Privacy Policy

Date of publication: 20.04.2019

SISCOG is committed to respecting the online privacy of the users (the “Users”) of the websites http://www.siscog.pt, http://www.siscog.eu and http://www.siscog.com (the “Website”) and has laid down this set of rules (the “Privacy Policy”) to inform the Users of how personal data are processed in the context of the use of the Website and its respective services, such as the download of brochures and other information, as well as the analysis of job applications (the “Use of the Website”).

This Privacy Policy has been developed in strict compliance with the applicable legislation in this field, notably Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”), Law no. 67/98 - the law on the protection of personal data, which transposes into the Portuguese legal system Directive no. 95/46/CE of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, for all matters not contrary to the GDPR, until a new statute becomes applicable, and the guidelines issued by the Portuguese national data protection committee, the Comissão Nacional de Proteção de Dados (the “CNPD”).

This Privacy Policy describes, when applicable, the type of personal data we collect on this Website and how we process it once collected.

In general, various pages of this Website are made available for information purposes.

1. Controller. In accordance with this Privacy Policy, SISCOG - Sistemas Cognitivos, S.A., a commercial company registered with the Lisbon Commercial Registry and with legal entity number 501707336, whose registered office is at Campo Grande, no. 378 - 3rd floor, 1700 - 097 Lisbon, Portugal (“SISCOG”), is the controller of the personal data. Email address to be used by the User in the context of personal data protection: ims@siscog.pt.
   
   
2. Scope of the processing of personal data. SISCOG will process the personal data in the context of access and navigation in the Use of the Website, with a view to analysing job applications, accessing private areas of the Website (the customer area) or managing User communication programmes, notably in terms of business and marketing communications. If the User supplies us with personal data, we may use this data to meet his/her requests, customise his/her registration on the Website, assess his/her satisfaction with SISCOG's products and/or services or to contact him/her by mail, email, SMS or telephone, or, when permitted, to inform him/her of new products or services using any of the aforementioned means.
   
   
3. Type of data collected. When the User accesses the Website, we may automatically collect any personal data which might identify him/her or concerning his/her personal details. Additionally, we collect and store any information the User may voluntarily decide to supply to us, so that we can provide activities resulting from the Use of the Website or so that we may contact the User in the context of any interest shown in information on the Website. When any personal data are treated, we shall ensure the lawful processing of such data. We will not undertake any subsequent processing which proves to be incompatible with the purpose for which the information was originally processed.

   We collect the following data, depending on the use: Title (e.g. Mr. Ms.), Name, Company, Function, City, District, Country, Email, Telephone, Curriculum vitae (CV), LinkedIn profile, University degree, Area applied for (job applications), Date and time of download, Identification of the document downloaded, IP address.

   When he/she transmits personal data in the context of the Use of the Website, the User of the Website warrants that the personal data he/she makes available are true and accurate.
   
   

4. Terms of processing. SISCOG, in its capacity as controller of the personal data made available by the Users of the Website, shall comply with the applicable legal provisions with regard to the processing of any data collected by it.
   SISCOG shall ensure the integrity and secrecy of any data entrusted to it, as well as the lawfulness of their processing in accordance with the law, notably: the lawfulness, security and confidentiality of the processing and that the personal data will not subsequently be used for any purpose other than those stated upon their collection, save with the User's subsequent express consent and subject to such data being stored only as long as necessary to pursue the purposes which have led to their collection/processing.

   SISCOG has appropriate technical and organisational measures to protect the Users' personal data against unauthorised modification, disclosure and/or access. SISCOG uses appropriate systems and procedures to protect and safeguard the integrity of any personal data supplied to it, notably organisational, technical and physical security restrictions on access to servers and control of access to servers, among others. Only authorised employees may access the personal data while executing their work and for the purposes stated herein.

   Notwithstanding, to the maximum extent permitted by law, SISCOG shall not be held liable for attacks or any unlawful actions by third parties.
   
   

5. Duration of the processing of personal data. Personal data will be stored in the context of the Use of the Website, as follows:

   (i) For the purposes of sending communications or brochures: until the User asks us to remove a certain item of data (provided the legal requirements to this end are met) or for any other period provided for in the legislation, whichever occurs first.

   (ii) For recruitment purposes: for the appropriate period to pursue the purpose in mind.

   a. Should the candidate be recruited, his/her personal data will be stored as long as the employment relationship lasts, unless a longer period is required by law.

   b. Where candidates are not recruited, taking into account that the functions for which SISCOG hires are, as a rule, highly specialised, it is expectable that candidates wish that their date be stored for a significant part of their active professional career. Accordingly, the data will be stored for up to 10 years or until the candidates withdraw the consent presently given. Each User has the right to withdraw, at any time, his/her consent to store his/her personal data.
   
   

6. Transmission of data. The Users' personal data will be treated by collaborators of SISCOG duly authorised to process such data in the context of performance of their functions, being functionally and contractually bound to process the Users' personal data in accordance with the law and this Privacy Policy.

