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VIRTUAL POWER SOLUTIONS S.A. PRIVACY POLICY

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1.Legal information relating to data protection

 

At Virtual Power Solutions S.A. (the „Company” or „VPS”) we care about the safety of our customers and we are subject to the highest privacy standards. We know that the use of your personal data requires your complete confidence therefore we will only use your personal data for clearly identified purposes and in accordance with your data protection rights.

 

However, as no method of transmission or electronic data storage is 100% secure, we count on your attention to prevent any incidents related to computer fraud, risks or any other infraction in which your information can be accessed or disclosed without our expressed authorisation and for which, of course, we cannot be held responsible.

 

We are committed to ensuring the transparency, confidentiality and integrity of your personal data.

 

This Privacy Policy of March, 2021 takes effect when accepted by the Board of Virtual Power Solution S.A. and replaces our Privacy Policy dated May, 2018.

 

 

2. Who is responsible for the processing of your personal data

 

VPS is responsible for the processing of the personal data of its customers and / or potential customers as well as its suppliers and/or potential suppliers (whether natural or legal persons, represented by its managers, administrators or attorneys-in-fact), the personal data of which the Company gets into the possession of on the legal grounds described in section 5.

 

This policy is intended to describe the use of your personal data by the employees of the Company and any third party the Company shares the personal data with.

 

 

3. How do we collect your personal information

 

Your personal data will be collected and processed in situations and scenarios described in section 5. For your privacy, we advise you not to include personal data, and in particular, sensitive and/or confidential data in the emails you send us, such as credit card numbers.

 

We do not knowingly collect personal information from minors. In your capacity of legal guardian, we thank you for not allowing your children, under the age of 13, to send us their personal information.

 

 

4. For what purposes can your personal data be used

 

Your personal data will be collected and used for (i) delivering our contractual obligations, (ii) performing our legal obligations, (iii) protecting our legal interests, (iv) providing customer services (orders, transactions on paper or online (see also section 9), (v) marketing activities (communication of information about our campaigns, news and other services, Company newsletters, requests for comment on the satisfaction of our products and services), and (vi) if you are a job applicant, for our recruitment and staffing activities. Under the data protection legislation in force in Portugal and in the European Union (General Data Protection Regulation), the use of personal data must be justified under at least one legal basis for the processing of personal data, as described in section 5.

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5. Legal basis for the processing of personal data

 

  1. When you share personal information with us by establishing and/or maintaining business with us or by simply contacting us whether as part of exploring business opportunities, signing any contract, opening an on-line customer account when starting using our products or services; or otherwise (for example, if you are a job applicant, sharing your curriculum vitae, salary expectations and other person data with us) we consider that you have carefully reviewed and accepted this Privacy Policy and you agreed to the processing of your personal data for the respective;

  2. When processing is required to conclude a contract or to execute it;

  3. When the processing is necessary for the fulfilment of the legal obligations to which the Company is subject;

  4. When processing is necessary to achieve a legitimate interest and our reasons for its use prevail over the data protection rights of the customers and / or potential customers as well as its suppliers and/or potential suppliers;

  5. When processing is necessary so that we may exercise or defend a right in a legal proceeding to be brought or brought by a third party against us, or our customers and/or potential customers as well as its suppliers and/or potential suppliers.

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6. What personal data can be collected

 

The following categories of personal data may be collected through the channels and services described in this Privacy Policy:

 

Data collected by the company:

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  • Name Your company & business sector

  • Email

  • Phone

  • Address

  • NIF (VAT ID, if applicable)

  • Data generated while you use our products or services

  • Cookies while you visit our website (please see section 9)

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7. How do we keep your personal data safe

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We use a variety of security measures, including encryption and authentication tools such as passwords, to help protect and maintain the security, integrity, and availability of your personal information.

