Privacy policy
Introduction
Sea Senso is committed to protecting the privacy and security of personal data in accordance with the General Data Protection Regulation (GDPR), Portuguese Data Protection Law (Lei n.º 58/2019), and other applicable legal frameworks. As a registered company in Portugal, we recognize the importance of processing personal data responsibly and transparently. This policy outlines how we collect, use, protect, and manage personal data.
1. Data Protection Principles
We adhere to the following principles in our data processing activities:
Lawfulness, Fairness, and Transparency: Personal data is processed in a lawful, fair, and transparent manner.
Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and is not further processed in a manner incompatible with those purposes.
Data Minimization: Only data that is adequate, relevant, and limited to what is necessary for the intended purposes is collected.
Accuracy: Personal data is kept accurate and up to date, with every reasonable step taken to ensure that inaccurate data is corrected or deleted promptly.
Storage Limitation: Data is kept in a form that permits identification of data subjects for no longer than necessary for the purposes for which the data is processed.
Integrity and Confidentiality: Personal data is processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
2. Data Controller
Sea Senso is the data controller responsible for the processing of personal data. We can be contacted for any questions or concerns regarding this policy or data protection matters at:
Company Name: Sea Senso
Registered Address: Rua Castilho , Nº.14 C, 5°, Freguesia de Santo António, 1250- 069 Lisboa, Portugal
Email: [email protected]
Phone: +351 300 609 026
3. Data Collection
We collect the following types of personal data:
Personal Identification Data: Name, address, phone number, email address, passport details, date of birth, identification numbers (e.g., ID card, NIF).
Professional Data: Job title, employment history, qualifications, references, salary information, employment contracts, performance evaluations, CV
Financial Data: Bank account details, salary records, tax information.
Sensitive Personal Data: Health information, and other data as required for employment or by law.
Technical Data: IP addresses, browser types, and other data collected through cookies and similar technologies through our website
Methods of Data Collection
Data is collected through various channels, including:
Directly from Individuals: Via forms, website portal(s), contracts, emails, or other communications.
Automatically: Through website cookies, logs, and similar tracking technologies.
Third Parties: From recruitment agencies, background check providers, or other external service providers.
4. Legal Basis for Processing
We process personal data based on the following legal grounds:
Contractual Necessity: When processing is necessary for the performance of a contract or to take steps at the request of the data subject prior to entering into a contract.
Legal Obligation: When processing is necessary to comply with legal obligations, such as employment, tax, and social security laws.
Legitimate Interests: When processing is necessary for our legitimate business interests, provided that such interests do not override the rights and freedoms of data subjects.
Consent: When the data subject has given explicit consent for processing for one or more specific purposes.
5. Purpose of Data Processing
We process personal data for various purposes, including:
Recruitment and Staffing: Managing job applications, conducting interviews, verifying qualifications, and onboarding employees.
Employee Management: Administering employment contracts, payroll, benefits, performance reviews, and training.
Compliance: Ensuring compliance with legal obligations, such as tax reporting, labor laws, posting and health and safety regulations.
Client Services: Providing HR services to clients, including recruitment, payroll, and employee management.
Security: Protecting our premises, employees, and IT infrastructure.
Marketing: With consent, sending information about our services and updates.
6. Data Sharing and Disclosure
We may share personal data with:
Service Providers: Third-party service providers who process data on our behalf, such as payroll processors, IT service providers, and legal advisors. These providers are required to comply with our data protection standards and are not permitted to use personal data for their own purposes.
Legal and Regulatory Authorities: For visa processing and when required to comply with legal obligations or to protect our rights and interests.
Clients and Business Partners: Where necessary for the provision of our HR services, ensuring compliance with data protection laws.
Other Entities: In the event of a merger, acquisition, or sale of our business, personal data may be shared with prospective buyers, provided that they agree to comply with data protection requirements.
7. Data Transfers Outside the European Economic Area (EEA)
Where personal data is transferred outside the EEA, we ensure that adequate safeguards are in place, such as:
Adequacy Decisions: Transfers to countries recognized by the European Commission as providing an adequate level of data protection.
Standard Contractual Clauses: Using contracts that include standard data protection clauses approved by the European Commission.
Binding Corporate Rules: For intra-group transfers, ensuring consistent data protection standards.
8. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, in line with legal, regulatory, or contractual requirements. After the retention period ends, personal data will be securely deleted or anonymized.
9. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
Access Controls: Restricting access to personal data to authorized personnel only.
Encryption: Protecting sensitive data during transmission and storage.
Regular Audits and Reviews: Conducting regular security assessments and audits.
10. Data Subject Rights
Under the GDPR and Portuguese Data Protection Law, data subjects have the following rights:
Right to Access: Request access to the personal data we hold about them.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure: Request deletion of personal data under certain conditions.
Right to Restrict Processing: Request the limitation of processing under certain conditions.
Right to Data Portability: Request the transfer of their data to another controller in a structured, commonly used, and machine-readable format.
Right to Object: Object to processing based on legitimate interests or direct marketing.
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
To exercise any of these rights, data subjects can contact us using the contact details provided. We will respond to requests within the legal time frame and ensure that any action taken is in compliance with applicable laws.
11. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance user experience, analyze website performance, and for marketing purposes. Data subjects can control cookie preferences through their browser settings or by using cookie management tools provided on our website.
What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
How do we use cookies?
Our Company uses cookies in a range of ways to improve your experience on our website, including:
Keeping you signed in
Understanding how you use our website
What types of cookies do we use?
There are several different types of cookies, however, our website uses:
Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies are used.
Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company will not share aspects of this data with third parties for advertising purposes.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Privacy policies of other websites
If the Our Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
12. Data Breach Notification
In the event of a data breach that poses a risk to data subjects, we will notify the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados – CNPD) within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will also notify the affected data subjects without undue delay.
13. Training and Awareness
We ensure that all employees and contractors understand their responsibilities regarding data protection and receive regular training on GDPR compliance, Portuguese data protection law, and this policy.
14. Policy Review and Updates
This policy will be reviewed annually or as needed to reflect changes in laws, regulations, or business practices. Significant changes will be communicated to all relevant stakeholders.
15. Contact Information
For any questions, concerns, or requests regarding this Data Protection Policy, please contact:
Email: [email protected]
Phone: +351 300 609 026
Address: Rua Castilho , Nº.14 C, 5°, Freguesia de Santo António, 1250- 069 Lisboa, Portugal
By adhering to this policy, Sea Senso ensures that personal data is handled in accordance with the highest standards of security and privacy, thereby protecting the rights of all individuals whose data we process.