Privacy policy

⦁ Scope

We are committed to protecting your privacy.

This Privacy Policy explains what Personal Data we, MSNAPZTECH SOLUTIONS, LDA., a Portuguese private company with registered office at Rua de Sá da Bandeira Nº819, 7º Left 4000-267 Porto, and presence in Portugal, collects about you, how we process it, what we use it for, who we share it with and how we protect it. It also sets out your rights and who you can contact for more information or queries. When used in this Privacy Policy, “we”, “us”, “our” or “SNAPTECH” and “SNAPTECH SOLUTIONS” refer to MSNAPZTECH SOLUTIONS, LDA. Personal Data refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
We may also sometimes collectively refer to handling, collecting, protecting, and storing your Personal Data as “processing” such Personal Data.
With this Privacy Policy we aim to ensure the principles relating to processing of Personal Data (lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; accountability) are considered in all our activities.
We have endeavored to make this Privacy Policy as straightforward as possible. However, if any of the terms used are unfamiliar to you or if you have any questions, please feel free to get in touch with us. Furthermore, we recommend that you regularly review this page, as our Privacy Policy may undergo changes.

⦁ What Personal Data We Collect

Please note that you are not obliged to provide SNAPTECH with your Personal Data. However, if you choose not to provide, or – where applicable – object to us processing the information we collect (see section “Your rights” below), we may not be able to process your requests or provide you tailored communication, service, or assistance.

We may collect and process your data because:

  1. you give it to us (for example, (1) through the webpages of this Website or any other Website or application of SNAPTECH which links to this Privacy Policy (collectively referred to as the “Website”), or (2) through any other mode of interacting with you relating to SNAPTECH communications, such as online social media, newsletters or offline events, that reference this Privacy Policy or link thereto (“Communication”));
  2. it is publicly available.

The Personal Data we collect has specified, explicit and legitimate purposes and will not be further processed in a manner that is incompatible with those purposes. If so, prior to that further processing we will provide information on that other purpose and any relevant further information.

We understand the importance of protecting children’s privacy. It is not our policy to intentionally collect or store information about children.

The Personal Data we process may differ in alignment with the type of association you have with us.

⦁ If You Are a Candidate

In order to identify and get the best possible job opportunities and/or services tailored to you, we need to process certain information about you. We only ask for information that will be relevant to us. If you have an interest in working with us, you might fill a spontaneous application. This application is addressed to us through our Career Tool. In this case, the Personal Data we collect will include your: full name, birth year, phone number, e-mail, job and education background. If we have an open position, we might also collect your Curriculum Vitae (CV) through a job hunt platform. Similar information may be collected and processed if you get in touch with us through a register at your university employment platform, job fairs, references of employees or former employees, workshops and partnerships with the goal of being contacted by SNAPTECH.

Our recruiting process also includes interviews, meetings and follow ups with our Team. During these interactions, the Personal Data we collect will include your: full name, birth year, phone number, e-mail, gender, marital status, if you have any dependents, current and expected salary, country of residence, physical address, immigration status, business & industry interests, job and education background, CV.

⦁ If You Are an Employee

If you are or you are going to be an employee of SNAPTECH the Personal Data we collect will include your: full name, birth year, phone number, e-mail, gender, marital status, if you any dependents, current and expected salary, country of residence, physical address, immigration status, business & industry interests, job and education background, CV, social security number, bank details , photograph, copy of a Citizen Card/Passport or other equivalent ID, structure of your household and other financial information (in cases where we have to carry out checks on the financial context). When appropriate, and in accordance with the law, we may also collect information or miscellaneous data on any criminal convictions.

Where we do not usually seek to collect ‘sensitive’ or ‘special categories’ of Personal Data (e.g., data relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying the sex life or sexual orientation of an individual), the Personal Data we collect may include so called ‘sensitive’ or ‘special categories’ of Personal Data, such as details about your:

  • dietary requirements (for example, when we would like to provide you with lunch during a meeting);
  • health (for example, so that we can make it easy for you to access our buildings, events).

We will only process these special categories of Personal Data when we are required to do so as a result of legal requirements imposed on us or after obtaining your explicit consent.

