About Aubay

Aubay Portugal, S.A. is committed in protecting all personal data that are under his responsibility. For that motive, all personal data is processed and protected according the applicable law: Regulation EU 2016/679, General Data Protection Regulation (GDPR).

This Privacy Policy explains who we are, for what purposes we process your personal data, how do we process them, to whom we may disclosure, such as, customers and/or other subsidiaries of the Aubay Group, to where they can be transferred and from where they can be accessed and what are their rights.

Aubay Portugal, S.A. (from this point forward designated by “Aubay Portugal” or “Aubay”), will process your personal data (also referred in this policy has “information”) according to the purposes described below.

Aubay Portugal is responsible for your personal data processing.

Your personal data will be subject of processing only for the following purposes:

Why do we need your information?

A. Relevant purposes to Aubay employees

Human Resources Management

Includes the processing of all data necessary to the signing, fulfilling, ceasing of a work contract, timesheet management, absences and vacations, salaries processing and other benefits, Fiscal Authority and Social Security relations, promotions and career management, training, assessment, representation expenses and employee communication, organizational disciplinary application.

Business and Internal Management

Includes activities like planning of projects, work time register, corporate assets management, provide centralized services to increase operations efficiency, audits and investigations execution, management controls implementation, internal databases usage, archive management, assurance, prevention, conflict preparation and management.

Workplace Security, Hygiene and Healthcare

Includes activities related with workplace security, hygiene and healthcare, workforce and company assets, authentication and access control of employees.

Analysis and Management

Includes activities like satisfaction questionnaires, acquiring and fusions processes management, businesses units’ sales and employees’ data processing for reporting and analysis purposes.

Fulfilment of Legal Obligations

Includes the personal data processing strictly necessary to fulfill the legal obligations, like the disclosure of data due to court orders, collaboration with supervision and regulatory entities and the protection of Aubays’ legitime rights.

Protection of Vital Interests

The personal data processing for the protection of the employees’ vital interests.

B. Candidates Relevam Purposes

Recruitment

Includes recruitment activities such as search, selection and assignment in Aubays’ Portugal customers, as well in related activities. In this scope, data processing will also be applied to salaries processing and human resources management.

Contracts Execution

Includes activities like the celebration of customers and partners contracts, as also communication to third parties involved in the contracts (assurance companies, beneficiaries, intermediaries) and answering to customers and partners requests.

Development and Service Improvement

Includes activities necessary for the development and service improvement provided by Aubay Portugal, activity analysis and processing for statistical and scientifical purposes.

How will be used my information?

Personal Data Processing Legitimacy

Your personal data will only be used if one the following situations occurs:

1. Gave your consent by signing a paper document or accepting on an online webform.

2. If your personal data is necessary for the fulfillment of the legal work contract obligations.

3. If your personal data is necessary for Aubays’ mandatory fulfillment of legal obligations, such as data disclosure to the Fiscal Authority and to Social Security, as well to other authorities.

4. If your personal data is necessary for Aubays’ legitimate interests execution, if those do not overcome the interests and rights, liberties and warranties of the data subject.

Your personal data will not be used for purposes other than those described in this policy, without being informed in advance or, where appropriate, obtained your consent.

Your personal data will be processed by Aubay Portugal by applying technical and organization measures to assure a high level of security, according to the GDPR.

For job candidates, Aubay Portugal defines and analyses behavior profiles to provide a continuous improvement in human resources selection and recruitment service.

For how long will you keep my information?

Your personal data will be kept for the minimum period necessary and proportional to the pursuit of the purposes described above.

In the case of employees, your data will be kept for the purposes of compliance with legal obligations and protection of the legitimate interests of Aubay.

Regarding recruitment processes, and in terms of labor laws, your personal data will be kept during a period of 2 (two years).

Will my personal data be shared with others?

Your personal data may be disclosed

1. In the scope of the Aubay Corporate Group. Aubay Portugal is included in a multinational group. Your personal data may be disclosed to the other companies of the group in the context of providing shared services between group companies and to internal reporting purposes;

2. To Aubay Customers. In the scope of human resources recruitment services and providing temporary work;

3. To third party Aubay suppliers. Aubay uses several third-party entities to provide services, whom may have access to your personal data;

4. To Public Authorities. Under applicable law, Aubay is obligated to disclosure your personal data to the Fiscal Authority, Social Security, Work Conditions Authority and answering to court orders and their respective judiciary authorities.

Accordingly, to the present privacy policy, your personal data may involve transference to other countries.

What are my rights?

At any moment, you may request us:

1. To access to your personal data;

2. To update your personal data;

3. To oppose, delete or limit your personal data processing;

4. The portability of your personal data in a structured, compatible and readable form.

To fulfill your rights, please contact our DPO using the following email: dpo@aubay.pt.

Your requests will be handled carefully, so that we can assure the efficiency of your rights. We may request that you prove us your identity to assure us that the sharing of personal data is only done with the data subject.

You should be aware that in certain cases, under applicable law, your request may not be immediate or fully satisfied. In any case, it will be informed of the measures taken to that effect within one month from the moment the request is made.

You also have the right to complain to the national supervisory authority: www.cnpd.pt.

May I remove the consent afterwards?

If the consent was legally necessary for the personal data processing, the data subject has the right to remove the consent at any time.

However, this right does not compromise the fairness of the treatment made based on the consent previously provided, as well as the subsequent treatment of the same data, with another legal basis, such as the fulfillment of the contract or the legal obligation that Aubay is subject.

In case you wish to remove your consent, please contact our DPO using the following email: dpo@aubay.pt

Still have questions...

If you remain with questions regarding this policy or other privacy issues, or wish to exercise any of your rights, please contact us through the email: dpo@aubay.pt or by postal address: Av. Duque d’Ávila, n. º 46, 7 C, 1050-093 Lisboa.

Updated in: 23th May 2018