SSF Investments

Privacy and Cookies

The services available to you on this site are provided in the form of free access by the owner, which is committed to privacy.

We assure users that no personal data will be provided to third parties without the prior consent of the holder and that none of the personal data provided to us will be transferred, free of charge or commercially, to marketing companies.

The protection of your data is a priority for our company / website.

The use of our website is possible without providing any personal data. However, if a person or company wishes to use any service or product presented or available on our website, it may be necessary to collect and process personal data.

The processing of personal data, such as name, address, email address or telephone number, follows the rules established in the General Data Protection Regulation (GDPR) and is in accordance with the data protection legislation applied in Portugal.

Through this data protection declaration, our company informs the general public of the nature, scope and purpose of the personal data that we collect, use and process. Furthermore, data subjects are informed, through this data protection declaration, of the rights to which they are entitled.

Our company / website has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may, in theory, suffer from potential security gaps, so absolute protection may not be guaranteed. For this reason, all data subjects are free to transfer their personal data to our company via alternative means, for example by telephone.

1. Definitions

The data protection declaration on this website is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration must be legible and understandable for the general public as well as our customers and business partners. To ensure this, we would like to explain the terminology used.

In this data protection declaration, we use the following terms:

a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). 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, an online identifier or to one or more factors specific to physiology, physiology and genetic, mental, economic, cultural or social identity of that person.

b) Data subject
It is understood as an identified or identifiable natural person, whose personal data is processed by the controller.

c) Treatment
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, conservation, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

d) Limitation of treatment
Limitation of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Definition of profiles
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that person’s performance at work, economic situation, health, personal preferences, interests, trustworthiness, behavior, location or movements.

f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data cannot be attributed to a specific individual holding the data without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that personal data is not attributed to an identified or identifiable natural person.

g) Responsible for processing
Responsible for processing is the natural or legal person, public authority, agency or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.

h) Subcontractor
Processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

i) Recipient
The recipient is a natural or legal person, public authority, agency or other body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a specific inquiry in accordance with Union or Member State law shall not be regarded as recipients. The processing of these data by these public authorities shall be in compliance with applicable data protection rules, in accordance with the purposes of the processing.

j) Third parties
Third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the subcontractor and persons who, under the direct authority of the controller or subcontractor, are authorized to process data personal.

k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, provides agreement to the processing of his or her personal data.

2. Name and address of the controller

The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union and other provisions related to data protection is:

Silva, Simões & Filhos Lda
Parque Industrial do Camporês
Rua Amarela Lt. 6
3240-509 Chão de Couce
Ansião
NIPC 503770744

Email: [email protected]
Phone: +351 236 147 370
Website: ssfinvestments.pt

3. Cookies

Our company’s web pages use cookies. Cookies are text files that are saved on a computer system via an Internet browser.

Many websites and servers on the Internet use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was saved. This allows visited websites and Internet servers to differentiate the individual browser from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the cookie’s unique ID.

Through the use of cookies, our website can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

Using a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us to recognize users of our website. The purpose of this recognition is to facilitate the use of our website. The user of the website that uses cookies, for example, does not need to enter access data every time the website is visited, because this is taken over by the website, and the cookie is therefore saved on the user’s computer system. Another example is the cookie from a shopping cart in an online store. The online store records the items that a customer has placed in the virtual shopping cart using a cookie.

The data subject may, at any time, prevent the setting of cookies by means of a setting in the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible on all Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

What types of cookies are there?

There are two groups of cookies that can be used

– Permanent cookies – these are cookies that are stored at the browser level on your access devices (PC, mobile and tablet) and are used whenever you make a new visit to one of our websites. They are generally used to direct navigation to the user’s interests, allowing us to provide a more personalized service.

– Session cookies – are temporary cookies that remain in your browser’s cookie file until you leave the website. The information obtained by these cookies is used to analyze web traffic patterns, allowing us to identify problems and provide a better browsing experience.

Cookies used on this website

For what purposes do we use cookies on our website?

