WALKEMORE S.A.
PRIVACY MANAGEMENT POLICY
1. Application
The Privacy Management Policy presents the commitment of Walkemore, S.A. 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 Walkemore, S.A. 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 Walkemore, S.A. 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 Walkemore, S.A. 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 Walkemore, S.A. 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 Walkemore, S.A., headquartered in Rua das Casas Queimadas, nº567, 4415-439 Grijó, Vila Nova de Gaia, Portugal, VAT nr. PT 513 165 703.
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 Walkemore, S.A. website, job application with curriculum vitae sharing, filling out paper forms, capturing images and videos, biometric data, e-mail adresse or phone.
Personal data can also be collected indirectly by importing Curriculum Vitae content into the internal candidate management platform.
No other method of indirect collection of personal data will be executed.
The collection of sensitive personal data will only be carried out in strictly necessary cases justified by legislation, in particular, and as exemple, for the work medicine.
4.1.2 Situations Involving Web Tools
Personal data are collected directly through the Walkemore, S.A.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
There are also indirect collections through subcontracting partners regarding order placement, such as Amazon and Overcube.
The cookie management policy complements this topic by presenting the "opt-in" and "opt-out" options that are available at Walkemore, S.A.official website.
The data holder can also “opt out” of online advertising services in Walkemore, S.A. social tools, namely Facebook, Google Ads and Instagram.
Walkemore, S.A. 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 Walkemore, S.A..
4.2 Personal Data Treatment
Authorized personal data will only be used by Walkemore, S.A. with the strict objective of sustaining its commercial activities and legal obligations.
4.2.1 Situations that do not involve Web tools
Included Activities:
Justification | Purpose of Treatment | Grounding |
Management of job applicants | Curriculum analysis and interview selection | Life cycle management of employee hiring |
Curriculum Vitae export data to internal candidate management platform | ||
Contact with the job applicant at different stages of the process | ||
Communication of data to the job applicant in case of selection | ||
Data retention for future opportunities | ||
Contact the job applicant for new opportunities and for updating data | ||
Human Resource Management | Administrative management of human resources Wage processing | Operational management of the organizational support area |
Employee card and placement in company contacts and access directory | ||
Physical Security | Access control Images of video surveillance Attendance record | Physical security control of buildings |
Internal and External Communication | Publication of news, testimonies, images and videos on the company's website, internal newsletter and social networks | Promotion of the company and the events in which it participates |
Commercial Management | Customer Registration in ERP and Customer Form Registration and archiving of commercial proposals | Customer relationship management |
Financial Management | Billing and Collection Information Shared with External Accounting Service | Operational management of the organizational support area |
Purchasing Management | Supplier registration in ERP and supplier form Supplier contact query and activity log | |
Technical Assistance | ERP registration for technical assistance Marking the beginning and end of technicians route for record of distance covered | Operational management of the organizational support area |
Information Systems Management | E-mail system account management and related services | Access control |
Preparation of machines to delivery to the employee Retention of employee data for the previous objective | Employee service provision | |
Partner contacts query | Partner Relationship Management | |
Consultation and custody of customer databases | Provision of application software maintenance service |
No data will be used for the creation and use of sales profiles or indicators of products, regions or trends.
4.2.2 Situations Involving Web Tools
Included Activities:
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
4.3.1 Situations that do not involve Web tools
Personal data sharing will be made for strictly necessary and authorized purposes by the data holder as a support for the development of Walkemore, S.A., activities, including:
Sharing Destination | Data Shared | Grounding |
Portuguese Legal Authorities | Number, address, tax identification number, social security number, admission data, ID card number | Social security inscription Communication with tax authority, customs or other legal entities |
Portuguese Control Authority for the Protection of Personal Data | Number, address, E-mail address, phone number, ID card number | Communication of complaints or breaches of privacy DPO communication |
Work Medicine | Name, birthdate, admission data, social security number | Work Medicine services registration Medical form creation |
Insurers | Name, tax identification number, address, birthdate, admission data | Employee inscription in the work accident insurance |
Bank Entities | Name, international bank account number | Salary processing and expenses payment |
Accounting Services Providers | Name, tax identification number, address, ID card number | Compliance with tax obligations and management of company accounting |
Legal Services Providers | Name, tax identification number, address, ID card number | Conflict management Contracts signing |
Informatic Service Providers | Name, job history | Candidates presentation for outsourcing service |
Any additional requirements will be subject to a supplemental request for informed consent to the respective data holders.
