BABY SISTERS (“BABY SISTERS”) is firmly committed to the privacy and rights of the holders of personal data, acting in accordance with the provisions of the General Regulation on Data Protection (“GDPR”) and other legislation applicable.
- Collection and processing of personal data
- Purposes and legal grounds for the processing of personal data
- Period for storage of personal data
- Personal data transfers
- Security of personal data
- Rights of the Holder of Personal Data
- Mode of exercise of rights by the Holder, questions, and suggestions
1. COLLECTION AND PROCESSING OF PERSONAL DATA
Personal data is any information relating to an identified or identifiable individual. Identifiable is an individual who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, electronic identifiers or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
BABY SISTERS may process the following categories of personal data:
Identification data (e.g., name, date of birth, gender, address, contacts, citizen card data, passport and taxpayer number, nationality);
Data relating to education and work experience (e.g., education, qualifications, certifications, languages, CV, former employer information);
Professional data (e.g., title, role, job description, company, office address);
Professional activity data (e.g., business activities, information relating to processes and dossiers, information relating to due diligence);
Billing and expense data (e.g., fees, travel expenses and communications on behalf of the customer); and
Image and sound recording data (e.g., photographic and video images).
Holders of personal data are individuals to whom the data relates.
The categories of personal data indicated above may belong to different categories of Data Subjects, such as customers, employees of customers (companies), counterparties or candidates of BABY SISTERS.
BABY SISTERS collects personal data through various means and at different times, namely when the Holder sends an email or responds to an invitation, when he delivers his personal card, when he subscribes to our information or events, when he makes an application or when you hire our services.
With regards specifically to the BABY SISTERS Website, access to it and its use do not necessarily imply the provision of personal data by users. However, the use of certain functionalities of the Site may imply the provision of personal data, namely in the case of requests for contact or submission of applications.
2. PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
BABY SISTERS may process personal data for the following purposes and on the following legal grounds:
- A) FOR THE PROVISION OF BABYSITTING SERVICES OR ORGANIZATION OF CHILD CARE ACTIVITIES.
- BABY SISTERS’ interest in handling its customers’ information in a sustained and efficient manner, which ensures its quality and integrity and allows the provision of excellent services; and
- For communications and sending information, including disclosure of commercial and advertising information (e.g., newsletters, briefing).
Legal basis ► legitimate interest:
- Respond to requests from subscribers to forms on the BABY SISTERS Website and adjust the respective communication.
- Reinforce the BABY SISTERS culture.
- For event management, which includes sending invitations to events and registration of event participants and internal and external promotion of events.
Legal basis ► legitimate interest and consent (*):
- Respond to requests from subscribers to forms on the BABY SISTERS Website and adjust the respective communication.
- Publicize events promoted by BABY SISTERS.
(*) The holder’s prior consent will be requested in cases where the event is recorded, either in sound or image, or if photographs are taken.
- For compliance with legal obligations in terms of compliance.
Legal basis► fulfilment of legal obligation.
- For invoicing and accounting management, which includes expense accounting, cost, and reimbursement control (e.g., travel expenses and mobile communications to be borne by customers), invoicing and current account management and file maintenance of accounting records and documentation support.
Legal basis ► execution of contract, legitimate interest and fulfilment of legal obligation:
- Maintain efficient management control.
- Invoice in a timely manner for the services provided; and
- Ensure compliance with applicable legal obligations.
- For recruitment and selection, which includes the analysis of applications and curriculum, as well as the internal process of selection of service providers and employees according to the needs detected.
Legal basis ► pre-contractual due diligence at the request of the data subject and legitimate interest.
- BABY SISTERS’ interest in analysing applications and submitting candidates to an internal selection process, in accordance with previously defined criteria.
3. TERM FOR THE STORAGE OF PERSONAL DATA
Personal data will be kept by BABY SISTERS for the period necessary to fulfil the purposes defined in this Policy or for the period required by applicable legal or regulatory rules.
The retention periods for personal data, according to each processing purpose, are as follows:
Provision of services = Duration of the contractual relationship, plus 7 years.
Communications and sending of information = Until the Data Holder expresses his/her opposition.
Event management = 2 years, counting from the initial contact or participation in an event (as the case may be) if there is no contact or participation in another event by the Data Subject.
Fulfilment of legal obligations in terms of compliance = 7 years, after the moment when the customer’s identification was processed or, in the case of business relationships, after their end.
Invoicing and accounting management = 10 years.
Recruitment and selection = 2 years, counted from the submission of the application or curriculum, in case the candidate is not selected; and
Other cases = during the period in which the contractual relationship with BABY SISTERS is maintained.
Personal data transfers
BABY SISTERS does not transmit the Holder’s personal data to third parties, except in cases where this proves to be necessary for the provision of services contracted or to comply with legal obligations to which BABY SISTERS is subject.
