Scope and objective
This Privacy Policy has been implemented with the purpose of demonstrating the commitment and respect of Dougás – Participações Sociais, Sgps S.A. (hereinafter “Dourogás”) to the rules of privacy and protection of personal data.

Why this privacy policy?
This Privacy Policy arises because we intend to disclose the general rules of privacy and treatment of your personal data, which we collect and treat in strict compliance with national and community legislation for the protection of personal data.

Dourogás undertakes to respect the best practices in the field of security and protection of personal data in order to protect the data made available by all those who are related to it in any way.

What does this privacy policy cover?
This Privacy Policy applies to the collection and processing of personal data carried out by Dourogás.

Recipients
This Privacy Policy is intended for the general public and in particular to customers of Dourogás.

Definitions
Personal Data – All information relating to an identified or identifiable natural person (“data subject”); an identifiable person is considered to be identifiable, directly or indirectly, such as a name, an identification number, location data, identifiers by electronic means or to one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social nature of that natural person.

Special Personal Data Categories – Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership of a natural person, as well as the processing of genetic data, biometric data to identify a person of health data or data relating to sex life or sexual orientation.

Treatment – The operation or set of operations carried out on personal data or on personal data sets, by automated or non-automated means, such as collection, registration, organization, structuring, preservation, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of disclosure, comparison or interconnection, limitation, erasure or destruction.

Responsible for Treatment – Is the natural or legal person, public authority, agency or other entity that, individually or jointly with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for his appointment may be laid down by Union or Member State law.

Infringement of Personal Data – It is a breach of security that causes, accidentally or unlawfully, the unauthorized destruction, loss, alteration, disclosure or access to personal data transmitted, stored or otherwise subject to treatment.

Subcontractor – A natural or legal person, public authority, agency or other entity that treats personal data on behalf of the controller.

Third – A natural or legal person, public authority, service or entity other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process personal data.

Collection and processing of cardsubject data
Within the scope of Dourogás activity, as Distribution Network Operator (“ORD”), subject of concession / license in the geographical area related to the municipalities of Macedo de Cavaleiros, Mirandela, Peso da Régua, Santa Marta de Penaguião, Arcos de Valdevez, Ponte da Barca and Póvoa de Lanhoso, and Marketer of Last Resort (“CUR”), the collection, registration, organization, conservation, use and consultation of personal data takes place. Other operations or set of operations that, under the terms of the RGPD, may be called “processing of personal data”.

The personal data collected includes, among others, customers and/or former clients, potential customers, employees, job seekers, suppliers, partners, service providers and their employees.

Use and purpose of the subject’s data processing
In general terms, Dourogás treats the personal data necessary for the purposes of financial, accounting and administrative management, commercial activity management (contact and client management), human resource management (recruitment and selection of personnel), litigation management (management of collections and recovery of credit, provision of information to judicial, administrative, supervisory and/or regulatory authorities), capture and recording of images by CCTV devices, and compliance with legal and/or contractual obligations (by way of example, maintenance of all the infrastructures that integrate the natural gas network – article 20 of DL 140/2006 of July 26, or treatment of requests for information and complaints – article 46 of Decree-Law 30/2006 of 15 February and articles 28 et seq. of Regulation no. 139-A / 2013 of April 16 – Quality of Service Regulation).

When collecting Personal Data, Dourogás provides data subjects with detailed information on the nature of the data collected and, on the purpose, and treatment to be performed in relation to personal data.

Category of personal data processed
In the development of its activity, Dourogás treats categories of personal data related to data subjects, which may include:

• Identification and contact details – for example, name, citizen’s card number, postal address, telephone/mobile phone number, e-mail;
• Commercial data for the provision of services – for example, meter reading, universal facility code (CUI), delivery point code (CPE), consumption data, data resulting from the information provided in response to any questions;
• Payment data – for example, tax identification number, credit and/or debit card numbers, payment dates, amounts owed, payments received, billing history;
• Data capture and recording of images by CCTV devices – images captured by the video surveillance system;
• Security credential data – for example, user identification, password, security information for authentication, and access to the client area.

