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Code of Conduct
By-laws of the CLS
Privacy Notice 

CLS Privacy Notice

This Privacy Notice is intended to inform website visitors of www.camaralusosueca.pt regarding the processing of data when you visit our website, contact us, become a member, attend our events or contact us regarding recruitment.

We only collect a limited amount of information about you that is necessary for improving our services and website. We do not use profiling, we do not sell or in any other way spread your data to third parties save from our partners and suppliers, we do not use your data for purposes other than what we specified. We do not knowingly collect personal information from any person who is under the age of 18, we will delete this information immediately. If you have reason to believe that this has occurred, please email us at , and we will delete all relevant information. 

We also make sure that your data is stored securely. We delete all information deemed no longer necessary. We constantly review our Privacy Notice in order to make it better and protect you more.

We only collect information for the below mentioned purposes and only based on the legal grounds specified for each purpose.

Privacy notice updated on 2018-09-01

1.1.  When you visit the website

You can visit our website without giving away a lot of your personal data. In an effort to limit privacy-intrusive methods, The Swedish-Portuguese Chamber of Commerce (CLS) use only one (1) session cookie in order to improve the use of our website.

1.1.1. Cookies
Cookies are small text files that are stored on your computer when you visit some websites. The CLS website uses only one session cookie to ensure increased functionality of our website. The cookie expires as soon as you close the browser. We do not process website visitor data for any additional purpose, such as to profile those who
access our website. We do not collect information such as your age, gender, interests, bank details or clickstream.

Legal basis: Legitimate interest.

1.2. When you contact us

While you can use our website without giving out a lot of your personal information, once you contact us via the CLS website, CLS collects a limited amount of information about you. If you get in touch with us via email, phone, post or other form of communication, we may keep records of those correspondences and their content in order to be able to respond to you or document your complaint. If you wish for your information to be deleted from our systems, you can contact us at and read more about your rights below.

Legal basis: Legitimate interest.

1.3. Recruitment

If you apply for a job with CLS, we will collect, process and store the information you have sent us for recruitment-related purposes, such as contacting you and performing screening and interviews.

CLS has a low turnover on recruitment, and rarely publishes offers. If we receive spontaneous applications, the information may be saved for a period for the purpose of considering you, should opportunity arise. Before we do that, we will ask your approval to store the information and the time you accept.

Legal basis: Consent.

1.4. Events

If you sign up to participate in an event with CLS, we will collect, process and store the information necessary for us to be able to communicate with you regarding the specific event. If the event is related to a participation fee we will also request billing information.

The information we collect on these occasions may include: full name, address, title, contact details, billing information. We offer a wide range of events throughout the year, from seminars, lunches and a golf tournament. 

Legal basis: Contract.

1.5. Members

The majority of CLS members are corporate, meaning that the main part of our business is based on providing services and/or products to organisations, rather than to individuals. If you are a member of CLS, please consult the application form you´ve signed with us because it may contain a more detailed set of information on personal data processing.

Furthermore, when data is processed for the purposes of delivering benefits of the membership, the processing is done based on a performance of a contract.

 

2. International transfers

CLS aims to limit the international transfers of personal data to which it is a custodian. Therefore, international transfers are limited to a minimum necessary to obtain analytics of our website usage and our customer relationship management. We only transfer personal data when there is a basis for such transfers and having due consideration of the risks to the individual that may be connected to such transfers.

2.1. INTERNATIONAL TRANSFERS TO THE UNITED STATES OF AMERICA
Microsoft Office 365. CLS uses the Microsoft Office 365 suite for external communication and internal use. This entails a transfer of some personal data to the United States of America. Microsoft is a certified EU – U.S. Privacy Shield organization, meaning that the transfers are performed under this legal mechanism for international transfers.

3. Security measures

We undertake security measures appropriate to the size and nature of our business, all with the aim of keeping your personal data safe and secure.

We strive to protect our environments and systems to the fullest extent possible. This means that we continuously work on maintaining a high IT standard for our systems so that personal data is kept safe. For example, aside from the technical measures we implement, we also ensure that both our staff and our board of members have been trained in data protection and undergo continuous training. In addition to that, physical security measures are put in place, as well as need-to-know need-to-access basis for our employees thereby limiting the access to personal data only to those who need it in order to fulfil the purposes of processing.

