Privacy and data protection policy

The privacy of your data is very important to us. The National Association of Liberal Professionals (hereinafter ANPL) is committed to protecting the privacy of your data in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679, of the European Parliament and of the Council of the 27th of April 2016), in accordance with the respective portuguese implementing law (Law no. 58/2019, of the 8th of August), and other applicable legislation. 

WHAT IS PERSONAL DATA?

Personal data means any information relating to an identified or identifiable natural person (“data subject”), in particular, a name, an identification number, the e-mail address, the mailing address, title, date of birth, gender, profession, or other specific physical, physiological, genetic, mental, economic, cultural or social identity. 

WHO IS THE DATA CONTROLLER? 

The data controller is the National Association of Liberal Professionals located at Street Marechal Saldanha, no. 613, 4.º G 4150-658 Porto, which defines the purposes and means of the processing. 

HAS ANPL APPOINTED A DATA PROTECTION OFFICER (DPO)? 

A Data Protection Officer has been appointed and may be reached via the following contact:  dpo@anpl.pt

The DPO has the following functions: 

  • Informing and advising the controller about the data protection as well as in conducting impact assessments; 
  • Ensure compliance with this privacy policy and other existing related policies; 
  • Monitor compliance with the GDPR and other applicable data protection legislation; 
  • Cooperate and be the point of contact with the supervisory authority, in Portugal, Comissão Nacional de Proteção de Dados

For any questions regarding this policy, you may contact the DPO using the contact information above.

WHAT ARE THE LAWFUL GROUNDS FOR PROCESSING YOUR DATA? 

  • Consent, as a free, specific, informed, and unambiguous indication of the data subject’s will, through a statement or a clear affirmative action, to receive marketing communications, advertising, newsletters or for image and sound collection by ANPL or its partners; 
  • Application and execution of a contract to which the data subject is a party or for the purposes of admission and contractual management of members and also in the event of a merger of ANPL into another association, ensuring the maintenance of the existing pre-contractual relationship;  
  • Legitimate interests of ANPL, namely for the purpose of issuing and communicating alerts related to information security, website operations, eventual satisfaction questionnaires, management of new members, maintenance of the relationship between ANPL and its members, organization of events and initiatives of an institutional, cultural and informative scope, curricular and professional statistical analysis of its members, and also for the purpose of representing its members before any public or private entities, under the terms of ANPL’s statutory and regulatory attributions;  
  • Compliance with a legal obligation stemming from the national or Union law, namely regarding the fulfillment of tax or judicial obligations, or from any sectorial and regulatory entities. 

WHAT CATEGORIES OF DATA ARE PROCESSED?

  • Identification Data; 
  • Nationality Data;
  • Gender Data; 
  • Contact Data; 
  • Tax Data;
  • Bank Data; 
  • Curricular and Professional Data. 

WHAT ARE THE PURPOSES OF PROCESSING YOUR PERSONAL DATA?

  • Admission, administrative and financial management of its members;
  • Sending marketing communications and advertising for information and dissemination of its or partner entities, events and initiatives through its newsletter; 
  • Management of the payment and collection of fees; 
  • Fulfillment of the necessary communications with the authorities, namely the tax authority;
  • Image and sound collection within the scope of events and initiatives for publication on its website, newsletter or other ANPL information channels, upon consent of the data subject; 
  • Carrying out training activities, raising awareness, and promoting and placing internships among its associates; 
  • Representation of its members close to several entities of the private or public sector, namely sovereign bodies and sector regulation; 
  • Conducting surveys, studies, and statistical analyses. 

WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Personal data is collected exclusively by the ANPL and is not sent to any third-party entities. However, and exceptionally, the sharing of data with third parties may only occur within the framework of a legal obligation under national or European law, and for the purpose of pursuing and fulfilling the respective purposes for which the data were collected and processed.

In case data is shared with data processors for the processing of personal data, ANPL will require the appropriate guarantees for compliance with the applicable data protection and information security legislation and best practices, to ensure the confidentiality, integrity and availability of data.

To this end, ANPL will enter into data protection agreements with data processors under the provisions of Article 28 of the GDPR, imposing the necessary requirements for data protection.

WHAT IS THE FATE OF THE DATABASES IN CASE OF EXTINCTION OR MERGER OF ANPL?

In the event of termination, your data may be deleted or transferred to one of our partners on the appropriate legal basis.  