Subcontracted entities

In the processing of the data of the subject, Dourogás uses or may have recourse to third parties, subcontracted by itself, to, in its name and in accordance with the instructions given by it, proceed with the processing of the data of the subject, in strict compliance with the provisions of the law and this Privacy Policy.

These subcontracted entities will not be able to transmit the data of the subject to other entities without Dourogás giving, prior and in writing, authorization to do so, being also prevented from contracting other entities without previous authorization of Dourogás.

Dourogás undertakes to subcontract only entities that have sufficient guarantees to carry out the appropriate technical and organizational measures in order to ensure the defence of the rights of the subject. All entities subcontracted by Dourogás are bound by the latter in a written agreement which governs, in particular, the purpose and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties.

When collecting personal data, Dourogás provides the data subject with information on the categories of subcontracted entities that, in this case, can process data on behalf of Dourogás.

The data of the subject collected by Dourogás are not shared with third parties without the consent of the subject. Notwithstanding, in the applicable legal terms, Dourogás may transmit or communicate the data of the subject to other entities in case such transmission or communication is necessary for the performance of the contract established between the subject and Dourogás or for pre-contractual procedures on request of the subject, in case it is necessary for the fulfilment of a legal obligation to which the Dourogás is subject, or in case it is necessary for the purpose of pursuing the legitimate interests of the Dourogás, or of a third party. In the event of a transmission of data from the subject to third parties, efforts will be made that are reasonable for the transmitter to use the data of the subject transmitted in a manner in accordance with this Privacy Policy.

General principles appropriate to the processing of proprietary data
In terms of general principles regarding the processing of personal data, Dourogás undertakes to ensure that the data of the subject treated by it are:

• To be the object of a lawful, fair and transparent treatment in relation to the data subject;
• Collected for specified, explicit and legitimate purposes and not subsequently treated in a manner incompatible with those purposes;
• Appropriate, relevant and limited to what is necessary for relation to the purposes for which they are processed;
• Accurate and up-to-date when necessary, all appropriate measures being taken to ensure that inaccurate data, taking into account the purposes for which they are processed, are erased or rectified without delay;
• Preserved in a way that allows the data subject to be identified only for the period necessary for the purposes for which the data are processed;
• Treaties in a manner that ensures their safety, including protection against their unauthorized or unlawful treatment and against their accidental loss, destruction or damage, and appropriate technical or organizational measures are taken.

Basics of lawfulness
Data processing performed by Dourogás is legal when at least one of the following situations occurs:

• The data subject has given his explicit consent to the processing of the data subject’s data for one or more specific purposes;
• Processing is necessary for the performance of a contract in which the data subject is a party or for pre-contractual arrangements at the request of the data subject;
• The treatment is necessary for the fulfilment of a legal obligation to which the Dourogás is subject;
• Treatment is necessary for the defence of vital interests of the data subject or another natural person;
• The treatment is necessary for the legitimate interests pursued by Dourogás or by third parties (except if the interests or fundamental rights and freedoms of the data subject that require the protection of personal data prevail).

Dourogás undertakes to ensure that the data subject is treated only under the conditions set out above and with respect to the above principles.

When the data subject is processed by Dourogás on the basis of the data subject’s consent, the data subject has the right to withdraw his consent at any time. The withdrawal of consent, however, does not compromise the legality of the treatment made by Dourogás based on the consent previously given by the data subject.

The length of time during which the data is stored and stored varies according to the purpose for which the information is processed.

Effectively, there are legal requirements that require you to retain the data for a minimum period of time. Thus, and where there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that led to their collection or subsequent processing, after which they will be eliminated.

Technical, organizational and security measures implemented
In order to guarantee the security of the data of the subject and the maximum confidentiality, Dourogás treats the information that has provided us in an absolutely confidential way, in accordance with its internal policies and procedures of security and confidentiality, which are updated periodically according to the needs, well as well as in accordance with legally established terms and conditions, in order to promote security and integrity, in particular with regard to unauthorized or unlawful processing of your personal data and their accidental loss, destruction or damage.

