I- Our personal data collection devices and media in use:

We have, edit and manage the following media for processing personal data
– IT system consisting of a set of software solutions supported by a set of hardware devices and other similar solutions, including email services and other external digital repositories and communication solutions.
– Paper files stored in cupboards and shelves in rooms with restricted access;
– Brasa Calçado website – https://www.brasacalcado.com/

II- Personal and material scope of this Privacy Policy:

This privacy policy binds the company exclusively with regard to the personal data it collects, processes and circulates.
The same policy or similar will also be assumed, by means of contracts entered into with Brasa Calçado, by the entities that process the same personal data on its behalf.
The provision through the Brasa Calçado website of links to other websites outside Brasa Calçado is done in good faith and in the interest of the user, and Brasa Calçado cannot be held responsible in any way for the collection, processing and destination of data on these websites, nor for the reliability, accuracy, legality and functionalities available therein, and therefore this privacy policy does not apply to them.
Brasa Calçado considers it obligatory and will assume for all intents and purposes, without the possibility of proof to the contrary, that you have read the privacy policies of all the websites you access.

III- The reason for and publication of this Privacy Policy:

In addition to implementing it in its organizational processes, Brasa Calçado has drafted this Privacy Policy in order to make available, make known and publicize an instrument explaining the general rules of privacy and processing of the personal data it collects, always in strict compliance with the relevant legislation.
To this end, the text of this privacy policy will be available on paper in a visible place and in digital format on the website https://www.brasacalcado.com/.
The provisions of this Privacy Policy complement those stipulated in formal or informal contracts with Brasa Calçado.
We ask you to please read this Privacy Policy carefully, as providing your personal data, either in person or when accessing the aforementioned website, implies that you know and accept the conditions contained herein and their processing for the lawful and legitimate purposes provided for by law.
Brasa Calçado expressly reserves the right to change this privacy policy at any time, the result of which will be duly published by the same means.

IV- Concept of personal data:

Personal data means any information or record of any nature and regardless of its support or format, namely sound, image, writing, chirograph or characteristic, relating to an identified or identifiable natural person.
An identifiable person is one who can be directly or indirectly identified by reference to one or more specific pieces of personal data, taken alone or in combination, in particular their physical, physiological, psychological, economic, ethnic, cultural, geographical, social identity or their location.

V- The entity responsible for processing personal data:

The entity responsible for collecting and processing personal data is Brasa Calçado, which, in the context of its relationship with the holder of the personal data, establishes, always on a lawful and legitimate basis, which data is collected, the means of processing and the purposes of such collection and processing.

VI- Types of personal data collected and processed:

As part of its activity, Brasa Calçado collects and processes the following:

1. Personal data necessary for the supply of products to its customers, processing data such as name, tax identification number, address, telephone number and email address, among other strictly necessary, proportionate and lawful data.
2. Personal data necessary for the performance of the employment or service contract entered into with its employees, processing in this context data such as name, identification document number and other data, tax identification number, household composition, social security number, address, telephone numbers and email address, health data, access data, location data, among others that are strictly necessary, proportionate and lawful.
3. Personal data necessary to comply with legal obligations, both towards public and private entities, processing data such as name, identification document number and other data, tax identification number, household composition, social security number, telephone number(s) and email address, health data and other strictly necessary, proportionate and lawful data.
4. Data necessary for managing customers and suppliers, contracting and managing the contractual relationship with customers and suppliers, sending suggestions, information and marketing actions, publicizing campaigns, promotions, advertising and news about products, managing complaints, dealing with telephone number(s) and email addresses, among other strictly necessary, proportionate and lawful data.
5. All personal data necessary for the exercise of Brasa Calçado’s rights within the scope of the relationships referred to in the previous items, and in the pursuit of its activity and legitimate interest, in particular accounting, tax and administrative management, litigation management, judicial evidence, fraud detection, revenue protection and auditing, network and systems management, information security and physical security control, and facilities security.
   Notwithstanding compliance with legal rules or legitimate orders from competent authorities regarding the storage and transmission of data, Brasa Calçado only processes personal data necessary for its activity, to the fair and strict extent required by the nature of the contractual or other relationship established with the data subject, or their prior, legitimate, lawful and informed consent.

VII- When and how personal data is collected:

Brasa Calçado collects personal data in person, in writing, by telephone or through its websites.
As a rule, personal data is collected when the relationship or collaboration, contractual or otherwise, necessary for the pursuit of Brasa Calçado’s activity, between Brasa Calçado and the data subject begins.

Our website may collect contact forms. These will be sent directly to our email server via an encrypted connection and will only be available to those responsible for processing them. Whenever necessary, the information will be made available for evaluation by a person responsible for each specific department.
Some personal data is compulsory and necessary for the start and normal and legal development of the aforementioned relationship or collaboration, so in the absence or insufficiency of this data, it will not start or continue, in which case Brasa Calçado will inform the data subject of this compulsory and necessary nature.