⦁ If You Are a Business Partner

If you are (or if you can potentially be) a SNAPTECH Partner, Customer or Client, we need to collect and use information about you or the people in your company, in the context of our service provision, in order to provide you with the most complete service possible and for our contractual relationship to unfold correctly. The Personal Data we collect will include your: name, email, position and contact number of employees relevant to the provision of services.

⦁ If You Are a Supplier

When referring to suppliers we intend to include any companies (including sole traders) and atypical service providers, such as independent contractors and self-employed, who provide services to SNAPTECH. In certain circumstances, SNAPTECH will subcontract the services it provides to customers to third party suppliers that perform the services on behalf of SNAPTECH. In this context, suppliers who are sole traders, self-employed persons or employees of suppliers will be treated as candidates for the purposes of data protection. Please note that, in this context, SNAPTECH requires suppliers to communicate the relevant parts of this Privacy Policy (namely the sections addressed to candidates) to their employees.

We need a small amount of information regarding your Personal Data in order to ensure that everything works correctly. We need contact details for certain people in your company, so that we can communicate with you, as well as other information, such as your bank details so that we can pay you for the services you provide (if this is part of the contractual arrangements between us). We may also have information that someone in your company has chosen to share with us.

⦁ If You Are a Newsletter Subscriber

When you subscribe to our newsletter, we collect certain Personal Data to provide you with relevant updates and content. The Personal Data we collect will include your: name and email, to deliver newsletters and keep you informed about our latest updates, events, and relevant content.

⦁ If You Are a Website User

We may collect Personal Data from you when you interact with the Website. For example, we or our service provider(s) may use cookies (small text files stored in a user’s browser) or web beacons (electronic images that allow us to count users who have accessed particular content and to access certain cookies) to collect aggregate data. Where applicable, additional information on how we use cookies and other tracking technologies, and how you can control these, can be found in our Cookie Policy.

Our Website is connected to Google Analytics to gain insights and improve the user experience or for analytical marketing purposes.

⦁ What Are Our Purposes and Grounds Of Processing Personal Data

The purposes and fundamentals on the basis of which SNAPTECH treats your Personal Data depends on your association with SNAPTECH.

⦁ If You Are a Candidate or an Employee

(Including suppliers who are sole traders, self-employed or supplier employees)

Candidates Personal Data will be collected and processed, namely, for the following purposes:

  • Recruitment – includes recruiting activities to provide services or back office functions, such as research and selection. In the case of service provision, there is an approach to current and potential SNAPTECH business partners in order to find an opportunity to collaborate. In this context, data related to salary processing and human resources management will also be treated;
  • Execution of contracts – includes activities such as starting contracts with SNAPTECH and partners, as well as communication with third parties involved in the contracts (insurance companies, beneficiaries, intermediaries);
  • Development and improvement of services – includes activities necessary for the development and improvement of services provided by SNAPTECH, activity analysis and processing for potential future opportunities.

⦁ If You Are a Business Partner or a Supplier

Supplier/Service Providers or Business Partner/Customer/Client Personal Data will be collected and processed, namely, for the following purposes:

  • Contract execution – includes all activities necessary for the execution of the service contract, namely with regard to payment processing;
  • Communications – includes the necessary contacts so that we can contact you regarding our contracts;
  • Development and improvement of services – includes activities necessary for the development and improvement of services provided to or by SNAPTECH, activity analysis, processing for statistical and scientific purposes, as well as to offer services or to obtain support and services from you;
  • Compliance with legal obligations.

⦁ If You Are a Newsletter Subscriber

When you subscribe to our newsletter, we collect your Personal Data with your explicit consent and it will be processed in order to deliver our newsletters. You can manage your preferences at any time. You can update your subscription details or unsubscribe by following the links provided in SNAPTECH’s newsletters or by contacting SNAPTECH directly.

⦁ If You Are a Website User

We may use the Personal Data we collect in our Website for the following purposes:

  • managing and/or improve our Website, for instance, by tailoring the content of our Website to provide you with a more personalized experience or by drawing your attention to information about products and services that may be of interest to you;
  • conducting data analysis including, for example, regarding usage of the Website, demographics analyses and advertising activities.

