Privacy Policy
A Zaphira Capital UK, Ltd., (“Zaphira”) respect your privacy and value the relationship they have with you.
This Data Protection and Privacy Policy aims to inform you about the way Zaphira processes your Personal Data and ensures your privacy in the development and carrying out of its activities, namely:
- Controller of your Personal Data
- Principles applicable to the protection of your Personal Data
- Personal Data, Processing of Personal Data and Data Subjects
- Category of Personal Data that Zaphira processes
- Purposes of the processing of your Personal Data
- Lawful Bases
- Storage period of your Personal Data
- Sharing of your Personal Data
- Your rights and how you can exercise them
- Security of your Personal Data
- Confidentiality
- Cookies
- Contacts
- Alterations to this Data Protection and Privacy Policy
1. Controller of your Personal Data
The Controller of your Personal Data is Zaphira determining, to this end, without limitation:
- The Personal Data that have to be processed in the context of providing services and/or supplying products;
- The Purposes for which the Personal Data are processed; and,
- The means to be used for the processing of the Personal Data.
2. Principles applicable to the protection of your Personal Data
In the context of the relationship established with you, the processing of your Personal Data is carried out by Zaphira according to the general principles enunciated in the General Data Protection Regulation (“GDPR”), namely:
- Guarantees that your Personal Data will be processed lawfully, fairly and transparently (“Principle of lawfulness, fairness and transparency”);
- Collects your Personal Data for certain explicit and legitimate purposes and does not subsequently process the same Data in a way incompatible with those purposes (“Principle of purpose limitation”);
- Ensures that only Personal Data are processed that are appropriate, relevant and limited to what is strictly necessary for the purposes for which they are processed. (“Principle of data minimisation”);
- Takes appropriate measures so that inaccurate Personal Data, bearing in mind the purposes for which they are processed, are deleted or rectified without delay (“Principle of accuracy”);
- Stores Personal Data in such a way that it allows them to be identified only during the period necessary for the purposes for which they are being processed. (“Storage limitation principle”);
- Ensures that your Personal Data are processed in a way that ensures their security, including protection against unauthorised or unlawful processing and against loss, destruction or accidental damage, adopting all appropriate technical and organisational measures to that end (“Principle of integrity and confidentiality”).
3. Personal Data, Processing of Personal Data and Data Subjects
“Personal Data” are all information and/or elements that, regardless of how they are stored, can identify you or make you identifiable, directly or indirectly, to Zaphira, in particular by reference to an identifier, for example a name, an identification number, your location data and/or online identifiers, or to one or more specific elements of your physical, physiological, genetic, mental, economic, cultural or social identity.
“Personal Data Processing” means the operation or set of operations performed on the Personal Data of Data Subjects, via automated or non-automated means, from the gathering of information until its destruction. Within this cycle, among others, are included: recording, organisation, structuring, storage, adaptation or alteration, recovery, consultation, use, disclosure via transmission, dissemination or otherwise making available, comparison or interconnection, limitation, deletion. The concept of Personal Data Processing is quite broad and shall be applicable to all operations or sets of operations performed by Zaphira with reference to your Personal Data.
In the context of the activities carried out by Bllom Marinha, the “Data Subject”is, without limitation, the customer and/or former customers, potential customers, investors, partners, candidates for a job, employees and ex-employees, employees of partners, suppliers and contractors and their employees, applicants and claimants, visitors and individuals captured in CCTV images and all those individual people that have a relationship with Zaphira and who are the subjects of the Personal Data.
4. Category of Personal Data that Zaphira processes
In the carrying out of its activities, Zaphira processes Personal Data from a significant set of categories of Data Subjects. The personal data collected by Zaphira always depends upon the nature of the interaction, but may include the following:
- Identification and contact data: name, surname, citizen card number, postal address, landline or mobile phone number, fax number, email address and/or other similar contact information.
- Business data for providing Zaphira services and/or products: data related to the products and/or services provided by Zaphira, payment and billing data, data arising out of information in the context of response to any questions, requests or complaints.
- Payment Data: credit/debit card numbers or other related billing information.
- Account Data: method of acquisition of or subscription to products and/or services, their transactions, billing history and customer loyalty, within the context of the Zaphira services that they use or any other related information.
- Demographic data: country, gender, age and date of birth, language, general education and professional history, as well as data of general interest about work.