Apart from data of this nature, data included on any public list and data that may be used in the legitimate interest of Brasa Calçado, your data will only be collected and processed if and for the purposes to which you have previously consented, in a free, informed, specific and unequivocal manner, by means of a written or oral statement or by validating an option, namely to subscribe to newsletters or marketing communications, in which case the other rules of this privacy policy will apply.
If you wish to stop receiving these communications, you can object at any time.

The data collected will be processed documentarily, either on paper or digitally, in strict compliance with the legislation governing the protection of personal data, being stored and contained in paper files and/or a specific database, created and managed for this purpose and with restricted and exclusive access to Brasa Calçado employees who necessarily have to process them in the pursuit of its activity. Under no circumstances will the data collected be used for any purpose other than that for which the data subject’s consent was given, if this is necessary, or for the lawful and legitimate purpose for which it was collected.

VIII- Purposes for collecting and processing personal data:

In general, the personal data collected is used to manage customers, suppliers and employees, to contract and manage the contractual relationship with customers, suppliers and employees, to receive and provide the contracted supplies, to tailor the provision of supplies to the customer’s needs and interests, to send suggestions, for information and marketing purposes, to publicize campaigns, promotions, advertising and product news, carrying out market research and satisfaction surveys, managing complaints, accounting, tax and administrative management, litigation management, judicial evidence, fraud detection, revenue protection and auditing, network and systems management, information security and physical security control, premises security, compliance with legal obligations and for all other purposes for which Brasa Calçado has a legitimate interest under the law.
When the data is collected, or when you request it, you will be informed in more detail about how we process your data.

IX- Time limits for keeping your personal data:

Whenever there is a specific legal requirement to keep data for a minimum period of time, Brasa Calçado will comply with this.
Brasa Calçado will keep your personal data stored for the minimum period of time strictly necessary for the purpose for which the information is collected and processed, after which it will be deleted.

X- Right of access, rectification, opposition, erasure, limitation and portability of your personal data:

Brasa Calçado guarantees the holder of personal data the right to access, rectify, oppose, erase, limit and port their personal data.
You can exercise the rights mentioned above by contacting Brasa Calçado directly at our head office at R. de Revinhade, 4650-373, Felgueiras – Portugal.

If you consider it appropriate, you can file a complaint with the National Data Protection Commission – Av. D. Carlos I, 134 – 1.º 1200-651 Lisboa – Tel.: +351 213928400 – Fax: +351 213976832 – e-mail: geral@cnpd.pt

XII- Measures we adopt for the security of your personal data:

Brasa Calçado observes the best practices, for which it adopts the technical and organizational measures appropriate to the risk, in the field of security and protection of personal data, having for this purpose approved and implemented a demanding plan of compliance with the objectives, the Law and the interest of the holders of personal data, capable of safeguarding the protection of the data made available to us by all those who in some way relate to us, in order to protect them against their dissemination, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of illicit treatment.

Thus, the digital or paper personal data collection form(s), whether filled in at Brasa Calçado’s physical premises or on the website, (which require encrypted browser sessions) are stored securely in our physical repositories and digital systems.

All the personal data you provide us with about yourself is stored in a digital repository owned by SOLPRÉ or its subcontractor, under cover of all the advanced physical and logistical security measures that we believe are indispensable for the protection of your personal data.

Whenever, in the legitimate and lawful pursuit of Brasa Calçado’s business objectives, it adopts measures to monitor its employees, particularly with regard to access control, working hours, tasks and productivity, movement and transportation, not only will those affected have prior knowledge of the respective implementation – and, whenever legally necessary and lawful, their consent will be requested – but the tools used for this purpose will ensure the same level of security for the personal data they collect and process.

XIII- Communication of data to other entities, subcontractors or third parties:

Brasa Calçado may use subcontractors to collect and process data for the same purposes, obtaining from these entities, by contract, a guarantee of reputation and an obligation to develop the appropriate technical and organizational measures to protect the data and ensure the defence of the rights of the data subjects. In certain circumstances determined by law, certain personal data may have to be communicated to public authorities, such as tax authorities, courts and security forces.

In this way, any of these subcontractors will process the personal data of our Clients, in the name and on behalf of Brasa Calçado, under the obligation to adopt the technical and organizational measures appropriate to the risk in order to protect personal data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access and against any other form of unlawful processing.

XIV- Transfer of personal data:

The pursuit of Brasa Calçado’s activity may imply the transfer of your data outside Portugal.
In this event, Brasa Calçado will strictly comply with the applicable legal provisions, particularly with regard to determining the reliability and suitability of the destination country with regard to the protection of personal data and the requirements applicable to such transfers.