⦁ Complementary Considerations

In certain circumstances, to assist us in declaring, exercising or defending a right, SNAPTECH may use third parties or external service providers, who perform functions on behalf of SNAPTECH, such as companies that host or operate the SNAPTECH Website, process payments, health and safety at work assessments, analyze data, provide customer services, and sponsors or other collaborating third parties directly with the activity developed by SNAPTECH.
Your Personal Data can be processed by these third parties for the purposes described in this Privacy Policy. These third parties must process your Personal Data in accordance with this Privacy Policy and in accordance with applicable law.
When we collect your Personal Data for the purposes described above or for other purposes, we inform you beforehand or at the time of collection, and we will seek your consent whenever necessary to legitimize the processing of your data. When you have provided your consent for processing activities, you have the right to withdraw your consent at any time.
However, there may be some cases in which it is not your consent that legitimizes the processing of your Personal Data, but one of the following grounds:

  • When treatment is necessary to conclude a contract with you or proceed with its execution;
  • When treatment is necessary to comply with the legal obligations to which SNAPTECH is subject;
  • When processing is necessary to achieve a legitimate interest pursued by SNAPTECH, which does not jeopardize its fundamental interests, rights and freedoms that require the protection of Personal Data – this legal basis will only be used if there is no less intrusive way of treat your Personal Data. We can assure you that if the legitimate interest is used as a reason to process your Personal Data, we will keep a record of that action and you will have the right to request that information;
  • When treatment is necessary for the purposes of declaring, exercising or defending a right in a judicial proceeding or providing information to a public body or law enforcement agency.

⦁ With Whom Your Personal Data Will Be Shared

In connection with one or more of the purposes outlined in the “What Are Our Purposes and Grounds Of Processing Personal Data” section above, we may disclose details about you to: other members of the SNAPTECH for legitimate business-related purposes; present or future external service providers that perform functions on behalf of SNAPTECH (for additional details, please check “What Are Our Purposes and Grounds Of Processing Personal Data” ); third parties as part of a corporate transaction (such as a sale, divestiture, reorganization, merger or acquisition); competent authorities (including courts and authorities regulating us or another member of the SNAPTECH) and other third parties that reasonably require access to Personal Data relating to you for one or more of the purposes outlined in the “What Are Our Purposes and Grounds Of Processing Personal Data” section above. As we work in different projects side by side with several Partners. If you are a candidate or an employee, your job and education background, as well as your name and current position might be shared with our Business Partners, within the scope of technical consultancy services. Under the terms of the applicable law, SNAPTECH is obliged to disclose data to the Tax Administration, Social Security, the Working Conditions Authority, and, following judicial mandates, to the judicial authorities. We may also need to disclose your Personal Data if required to do so by law, by a regulator or during legal proceedings.

⦁ General Considerations

SNAPTECH is part of a business group, so our data can be disclosed to other companies in the group in the context of the provision of services shared between group companies and for the purposes of internal reporting.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
We do not have in place an automated decision-making mechanism, including profiling. We do not sell your Personal Data.

⦁ International Data Transfers

Please note that some of the recipients of your Personal Data referenced above may be based in countries without data protection laws similar to those in Portugal or in effect in your area of residence.

SNAPTECH will only send Personal Data collected within the European Economic Area (EEA) to foreign countries where necessary to follow your instructions, to comply with a legal duty, or to work with agents and consultants who help us to manage our business and services.

If you transfer Personal Data outside the EEA, SNAPTECH will ensure that they are protected in the same way as if they were being used in the EEA. For this purpose, we will use one of the following safeguards:

  • Transfer to a non-EEA Country whose privacy legislation ensures an adequate level of protection of Personal Data similar to those existing in the EEA;
  • Implementation of a contract with the foreign entity that requires it to protect Personal Data according to the same standards used in the EEA;
  • Transfer of Personal Data to organizations with specific international data transfer agreements with the European Union.

Further details of the transfers described above, and the adequate safeguards used by us in respect of such transfers, are available. For such information, please contact us by using the “How Can You Contact Us” section below.

