DGL – Confeção Têxtil Unip.

PRIVACY MANAGEMENT POLICY

1. Application

The Privacy Management Policy presents the commitment of DGL - Confeção Têxtil Unip. in relation to the privacy management of the personal data of data holders, as well as compliance with the General Regulation on Data Protection, identified as Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27th April 2016.

Taking into account the inventory of personal data that DGL - Confeção Têxtil Unip. keeps updated, all the data considered private and / or sensitive managed according to the requirements of the General Regulation on Data Protection in order to guarantee the data holders rights.

2. Confidentiality and Privacy of Personal Data

For DGL - Confeção Têxtil Unip. personal data holders are all contractual corporate customers, web clients, company employees and suppliers / service providers (subcontractors).

Personal and/or sensitive data that are placed in custody of DGL - Confeção Têxtil Unip. are accessed by company employees formally authorized to perform such tasks.

The data are used only for activities that were previously authorized by the data holders through prior, informed and free consent.

Therefore, in the commitment to guarantee the privacy of personal data, confidentiality is also guaranteed.

The guarantee of confidentiality is ensure through the celebration, with DGL - Confeção Têxtil Unip. employees, of agreements for the protection of personal data that they access and work in the course of their professional activities.

3. Identification of the Responsible for Personal Data Treatment

The responsible for the personal data treatment is DGL - Confeção Têxtil Unip, headquartered in Rua das Fábricas, 42 S.Salvador do Campo, 4750-361 Barcelos, Portugal VAT nr. PT504780930.

4. Collection, Treatment, Sharing and Retention of Personal Data

4.1 Collection of Personal Data

4.1.1 Situations that do not involve Web tools

Personal data are collected directly from the following sources: form filling in DGL - Confeção Têxtil Unip. website, job application with curriculum vitae sharing, filling out paper forms, capturing images and videos, biometric data, e-mail adresse or phone.

No other method of indirect collection of personal data will be executed.

4.1.2 Situations Involving Web Tools

Personal data are collected directly through the DGL - Confeção Têxtil Unip. official Web tools, such as online shopping sites, or indirectly through “marketing automation” tools and “online” advertising through duly authorized and fully compliant subcontracting partners with privacy management policy

The cookie management policy complements this topic by presenting the "opt-in" and "opt-out" options that are available at PLAYSTAR42®. official website.

DGL - Confeção Têxtil Unip. assumes that in no case will a manual or computerized form have pre-filled options. All alternatives are selected by the data holder.

The collection of personal data will always be minimized for activities strictly necessary to the legitimate commercial interest of DGL - Confeção Têxtil Unip.

4.2 Personal Data Treatment

Authorized personal data will only be used by DGL - Confeção Têxtil Unip. with the strict objective of sustaining its commercial activities and legal obligations.

Justification

Purpose of Treatment

Grounding

E – Commerce

User registration on online store or marketplaces

Legitimate interest for Web client service providing

Online order management on websites

Communication with the user/customer in the different stages of the ordering process

Data transfer to logistics and freight providers

Retention of customer data with registration for new purchases

Data transfer to the platform for sending promotional digital marketing newsletters

Data transfer for online advertising on social networks

Customer service (online or by phone)

4.3. Personal Data Sharing

Personal data sharing will only be done with subcontracting partners who have signed the security management agreement in accordance with the determinations of the privacy management policy of DGL - Confeção Têxtil Unip.

Sharing Destination

Data Shared

Grounding

Marketing Automation

Gender, age and birthdate

Customized Campaigns for the Customer

Sending Newsletters and / or SMS

Name, e-mail address, address, birthdate, phone number

Sending personalized news, campaigns and offers to the customer

Online Advertising

E-mail address

Google Ads, Facebook and Instagram Advertising

Logistics and Delivery

E-mail address, name, phone number, shipping and billing address, birthdate, payment method, tax identification number

Operational requirements for interconnection with Nacex, CTT and DHL

Online Payment

Bank card number and ATM reference (if applicable)

Operational requirements for interconnection with HiPay and Paypal

There is data sharing with formally authorized subcontractors for digital marketing purposes. The personal data involved in these actions are subject to the consent of the data holder and, at any time, there is the possibility of “opt-out”.

In case of targeting digital marketing campaigns with intercontinental subcontracting partners, these actions can lead to the transfer of data outside the European Union.

In these cases, DGL - Confeção Têxtil Unip. will implement appropriate security controls to each identified risk situation, also ensuring data holders the guarantee of unconditional execution of their rights and all the requirements of the General Regulation on Data Protection.

4.4 Personal Data Storage

For each treatment purpose DGL - Confeção Têxtil Unip., will retain the personal data, for the maximum periods indicated below:

Purpose of Conservation

Retention Time

Grounding

Legal Documents

10 years

Current legal requirements

Employment Application Data

5 years

Contract Customer Orders Data

3 years

Depending on the organization operational needs

Web Clients Orders Data

3 years

Depending on the organization operational needs

Marketing and Advertising Data

Until "opt-out"

Include cookies, "newsletters” and SMS

Complaints and Privacy Violations

5 years

Legal proceedings support (if necessary)

Audit Records and Evidence

5 years

Legal proceedings support (if necessary)

Retention is the secure storage of data, in digital or paper format, in resource(s) under the responsibility of DGL - Confeção Têxtil Unip., which guarantees the conditions of longevity and use in function of the defined time.

5. Data Holder Rights

DGL - Confeção Têxtil Unip., ensures that data holders will be able to exercise their rights, if provided for and as described in the General Regulation on Data Protection,

Data holder, in order to exercise their rights and/or submit any question related to this subject, namely the presentation of complaints, should send their request, in writing, to the email address cs@playstar42.com.

In the event of a breach of privacy, the data holder may communicate through this same route or directly with the controlling authority.

6. Roles and Responsibilities

DGL - Confeção Têxtil Unip. management ensures that the Privacy Management Policy is aligned with the company's strategy, in addition to ensuring its continuous improvement.

Data Protection Officer has the role of ensuring compliance with the requirements of the General Regulation on Data Protection in a continuous and systematic manner, that all rights of the data holders are being met and that the security controls are adequate for these purposes..

All DGL - Confeção Têxtil Unip. employees, as well its subcontractors, have the responsibility to comply with and enforce the commitments of the Privacy Management Policy.

7. Review and Continuous Improvement

Privacy Management Policy will be reviewed annually, or whenever there are significant changes in the personal data inventory and/or in the informatics or documentary supports that warrant the rights of data holders.

Each revision will give rise to a new version of the Privacy Management Policy.

8. Disclosure and Publication

The Privacy Management Policy will be disclosed to all data holders who interact with DGL - Confeção Têxtil Unip. and will be available upon request, as the information contained therein is classified as publicly accessible.

The Privacy Management Policy is available on the institutional website, on the Internet tools that support the business and also in the social media where DGL - Confeção Têxtil Unip. is represented.