Privacy, Cookies and Data Protection Policy

Commitment to Comply with Applicable Data Protection and Privacy Laws

Sonae IM is committed, at all times, to comply with the applicable laws regarding, namely, Data Protection, Privacy and Information Security, in order to protect your personal data when processed by Sonae IM.

In order for Sonae IM to provide you its services and website experience, Sonae IM will sometimes need to collect and use your personal data.

As such, this Data Protection, Privacy and Cookies Policy (henceforth, “Privacy Policy”) has the purpose to inform and explain you the following:

  • what personal data Sonae IM may collect about you;

  • how Sonae IM will use the personal data it collects about you;

  • when Sonae IM may use your details to contact you;

  • whether Sonae IM will disclose your details to anyone else;

  • your rights regarding the personal data you provide to Sonae IM;

  • the use of cookies on Sonae IM websites and how you can reject cookies.

Sonae IM website includes social media features, including the “Follow” button of Facebook, Twitter and LinkedIn.

These features may collect your IP Address and the page you are visiting on our website, and may set a cookie to enable the feature to run properly. Your interactions with these features are managed by the privacy policy of the company providing it.

Our websites also include links to other websites whose privacy practices may differ from those of Sonae IM. If you submit personal data to any of those websites, your information is managed by their privacy policies. Sonae IM is not liable in any way for the use of information outside our website.

Who we are

Sonae Investment Management – Software and Technology, SGPS, S.A. (“Sonae IM”), duly established under the laws of Portugal, with a share capital of € 25.650.000,00, with registered office located at Lugar do Espido, Via Norte, 4470-177 Maia, Portugal, and which is registered under the Commercial Registry Office of Maia under number 505 195 011, is the responsible company for providing the corresponding services and running the website www.sonaeim.com, by which the users have web access to Sonae IM’s information about its commercial activities, as developed from time to time.

Collection and Processing of Personal Data

Your personal data may be requested when you contact or request a contact from Sonae IM - namely for a meeting with Sonae IM -, registry and participation in events organized by Sonae IM, and may be processed for recruitment processes for job opportunities and/or spontaneous job applications.

The personal data processing by Sonae IM under its job opportunities recruitment and selection processes and/or spontaneous job applications is also subject to a specific Recruitment Privacy Notice - to be read together with this Privacy Policy -, available through the following link:

https://sonaeim.csod.com/clientimg/sonaeim/emailUploads/Geral/Recruitment/Recruitment_Privacy_Notice_SONAE_IM.pdf

For clarity purposes, the types of personal data that may be subject to processing by Sonae IM for the purposes below defined are the following:

  • Name;

  • E-mail;

  • Phone number;

  • Address;

  • Date of birth;

  • Qualifications/Experience/Employment history;

  • Skills and expertise;

  • Information about your company, such as the name and your role within the company;

  • Photos, images and sound recordings (strictly related to Sonae IM events attendance).

Use and Purpose of Collected Personal Data

Sonae IM may process your collected personal data (i) to contact you when request a contact from Sonae IM and/or within the commercial or professional relationship you may establish with Sonae IM, (ii) for managing and publicize events organized by Sonae IM, (iii) for Sonae IM’s website use, and to provide general statistics regarding use of Sonae IM website, and (v) for recruitment and selection processes.

We may process your personal data to contact you when request a contact from Sonae IM and/or within the commercial or professional relationship you may establish with Sonae IM.

The legal basis for the said processing is the necessity for the purposes of the legitimate interests pursued by Sonae IM or by a third party.

We may process your personal data to manage and publicize events organized by Sonae IM, including your invitation, registration, participation and internal and external publicizing of the relevant event.

The legal basis for the said processing is the necessity for the purposes of the legitimate interests pursued by Sonae IM or by a third party, and/or consent (previous consent will be requested in case of video, audio or image collection of the event participants).

We may process your personal data to ensure our site is relevant and adequate to your needs, including to:

  • To administer our websites, including troubleshooting, data analysis, testing, statistical and survey purposes;

  • Analyze users’ use of the website to provide general statistics;

  • For purposes made clear to you at the time you submit your information – for example, to provide you with information you have requested about Sonae IM’s activity.

The legal basis for the said processing is the necessity for the purposes of the legitimate interests pursued by Sonae IM, considering the above identified purposes and interests.

We may process your personal data to recruitment and selection processes, which includes applications and CV’s review, and internal process of selection in accordance with Sonae IM’s identified needs.

The personal data processed by Sonae IM hereunder is also subject to a specific Recruitment Privacy Notice - to be read together with this Privacy Policy -, available through the following link: https://sonaeim.csod.com/clientimg/sonaeim/emailUploads/Geral/Recruitment/Recruitment_Privacy_Notice_SONAE_IM.pdf.

The legal basis for the said processing is (i) the necessity to take steps at the request of the relevant data subject prior to entering into a contract with Sonae IM, and (ii) the necessity for the purposes of the legitimate interests pursued by Sonae IM in reviewing the applications and submitting the candidates to an internal selection process, in accordance with previous defined criteria.

Lawfulness of Processing of Personal Data

As stated, all personal data processing operations carried out by Sonae IM are lawful and have a legal basis, either (i) based on your consent to the processing of the relevant personal data for one or more specific purposes, or (ii) because the processing is necessary for the performance of a contract with Sonae IM to which you are a party or in order to take steps at your request prior to entering into a contract with Sonae IM, or (iii) because the processing is necessary for compliance with a legal obligation to which Sonae IM is subject, or (iv) because the processing is necessary for the purpose of the legitimate interests pursued by Sonae IM or by third parties.

