Administrative Council
The organizational structure of Dourogás GNV has allowed, over the years, the perfect alignment of interests between all the company’s management bodies, translating into an effective link between all of them. A daily work, carried out competently and transparently, and which has allowed the constant corporate evolution.
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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:
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:
Basics of lawfulness
Data processing performed by Dourogás is legal when at least one of the following situations occurs:
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:
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:
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:
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):
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:
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:
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.
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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
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E-mail: info@arbitragemauto.pt