The transmission of data to third parties is carried out in accordance with the applicable legislation on data protection and within the limits of the purposes and legal grounds defined in this Policy.
BABY SISTERS may share personal data with the following entities:
Parties relevant to the provision of services, eg hotels, schools, event venues;
Service providers who provide services to BABY SISTERS within the scope of the purpose described above, such as, for example, IT providers, communications services, and digital and physical archive services.
In cases where the transmission of personal data to the aforementioned entities involves an international transfer of personal data (i.e., outside the European Union), BABY SISTERS:
It will carry out this transfer based on an adequacy decision by the Commission, under which the country or international organization in question guarantees a level of protection of personal data equivalent to that resulting from European Union legislation; or,
If there is no adequacy decision by the Commission, it will ensure that these data transfers are carried out in strict compliance with legal provisions and that adequate guarantees are implemented to ensure the protection of personal data.
5. SECURITY OF PERSONAL DATA
BABY SISTERS makes its best efforts to protect personal data, namely through the adoption of appropriate technical and organizational measures against destruction, loss, alteration, disclosure, or unauthorized access and against any other form of illicit or abusive treatment.
The technical and organizational security measures created and implemented by BABY SISTERS are also required of BABY SISTERS’ service providers who can process personal data on their behalf.
With regard specifically to the use of the BABY SISTERS Website, it is the responsibility of users who hold personal data to guarantee and ensure that the devices and equipment used to access the Website are adequately protected against harmful software, computer viruses that may place the security of the personal data provided through the Site at stake.
6. PERSONAL DATA HOLDER’S RIGHTS
The holder of personal data enjoys the following rights:
- RIGHT OF ACCESS
At any time, the Holder may request confirmation as to whether BABY SISTERS processes their data. personal data, access to your personal data and information about their treatment. The Holder may also obtain a copy of the personal data subject to treatment.
- RIGHT TO RECTIFICATION
If the Holder’s personal data are incorrect or incomplete, he may request that they be rectified or completed.
- RIGHT TO DELETION (“RIGHT TO BE FORGOTTEN”)
In certain situations, the Holder has the right to request the erasing or destruction of their personal data. This right may be limited in certain situations, such as, for example, when data processing is necessary to comply with legal obligations to which BABY SISTERS is subject, or when such processing is necessary for the purposes of declaring, exercising, or defending a right. in a court proceeding.
- RIGHT TO LIMIT THE TREATMENT
In certain situations, the Holder may ask BABY SISTERS to limit access to personal data or to suspend processing activities. This will happen, for example, in cases where the Holder contests the accuracy of his personal data, during a period of time that allows BABY SISTERS to verify its accuracy, or in cases where the Holder has objected to the processing, until verification that the legitimate interests of BABY SISTERS or a third party prevail over those of the Holder.
- RIGHT TO DATA PORTABILITY
In cases where the processing of data is based on a contract to which the Holder is a party or on the Holder’s own consent, the latter may ask BABY SISTERS to deliver the data provided in a structured, commonly used, and machine-readable format. The Holder may also ask BABY SISTERS, if this is technically possible, to transmit this data to other persons responsible for the processing of personal data.
- RIGHT OF OPPOSITION
When the processing of data is based on the legitimate interest of BABY SISTERS or when it is carried out for purposes other than those for which the data was collected, but which are compatible with them, the Holder has the right to object to the processing of their personal data, for reasons related to their particular situation. BABY SISTERS will, in these cases, stop treating the personal data of the Holder, unless there are legitimate reasons to carry out this treatment and these must prevail over the interests of the Holder.
- RIGHT NOT TO BE SUBJECT TO AUTOMATED INDIVIDUAL DECISIONS
BABY SISTERS does not adopt automated individual decisions, including profiling, that produce effects within the Holder’s legal sphere or that significantly affect him in a similar way.
- RIGHT TO WITHDRAW CONSENT
In cases where the processing of data is carried out based on the consent of the Owner, he may withdraw consent at any time. If the Holder withdraws his consent, his personal data will no longer be processed, unless there is another legal basis that allows this treatment.
- RIGHT TO SUBMIT COMPLAINTS TO THE CONTROL AUTHORITY
The Holder has the right to file complaints with the competent supervisory authority, regarding matters related to the processing of their personal data. In Portugal, the competent supervisory authority is the National Data Protection Commission.
7. HOW TO EXERCISE RIGHTS BY THE HOLDER, QUESTIONS AND SUGGESTIONS
In order to exercise any of the aforementioned rights, as well as to obtain clarifications or make suggestions related to the processing of personal data, the Holder must submit a written request to the following contacts:
Address: Avenida de Poiares, Safail, nº 86, R/C Esq, 3350-103 Vila Nova de Poiares. The exercise of said rights by the Data Subject is free of charge.
Date of last update: 10/31/2018