Privacy Policy

Privacy Policy and Protection of Personal Data

Purpose and Scope
Indústria de Calçado Celita, Lda hereby adopts the Privacy Policy and Protection of Personal Data, whose main objective is to
ensure that the processing of personal data complies with the rules established in the General Regulation of Data Protection
(EU) 2016/679, and other legal provisions, in particular with regard to the processing and protection of personal data and the
free movement of such data, in accordance with the needs of our customers, partners and employees.

Responsible for the Treatment Social designation:

Indústria de Calçado Celita, Lda

address: Rua Cidade de Guimarães, 187 – São Torcato

4800-858 Guimarães – Portugal

Contacts: 253543098 | dados@ambitious-shoes.com

Personal Data and Consent of the data subject

Personal Data is any information of any nature and regardless of its support, including sound and image, relating to an
identified or identifiable natural person ("data subject"); a person who can be identified directly or indirectly, namely by
reference to an identifier such as the name, identification number or one or more specific elements of his physical,
physiological, mental, economic, cultural or social identity.
Sensitive Data: Personal Data relating to philosophical or political beliefs, trade union membership, religious belief, private
life and racial or ethnic origin, as well as the processing of data on health and sexual life, including genetic data.
Consent of the data subject: Any express, free, specific, informed and explicit willingness, according to which the data
subject accepts, by means of a declaration or an unequivocal positive act, that their personal data are processed.

Data Owner
Data Owner is understood as the natural person to whom the data relate.
Concerning the activity of the Indústria de Calçado Celita, Lda, most of the processed data are collective persons (companies
and associations). However, in order to carry out its tasks, data of the following types of natural persons may be collected
and processed:

Employees
Clients and their collaborators
Service providers and their collaborators
Suppliers and their collaborators
Visitors to events where the Indústria de Calçado Celita, Lda is present as an exhibitor

Purpose of data processing
The personal data collected by Indústria de Calçado Celita, Lda are processed for specific, explicit and legitimate purposes.
Whenever personal data are collected, they are intended exclusively for the purposes expressly identified at the time of
collection. Here we outline the main purposes that justify the collection of personal data by the Indústria de Calçado Celita,
Lda:

Treatment of personal data of its workers, under the contract of employment:
Treatment of personal data of its suppliers and customers (individual name), in the scope of the commercial
relation.

Collection, processing and preservation of Personal Data
Personal Data Processing means any operation or set of operations performed on Personal Data, with or without automated
means, such as collection, registration, organization, conservation, adaptation or alteration, retrieval, consultation, use,
communication by transmission, dissemination or otherwise making available, by comparison or interconnection, as well as
limitation, erasure or destruction.

Indústria de Calçado Celita, Lda will only process Personal Data if it is necessary for the continuation of its activity,
compliance with legal or contractual obligations or for the pursuit of the purposes indicated above.
Indústria de Calçado Celita, Lda assumes that the data collected was inserted / made available by the respective owner and
that its insertion / making available to Indústria de Calçado Celita, Lda, has been authorized by it, and the Personal Data in
question is true and accurate. Indústria Calçado Celita, Lda shall take appropriate measures to ensure that inaccurate or
incomplete data are erased or rectified, taking into account the purposes for which they were collected or for which they are
subsequently processed.

The Personal Data collected will be stored in such a way that they can be identified only for the period necessary to carry out
the purposes of collection or further processing, after which they will be definitively eliminated without any possibility of
recovery. In case it is necessary to retain the data for a certain period of time, the information must be preserved with
restricted access.

Communication to Third Parties
Indústria de Calçado Celita, Lda may communicate Personal Data to third parties, within the scope of compliance with a legal
obligation, a decision of the National Data Protection Commission (CNPD) or a court order; when the communication of data
is carried out to protect vital interests of the holder of the Personal Data; in connection with a sale, assignment or other
transfer of the business to which the Personal Data relates; or any other legitimate purpose under the LPDP.

Subcontracting
Indústria de Calçado Celita, Lda may communicate the Personal Data to entities subcontracted by them for the purpose of
handling them, on behalf of and under the instructions of Industria de Calçado Celita, Lda as responsible entity.
Indústria de Calçado Celita, Lda will only contract entities that offer sufficient guarantees regarding the technical security
measures and organization of the Treatment of Personal Data to be made, and must ensure compliance with these
measures. Such subcontractors will be subject to full compliance with the rules set forth in these Data Processing Conditions,
when processing Personal Data on behalf of and under instructions of Indústria de Calçado Celita, Lda.

Rights of Data Holders
In accordance with current legislation, Data Rights holders are guaranteed a set of rights that they may exercise with the
Indústria de Calçado Celita, Lda:
Right of access: right that allows you to obtain information regarding the treatment of data and its characteristics.
Right of rectification: right that allows to request the rectification of your data, requiring that they be accurate and current.

Right to delete data or "Right to be forgotten": right that allows to request to delete data, when considered that
there are no valid grounds for data retention and provided that there is no other valid basis for such treatment (such
as the execution of a contract or the fulfillment of a legal or regulatory obligation).
Right to Limitation: right that allows the suspension of treatment or limitation of treatment to certain categories of data or purposes.

Right to Portability: right through which you can request the sending of your data, in digital format and current use,
that allows the re-use of such data. Alternatively, you may request the transmission of your data to another entity
that becomes responsible for the processing of your data.
Right of Opposition: right that allows you to oppose certain purposes and provided that there are no legitimate
interests that prevail over your interests.

Right to Withdraw Consent: right that allows you to withdraw your consent, but which can only be exercised when
your consent is the only condition of legitimacy.

Security measures
Indústria de Calçado Celita, Lda implements technical and organizational measures necessary to protect Personal Data in
accordance with the level of confidentiality of the data to be protected.

Changes to the Description / Conditions of Data Processing
Indústria de Calçado Celita, Lda reserves the right at all times to change, add or revoke, partially or totally, the present
Conditions of Data Processing. Any changes will be timely disclosed through written communication.

Clarifications
To find out more about how Indústria de Calçado Celita, Lda treats your personal data, or to clarify any doubt, make any
complaint or comment about the Privacy Policy, please contact us through the contacts mentioned in the identification of the
responsible by treatment.

Validity
This Data Processing Description / Conditions shall take effect on May 25, 2018.

Guimarães, May 26, 2018