Arising from our vision and aligned with our objective of acting responsibly within our business area and in our relationships with employees, clients, and suppliers, the protection of privacy and personal data, as well as their transparent and ethical processing, are core values of NomadReflex.
For this reason, personal data is processed based on the following principles:
- Personal data is processed lawfully, fairly, and transparently;
- Data is collected only for specific, explicit, and legitimate purposes, in accordance with applicable law;
- Data collected is limited to what is strictly necessary and kept only for as long as required for its intended purposes;
- Access to personal data is restricted to NomadReflex employees and partners whose duties require it;
- Personal data is processed confidentially.
1. Personal Data
According to data protection legislation, personal data means any information relating to an identified or identifiable natural person (the data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifiers, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
2. Processing of Personal Data
a) Conditions for processing
NomadReflex will only process personal data when one of the conditions established by data protection legislation is met, namely:
- When processing is necessary for the performance of a contract to which the data subject is a party, or to take pre-contractual steps at the request of the data subject;
- When processing is necessary for compliance with a legal obligation to which NomadReflex is subject;
- When processing is necessary to protect NomadReflex’s legitimate interests;
- When the data subject has provided consent for the processing of their personal data.
b) Data Controller
The data controller is NomadReflex, the company with which the data subjects maintain a relationship.
c) Data retention
Personal data processed by NomadReflex will be retained only for as long as strictly necessary for the purposes for which it was collected, or for the period required by applicable law, if longer. Retention periods are determined according to defined and appropriate information retention criteria, in compliance with legal and regulatory obligations.
3. Data Subjects’ Rights
NomadReflex ensures that data subjects can exercise the rights granted under data protection legislation, in accordance with the applicable legal framework, namely:
- Right of access: the data subject may obtain confirmation of whether their data is being processed and access related information.
- Right to rectification: the data subject may request correction or updating of their data.
- Right to erasure (“right to be forgotten”): the data subject may request deletion of their data in specific situations, such as:
- when the data is no longer necessary for the purpose for which it was collected;
- when consent is withdrawn and no other legal basis exists;
- when the data subject objects to processing and there are no overriding legitimate interests;
- when processing is unlawful;
- when erasure is required by law;
- when data was collected in the context of information society services.
- Right to restriction of processing: the data subject may request restriction of processing where:
- the accuracy of data is contested;
- processing is unlawful;
- data is no longer needed but required for legal claims;
- an objection has been filed and is pending assessment.
- Right to data portability: where processing is based on consent or a contract and carried out by automated means, the data subject may request their data in a structured, commonly used, machine-readable format, or request direct transfer to another controller if technically feasible.
- Right to object: the data subject may object to processing at any time, particularly when based on legitimate interest.
- Right not to be subject to automated decision-making: the data subject may request human intervention in decisions based solely on automated processing that significantly affect them.
- Right to withdraw consent: the data subject may withdraw previously given consent at any time.
- Right to lodge a complaint: the data subject may file a complaint with the Portuguese Data Protection Authority (CNPD) regarding any matter related to their personal data processing.
If you wish to exercise any of the rights referred to above or clarify any matters related to the protection of privacy and personal data by NomadReflex, you may do so by letter or email, using the contact details provided in paragraph 6.
6. Security Measures
NomadReflex has implemented technical and organizational security measures to protect personal data against breaches — namely the destruction, loss, alteration, unauthorized disclosure, or access to personal data — and against any other form of unlawful processing.
The company’s commitment to data protection also means that, whenever personal data is transmitted to other entities, those entities are required to adopt technical and organizational measures that ensure the same level of protection.
7. Disclosure of Personal Data to Other Entities
During its activities, NomadReflex may need to disclose or grant access to personal data to other entities, always ensuring that such entities implement appropriate technical and organizational measures to adequately protect personal data.
Personal data will only be accessed or shared with the following entities:
- Companies belonging to the NomadReflex group;
- Clients of NomadReflex;
- Service providers to NomadReflex, such as IT support, document management, legal advisory, or human resources providers;
- Public authorities, such as the Tax and Customs Authority.
6. Contacts
If you wish to obtain more information about privacy or the processing of your personal data by NomadReflex, you may do so through the following contacts:
NomadReflex
Phone: +351 212 389 111
Address: Centro de Empresas Maquijig,
2950-402 Palmela, Portugal
Email: contact@nomadreflex.pt