– Strictly necessary cookies – They allow you to browse the website and use its applications, as well as access secure areas of the website. Without these cookies, the services you have requested cannot be provided.

– Analytical cookies – They are used anonymously for the purposes of creating and analyzing statistics, in order to improve the functioning of the website.

– Functionality cookies – They store the user’s preferences regarding the use of the website, so that it is not necessary to reconfigure the website each time they visit it.

– Third-party cookies – Measure the success of applications and the effectiveness of third-party advertising. They can also be used to customize a widget with user data.

Advertising cookies – They direct advertising according to the interests of each user, in order to direct advertising campaigns taking into account users’ tastes, and, in addition, they limit the number of times you see the advertisement, helping to measure the effectiveness of advertising and the success of website organization.

We do not use cookies to:

Collect any personal information (without your express permission)
Collect confidential information (without your express permission)
Transmit personally identifiable data to third parties
Pay sales commissions

Consent to the use of cookies

If the settings of the software you are using to view this website (your internet browser) are set to accept cookies, and you continue to use our website, we will consider that you consent to their use. If you wish to remove or not use cookies from this website, you can disable the use of cookies in your browser. However, this will likely mean that the website will not work as you would like.

How can you manage cookies?

All internet browsers allow the user to accept, refuse or delete cookies, in particular by selecting the appropriate settings in the respective browser. You can configure cookies in the “options” or “preferences” menu of your browser.

Please note, however, that disabling cookies may prevent some web services from functioning correctly, partially or completely affecting website navigation.

Connections

For more information about cookies and their use, we suggest you consult the following links:

Microsoft Cookies Guide
Limpar, ativar e gerir cookies no Chrome
Ativar e desativar cookies Firefox
All About Cookies

4. Collection of data and general information

Our website collects a series of general data and information when a data subject or automated system accesses the website. This general data and information is stored in the server’s log files. Among the elements collected may be:

(1) the types of browsers and versions used
(2) the operating system used by the access system
(3) the website from which an access system reaches our website (so-called referrers)
(4) date and time of access to the Internet website
(5) Internet address (IP address)
(6) Access system Internet access provider (ISP)
(8) any other data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, our website does not draw any conclusions about the data subject.

Rather, this information is necessary to:
(1) deliver the content of our website to the user correctly
(2) optimize the content of our website as well as its advertising
(3) ensure the long-term viability of our information technology systems and website technology
(4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack.

Therefore, the HOLDER analyzes data and information collected anonymously, with the aim of increasing the data protection and data security of our company and ensuring an optimal level of protection for the personal data we process. Anonymous data from server log files is stored separately from all personal data provided by an individual data holder.

5. Subscription to our newsletters

On the HOLDER’s website, users have the opportunity to subscribe to our company’s newsletters. The subscription request for this purpose determines which personal data is collected.

The HOLDER regularly informs its customers, the interested public and business partners through a newsletter about content related to our activity and business offers. The company newsletter can only be received by the data subject if:

(1) the data subject has a valid email address
(2) the data subject has registered by accepting the sending of the newsletter.

A confirmation email will be sent to the email address registered by a data subject the first time, for legal reasons, as part of a double opt-in procedure. This confirmation email is used to prove whether the owner of the email address is authorized to receive the newsletter.

During registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration.

The collection of this data is necessary to understand the (possible) misuse of a person’s email address at a later date and therefore serves the aim of the legal protection of the controller.

Personal data collected as part of a newsletter registration will only be used to send our newsletter. Furthermore, newsletter subscribers may also be informed by email, as long as this is necessary for the operation of the newsletter service or registration in question, such as in the case of modifications to the newsletter system, or in the event of a change in circumstances techniques. There will be no transfer of personal data collected by the newsletter service to third parties. Subscription to our newsletter may be terminated by the data subject at any time. The consent to store personal data, which the data subject provided for sending the newsletter, may be revoked at any time. For the purposes of revoking consent, a corresponding link is provided in each newsletter. It is also possible to unsubscribe at any time by communicating this desire in a different way.