4. Disclosure to third parties

Personal data shared with us is treated confidentially. Therefore, as a general rule, we do not disclose personal data to third parties, save from circumstances in which we share data with our partners and suppliers. This is common for most businesses today, and we only share your personal data with third parties when necessary and always according to the principles stated in this Privacy Notice.

5. Your rights

According to applicable law, you have a set of rights when it comes to your personal data and its processing by personal data controllers such as CLS. We summarized them for you so that you can be aware of them and be able to exercise them if you so wish. You have the right to know what we process on you and receive a copy, you have the right to correct or complete as well as delete your personal data or object to processing, subject to certain conditions. In case our processing is based on a consent granted by you, you may withdraw the consent at any time by contacting us at info(a)camaralusosueca.pt.

5.1. Access to Information
Access to Information If you would like to obtain a confirmation of whether CLS process your personal data, please contact us at . You have the right to access the personal data we process on you to the extent that the access request is done in reasonable intervals and that fulfilling this request would not adversely infringe on other persons’ rights and freedoms. You are also entitled to obtain a copy of the personal data we process on you. This could mean that we will charge you an administrative fee to be able to meet your request. Please note that we will always go through a verification process to check your identity before you can exercise your rights.

5.2. Information rectification, deletion, and objection to processing
If you believe the information we have on you is incorrect or incomplete, you may request for a correction and completion of that information by contacting us via . When certain conditions are met, you also have the right to erasure (“right to be forgotten”). Feel free to contact us if you believe your situation meets the conditions for erasure: . You may also object to processing done with the purpose of direct marketing. In such a case, you can contact us here: . Please note that we will always go through a verification process to check your identity before you can exercise your rights. 

6. Retention periods

As a general rule, we store personal data of our customers for the duration their membership with us. We may retain information such as billing or financial information for longer than that in order to comply with applicable laws as well as for the establishment, exercise or defence of legal claims. When it comes to personal data generated by the cookie on our website, this is only retained for the duration of your visit, i.e. the cookie is deleted as soon as you exit the browser you are using for the visit. We do not retain personal data for the sole purpose of verifying your identity, except for us to be able to react to potential requests.

7. When this privacy notice applies

This Privacy Notice is applicable to the use of this website and CLS´s services towards its customers and members. Our website contains links to other websites. Once redirected to another website, this Notice is no longer applicable. 
This version of the Privacy Notice is effective from September 1st, 2018.

8. Changes to this privacy notice

CLS reserve the right to make changes and amendments to this Privacy Notice at any time and for any reason. We will always make sure to have our Privacy Notice be freely available and easily accessible so that you may be informed of the content of this Privacy Notice by reading it on our website. We will, however, notify you if there are significant changes to this policy by a website notification.

9. Contact in case of questions or complaints

You are always welcome to contact us:

Câmara de Comércio Luso-Sueca
Swedish-Portuguese Chamber of Commerce
c/o NINHO
Rua Júlio de Andrade 5
1150-225 Lisbon - Portugal


Phone: +351 910 091 731
Email:
www.camaralusosueca.pt

In the event of a complaint, you have the right to contact the Portuguese Supervisory Authority: Comissão Nacional de Protecção de Dados – CNPD.

10. To sum up

We only collect a limited amount of information about you that is necessary for improving our services and website. We do not use profiling, we do not sell or in any other way spread your data to third parties save from our partners and suppliers, we do not use your data for purposes other than what we specified. We do not knowingly collect personal information from any person who is under the age of 18, we will delete this information immediately. If you have reason to believe that this has occurred, please email us at , and we will delete all relevant information.

We also make sure that your data is stored securely. We delete all information deemed no longer necessary. We constantly review our Privacy Notice in order to make it better and protect you more.

Glossary:


Legitimate interest
Legitimate interest is one of the six legal bases for processing according to the General Data
Protection Regulation (GDPR). Legitimate interest may be used for processing as long as that
interest is not detrimental to you as an individual in the sense that it would infringe on your rights and freedoms. We use legitimate interest in the following situations:

  • To enhance your experience on our website, only for the duration of your visit to our website.
  • To review your job application sent to us.


Contract
Contractual obligation is one of the six legal bases for processing according to the General Data
Protection Regulation (GDPR). When we use this basis for processing, it means that the processing is necessary for a contract you have signed with us or as a preparatory step towards signing the contract.