NUCHAR is a trademark of FONCASAL TRADING, S.L.U. (hereinafter referred to as "FONCASAL")

PRIVACY POLICY

1 - FRAMEWORK

This Privacy Policy establishes the commitment of FONCASAL company belonging to VIGENTGROUP and each of the companies of the same, with its stakeholders (customers, employees, suppliers, shareholders and investors) in the protection of personal data for which it is responsible, with the intention of contributing to strengthen and consolidate the relationship of trust and closeness it has with them, through clear and transparent communication of what it does with such data and what rights it recognizes to its holders and how they can exercise them.

NUCHAR S. L. (VIGENTGROUP) acts in strict compliance with the principles described in this policy, Regulation (EU) 2016/679 (General Data Protection Regulation) and applicable data protection legislation in all personal data processing activities under its responsibility.

The Privacy Policy is part of VIGENTGROUP's regulatory body that applies to its associated companies, for the protection of personal data, and includes rules and procedures for managing the security and privacy of personal data.

FONCASAL (VIGENTGROUP) processes personal data through various operational and technical means to support the activities of its business processes.

     1. Objectives

The Privacy Policy, as a communication tool, has the following main objectives:

- Strengthen and consolidate the relationship of trust and proximity between FONCASAL (VIGENTGROUP) and all its stakeholders;

- Demonstrate transparency about the purposes and processing activities carried out by FONCASAL (VIGENTGROUP), as well as about the periods of conservation of the personal data collected;

- Inform the holders of personal data of their rights in relation to their protection and how they can exercise them;

- To inform the holders of personal data who are the people in charge of FONCASAL (VIGENTGROUP) to whom they can address to exercise their rights or clarify how their personal data are treated.

     2. Scope of Application

The Privacy Policy applies exclusively to the processing of personal data carried out by FONCASAL (VIGENTGROUP) in the context of the intended purposes.

For the purposes of this policy, the following is considered personal data any information relating to a specific person or individual (data subject)

The individual or data subject may be identified directly or indirectly, usually through an identification number or by their physical, physiological, genetic, intellectual, economic, cultural or social characteristics.

     3. Maintenance, Communication and Implementation of the Policy

The Privacy Policy must be reviewed annually when there are changes in circumstances and whenever there are legislative changes, to ensure that it remains current and adapted to the regulations and laws in force. Proposals to revise the policy and monitor its implementation and compliance are the responsibility of the competent management body of FONCASAL (VIGENTGROUP).

This policy must be known to all employees of FONCASAL (VIGENTGROUP) and must be made available to its stakeholders, whenever it concerns the processing of their personal data, through the appropriate channels, normally the FONCASAL (VIGENTGROUP) website.

2 - CONTENT OF THE PRIVACY POLICY

     1. Our Privacy Commitment

FONCASAL (VIGENTGROUP) works on the basis of trust and transparency. This commitment is applied in our day-to-day relationships with our customers, employees, suppliers and other stakeholders.

The privacy and security of the data you entrust to us is a priority for us.

We are committed to collecting, storing, processing, transmitting or deleting your personal data in a transparent manner and only those data that are essential to the relationship.

We will inform you about how we use your personal data and for what purposes, and we assure you that we collect, share and store it in accordance with best practices in the field of security and protection of personal data.

We want to convey to you that the personal data contained in our system are duly protected, and that we will commit ourselves with seriousness and commitment to maintain your privacy, assuming our responsibility with regard to the protection of the same.

For any clarification you may need about the use we make of your personal data, you can contact us via email at dataprotection@vigent.pt

     2. Who is Responsible for your Personal Data

The company identified above to which you have provided your personal data is the data controller under the General Data Protection Regulation and complementary legislation on the protection of personal data in force in the countries in which it operates.

FONCASAL is part of the VIGENTGROUP group of companies, so your personal data may be transmitted and processed by any of the companies belonging to the VIGENTGROUP group.

     3. Personal Data We May Collect

In this Privacy Policy, the term "Personal Data" refers to the set of information that relates to you and that allows us to identify you directly or indirectly. Your personal data may include, for example, your name, your tax identification number and your contacts (physical and/or electronic).

We may also receive your personal data from other companies, in particular when they collect, process or store it under a service contract.

     4. How and why do we use your Personal Data?

We use your personal data to the extent strictly necessary to maintain the existing relationship.

     5. How Long Do We Keep Your Personal Data?

We retain your personal data only for as long as is necessary to fulfill the purposes set out in the context of the relationship and in compliance with the law.

Once the maximum retention period has been reached, your personal data will be anonymized or securely destroyed/deleted.

     6. With whom we may share your personal information

In some cases, we may disclose your personal data to other entities in the context of the services provided by them. In such cases, we require them to have appropriate security measures in place to protect your personal data.

We may need to disclose your personal data to authorities or third parties when we are required to do so by law.

In case of transfer or access of your personal data by a VIGENTGROUP company to suppliers or service providers based outside the European Union, we ensure that your personal data is processed in accordance with appropriate security and protection measures compatible with those we use.

     7. How You Can Exercise Your Personal Data Protection Rights

In certain circumstances, you have the right to access or request:

1. Additional information about our use of your personal data;
2. Your personal data in our possession
3. That we transfer the personal information you have provided to us to another entity;
4. Updating your personal data;
5. The deletion of your personal data, with the exception of data that must be kept by legal/judicial imposition;
6. Opposition to the processing of your personal data;
7. Limit how we use your personal data while we correct or clarify any questions about its content or our use of it;
8. The establishment of a communication channel for the data subject to challenge decisions based on his or her personal data.

You also have the right to withdraw or change, at any time, the consent you have given us to use your personal data.

The exercise of these rights is guaranteed except when your personal data must be used to safeguard the public interest, especially in cases of crime detection and prevention, or when they are subject to professional secrecy.

To exercise your personal data protection rights or whenever you have any questions about our use of your personal data, please contact us by e-mail: dataprotection@vigent.pt

If you are not satisfied with the way we use your personal data or our response to your request to exercise your rights, you may file a complaint with a competent supervisory authority.

     8. How We Protect Your Personal Data       

FONCASAL (VIGENTGROUP) has a variety of security and information protection measures, aligned with national and international best practices, in order to protect your personal data, including technological controls, administrative, technical, physical measures and procedures that ensure the protection of your personal data, preventing its misuse, unauthorized access and disclosure, loss, improper or inadvertent alteration, or unauthorized destruction. We assume the same commitment to continuous improvement that we base on our daily activity in terms of information security.

Among others, we highlight the following measures:

1. Restricted access to your personal data only by those who need it for the purposes set forth above;
2. Storage and transfer of personal data only in a secure manner;
3. Protection of information systems through devices that prevent unauthorized access to your personal data;
4. Implementation of mechanisms that guarantee the safeguarding of the integrity and quality of your personal data;
5. Permanent monitoring of information systems, with the objective of preventing, detecting and preventing the improper use of your personal data;
6. Redundancy of personal data storage, processing and communication equipment to avoid loss of availability;
7. We may have to provide your personal data to authorities or third parties where we are required to do so by law, and in such a case, our control over how your personal data is protected is limited.
8. Updates to this Privacy Policy   

This Privacy Policy may be updated from time to time, and when this happens, it will be disclosed through the appropriate channels, namely the FONCASAL (VIGENTGROUP) website.