Depending on the nature, scope, context and purpose of data processing, as well as the risks arising from the treatment of the rights and freedoms of the subject, Dourogás undertakes to apply, both when defining the means of the technical, organizational and logical and physical security measures necessary and adequate for the protection of the data of the subject and the fulfillment of the legal requirements. It also undertakes to ensure that, by default, only the data that is necessary for each specific purpose of treatment is processed.

Transfer of data outside the European Union
Personal data collected and used by Dourogás are not made available to third parties established outside the European Union. Should this transfer take place in the future, Dourogás undertakes to ensure that the transfer complies with the applicable legal provisions, in particular as regards the determination of the suitability of such country as regards data protection and the requirements applicable to such transfers.

Rights of data subjects
As the subject of the personal data processed by Dourogás, you have the right of access, rectification, limitation, portability, deletion and opposition, which may be exercised under certain circumstances and under certain conditions.

THE RIGHT TO INFORMATION
The data subject has the right to obtain clear, transparent and understandable information on how Dourogás treats its data, such as:

• The identity and contacts of Dourogás, responsible for the treatment;
• The purposes for which the personal data are processed and, where applicable, the legal basis for processing;
• If the processing of the data is based on the legitimate interests of Dourogás or a third party, an indication of such interests;
• If applicable, recipients or categories of recipients of personal data;
• If applicable, an indication that personal data will be transferred to a third country or an international organization, and whether or not there is a compliance decision adopted by the Commission or reference to appropriate or appropriate transfer guarantees;
• Deadline for the preservation of personal data;
• The right to ask Dourogás for access to personal data, as well as its rectification, erasure or limitation, the right to object to the treatment and the right to portability of data;
• If the processing of the data is based on the consent of the subject, the right to withdraw consent at any time without compromising the lawfulness of the treatment effected on the basis of the consent previously given;
• The right to complain to the CNPD or other supervisory authority;
• Indication whether or not the communication of personal data constitutes a legal or contractual obligation or a requirement to conclude a contract and whether the subject is required to provide the personal data and the possible consequences of not providing such data;
• Where applicable, the existence of automated decisions, including the definition of profiles, and information on the underlying logic, as well as the importance and expected consequences of such processing for the data subject;
• In the event that the data of the subject is not collected directly by Dourogás from the data subject, in addition to the information mentioned above, the subject is also informed about the categories of personal data being processed, as well as about the origin of the data and possibly derived from sources accessible to the public;
• If Dourogás intends to process the data of the subject for a purpose other than that for which the data were collected, prior to such processing, Dourogás shall provide the subject with information on that purpose and any other pertinent information, in the terms mentioned above;

Procedures and measures implemented to fulfil the right to information
The abovementioned information is provided to the subject, in writing (including by electronic means), by Dourogás and prior to the processing of personal data in question. Under the applicable law, Dourogás does not have the obligation to provide the subject with this information when and to the extent that the subject already has knowledge of them.

The information is provided by Dourogás, free of charge.

The right to access personal data
Dourogás guarantees the means by which the data owner can access his / her personal data.

The data subject has the right to obtain confirmation from Dourogás that the personal data concerning him are treated or not and, if applicable, the right of access to his personal data and the following information:

• The purposes of data processing;
• The categories of personal data in question;
• The addressees or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients established in third countries or belonging to international organizations;
• The term of retention of personal data;
• Right to request from Dourogás the rectification, deletion or limitation of the processing of personal data, or the right to object to such processing;
• Right to file a complaint with the CNPD or other supervisory authority;
• If the data have not been collected from the subject, the available information on the origin of the data;
• The existence of automated decisions, including the definition of profiles, and information on the underlying logic, as well as the importance and expected consequences of such processing for the data subject;
• Right to be informed about the appropriate safeguards associated with the transfer of data to third countries or international organizations.

Upon request, Dourogás will provide the data subject, free of charge, with a copy of their data that is in the process of being processed. The supply of other copies requested by the subject may entail administrative costs.

The right of rectification of personal data
The data subject has the right to request, at any time, the rectification of his personal data, as well as the right to incomplete personal data, including by means of an additional declaration.