- Data on preferences: information on the preferences and interests of subjects, insofar as this is related to products and/or services, and on the method via which the subject prefers to receive information.
- Data from social networks: information shared on social networks in the interaction with Zaphira, where transparency is ensured through the existence of appropriate privacy policies.
- IT usage data: user ID, functions, rights, session start and finish times, computer name and/or IP address.
We stress that you will not be required to share your Personal Data with Zaphira. Nevertheless, if you choose not to share your personal information, in some cases Zaphira may not be able to provide the desired services or supply the desired products, guarantee certain specialised features and/or respond effectively to certain questions that you may have.
5. Purposes of the processing of your Personal Data
The development and performance of various activities pursued by Zaphira means the existence of a significant set of specific, explicit and legitimate purposes for the processing of your Personal Data, such as:
- Accounting, Tax and Administrative Management: customer management, vendor management, administrative management and economic and accounting management;
- Commercial and Marketing Activity: contacts management, customer management for providing Zaphira services and/or products, marketing, online advertising and opinion surveys and polls;
- Definition and Analysis of Profiles;
- Human Resources Management: selection of personnel and recruitment;
- Electronic Communications Management: website management and storing of traffic data;
- Litigation Management: collections management and credit recovery, providing information to judicial, administrative, supervisory and/or regulatory authorities;
- Compliance with Contractual and/or Legal Obligations: transferring data to third parties prevention of fraud and security.
6. Lawful Bases
Regarding the “Lawfulness Principle” enshrined in current and future data protection laws, in developing and performing its activities, Zaphira only processes your Personal Data when there is a lawful basis that legitimises the processing, namely:
Consent: Zaphira will only process your Personal Data if you consent to the respective Processing via a free, specific, informed and explicit declaration of willingness, by which you accept, by a declaration (in writing or orally) or a positive unambiguous act (by filling in an option), that your Personal Data may be the subject of Processing
Pre-contractual procedures or the execution of a contract: Zaphira may process your Personal Data if they are needed, without limitation, for the execution of a contract to provide services and/or supply products to which it is a party as Contractor, Client, Supplier and/or partner, or in order to carry out pre-contractual procedures for your order.
Compliance with a legal obligation: Zaphira may process your Personal Data to ensure and guarantee compliance with legal obligations to which it is subject by the laws of a Member State and/or the European Union.
Defence of vital interests of the Data Subject: Zaphira may process your Personal Data to ensure the defence of your vital interests, especially when such Processing is essential to your life.
Legitimate Interests: Zaphira, other Controllers or Third Parties, may process your Personal Data provided that this Processing does not prevail over your interests and fundamental rights and freedoms.
7. Storage period of your Personal Data
Zaphira stores your Personal Data only for the period of time necessary to execute the specific purposes for which they were collected. However, Zaphira may be obliged to store some Personal Data for a longer period, taking into consideration factors such as:
- Legal obligations, under the laws in place, to store Personal Data for a given period;
- Contractual obligations and/or legitimate interest of Zaphira;
- Terms of prescription, under the laws in place;
- (possible) Litigation; and,
- Guidelines issued by the competent data protection authorities.
During the Processing period of your Personal Data, Zaphira ensures that they are treated in accordance with this Data Protection and Privacy Policy. As soon as your Data are no longer needed, Zaphira will delete them securely.
8. Sharing of your Personal Data
Processors: Your Personal Data may be shared with companies hired to provide services to Zaphira.
Companies hired to provide services are bound to Zaphira by written agreement, and may only process your Personal Data for the purposes specifically established and are not authorised to process your Personal Data, directly or indirectly, for any other purpose, for their own advantage or that of third parties.
Other Controllers and/or Third Parties: Your Personal Data may be shared internally with other CPU Group companies which will comply with applicable data protection rules depending on the purposes attached to the Processing that is carried out.
At your request and/or with your consent, your Personal Data may be shared with other entities.
In compliance with legal and/or contractual obligations, Personal Data may also be transmitted to judicial, administrative, regulatory or supervisory authorities, to third parties with whom Zaphira establishes partnerships and also to entities that perform, lawfully, data-gathering activities, actions to prevent and combat fraud, statistical or market studies.
9. Your rights and how you can exercise them
As a Subject of Personal Data processed by Zaphira, you have the right to access, rectification, limitation, portability, deletion and the right to object to the Personal Data Processing, in certain circumstances, which may be exercised under the terms of this chapter of the Data Protection and Privacy Policy.
