executive Team
Who is responsible for storing the data?
Administrative Technician Social Direction and Executive Team Social and Technical Administrative Direction Project Technician Administrative Technician Social Direction and Executive Team Administrative Technician Executive Team

 

Who has access to the data?
Social Direction and Executive Team Social Management and Executive Team; Funders and partners only on request Social Direction and Executive Team Social Management and Executive Team; Funders and partners only on request Treasurer of the Social Direction, Executive Team and Certified Accountant Treasurer of the Social Direction, Executive Team and Certified Accountant Social Direction and Executive Team Social Direction and Executive Team
Where is the data stored?
In digital format in the Solsef database and/or in physical format, in files, when the original documents are delivered to Solsef
When is the data deleted?
When the member informs that he/she no longer wants to be a member and wants his/her data to be deleted from the Solsef database 7 years after the end of the volunteering project or if requested by the volunteer 7 years after the end of the employment contract or if requested by the ex-employee 7 years after the end of the project or if requested by the beneficiary When requested by the donor When requested by the supplier When you inform us that you wish your data to be deleted from Solsef’s database When requested by the holder
How can data subjects’ access and demand the deletion of their data?
Whenever data subjects wish to access their data they may contact Sol sem Fronteiras by email at info@solsef.org, telephone number 213940047 or by letter to the address Rua de Santo Amaro n.º43, 4º andar, 1200-801 Lisboa, requesting access, alteration or elimination of their data.

[1] Raise N’GO (2018). Guia para Aplicação do RGPD para a Economia Social e Ensino. S. João da Madeira: Raise N’GO

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