In case of rectification of the data, Dourogás will notify each addressee to whom the data have been forwarded for rectification unless such communication proves impossible or involves a disproportionate effort for Dourogás.

The right to erase personal data (“Right to be forgotten”)
The data subject has the right to obtain, on the part of Dourogás, the erasure of his data when one of the following reasons applies:

• The subject’s data are no longer necessary for the purpose for which they were collected or processed;
• The subject withdraws the consent on which the data treatment is based and there is no other legal basis for such treatment;
• The subject opposes treatment under the right of opposition and there are no prevailing legitimate interests justifying treatment;
• In case the subject’s data is treated unlawfully;
• In case the data of the subject must be erased in order to fulfil a legal obligation to which the Dourogás is subject.

Under the applicable legal terms, Dourogás does not have the obligation to erase the data of the subject to the extent that the treatment proves necessary to fulfil a legal obligation to which Dourogás is subject or for the purposes of declaration, exercise or defence of a right of Dourogás in legal proceedings.

In case of deletion of the data, Dourogás notifies each recipient/entity to whom the data has been transmitted the deletion unless such communication proves impossible or involves a disproportionate effort for Dourogás.

When Dourogás has made public the data of the subject and is obliged to delete them under the right of erasure, Dourogás undertakes to ensure the measures that are reasonable, including of a technical nature, taking into account the available technology and the costs of its application to inform those responsible for the effective processing of personal data that the subject has asked them to erase the links to these personal data, as well as copies or reproductions thereof.

The right to limit the processing of personal data
The data subject has the right to obtain, on the part of Dourogás, the limitation of the processing of the data of the subject, if one of the following situations applies (the limitation is to insert a mark in the personal data conserved with the objective to limit his treatment in the future):

• If you challenge the accuracy of personal data, during a period that allows Dourogás to verify its accuracy;
• If the processing is unlawful and the data subject opposes the erasure of the data, requesting, on the other hand, the limitation of its use;
• If Dourogás no longer requires the data of the subject for treatment purposes, but such data is required by the data subject for the purposes of declaration, exercise or defence of a right in a judicial process;

In case the subject has objected to the treatment until it is verified that the legitimate reasons of Dourogás, prevail over those of the subject.

When the subject’s data are subject to limitation, they may only, with the exception of conservation, be treated with the consent of the subject or for the purpose of declaring, exercising or defending a right in a judicial process, defending the rights of another natural or legal person. or for reasons of public interest legally envisaged.

The subject of the data that has obtained the limitation of the treatment of their data in the above cases will be informed by Dourogás before the treatment limitation is annulled.

In case of limitation of data processing, Dourogás shall notify each recipient to whom the data have been transmitted, unless such communication proves impossible or entails a disproportionate effort for Dourogás.

Right of portability of personal data
The data subject has the right to receive the personal data concerning him or her that he has provided to Dourogás in a structured, current and automatic reading format and the right to transmit that data to another data controller if:

• Treatment is based on consent or a contract to which the subject is a party; and
• The treatment is performed by automated means.

The portability right does not include inferred data or derivative data, i.e. personal data that is generated by Dourogás as a consequence or result of the analysis of the data being processed.

The data subject has the right to have the personal data transmitted directly between those responsible for the treatment, whenever this is technically possible.

Right to object to the treatment
The subject shall have the right at any time to object, on grounds relating to his particular situation, to the processing of personal data concerning him which is based on the exercise of legitimate interests pursued by Dourogás or when the processing is carried out for purposes that do not are those for which personal data have been collected, including the definition of profiles, or when personal data are processed for statistical purposes.

Dourogás shall cease processing the data of the subject unless it presents imperative and legitimate reasons for such treatment that prevail over the interests, rights and freedoms of the subject, or for the purposes of declaration, exercise or defence of a Douro’s right in a judicial process.

Procedures for the exercise of rights by the subject
The right of access, the right of rectification, the right of erasure, the right of limitation, the right of portability and the right to opposition may be exercised by the data subject through contact with Dourogás and by filling out the respective form.

