Privacy and Data Protection Policy

INOV – Instituto de Engenharia de Sistemas e Computadores Inovação (INOV) is a private not-for-profit association, VAT No. 505 002 892, headquartered at Rua Alves Redol, No. 9, 1000-029 Lisbon, Portugal, dedicated to strengthening the capacity for innovation, modernization and global competitiveness of business entities and public bodies, through research and technological development, technology transfer, consultancy and advanced training in the fields of Information, Communications Technologies and Electronics.

INOV is committed to protecting the privacy and personal data of data subjects, in full compliance with existing data protection legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“RGPD”).

Given the importance of transparency in the data processing processes of its Employees, Partners and other stakeholders, INOV has outlined a Personal Data Policy that covers the way in which personal data are collected, used, disclosed, transferred and stored. In this context, it is necessary to make known the general rules of data processing in strict compliance with the legislation in force.

In the scope of its activity, INOV treats personal data resulting from its relationship with the following groups of subjects: employees (hired workers, scholars, researchers, interns and service providers); applicants for jobs and/or scholarships available; trainees and trainers; customers and suppliers; partners and participants in research projects; institutional site visitors; and other stakeholders.

The collection and processing of personal data is done through the signing of contractual documents, to fulfil legal obligations arising from the activity of INOV, the pursuit of its legitimate interests (in particular, to assure the safety and security of people and property, to manage its relationships with clients and other external interlocutors, to manage internal processes and resources – e.g. in the context of the management of internal administrative procedures or financial and administrative management of co-funded projects), or even with the free and express consent of the data subjects, whenever applicable.

Depending on the different purposes, INOV processes the following categories of data of its employees: general identification and contact data (name, telephone number, email address, address, social security identification number, identity card number and validity), tax identification data (tax identification number, tax exemption factors) bank identification data (bank identification number/IBAN), professional background data (curriculum vitae data provided) and (in certain contexts) photos and/or videos of a person. INOV processes as well general identification, contact and professional background data of the applicants and candidates for the positions made available by the institute.

There are also processed by INOV – as a training entity or as a partner of public and private institutions – personal data of the trainees and trainers in the execution of the training programs.

INOV may also process the following personal data of its clients and other external interlocutors: general identification data (such as name), contact data and opinions about the products and technologies developed.

Additionally, in the context of research projects, personal data of project participants can be processed to the extent necessary for fulfilling the purposes of this research. In this case, the data subjects are always previously informed about the processing intended. Whenever feasible, personal data generated by scientific research and technological development will be anonymously processed.

During the visit to INOV’s institutional website and for the purpose of promotional information or sending newsletters, IP addresses in the context of log processing and, sometimes, general contact data are processed. The IP addresses can be also processed in the context of integrated log processing required for the management of the security of INOV infrastructure.

The processing of personal data is carried out through automatic and manual processes, with appropriate technological and organizational measures and controls that are proportionate to their protection and preservation. These include the management of authentication and access to systems and facilities, the management of system usage profiles, controlled access to restricted information, the signing of confidentiality and professional secrecy agreements with employees and third parties, and the use of more robust techniques such as encryption whenever necessary.

Generally, personal data are stored for as long as there is a link to INOV, for the necessary period to fulfil legal obligations or to pursue legitimate interests.

Personal data may be transferred, for the same purposes, to entities determined by applicable law or to third parties.

Whenever personal data are shared with third parties outside the European Economic Area, for recipients of information not referred to as adequate, INOV undertakes to fulfil the provisions of the RGPD as applicable to the transfer of the concerned data.

Responses to requests for access, retrieval and consultation of personal data, updating, modification or delivery shall be ensured, and deletion, restriction and opposition to processing may be requested in accordance with current legislation.

Where consent has been given, consent may be withdrawn at any time using the contact details below.

Data subjects may complain about their processing to the relevant Data Protection Authority (Comissão Nacional de Proteção de Dados).

Data Protection Officer (DPO)

The DPO plays a relevant role in the protection of personal data, ensuring, among other things, the compliance of processes with current legislation. The DPO also verifies compliance with the current Data Protection Policy and sets clear rules for processing of personal data, ensuring that all interested parties are aware of how INOV treats such data and what rights they have in this regard.

For this purpose, if the data subject needs to contact the INOV DPO, he/she may do so through the means and contact details below:

Through written communication addressed to the Data Processing Officer (INOV) at Rua Alves Redol, 9, 1000-029 Lisbon, or by email sent to: privacidade@inov.pt

10/2023