   Unless the law states otherwise or it is required by any competent entity, SISCOG undertakes not to make this data available to third parties without the User's prior consent, except if necessary for the Use of the Website or to manage interactive User programmes.

   The User further expressly accepts and consents to his/her personal data obtained while using this Website being transmitted, if permitted, to other countries where the servers supporting this Website are located (including any transmission from such locations back to the User's country of residence), in order to operate and develop this Website and SISCOG's services.

   SISCOG may use processors that operate in the context of management of the Website, storage of information in databases or analysis of job applications. These processors will process the data in accordance with the instructions and on behalf of SISCOG. These subcontractors are not authorised to use the aforementioned personal data for any other purpose and the provision of their services shall be subject to confidentiality obligations which comply with the applicable legislation.

   In addition to the aforementioned entities, Users' personal data may be communicated, when required by the applicable legal provisions, to judiciary or law enforcement authorities or any other authorities lawfully entitled to receive them. Users' personal data may, among others, be communicated to administrative and court authorities in the context of proceedings for breach of the general terms of Use of the Website with a view to assessing any possible civil, regulatory or criminal liability.
   
   

7. Data traffic and cookies. SISCOG uses on its Website software and IT systems that, during their normal operation, collect some personal data (called record files) whose transmission is implied in the use of Internet communication protocols. This information is not collected to be associated with identified persons; however, due to its nature, it may, through processing and integration with data held by third parties, make it possible to identify Users.

   SISCOG reserves the right to monitor and analyse traffic and the clickstream flow, i.e. the way and the time to move from one page to another, exclusively for statistical purposes and to gain a better understanding of the similarities, differences and habits of Users with a view to customising and improving the Website. Information may also be placed on the User's computer to enhance the operation of the Website and the Use of the Website. This information is usually called cookies. Cookies are data stored on the User's hard disk drive and not on the Website. They enable the collection of certain information on the User's computer, including the Internet protocol address, the computer’s operating system, the type of browser, an analysis of the Website traffic and demographic profile, albeit anonymised. Should you not wish to receive cookies or should you wish to be informed of their date of installation, you may configure your web browser to this end, provided your web browser has this functionality. You should be aware that if you disable the cookies, you may be unable to view certain parts of this Website. When you visit the Website, our server also automatically records the IP (Internet protocol) address. An IP address is a number automatically assigned to the User's computer by the Internet Service Provider (ISP) each time he/she accesses the Internet. The collection of IP addresses by SISCOG may only be used to organise aggregate and non-personal data on the number of visitors to the Website or to prevent access by a certain visitor. In general, these data may also be used to obtain anonymised statistical information on the Use of the Website and to verify whether it is operating properly.
   
   

8. Links to third-party websites. SISCOG's Website may content hyperlinks (links) to third-party websites. Accordingly, we recommend that you consult the pages of such websites that refer to their privacy policies. SISCOG's Privacy Policy does not apply to third-party websites. SISCOG shall not be liable for the privacy policy or content made available on third-party websites.
   
   
9. Users' rights. In some cases and under certain circumstances, the User has the right to access, rectify, erase and restrict his/her personal data and to the portability of such data. These rights may be exercised at any time in writing by sending a message using his/her email address (which must the same as that previously supplied through the Website) to this email address: ims@siscog.pt.

   SISCOG will respond in writing (including by electronic means) to the User's request not later than 30 (thirty) days after receipt of the request, except in cases of particular complexity, where this period may be extended by a further 30 (thirty)-day period, subject to sending prior justification.

   The User of the Website may also submit complaints to the Portuguese national data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), or any other supervisory authority in the field of personal data protection. The CNPD’s contact details are the following: Rua de São Bento no. 148 - 3rd floor, 1200-821 Lisbon - Tel: +351 213928400 - Fax: +351 213976832 - email: geral@cnpd.pt.
   
   

10. Amendments. SISCOG is regulated by the legislation in force and pledges to comply with this Privacy Policy. Any amendment to the Privacy Policy will be published on the Website. Therefore, we advise you to consult this document regularly. The version published on the Website is the one currently in effect. Notwithstanding, SISCOG may amend this Privacy Policy or alter, modify or cancel access to this Website without prior or subsequent notice. Accordingly, we advise you to read and review this Privacy Policy each time you access the Website, in order to become aware of any changes. Similarly, SISCOG  may review the security policies and processes and the provisions related to data protection as it deems fit.
    
    
11. Consent. By accessing and using the Website, the User expressly, unequivocally and freely declares that he/she consents to SISCOG processing, using automated means, any personal data he/she transmits (including the collection, recording, storage and modification of the aforementioned personal data and their inclusion and organisation in a database) in the terms set forth in this Privacy Policy.

More detailed information on personal data protection may be obtained by consulting the applicable legislation, in particular the GDPR.