Dourogás will respond in writing (including by electronic means) to the request of the subject within a maximum period of one month from the receipt of the request, except in cases of special complexity, where this period may be extended by up to two months.

If the applications submitted by the subject are manifestly unfounded or excessive, in particular, because of their repetitive nature, Dourogás reserves the right to charge administrative costs or refuse to comply with the request.

Violations of personal data
In the event of a breach of data and to the extent that such breach is liable to pose a high risk to the rights and freedoms of the owner, Dourogás undertakes to notify the National Data Protection Commission (CNPD “), Within 72 hours of the incident being notified.

Under legal terms, notification to the subject is not required in the following cases:

• If Dourogás has applied adequate technical and organizational protection measures and these measures have been applied to personal data affected by the violation of personal data, especially measures that make personal data incomprehensible to any unauthorized person to access such data, such as encryption;
• If Dourogás has taken subsequent measures to ensure that the high risk to the rights and freedoms of the subject is no longer likely to materialize; or
• If the communication to the subject implies a disproportionate effort for Dourogás, in which case it will make a public communication or take a similar measure through which the subject will be informed.

Newsletter Subscription
Dourogás GNV informs that by subscribing to our newsletter you will also be able to send communications from the Group that the company is part of – Dourogás SGPS.
Dourogás SGPS Newsletters address topics such as the future of the energy and gas sector in Portugal, constituting a way to continue close to the entire Dourogás community.
Subscribers may, at any time, cancel their registration using the option at the bottom of all Newsletters.

Contacts
Responsible for the Treatment: Dourogás Propano: Companhia Comercializadora de Propano, S.A.

Rua 31 de Agosto nº12, 5000-305 Vila Real
808 100 063

You may at any time, in writing, exercise the rights enshrined in the applicable legislation on Data Protection, by e-mail: protecaodedados@dourogas.pt

It is further informed that, as the subject of the data, you have the right to file a complaint with the CNPD (Av. D. Carlos I, 134 – 1º 1200-651 Lisboa – Tel: +351 213928400 – Fax: +351 213976832 – mail: geral@cnpd.pt) regarding the data processing.

Changes to the privacy policy
Dourogás reserves the right to change this Privacy Policy at any time. When you do, you will post the updated Privacy Protection Policy, so we advise you to check it regularly.

Applicable law
The Privacy Policy, as well as the collection, processing or transmission of data of the subject, are governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the applicable legislation and regulations in Portugal.

Cookies Policy

Cookies used on our website serve to improve its performance and your experience as a user. Cookies are small text files stored on your device that collect information about the device and its user experience.

This information is used to record visits and statistics about user activity on the website.

Holders of this domain do not use the information contained in these files for commercial purposes with third parties, nor do the cookies store data that may be used for marketing purposes.

By browsing this website, you are consenting to the use and storage of cookies on your device. Most browsers automatically accept cookies. You can prevent them from being stored on your device by setting your browser to not accept cookies. Cookies stored on your device can be deleted at any time.

What is the purpose of cookies?
Cookies help you get the most out of our websites, they help determine the usefulness, interest, and the number of uses of websites, allowing for faster and more efficient browsing, thus eliminating the need to repeatedly enter the website’s information.

What types of cookies do we use?

• Essential Cookies: They allow browsing the website and the use of your applications, also allowing access to safe areas of the website. Without these cookies, the services you have requested can not be provided.
• Analytical Cookies: They are used to analyse how users use the website and monitor its performance. This allows us to provide a high-quality experience by customizing our offer and quickly identifying and correcting any problems that are identified. These cookies are used only for the purpose of statistical creation and analysis, without ever collecting personal information.
• Functionality Cookies: They uphold user preferences about using the website, so you do not need to re-configure the website each time you visit.
• Third Party Cookies: Measure the success of applications and the effectiveness of third-party advertising. They can also be used to customize a widget with user data.

