PRIVACY NOTICE

Privacy information pursuant to art. 13 of EU the Regulation no. 679/2016

1. DATA CONTROLLER: IDENTIFICATION AND CONTACTS

The company responsible for the processing of your data is EUROCONSUMERS INVEST - EMPRESA DE INVESTIMENTO, UNIPESSOAL LDA (EUROCONSUMERS INVEST), legal person number 514184302, headquartered at Av. Eng.º Arantes e Oliveira, n.º 13 – 1.ºB, 1900-221, Lisbon, Portugal, with the email address info@euroconsumersinvest.org and the telephone number +351 21 032 19 39.

This company acts in Belgium through its branch office EUROCONSUMERS INVEST BELGIUM BRANCH (EUROCONSUMERS INVEST BELGIUM), legal person 0793.470.292, with its office  at 13 rue de Hollande , 1060 Brussels, Belgium, that you may contact through the telephone +32 27 90 41 72 or through the email info@euroconsumersinvest.be.

WHERE AND HOW WE COLLECT YOUR DATA

B1. Collect directly from the Data Subject

B.1.1 On the Website (https://www.euroconsumersinvest.org )

EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM may collect information about visitors on www.euroconsumenrsinvest.org, in case cookies are accepted and installed on your device, as described in our Cookies Policy.

In case the visitor wants to call upon the services provided by an EUROCOSUMERS’ INVEST or EUROCONSUMERS INVEST BELGIUM’s partner, as mentioned in the point D.2 bellow, the visitor should contact our partners directly. In these circumstances, by default, we will not collect any personal data from you. Nevertheless, in certain cases, with your prior and express consent, we may use some cookies that may collect certain information about your journey. Even in these cases, we will only use this information for analytical purposes. See our cookies policy for more information.

B.1.2 By email and by phone

Whenever you contact EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, by email or by telephone, the respective company will collect the personal data that you provide during the telephone call or by email.

B 1.3 In contracts, forms and questionnaires necessary for the provision of financial intermediation services.

In order to provide its services, namely investment advice, EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, as applicable, is obliged to collect various information about its Clients or potential Clients. The personal data collected in these contract forms and other (KYC and suitability forms etc…), are the data that the company needs to execute the financial intermediation contract and also the data needed to comply with legal obligations.

B2. Indirect collection

B.2.1 EURONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM (as applicable) indirectly collect Client’s data through Thomson Reuters, only to, in compliance with the anti-money laundering and fraud prevention laws, verify certain information for this purpose.

B.2.2. EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM BRANCH (as applicable), when specifically authorized for this purpose by the Client, may collect Client’s personal data directly from the Banks, Financial Institutions, or other financial intermediaries where the Client has financial assets.

B.2.3. In the Belgian Market, since the possibility of providing the service to private Clients within special price conditions depends on a valid magazine’s subscription (e.g. Test Achats Invest), EUROCONSUMERS INVEST BELGIUM periodically collects information on the validity and duration of that subscription.

EUROCONSUMERS INVEST BELGIUM may also receive information about the name, email contact, telephone number and membership number, if the Client has requested the respective forwarding by TEST-ACHATS to EUROCONSUMERS INVEST BELGIUM, with the aim of being contacted for the provision of the investment advice service.

3. WHAT DATA DO WE COLLECT, FOR WHAT PURPOSES AND ON WHICH LEGAL BASIS

When EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM (as applicable) collect your personal data, it will do so for the purposes described below and in compliance with:

4. TO WHOM DO WE COMMUNICATE YOUR PERSONAL DATA:

EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM (as applicable) may transmit your data to different types of recipients, in order to provide the services that you request.

We will refer to the main recipients in the list below. If you wish to know the exhaustive list of recipients to whom your data can be effectively transmitted, you should contact us through the contacts made available in our website or in the contract.

D1. DATA PROCESSORS:

EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM work with certain service providers that develop their activity in the following sectors: legal advice, technology service providers, IT service providers, security companies, instant messaging service providers, infrastructure management and maintenance companies and call service companies center. Within the scope and for the exercise of this subcontracted provision of services, these “subcontractors” may have access to some of your personal data, but they only process these data on behalf of EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, as applicable, always and only in accordance with the express instructions given to them by EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, as applicable, and as a result of the contract entered into between the latter and those service providers.

EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM follows strict criteria in the selection of service providers, in order to comply with its data protection obligations, committing to sign a data processing agreement with them, which includes, among others, the following obligations: apply appropriate technical and organizational measures; process personal data only for the agreed purposes and respond exclusively to the documented instructions of EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM; delete or return the data to EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM (as applicable) after the provision of the services.

EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM also have its employees and/or those in charge of specific activities for the processing of its respective Clients’ personal data and who have been appointed as "Authorized Persons" pursuant to article 29 of the GDPR; EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM may transfer your data for these purposes to these Data Processors or employees.

D2. SERVICE PROVIDER PARTNERS

When the Client intends to hire the services provided directly by EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM’s partners (depending on the applicable situation) as a rule, the Client will contact them directly, without the need for data transmission by the mentioned companies to these partners.