Right to the provision of information: You have the right to obtain clear, transparent and easily understandable information about how Zaphira uses your Personal Data and what your rights are. That is why Zaphira provides you with all this information in this Data Protection and Privacy Policy.
Right of access: You have the right to obtain information about the Personal Data that Zaphira processes (if it is processing them) and certain information (similar to that provided in this Privacy Policy) about how these Data are processed. This right allows you to know and confirm that we are using your Data in compliance with data protection laws.
Zaphira may refuse to supply the requested information whenever, in order to do so, Bloom marinha has to reveal Personal Data from another person or the information will have a negative impact on the rights of another person.
Right to rectification: If your Data are incorrect or incomplete (for example, if your name or address is wrong), you may ask Zaphira to take reasonable measures to correct them.
Right to deletion of data: This right is also known as the “right to be forgotten” and, so put simply, it allows you to request the deletion or elimination of your data, provided that there are no valid grounds for Zaphira to continue to use them or their use is illegal. This is not a generic right to deletion, because exceptions are allowed (for example, whenever these data are required for the defence of a right in a judicial process)
Right to restriction of processing: You have the right to “block” or prevent future use of your Data while Zaphira evaluates a rectification request or as an alternative to deletion. Provided that the Processing is limited, Zaphira continues to be able to store your data, but it cannot use them later. Zaphira keeps a list of subjects who have requested the “blocking” of future use of their data to ensure that this limitation is respected.
Right to data portability: You have the right to obtain and reuse certain Personal Data for your own purposes in various organisations. This right applies only to your own Data that you have provided to Zaphira and that Zaphira processes with your consent and which are processed by automated means.
Right to opposition: You have the right to object to certain types of processing, for reasons related to your particular situation, at any time during which this Processing takes place, for the purposes of Zaphira’s or Third Parties’ legitimate interests. Zaphira may continue to process these Data if it can prove “overwhelming legitimate reasons for Processing that prevail over your interests, rights and freedoms” or if these Data are necessary for the establishment, exercise or defence of a right in a lawsuit.
Right to submit a complaint: You are entitled to submit a complaint to the competent supervisory authority, namely, the National Data Protection Commission (CNPD, Comissão Nacional de Proteção de Dados), whenever you believe that the processing of your personal data violates your rights and/or the applicable data protection laws
You may at any time, in writing, exercise the rights enshrined in the Law on the Protection of Personal Data and other applicable legislation, via the email info@zaphiracapital.com.
10. Security of your Personal Data
Your Personal Data will be processed by Zaphira, within the context of the purposes identified in this Policy, according to Zaphira internal policy and standards, and with the assistance of appropriate technical and organisational measures to promote their security and integrity, notably in relation to unauthorised or unlawful processing of your personal data and their loss, destruction or accidental damage.
Without limitation, Zaphira uses logical and physical security requirements and measures to ensure the protection of your Personal Data by preventing unauthorised access, it ensures that the storage of the information is carried out on secure computers in a closed and certified information centre and implements control procedures to ensure compliance with the security and privacy policies of Zaphira.
However, given that the transmission of information via the internet is not completely secure, Zaphira cannot guarantee the security of your Data when transmitted on an open network.
11. Confidentiality
Zaphira recognises that the information you provide may be confidential. Zaphira does not sell, rent, distribute Personal Data, or make them available commercially or in any other away to any third-party entity, except in cases where it needs to share information for the purposes set forth in this Data Protection and Privacy. Zaphira maintains the confidentiality and integrity of your Personal Data and protects them in compliance with this Data Protection Privacy Policy and all applicable laws.
12. Cookies
Zaphira uses cookies to collect information about the use of the website. Whenever you use the website, Zaphira processes your Personal Data collected via the use of cookies in compliance with our CookiesPolicy. For more information about the use of cookies, we advise you to read and review the Cookies Policy and to check it regularly to find the most up-to-date versions.
13. Contacts
If you have any questions or would like more information about how we process your Personal Data and/or about our information security practices, please feel free to contact us at the following address:
Email: info@zaphiracapital.com
14. Alterations to this Data Protection and Privacy Policy
Zaphira may periodically alter this Data Protection and Privacy Policy. When it does so, it will publish the updated Data Protection and Privacy Policy, and you are therefore advised to check it regularly.
All alterations will take effect as soon as the Updated Policy is published but.
Date: 16 October 2019