Cookies can be:

• Permanent – They remain stored, for a variable time, at the level of the browser in their access devices (pc, mobile, and tablet) and are used whenever the user makes a new visit to the website. They are generally used to direct navigation according to the interests of the user, allowing us to provide a more personalized service.
• Session– These are temporary, remain in the cookies of your browser until you leave the website. The information obtained allows you to identify problems and provide a better browsing experience.

Cookie Management:
Some cookies are deleted as soon as you close the tab or browser (depending on which browser you use), others are renewed with each visit, and others are deleted after a period of time.

You can configure the devices and browsers you use to reject some or even all of the cookies.
The most common method is by anonymous browsing.

Information about “Incognito Navigation” and Cookies management in the Chrome browser:
https://support.google.com/chrome/answer/95647?hl=en

Information about “Incognito Navigation” and Cookies management in the Firefox browser:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Information about “Incognito Navigation” and Cookies management in the Safari browser:
https://support.apple.com/kb/ph21411?locale=en_US

Information about “Incognito Navigation” and Cookies management in the Internet Explorer browser:
https://support.microsoft.com/pt-pt/help/17442/windows-internet-explorer-delete-manage-cookies

You can also get more information on how to handle cookies here:
https://www.aboutcookies.org/how-to-control-cookies/

To manage cookies in your Chrome browser:
https://support.google.com/chrome/answer/95647

To manage cookies in the Firefox browser:
https://support.mozilla.org/pt-PT/kb/ativar-e-desativar-cookies-que-os-websites-utiliza

To manage cookies in the Safari browser:
https://support.apple.com/kb/ph21411?locale=pt_PT

To manage cookies in the Internet Explorer browser:
https://support.microsoft.com/pt-pt/help/17442/windows-internet-explorer-delete-manage-cookies

For information on how to delete cookies in other browsers:
https://www.aboutcookies.org/how-to-delete-cookies/

If you take the action of blocking or deleting cookies in this domain, you are restricting a significant portion of the features that are available that could lead to unexpected behaviour.

For more information about cookies and their use, we suggest you check the following links:

http://www.allaboutcookies.org
https://www.aboutcookies.org

To control the collection of information from third-party cookies, you can do so here:

http://optout.aboutads.info
http://www.youronlinechoices.com
http://preferences-mgr.truste.com/

DNT (Do not track) is a standard that is not adopted by default by many third-party cookies. To see if your browser navigation is being monitored and change your settings, click here: https://allaboutdnt.com/

Cookies used:

Google Analytics
Duration: 2 years
Responsibility: Google Inc.
Reason for use: Session registration, page movement and interaction with content for statistical purposes
More information and opt-out: http://tools.google.com/dlpage/gaoptout

DoubleClick
Duration: 1 year
Responsibility: Google Inc.
Reason for use: Records user actions after interacting with ads for the purpose of measuring and adjusting advertising effectiveness (Used only by Google)
More information and opt-out: http://www.google.com/policies/technologies/cookies/

Google Maps
Duration: Session
Responsibility: Google Inc.
Reason for use: Collects anonymous information about the interaction with the map for statistical purposes. (Used by Google only)
More information and opt-out: https://www.google.com/intl/pt_pt/policies/privacy/

Youtube
Duration: Session
Responsibility: Google Inc.
Reason for use: Collects anonymous session information and interaction with videos for statistical purposes and activity registration with possible advertisements on the content. (Used by Google only)
More information and opt-out: https://www.youtube.com/static?template=privacy_guidelines

Session ID
Duration: Session
Responsibility: Our own
Reason for use: Anonymous registration maintained during the session, from entering this site (websites) until it leaves, to memorize user preferences.

Cookie Consent
Duration: 1 year
Responsibility: Our own
Reason for use: It registers the consent of the user to our cookie policy.

Alternative Dispute Resolution

ARBITRATION CENTER – LAW 144/2015
MEMBER COMPANY OF THE AUTOMOBILE ARBITRATION CENTRE

Address: Av. Da República 44, 3º Esq., 1050-194 Lisboa
Telephone: +351 21 795 16 96 | +351 21 782 73 30
Mobile: +351 96 477 19 28 | +351 91 871 33 78
E-mail: info@arbitragemauto.pt