Data Protection Policy

The purpose is to inform all visas about how Apperoni protects and manages the protection of personal data and sensitive personal data collected in the course of its activity. The privacy policy refers to all the care taken in collecting the same data in terms of legitimacy, rights of the data owners and the respective privacy of the data owners, and the privacy policy can be consulted at the headquarters or at https: / /apperoni.com


PROTECTION OF SERVERS AND THE COMPUTER NETWORK

Apperoni undertakes to have its computer system protected with the following updated tools:

Firewall properly updated and installed;

Use duly legalized software;

Configuration of users requiring access password access;

Hierarchy of information within the user or the computer system itself;

Upgraded backups;

Regular change of passwords;

Use of secure passwords;


PASSWORD

Apperoni uses efficient password management while minimizing the risks of data breach with its efficient password management, and they change frequently. Apperoni's passwords are personal and non-transferable.


BACKUP

Apperoni regularly performs backups, having two levels of backups, regular and periodic backups. The regular ones are made to the servers and devices connected to them daily, and the periodicals are made monthly.

Each of these backups are made and disconnected from the computer network for its security and preservation.


PERMANENCE OF DATA

The personal data are processed by Apperoni for the legal period required required to achieve the defined purpose, in the case of contractual and legal obligations.

If there is no legislation that requires the file to be kept for a minimum period of time, the data will be stored for 2 years, or until the right of opposition is exercised, right to be forgotten or withdraw consent (in case you can do). After the respective storage period has elapsed, Apperoni will delete its data and destroy the paper records.


DELETING DATA

Apperoni will delete the data as follows:

The data stored on paper will be destroyed and later delivered to an ecoponto;

Data stored on computer media is erased from the system, and then erased in the backup after the period of one month defined by the periodic backup;

The data will also be eliminated from the pc's of the users of Apperoni's PC network;

Any residual data in the emails will be stored for a maximum period of 5 years, which is less than the time of the custody of any mentioned file;

At the time of computer destruction or physical destruction of their personal data, or only in some cases, Apperoni may permanently anonymize them for statistical purposes.


PAPER FILES

The paper file is also a concern of Apperoni, so it is safeguarded from the common access of all users or those who visit the facilities of Apperoni.

In this way Apperoni protects the access to your file being the same properly closed to the key, and having only access to him the employees who thus need. These same employees are responsible for sorting this file to proceed with the selection of the file that must be destroyed, and proceed to its respective destruction.


HIERARCHIZATION AND CLASSIFICATION OF INFORMATION

Apperoni's information is classified so that there is a clear separation of personal data, sensitive data, business data, and other data. Access to information is hierarchical and limited, and there is no free access by all to all information.


SIGIL AND CONFIDENTIALITY

Each of Apperoni's employees, as well as all its subcontractors, are contractually bound by the duties of secrecy and confidentiality required by Apperoni, and any failure to comply with these standards should be informed to the Data Protection Officer, who may be contacted through E-mail geral@clauditis.pt


TRANSFER OF DATA BETWEEN ENTITIES

The transfer of data between Apperoni and its subcontractors is always done through a secure form, and after signing a contract obliging the subcontractor to the duties of secrecy and confidentiality. In this way any database or set of personal data will always be transmitted by:

Email with encrypted attachments;

Cloud secure with data in the EU;


TRANSMISSION OF DATA TO THIRD PARTIES

Your personal data may be transmitted to entities to whom the data must be communicated for the fulfillment of legal obligations, such as:

Accounting;

Tax Authority;

Social Security;

Legal department;

Health and safety at Work;


AMENDMENTS TO THIS PERSONAL DATA PROTECTION POLICY

This data protection policy will be permanently updated in order to reflect the comments received and whenever warranted. When we post changes to this policy we will simultaneously change its "update date". We recommend that you periodically check our privacy policy to keep informed about how Apperoni protects your Personal Data.

Updated April 29, 2019

Version 1.0