However, in some circumstances, EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, in accordance with Client’s requests and indications, may transfer its name, company name, e-mail address and telephone number to our business partner, so that this partner can provide the service under the agreed terms. In that case, you will be asked for your consent in advance.

Our partners will be considered as third parties who carry out their own personal data processing activities, to provide their services and in accordance with their own privacy policies. The Client will be informed about these privacy policies as soon as these companies receive their data.

D3. REGULATORY AUTHORITIES AND JUDICIAL AUTHORITIES

The personal data of the Client of the investment advice service may be communicated to public bodies, namely regulatory authorities, or to judicial authorities, if required by law or to prevent or punish the commission of a crime.

For the purposes of anti-terrorism and anti-money laundering legislation, data may be communicated in Portugal to the CMVM (Portuguese Securities Market Commission), and in Belgium to the FSMA (Financial Services and Markets Authority), the Financial Intelligence Units and the police authorities of the respective countries.

5. TRANSFER OF DATA TO A THIRD COUNTRY

EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM may use services provided by third parties that may store your data outside the EEA European Economic Area. In that case, EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM will make sure that these companies are covered by an adequacy decision of the European Commission or will comply with the applicable rules for such a transfer to be considered legal.

6. HOW LONG WILL WE KEEP YOUR DATA (RETENTION POLICY)

1. The data necessary for the purposes of managing contacts, carrying out satisfaction surveys and sending Marketing communications will be kept for a period of 12 (twelve) months after your last contact with EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, unless you withdraw your consent or exercise your right of opposition, as applicable, at an earlier time.

2. The data necessary for the purpose of Client management will be kept for a period of 5 years after the end of the contractual relationship.

3. The data necessary for the purpose of complying with the legislation against money laundering and terrorist financing will be kept for a period of 10 years.

4. The data necessary for the purpose of managing complaints, namely privacy related, is kept for a period of 5 years.

5. In order to carry out pre-contractual diligences, your data will be kept for a maximum period of 30 days from collection. After that, the data will be deleted if the investment advisory agreement has not been concluded.

6. To comply with our tax obligations, we have to keep invoices data for 10 years.

7. After termination of the contracts or once contacts have ceased – as applicable – your personal data will be stored blocked (data is only accessible to people having special permission to access it), in order to meet the responsibilities resulting from the contractual relationship and other legal obligations of EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM. In such cases, EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM guarantees that it will not process your personal data unless strictly necessary in response to a request from the authorities, for the formulation, exercise and defense of claims, or when required by the Public Administration, Judges and Courts, during the period of limitation of your legal rights or obligations.

7. SECURITY

EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM implements and maintains appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or unauthorized disclosure or access to personal information.

Despite the efforts and security mechanisms adopted by EUROCONSUMERS INVEST and EUROCONSUMERS INVEST BELGIUM BRANCH in the event that the data collection takes place on open networks, your personal data may circulate on the network without security conditions, at the risk of being seen and used by unauthorized third parties.

1. RIGHTS OF THE DATA HOLDERS

You can exercise your rights under the General Data Protection Regulation (“GDPR”) by writing to:

Portugal and other markets: info@euroconsumersinvest.org ;

Belgium market: info@euroconsumersinvest.be;

The Data Subject is entitled to:

• Access to know which personal data is processed;
• Rectify your personal data;
• Restrict the data processing only to some processing activities and / or to oppose to some data processing activities such as direct marketing;
• Request the portability of your data to another entity;
• File a complaint with your local Supervisory Authority:
  • For Portugal and other markets: CNPD - Comissão Nacional de Proteção de Dados, Av. D. Carlos I, 134, 1º 1200-651 Lisboa, phone number: (+351) 213 928 400, email address: geral@cnpd.pt, and website: www.cnpd.pt
  • For the Belgian Market: Data Protection Authority, Drukpersstraat 35, 1000 Brussels, email address: contact@apd-gba.be, phone number +32 (0)2 274 48 00, but we kindly ask that you try to resolve any issues with us before contacting the aforementioned Authority.

When the processing of your data is based on consent, you can withdraw it whenever you want, without prejudice to the legitimacy of the treatments previously carried out.

To answer to your requests, if the information you provide is not sufficient to unambiguously and securely identify you, EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, as applicable, may request additional information to prove your identity pursuant to article 11 of the GDPR together with recital n.º 67th. In the event that your unjustified refusal prevents us from identifying you, we reserve the right not to process your request.

10. Data Protection Officer

You can contact our Data Protection Officer in Belgium at dpo@euroconsumersinvest.be and our Data Protection Officer in Portugal at dpo@euroconsumersinvest.org .

11. Changes

1. EUROCONSUMERS INVEST will inform the Client in case it is necessary to make changes to this privacy policy.

2. The Client must notify EUROCONSUMERS INVEST or EUROCONSUMERS INVEST BELGIUM, as applicable of any changes to their personal data in order to allow us to process their personal data accurately and securely.

Last version 2023/02/02