Retention of Personal Data

Sonae IM will retain your personal data as needed for the relevant activity or purpose, and, in any event, considering any applicable retention period defined by applicable law (legal obligation). If you wish to change your personal data or request that we no longer use it, in accordance with the applicable law, please contact us through the following e-mail contact: hello@sonaeim.com.

What are cookies?

Cookies are text files stored on your browser when you visit a website. Most websites use them to improve the user’s experience and the performance of the websites.

How does Sonae IM use Cookies?

Sonae IM uses cookies to record details about your relevant current session and language preferences and gather statistics to optimize the functioning of the website. Some features on the website may not work properly if you do not activate the use of cookies.

What types of cookies does Sonae IM use?

Sonae IM uses the following cookie types:

Session Cookies – These are temporary files that are created and only available until users close their browser. When users access their browser again, cookies will no longer be stored. The information obtained allows to manage sessions, identify problems and provide an improved browsing experience.

Performance Cookies - These cookies are used to analyze the use of our website, allowing to feature items or services tailored to our users’ interests, while monitoring the website performance, knowing which pages are most popular, what is the most effective method to link pages or determining why some pages report error messages. These cookies are used only to create and analyze statistic data, never collecting any personal data.

Functionality Cookies – Functionality cookies allow us to remember users and tailor our website to their browsing preferences. This way there is no need to reset preferences or customize profiles whenever visiting it.

How can you manage cookies?

Users may allow, block or delete Cookies placed on their devices in the settings menu of the browser installed in their computers. Please read the Help tab of your browser to learn more about how to enable “private browsing” or to disable certain Cookies.

Cookie settings in Chrome: for more information, please check out Chrome Help Center or the Help tab on your browser

Cookie settings in Firefox: for more information, please check out Mozilla Support or the Help tab on your browser

Cookie settings in Safari and IOS: for more information, please check out Apple Support or the Help tab on your browser

Cookie settings in Internet Explorer: for more information, please check out Microsoft Support or the Help tab on your browser

Data Transfer to Third Parties

Sonae IM does not transfer your personal data to third parties, except where needed for the execution of contracted services and/or for compliance with legal obligations that are applicable to Sonae IM.

Such transfer to third parties is, in any case, made in accordance with the applicable data protection law, and within the defined purposes and legal basis.

Sonae IM may share the personal data, to the extent strictly necessary, with the following entities:

  • Public entities, within the necessary compliance of legal obligations applicable to Sonae IM;

  • Service providers that provide services to Sonae IM within the above defined purposes.

The provision of information or services by Sonae IM to its users, namely, through its website, may involve the use of services of subcontracted third parties, which may imply access by these third parties to your personal data.

In these circumstances and where necessary, Sonae IM will only use subcontracted entities which present sufficient guarantees to carry out appropriate technical and organizational measures in a way that the processing meets the requirements of the applicable standards in accordance with the level of security appropriate to the risk and sensibility of the personal data in question, and such guarantees will be established by contract signed between the Sonae IM and each of these third parties.

Transfer of personal data to third countries or international organizations

If Sonae IM has to transfer collected personal data to a third country outside the European Union and not included in the list of countries that the EU has already considered to meet adequate levels of personal data protection. In such cases, Sonae IM will ensure that such personal data transfers are carried out in strict compliance with applicable legal standards that result from the applicable data protection laws, namely, the GDPR.

Security of your Personal Data

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the risks, of probability and variable severity, for your personal data, Sonae IM and all entities subcontractors apply the appropriate technical and organizational measures to ensure a level of safety appropriate to the relevant risk.

Sonae IM uses a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure.

Sonae IM secures the personally identifiable information you provide on computer servers in a controlled, secure environment protected from unauthorized access, use, or disclosure.

In case of need to subcontract services to third parties that may have access to your personal data, Sonae IM subcontractors will adopt the security and organizational measures, as well as the necessary technical measures, necessary to the protection of the confidentiality and security of your personal data, in order to prevent, namely, unauthorized access, loss or destruction of your personal data.

Your Rights under the GDPR as a Data Subject

Under the, and in accordance with, the GDPR, as data subject and in relation to the personal data processed by Sonae IM, you have the right to request from Sonae IM access to, rectification or erasure of your personal data or restriction of processing concerning you or to object to processing, as well as the right to data portability.

We will use reasonable efforts, within our legal duty, to supply, correct or delete personal data about you on our files.

For the said purposes, please contact us through the following e-mail contact: hello@sonaeim.com.

Where the processing is based on your consent for the relevant processing and purpose, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Without prejudice of all the means of contact between you and Sonae IM, you have, in any case, the right to lodge a complaint with a supervisory authority.

Incident Response

Sonae IM has implemented an incident management system related to data protection, privacy and information security.

We strive to maintain advanced threat detection technologies to help identify and respond to security or privacy events (and any personal data breaches under the GDPR) without delay, with Sonae IM being at all times committed to implement the appropriate technical and organizational measures to ensure an adequate level of security appropriate to the nature and characteristics of the personal data processed by Sonae IM.

Changes to Sonae IM’s Privacy Policy

This Privacy Policy may be updated from time to time, so we suggest you check it regularly.

In any case, if material or relevant changes are made to this Privacy Policy, namely, affecting how we would like to use your personal data, we will provide a more prominent notice, which may include an email notification or a notice when accessing Sonae IM’s websites.

Sonae IM Contacts

For the exercise of any kind of data protection and privacy rights or for any matter relating to data protection, privacy and information security issues, you may contact Sonae IM through the following e-mail address: hello@sonaeim.com, describing the subject of the request and indicating an e-mail address, a telephone contact address or a mailing address for reply.

For your information, Sonae IM’s general contacts are the following:

  • Address: Maia - Lugar do Espido, Via Norte, 4470-177 Maia, Portugal;
  • E-mail: hello@sonaeim.com