These data-sharing will be fully realized in the European Union.
Regarding these principles, personal data may be transmitted to subcontractors who, by means of a formal agreement specific to each case, undertake to comply with the necessary security controls in accordance with the privacy management policy of Walkemore, S.A..
4.3.2 Situations Involving Web Tools
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 Walkemore, S.A..
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 Chronopost, 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, Walkemore, S.A. 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 Walkemore, S.A., 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 | |
Human Resources Data | 1 year | |
Work Medicine Data | 5 years | |
Biometric Data | Until role change or end of contract | |
Video Surveillance | 1 month | |
Communication publications containing employees personal data | Until end of contract | Depending on the operational needs and communication strategy of the organization |
Communication publications containing personal data | 3 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 Walkemore, S.A., which guarantees the conditions of longevity and use in function of the defined time.
5. Data Holder Rights
Walkemore, S.A. assures all data subjects that they will be able to exercise their rights, as provided for and described in the General Data Protection Regulation. A Data Protection Officer (DPO) has been appointed for this purpose.
The data subject has the following rights:
5.1. Right to be informed:
The data subject has the right to receive information that is clear, transparent and easy to understand as to how Walkemore, S.A. uses his or her personal data. This is why this Privacy Policy and Cookie Policy have been made available.
5.2. Right of access:
In addition to the right to be informed, the data subject may also access his or her personal data processed and stored by Walkemore, S.A. In these cases, Walkemore, S.A. will provide him or her with a copy of his or her personal data that it processes.
5.3. Right to rectification:
The data subject shall have the right to rectification of inaccurate or outdated personal data concerning him or her or to have incomplete personal data completed. To this end, he or she may contact Walkemore, S.A. or, alternatively, if he or she has registered on the website, he or she may go to his or her “customer area”.
5.4. Right to erasure (‘right to be forgotten’):
The data subject shall have the right to obtain from Walkemore, S.A. the erasure of his or her data. However, there is no absolute right as there may be legal grounds or other legitimate reasons for retaining the personal data.
The erasure of personal data is irreversible, which means they cannot be recovered.
5.5. Right to object, including direct marketing:
The data subject may unsubscribe from the Walkemore, S.A. newsletter or choose to be removed from other direct marketing communications at any time, or object to the processing of his or her personal data. The data subject may remove himself or herself directly from the newsletter by clicking on “Remove”, alter his or her consent to notifications via e-mail and/or text messages in his or her customer area or contact Walkemore, S.A. and ask for these changes to be made. He or she may also object, at any time, to the creation of a profile and the use of his or her data for market research or other advertising campaigns.
5.6. Right to withdraw consent to data processing at any time:
The data subject may withdraw his or her consent to data processing when this processing is based on his or her consent. The withdrawal of consent shall not affect the legality of the processing based on consent before this was withdrawn.
5.7. Right to lodge a complaint with the regulatory authority:
If a breach of privacy is identified, the data subject may report this via the same route or directly to the regulatory authority he or she chooses.
After a complaint is made or a breach of privacy is reported, Walkemore, S.A. shall assure the implementation of communication proceedings with the data subject, informing him or her in good time and in accordance with the General Data Protection Regulation of each step in the processing of his or her complaint, in strict compliance with the time limits and conditions defined in the regulation.
5.8. Right to data portability:
The data subject has the right to move, copy or transfer data from our database to another.
5.9. Right to restriction of processing:
The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: the accuracy of the personal data is contested, the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead, Walkemore, S.A. no longer needs the personal data, but they are required by the data subject or if the data subject has exercised his or her above right to object, pending the verification whether the legitimate grounds of Walkemore, S.A. override those of the data subject.
To exercise his or her rights and/or ask any questions related to this subject, particularly lodging complaints, the data subject should make a written request to the following e-mail address: dpo@wockshoes.com
6. Roles and Responsibilities
Walkemore, S.A. 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 Walkemore, S.A. 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 Walkemore, S.A. 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 networks where Walkemore, S.A. is present.