6. Monitoring actions in the newsletter

The HOLDER’s newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails, which are sent in HTML format, to enable log file recording and analysis. This allows for a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the HOLDER can see if and when an e-mail was opened by a data subject and which links in that e-mail were called up by data subjects.

This personal data collected in the tracking pixels contained in the newsletters is stored and analyzed to optimize the sending of the newsletter, as well as to better adapt the content of future newsletters to the interests of the data subject. This personal data will not be transferred to third parties. Data subjects may, at any time, revoke the respective declaration of consent, issued through the “double-opt-in” procedure. Following a revocation, this personal data will be deleted. The HOLDER considers an unsubscription to the newsletter as a revocation.

7. Possibility to get in touch via the website

The HOLDER’s website contains information that allows quick electronic contact with our company, as well as direct communication with us, which also includes a general electronic mail address (email address). If a data subject contacts us via email or via a contact form, the personal data transmitted by the data subject will be automatically saved. Such personal data transmitted voluntarily by a data subject are retained for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

8. Personal data deletion and blocking routine

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is permitted by the European legislator or other legislators to which the company is subject.

If the storage purpose is not applicable, or if a retention period prescribed by the European legislator or another competent legislator expires, the personal data are blocked or erased in accordance with legal requirements.

9. Data subject rights

a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the persons responsible for data control in the company.

b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, European directives and regulations grant the data subject access to the following information:

  • the purposes of the treatment;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • where possible, the envisaged period for which personal data will be retained or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller the rectification or erasure of personal data, or the restriction of the processing of personal data relating to the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • when personal data are not collected directly from the data subject, any available information regarding their origin;
  • the existence of automated decisions, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic in question, as well as the significance and envisaged consequences of the processing for the data holder.

Furthermore, the data subject has the right to obtain information as to whether personal data is transferred to a third country or to an international organization. If this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to take advantage of this right of access, he or she may, at any time, contact any employee of the company responsible for the processing, the HOLDER.

c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erase (right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay if a for the following reasons:

The personal data are no longer necessary in relation to the purposes for which they were collected or were otherwise processed.
The data subject withdraws consent to which the processing is based pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR and when there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(n) 2 of the GDPR.
Personal data has been processed unlawfully.
Personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
Personal data was collected in connection with the provision of information society services referred to in Article 8(1) GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data held by the , he or she may, at any time, contact any employee of the controller. An employee of the HOLDER must immediately ensure that the deletion request is complied with immediately.

If the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking into account available technology and the cost of implementation , will take reasonable measures, including technical measures, to inform other entities processing personal data that the data subject has requested erasure, as long as the processing is not necessary.

e) Right to object to treatment
Each data subject has the right granted by the European legislator to obtain from the controller an objection to processing where one of the following situations applies:

The accuracy of the personal data is contested by the data subject, for a period that allows the controller to verify the accuracy of the personal data.

The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request opposition to the processing of personal data held by the HOLDER, he or she may, at any time, contact any employee of the controller. The HOLDER will provide opposition to the treatment.

f) Right to data portability
Each data subject has the right granted by the European legislator, to receive his or her personal data, which was provided to a controller, in a structured, commonly used and machine-readable format. You have the right to transmit these data to another controller, without obstruction from the controller to whom the personal data were provided, provided that the processing is based on the consent provided for in Article 6(1)(a) . GDPR or Article 9(2)(a) GDPR, or in a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, whenever technically possible and, when it does, does not affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may, at any time, contact any employee of the HOLDER.

g) Right to object
Each data subject has the right to object, at any time, for reasons related to their particular situation, to the processing of personal data concerning them, based on paragraphs e) or f) of article 6, no. 1 of the GDPR. This also applies to the creation of profiles based on these provisions.