 

Although data transmission via the internet or website cannot guarantee complete security against intrusions, the Company and its service providers and suppliers, business partners, consultants and advisors make reasonable every effort to implement and maintain physical, electronic, and procedural safeguards to protect your personal data in accordance with the applicable data protection requirements. Among others, we have implemented the following:

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  • Restricted personal access to your personal data based on the criterion of "need to know" and only within the scope of the purposes communicated;

  • Only our employees, service providers, business partners, consultants and advisors whose functions and/or tasks require this and who previously bind themselves to secrecy, GDPRcompliance and confidentiality will have access to the personal data processed by the Company;

  • Processing only personal data that are appropriate, relevant and not excessive and for the time strictly necessary will be processed;

  • Transfer of data collected only in encrypted form or with password protection;

  • Storage of highly confidential data (such as credit card information) only in encrypted form;

  • Protection of information technology systems through firewalls, to prevent unauthorised access to your personal data;

  • Continuous monitoring of access to information technology systems to prevent, detect and prevent the misuse of your personal data.

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8. How long we keep your personal information

 

We store your personal data only for as long as it is necessary for the purpose for which it was collected.

 

Once the maximum period of conservation has been reached, your personal data will be irrevocably anonymised (anonymised data may be retained) or destroyed in a secure manner.

 

For the purposes described in this Privacy Policy your personal data will be kept for a maximum period of 10 years from the last transaction or exchange with VPS (including its legal predecessors). In case of curricula vitae sent to us when applying to VPS (including its legal predecessors) jobs posted on our website, up to a maximum term of 5 years.

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9. With whom we can share your personal information and how we keep you safe

 

The Company does not sell, market or transfer to third parties your personally identifiable information. This does not include trusted third parties who help us manage or host our website or mobile applications by providing services to our customers, suppliers, business partners, consultants and advisors who need-to-know about the personal data processed by us, provided such third parties contractually agree to keep such information confidential to the level that guarantees GDPR-compliance.

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We may also share your personal information with our group member companies.

 

The Company’s website uses only those cookies that help us (i) to provide you with the best possible user experience, (i) to continue to improve our services and provide better and more useful resources to our website users and/or (iii) which are necessary for the safe operation of the website. By navigating the website you accept the use of such cookies by us and/or our website host supplier. By navigating our website you accept the use of such cookies by us and/or website host. Personally non-identifiable cookies may be provided to other parties for marketing, advertising or other uses.

 

Cookies are small software tags that are stored in your computer in the browser, retaining information related to your preferences, which does not include personal data , in other words cookies are pieces of information that are commonly used by many sites for record keeping purposes that may help remember, for example, your preferences. A cookie by itself does not personally identify any user of a particular website.

 

Please note that although you may find yourself on a website of the Company, you may also be referred to third-party website links, as we may include or offer third-party products or services on our platforms. These third-party websites have their own privacy policies independent of ours. These policies are neither managed nor controlled by the Company, which therefore does not assume any responsibility for them. However, we seek to protect you from risks even in such cases, therefore we recommend that you carefully read the terms and conditions and privacy policies of these sites before submitting any information or personal data.

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10. Virtual Power Solutions Contact Details

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Email: mail@vps.energy

Phone: +351 239 791 400, available from 9:00 a.m. to 6:00 p.m. from Monday to Friday

Office: Ladeira da Paula, nº6, 3040-574 Antanhol, Coimbra, Portugal

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11. Your data protection rights and the right to complain to your supervisory authority

 

If you have any questions regarding our use of your personal data, you should first contact our services.

 

Subject to certain conditions, you may have the right to request us to:

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  • Provide you with additional information about how we use your personal information;

  • provide you with a copy of the personal information you have provided to us;

  • update any inaccuracies or changes in personal data that we retain;

  • erase personal data whose use is no longer legitimate;

  • limit how we use your personal data until the complaint is investigated.

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Your exercise of these rights is subject to certain exceptions intended to safeguard the public interest (prevention or detection of crimes) or our legitimate interest (see section 5). If you exercise any of these rights, we will analyse your request and respond within 30 days. If you are dissatisfied with our use of your personal data or with our response after exercising any of these rights, you have the right to submit a complaint to the supervisory authority - National Data Protection Commission - CNPD | Rua de São Bento, nº 148, 3º, 1200-821 Lisbon | Tel: +351 213928400 | Fax: +351 213976832 | e-mail: geral@cnpd.pt) or to bring legal action on this basis.

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Coimbra, March, 2021

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