⦁ Which Security Measures We Have in Place For Your Personal Data

SNAPTECH takes all possible measures to ensure the confidentiality and security of your Personal Data, carrying out all efforts and security measures to protect your Personal Data from misuse, interference, loss, unauthorized access, modification, or disclosure.

Our measures include the implementation of appropriate access controls, to ensure that we encrypt, pseudonymize, and anonymize Personal Data whenever possible.

Access to your Personal Data is only allowed under the terms already described above, always depending on the actual need for your knowledge, and subject to strict contractual confidentiality obligations when processed by third parties.

Although data transmission over the internet or Website cannot guarantee total security against intrusions, SNAPTECH and its service providers ensure the best efforts to implement and maintain physical, electronic, and procedural security measures designed to protect your Personal Data in compliance with applicable data protection requirements, as well as education and training to relevant staff so they are aware of our privacy obligations when handling Personal Data.

⦁ What is the Storage Limitation of Your Personal Data

We will hold your Personal Data on our systems for the longest of the following periods:

  1. as long as is necessary for the relevant activity or services;
  2. any retention period that is required by law;
  3. the end of the period in which litigation or investigations might arise in respect of the services. Thus, we will retain your data only for the period strictly necessary to fulfill the purpose for which it was collected.

⦁ What are Your Rights

You have various rights in relation to your Personal Data, which are as follows:

  • Right to information – the right to be given concise, transparent, understandable and easily accessible information, using clear and simple language, on how we use your Personal Data and on your rights;
  • Right of access – the right to access your Personal Data at all times;
  • Right to rectification – the right to rectify inaccurate Personal Data concerning you, or to have incomplete Personal Data completed;
  • Right to erasure – under certain conditions, you have the right to the erasure of Personal Data concerning you, without undue delay;
  • Right to restriction of processing – under certain conditions, the data subject has the right to obtain restriction of processing of his Personal Data;
  • Right to data portability – under certain conditions, you have the right to receive Personal Data that concerns you and that you have provided, in a structured format, in current use and automatic reading, as well as the right to transmit that data to another entity;
  • Right to object – the right to object at any time, for reasons related to your particular situation, the processing of Personal Data concerning you, under the terms of the General Data Protection Regulation;
  • Right he right not to be subject to a decision based solely on automated processing – this includs profiling, which produces legal effects concerning you or similarly significantly affects you.
  • Right to lodge a complaint with a supervisory authority about the way we treat your Personal Data – which will be the National Data Protection Commission, with address in Rua de São Bento, no 148 – 3.o, 1200-821 Lisboa, phone +351 213928400, fax +351 213976832, and email geral@cnpd.pt; Right to withdraw your consent – in this case, withdrawing consent does not compromise the lawfulness of the treatment carried out based on the consent previously given.

To help us maintain the accuracy of your Personal Data, please contact us by using the “How Can You Contact Us” section below, if any of your personal details have changed.

⦁ When you Have a Personal Data Request

The aforementioned rights can be exercised at all times by means of a communication addressed to SNAPTECH, by using the “Contact information” section below. You may be asked to provide proof of your identity in order to ensure that Personal Data is shared only with the holder. Depending on your request, we may ask you to provide additional information. Once we receive this information, we will then review it and determine whether we are able to match it to the information SNAPTECH maintains about you to verify your identity.

If you are submitting a Personal Data request on behalf of someone other than yourself (third party request), please contact us by using the “Contact information” section below and include proof that you are authorized to make the request. This may be in the form of a written authorization signed by the person whom you are acting on behalf of or a valid power of attorney.

⦁ How Can You Contact Us

Last updated: 1st of August 2024

We may modify or amend this Privacy Policy from time to time.

To let you know when we make changes to this Privacy Policy, we will amend the date at https://snaptechsolutionsio.wordpress.com/privacy-policy. The new, modified, or amended Privacy Policy will apply from that revision date. Therefore, we encourage you to periodically review our Privacy Policy to be informed about how we are protecting your information.

This Privacy Policy was written in English. To the extent any translated version of this Privacy Policy conflicts with the English version, the English version stands.