The HOLDER will stop processing personal data in the event of objection, unless it is possible to demonstrate legitimate reasons for the processing that override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If the HOLDER processes personal data for direct marketing purposes, the data subject shall have the right to object, at any time, to the processing of personal data relating to him or her for such marketing actions. This also applies to profiling, as it is related to this direct marketing. If the data subject objects to the HOLDER the processing for direct marketing purposes, the HOLDER will no longer process the personal data for these purposes.

Furthermore, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data relating to scientific or historical research purposes, or for statistical purposes, in accordance with paragraph 1 of the Article 89 GDPR, unless the processing is necessary for the performance of a task for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the HOLDER. Furthermore, the data subject is free in the context of the use of information society services and, notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means and using technical specifications.

h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based exclusively on automated processing, including profiling, as long as the decision (1) does not involve data necessary to enter into or perform a contract between the data subject and a data controller or (2) is not authorized by Union or Member State law to which the controller is subject, or (3) is not based on the data subject’s explicit consent.

If the data (1) is necessary for the conclusion or performance of a contract between the data subject and a data controller or (2) is based on the explicit consent of the data subject, the HOLDER will implement appropriate measures to safeguard the rights and freedoms of the data subject and his or her legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights relating to automated individual decision-making, he or she may, at any time, contact any employee of the HOLDER.

i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of the HOLDER.

10. Data protection provisions about the application and use of Facebook

On this website, the controller has integrated components from the company Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which generally allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or allow the Internet community to provide personal or business-related information. Facebook allows social media users to create private profiles, upload photos and create a network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside the United States or Canada, the parent company is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download the display of the corresponding Facebook component.

If the data subject is logged in at the same time on Facebook, Facebook will detect every call-up to our website by the data subject – and for the entire duration of their visit to our website – and which specific pages were visited by the data subject. person concerned. This information is collected through Facebook components and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated on our website, for example the “Like” button, or if the data subject submits a comment, Facebook matches this information with the personal Facebook user account of the data subject. and will retain personal data.

If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from Facebook before a call-up to our website is made.

The data protection information published by Facebook, available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. Furthermore, the configuration options offered by Facebook to protect the privacy of the data subject are explained. Furthermore, different configuration options are available to allow the elimination of data transmission to Facebook.

11. Data protection information about the application and use of Google Analytics (with anonymization function)

On this website, the controller has integrated the Google Analytics component (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection and analysis of data about the behavior of website visitors. A web analysis service collects data about the website from which a person arrived (the so-called referrer), which pages were visited or how often and for how long a page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of the Google Analytics component is to analyze traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activity on our website, and to provide other related services.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission arrangements .

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet website, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass this personal data collected through the technical procedure to third parties.

The data subject may prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus deny the setting of cookies. Such an adjustment would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. Additionally, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

The data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google. To do this, the data subject must download an additional browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This add-on tells Google Analytics via JavaScript that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. Installing extra browser add-ons is considered an opposition to Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the extra browser add-ons.

12. Legal basis for data processing

The GDPR serves as the legal basis for data processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with the supply of goods or any other service, the processing is carried out on the basis of article 6. º, no. 1,b of the GDPR. The same applies to processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. When our company is subject to a legal obligation by which the processing of personal data is necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person.

13. The legitimate interests of the controller or a third party

When the processing of personal data is based on Article 6(1) GDPR, our legitimate interest is to conduct business in favor of the well-being of all our employees and shareholders.

14. Period for which personal data will be retained

The criteria used to determine the period for which personal data will be stored is the respective legal retention period. After expiration of this period, the corresponding data is deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract. In the case of CVs sent through the recruitment form, they will be kept for 2 months.

15. Provision of personal data as a legal or contractual requirement; Necessary requirement to conclude a contract; Obligation of the data subject to provide personal data; possible consequences of failure to provide such data

The provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual clauses (e.g. information about the contractual partner). Sometimes it may be necessary, in order to conclude a contract, for the data subject to provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide personal data when our company signs a contract with him. Failure to provide personal data will result in the contract with the data subject not being concluded.