In the event of a merger with another association or partner, the data will be transferred to that new legal entity, as part of its assets, maintaining the purposes for which they are processed and the basis for contractual performance. In this case, the entity will inform its associates of the merger, always giving the opportunity and guaranteeing the data subjects their right of opposition, without prejudice to the compelling and legitimate reasons that justify its processing. It is guaranteed that their consent will be collected in the cases duly applicable.   

HOW LONG WILL YOUR PERSONAL DATA BE STORED?  

Your personal data will be stored if it is necessary for the fulfillment of the stipulated purposes or as required by national or Union law. If the purposes in question cease to exist or the required legal period is exceeded, the data will be deleted immediately in a secure and controlled environment.  

WHAT ARE THE RIGHTS OF THE DATA SUBJECTS? 

Data subjects may exercise their right of access, rectification, objection, restriction, portability and the right to erasure of their personal data. It is also ensured their right to withdraw consent to receive marketing information, advertising, or newsletters, without this compromising the legality of the processing previously carried out under the aegis of that consent. 

Data subjects may exercise their rights by sending a communication using the following contact: 

The data subject also has the right to lodge a complaint with the supervisory authority, in Portugal, Comissão Nacional de Proteção de Dados, through its online address: www.cnpd.pt.

HOW IS YOUR DATA PROTECTED? 

ANPL is committed to ensure the application of all necessary technical and organizational measures for data protection and information security, thus ensuring the confidentiality m integrity, availability, and resilience of personal data. These technical and organizational measures are identified by the following [insert measures]

DOES ANPL TRANSFER YOUR DATA TO THIRD COUNTRIES?

ANPL processes your personal data within the European Economic Area. In case of transfer of personal data to third countries by virtue of national or Union law or by virtue of contractual performance, all necessary measures will be observed to the transfer to third countries deemed safe and appropriate through the issuance of adequacy decisions by the European Commission, the signing of standard clauses or obtaining the consent of the data subject. In addition to the technical and organizational measures, other measures will be employed in addition to those used, not only by the data controller, but also required of the recipient, to ensure data protection and information security. 

CAN THIS POLICY BE CHANGED?

Yes. ANPL may change this policy due to national or Union legal requirements or when ANPL deems it relevant and appropriate. The data subject should periodically consult this policy to keep abreast of any changes, without prejudice to its notice on the home page of the ANPL website.

The privacy of your data is very important to us. The National Association of Liberal Professionals (hereinafter ANPL) is committed to protecting the privacy of your data in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679, of the European Parliament and of the Council of the 27th of April 2016), in accordance with the respective portuguese implementing law (Law no. 58/2019, of the 8th of August), and other applicable legislation. 

WHAT IS PERSONAL DATA?

Personal data means any information relating to an identified or identifiable natural person (“data subject”), in particular, a name, an identification number, the e-mail address, the mailing address, title, date of birth, gender, profession, or other specific physical, physiological, genetic, mental, economic, cultural or social identity. 

WHO IS THE DATA CONTROLLER? 

The data controller is the National Association of Liberal Professionals located at Street Marechal Saldanha, no. 613, 4.º G 4150-658 Porto, which defines the purposes and means of the processing. 

HAS ANPL APPOINTED A DATA PROTECTION OFFICER (DPO)? 

A Data Protection Officer has been appointed and may be reached via the following contact:  dpo@anpl.pt

The DPO has the following functions: 

  • Informing and advising the controller about the data protection as well as in conducting impact assessments; 
  • Ensure compliance with this privacy policy and other existing related policies; 
  • Monitor compliance with the GDPR and other applicable data protection legislation; 
  • Cooperate and be the point of contact with the supervisory authority, in Portugal, Comissão Nacional de Proteção de Dados

For any questions regarding this policy, you may contact the DPO using the contact information above.

WHAT ARE THE LAWFUL GROUNDS FOR PROCESSING YOUR DATA? 

  • Consent, as a free, specific, informed, and unambiguous indication of the data subject’s will, through a statement or a clear affirmative action, to receive marketing communications, advertising, newsletters or for image and sound collection by ANPL or its partners; 
  • Application and execution of a contract to which the data subject is a party or for the purposes of admission and contractual management of members and also in the event of a merger of ANPL into another association, ensuring the maintenance of the existing pre-contractual relationship;  
  • Legitimate interests of ANPL, namely for the purpose of issuing and communicating alerts related to information security, website operations, eventual satisfaction questionnaires, management of new members, maintenance of the relationship between ANPL and its members, organization of events and initiatives of an institutional, cultural and informative scope, curricular and professional statistical analysis of its members, and also for the purpose of representing its members before any public or private entities, under the terms of ANPL’s statutory and regulatory attributions;  
  • Compliance with a legal obligation stemming from the national or Union law, namely regarding the fulfillment of tax or judicial obligations, or from any sectorial and regulatory entities. 

