At KEY – Centro de Formação, Lda (owner of the brands: KEY Training & Consulting, KEY School, KEY Corporate, KEY Consulting), we are concerned about your security and believe in the need to protect the privacy of the personal information you share with us.
For the purposes of what is stipulated in the General Data Protection Regulation (GDPR), users, clients, candidates, or service providers are informed that personal data provided to us, either by filling out any form, via email or by any other means, will be processed in accordance with this Personal Data Protection Policy.
This document aims to clarify the holders of personal data regarding the data we collect about them, the reason for this collection, as well as the options we provide for those data holders to access, rectify or delete the information, among other relevant information.
1. INFORMATION COLLECTED
1.1 KEY collects data about its visitors, clients, trainees, and suppliers when they register by creating an account, access the aforementioned Websites, or fill out electronic and paper forms.
1.2 For KEY, the security and privacy of personal data are of paramount importance, therefore the collection and processing of data are always carried out based on the consent of the data subject or when necessary for the provision of our services, always with a view to their improvement.
2. REGISTRATION OF PERSONAL DATA AT KEY
2.1 When a user transmits their personal data to KEY (through properly identified forms, documents, platforms), they are requested to provide a set of personal data.
2.2 This information is essential to guarantee the registration process and to provide a personalized service.
2.3 After registering – and provided you have given your authorization for this purpose – you may be sent news updates, as well as information about courses and training solutions, surveys, promotions, newsletters, or commercial offers.
2.4 You may cancel/limit this service at any time, and for this purpose, you should send an email message to the contact referred to in point 13 of this Privacy Policy.
3. CHILDREN'S DATA
3.1 We do not intentionally collect children's data, nor do we have a way to identify them, unless we collected additional, more intrusive information to reach that conclusion.
3.2 Given that responsibility for monitoring the child in all dimensions of their life, including the use of technological means, belongs to the holder of parental responsibilities, we will promptly delete the children's data at the moment the holder of parental responsibilities notifies us that such data has been collected.
4. DATA PROCESSING
Data processing operations are lawful when:
a) The processing of personal data is necessary for the execution of a contract;
b) When the data subject has given their consent for the processing of their data;
c) When the processing results from a legal obligation.
5. HOW WE USE THE DATA WE COLLECT
5.1 We use the information we collect to:
5.2 We will request your express consent before using the information for purposes other than those expressly set out in this Privacy Policy.
6. DATA COMMUNICATION
6.1 KEY communicates information to its commercial partners or subcontracted entities.
6.2 For this purpose, the user gives their consent, which they may withdraw at any time, request the deletion of their data, as well as exercise any of their rights set out below, in the chapter "RIGHTS OF DATA SUBJECTS".
7. INTERNATIONAL DATA TRANSFERS
7.1 The internet has no borders. Using the internet and its services necessarily involves the international transmission of information. Therefore, by interacting with us and consenting to the communication of data to third parties, you acknowledge that you are aware of and consent to the processing of data on this scale.
7.2 We take measures to ensure that appropriate measures and controls are applied whenever our service providers and hosting service providers transfer your information outside the national territory, in order to protect the said information in accordance with applicable data protection legislation and regulations.
7.3 All KEY brands are subject to KEY's data protection policies, which aim to protect data in accordance with European data protection legislation.
7.4 KEY has access to personal data as the data controller.
7.5 Commercial partners and subcontracted entities access the data only in that capacity: within the scope of contract execution or legal obligations.
7.6 In these cases, they will only have access to personal data strictly necessary for the achievement of the intended purposes.
8. AUTOMATED DECISIONS, INCLUDING PROFILING
8.1 We collect information about you with your explicit consent in order to provide you with a personalized service in the presentation of services according to your preferences.
8.2 You may object through the procedure described below in "RIGHTS OF DATA SUBJECTS".
9. SECURITY MEASURES
9.1 KEY is concerned with your privacy and the protection of your personal data, which is why it has implemented technical and organizational measures that ensure the confidentiality of your data.
9.2 Any subcontracted or partner entity will also be obliged to strict security measures and will only process the information according to our instructions.
10. RIGHTS OF DATA SUBJECTS
10.1 If you are located in the European Economic Area or in another jurisdiction with similar data protection laws, in some cases you have the following rights:
the right to be informed about how we use and obtain access to your information;
You may, by the same means and at any time, withdraw the consent you have given for the processing of your personal data, without this affecting the lawfulness of the processing carried out up to that point, based on the consent you have previously provided.
10.2. The User is advised that, for the execution of orders, the provision of data relating to identity (name, I.D. card), address, telephone, and email will be considered mandatory, as these data are necessary for the formalization and provision of services offered by KEY.
11. RETENTION PERIOD FOR PERSONAL DATA - I
11.1 The data will be retained for the time necessary to perform the contract, as well as for the period required by national and/or international legislation.
11.2 Subsequently, they will be retained in the form of a communication history for a period of ten (10) years, unless the user requests their deletion through the email address previously indicated.
11.3 In cases where the data is processed for sending commercial communications or for statistical purposes, they may be stored for a period of ten (10) years, unless the user objects.
12. RETENTION PERIOD FOR PERSONAL DATA – II
12.1 Similarly, if the user/candidate has sent us their curriculum vitae, their data will be retained until their job/service application is resolved, or for five (5) years in case new job opportunities that match their profile may arise.
12.2 Notwithstanding the foregoing, if hired, their data will be retained for the duration of their employment/service relationship.
12.3 The provision of data for this purpose is mandatory.
12.4 Otherwise, the request cannot be managed.
12.5 The data will be retained for the entire duration of the service relationship, and even afterwards, until the prescription of any liabilities that may arise from it.
13. CHANGES TO THE PRIVACY POLICY
KEY reserves the right to change its Privacy Policy, so we recommend regular reading of this section as well as the Terms and Conditions of our websites.
14. OUR CONTACTS
Website: www.KEY.pt
Email: direccao@KEY.pt
