Privacy Policy

a. OurCommitment to Privacy

SonaeSGPS, S.A. processes personal data with transparency and security. We applythis commitment in our daily relationship with our investors, business partners,customers and suppliers. Privacy and security of data entrusted to us is apriority.

Weare committed to collect, store, process, transfer and erase personal data ofour investors, business partners, customers and suppliers only in a transparentway and when they are needed to offer our best services. We inform you of howwe use your personal data and for what purposes, assuring that we collect,share and store those data applying security and data protection bestpractices.

Whenyour personal data are collected, stored, processed, transferred or erased bythird parties, we demand the same level of privacy and security.

Wewant you to feel confident that your data are safe with us, since we willalways be committed to protect your privacy, and take very seriously ourresponsibilities on the protection of your personal data. 

Wheneveryou have any question on the use we make of your personal data we will be availableto help you through the following channels:

- Address: Lugar do Espido, Via Norte, 4471-909Maia

- Electronicmail: protecaodedados@sonae.pt

Youmay also contact our Data Protection Officer using the same address and theelectronic mail dpo@sonae.pt.

 


b.Who isResponsible for Your Personal Data

SONAESGPS, S.A., with head office at Lugar do Espido, Via Norte,4470-909 Maia, registered with the Registrar of Companies with registration number500 273 170, with a share capital of €2.000.000.000,00,(SONAE), is responsible for processing your personal data under the terms ofthe General Data Protection Regulation and of related local data protectionlaws applicable in the countries in which it operates.

 

c.PersonalData We May Collect

Throughoutthis Privacy Policy, "Personal Data” means information relating to you which allowsus to identify you, directly or indirectly. Your personal data may include, asexamples, your name, your tax number, your address or electronic mail, your transactionsand your contacts with us.

Wemay receive your personal data from other companies, namely when they collect,process or store them in the context of a service agreement.

SonaeSGPS, S.A. may collect the following categories of personal data: 

        i.  Investor/Shareholderidentification and contact data – full or abbreviated name, identificationnumber, tax number, address, telephone number, e-mail and number of shares held;

      ii. Customeridentification and contact data – full or abbreviated name, address, telephonenumber, e-mail;

    iii. Supplierdata – in the case of individuals, full name and tax number; in the case ofcompanies, name and contact of representatives;

    iv. BusinessPartners data – in the case of individuals, full name and tax number; in thecase of companies, name and contact of representatives.

 

d.Howand Why We Use Your Personal Data

Weuse your personal data with the following purposes:

- Togive you information requested by you as an investor/shareholder and for internalreporting purposes;

- Toimplement actions resulting from Corporate Social Responsibility partnerships;

- Tocomply with regulatory reporting requirements;

- Toimplement communication and brand initiatives and projects.

 

e.ForHow Long Do We Keep Your Personal Data

Weonly keep your personal data for as long as we need to achieve the purposesstated in the previous paragraph and to comply with law.

Whenthe maximum retention period is attained, your personal data are anonymized ordestroyed/erased in a secure manner.

 

f.WithWhom May We Share Your Personal Data

Insome cases, we may share your personal data with other Sonae Group companies.In those cases, we require that these companies have in place appropriate securitymeasures to protect your personal data.

When requiredby law, we may have to share your personal data with legal authorities or thirdparties. In these cases, our control over the protection of your personal datais limited.

 

g.HowYou May Exercise Your Personal Data Protection Rights

Undercertain circumstances, you have the right to request from us:

         i. Additionalinformation on how we use your personal data;

        ii. Accessto your personal data;

      iii. Thatwe transfer to a third party the personal data you gave us;

      iv. Thatwe update your personal data;

        v. Thatwe erase your personal data;

      vi. Thatwe suspend processing of your personal data once you opposed to it;

    vii. Thatwe limit how we use your personal data, whilst we correct them or we clarifyany doubts we may have on their content or the way we use them;

   viii. Thatwe provide adequate means to enable you to object to decisions based solely onautomated processing of your data.

Youalso have the right to withdraw, at any moment, the consent which you may havegiven us to use your personal data, when this use is based on consent.

Youmay not exercise these rights when your personal data are used to protectpublic interest, namely when used for crime investigation and prevention, orwhen subject to professional confidentiality.

Toexercise your data protection rights or whenever you have any question on theuse we make of your personal data you should contact us through the followingchannels:

- Address: Lugar do Espido, Via Norte, 4470-177 Maia

- Electronicmail: protecaodedados@sonae.pt

Youmay also contact our Data Protection Officer using the same address and theelectronic mail dpo@sonae.pt.

Shouldyou be dissatisfied with how we use your personal data or with our response toyour request to exercise your rights, you may file a complaint with ComissãoNacional de Proteção de Dados (CNPD) – Address: Rua de São Bento, 148 – 3º, 1200-821 Lisboa – Telephone: +351213928400 –Telefax: +351213976832 – Electronic mail: geral@cnpd.pt.

 

h.How DoWe Protect Your Personal Data

Sonae,SGPS, SA has implemented several security measures, in line with best nationaland international practices, which enable the protection of your personal data.This includes technological controls, administrative, technical and physicalmeasures and procedures which ensure the protection of your personal data, andprevent improper use, unauthorized access and disclosure, loss, improper ornegligent modification, or unauthorized destruction of personal data. In termsof data security, we apply the same principles of continuous improvement whichwe use in all our daily activities.

Amongst others, we highlight the following security measures:

        i. Accessto your personal data is restricted to those who need them for the purposesstated above;

      ii. Personaldata are stored and shared only using secure techniques;

    iii. Informationsystems are protected to prevent unauthorized access to your personal data;

    iv. Implementationof mechanisms to guarantee the integrity and quality of your personal data;

      v. Continuousmonitoring of information systems, with the aim of preventing, detecting andavoiding improper use of your personal data;

    vi. Redundancyof storage, processing and communication devices, to avoid availability loss.

 

i.Updatesto this Privacy Policy

This Privacy Policy may be updated from time to time. Updates willbe made available on our website.




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