WHAT CATEGORIES OF DATA ARE PROCESSED?

  • Identification Data; 
  • Nationality Data;
  • Gender Data; 
  • Contact Data; 
  • Tax Data;
  • Bank Data; 
  • Curricular and Professional Data. 

WHAT ARE THE PURPOSES OF PROCESSING YOUR PERSONAL DATA?

  • Admission, administrative and financial management of its members;
  • Sending marketing communications and advertising for information and dissemination of its or partner entities, events and initiatives through its newsletter; 
  • Management of the payment and collection of fees; 
  • Fulfillment of the necessary communications with the authorities, namely the tax authority;
  • Image and sound collection within the scope of events and initiatives for publication on its website, newsletter or other ANPL information channels, upon consent of the data subject; 
  • Carrying out training activities, raising awareness, and promoting and placing internships among its associates; 
  • Representation of its members close to several entities of the private or public sector, namely sovereign bodies and sector regulation; 
  • Conducting surveys, studies, and statistical analyses. 

WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Personal data is collected exclusively by the ANPL and is not sent to any third-party entities. However, and exceptionally, the sharing of data with third parties may only occur within the framework of a legal obligation under national or European law, and for the purpose of pursuing and fulfilling the respective purposes for which the data were collected and processed.

In case data is shared with data processors for the processing of personal data, ANPL will require the appropriate guarantees for compliance with the applicable data protection and information security legislation and best practices, to ensure the confidentiality, integrity and availability of data.

To this end, ANPL will enter into data protection agreements with data processors under the provisions of Article 28 of the GDPR, imposing the necessary requirements for data protection.

WHAT IS THE FATE OF THE DATABASES IN CASE OF EXTINCTION OR MERGER OF ANPL?

In the event of termination, your data may be deleted or transferred to one of our partners on the appropriate legal basis.  

In the event of a merger with another association or partner, the data will be transferred to that new legal entity, as part of its assets, maintaining the purposes for which they are processed and the basis for contractual performance. In this case, the entity will inform its associates of the merger, always giving the opportunity and guaranteeing the data subjects their right of opposition, without prejudice to the compelling and legitimate reasons that justify its processing. It is guaranteed that their consent will be collected in the cases duly applicable.   

HOW LONG WILL YOUR PERSONAL DATA BE STORED?  

Your personal data will be stored if it is necessary for the fulfillment of the stipulated purposes or as required by national or Union law. If the purposes in question cease to exist or the required legal period is exceeded, the data will be deleted immediately in a secure and controlled environment.  

WHAT ARE THE RIGHTS OF THE DATA SUBJECTS? 

Data subjects may exercise their right of access, rectification, objection, restriction, portability and the right to erasure of their personal data. It is also ensured their right to withdraw consent to receive marketing information, advertising, or newsletters, without this compromising the legality of the processing previously carried out under the aegis of that consent. 

Data subjects may exercise their rights by sending a communication using the following contact: 

The data subject also has the right to lodge a complaint with the supervisory authority, in Portugal, Comissão Nacional de Proteção de Dados, through its online address: www.cnpd.pt.

HOW IS YOUR DATA PROTECTED? 

ANPL is committed to ensure the application of all necessary technical and organizational measures for data protection and information security, thus ensuring the confidentiality m integrity, availability, and resilience of personal data.

DOES ANPL TRANSFER YOUR DATA TO THIRD COUNTRIES?

ANPL processes your personal data within the European Economic Area. In case of transfer of personal data to third countries by virtue of national or Union law or by virtue of contractual performance, all necessary measures will be observed to the transfer to third countries deemed safe and appropriate through the issuance of adequacy decisions by the European Commission, the signing of standard clauses or obtaining the consent of the data subject. In addition to the technical and organizational measures, other measures will be employed in addition to those used, not only by the data controller, but also required of the recipient, to ensure data protection and information security. 

CAN THIS POLICY BE CHANGED?

Yes. ANPL may change this policy due to national or Union legal requirements or when ANPL deems it relevant and appropriate. The data subject should periodically consult this policy to keep abreast of any changes, without prejudice to its notice on the home page of the ANPL website.