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Privacy Policy OS

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Person responsible for processing personal data

This document sets out the Privacy and Cookie Usage Policies (hereinafter "Policy") of the company CUDELL - Outdoor Solutions, S.A. (hereinafter "COS"), with registered office at Estrada Nacional N12, Estrada da Circunvalação, 14037, 4100-179 Porto, VAT number 500 142 453.


The processing of personal data carried out by COS, as well as the sending of commercial communications carried out by electronic means are in accordance with the national and EU legislation in force, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data and guidelines issued by European and national authorities, model clauses approved by the European Commission or supervisory authorities, as well as any relevant case law, jointly referred to as the "Data Protection Regime", hereinafter "GDPR".

Processing of personal data

The processing of personal data is carried out in accordance with the general principles set out in the "RGPD", namely:

In the context of the relationship established with the data subject, we ensure that personal data will be processed lawfully, fairly and transparently ("Principle of lawfulness, fairness and transparency");
We collect personal data for specified, explicit and legitimate purposes and do not further process the same data in a way incompatible with those purposes ("Purpose limitation principle");
We ensure that only personal data that are adequate, relevant and limited to what is strictly necessary for the purposes for which they are processed are processed ("Principle of data minimization");
We take appropriate steps to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ("Principle of accuracy");
We retain personal data in a form which permits their identification only for as long as is necessary for the purposes for which they are processed ("Principle of storage");
We ensure that personal data is processed in a manner that ensures the security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures ("Principle of integrity and confidentiality").

What personal data we process

In the context of the activities carried out by COS, the Data Holder is, without limitation, the client and/or former clients, potential clients, investors, partners, job applicants, employees and former employees, employees of partners, suppliers and service providers and their employees, applicants and complainants, visitors and individuals and all those individual persons who maintain a relationship with COS and to whom the personal data concern.

COS does not voluntarily or directly solicit or collect personal data from minors. If COS discovers that it has inadvertently collected personal data from a minor under the age of 18, it will promptly delete the records containing that minor's personal data. We note, however, that COS may collect personal data relating to minors when provided by parents or a legal guardian who expressly consents to such collection or when such data is collected through CCTV systems.

In the course of its activities, COS processes personal data of a significant number of categories of Data Subjects.

The personal data COS collects always depends on the nature of the interaction, but may include the following:

Identification and contact data: First name, last name, postal address, telephone or mobile number, email address,
Data related to the provision of services and supply of goods, or for contractual execution or fulfillment of legal obligations, such as: invoicing data, invoicing history, current account values, payment data.
Data relating to how you purchased services, goods or subscribed to services, your transaction, billing and support history in the context of the COS services you use, or any other related information and information in the context of responding to any queries, requests or complaints.
Social media data: Information shared on social media in interaction with COS, where transparency is ensured through the existence of appropriate privacy policies.
Depending on the relevant circumstances and applicable local laws and requirements, we may collect additional information that you choose to share with us;
Images from CCTV systems if you visit our premises.
Please note that you will not be obliged to share personal data with COS. However, if you choose not to share your personal information, in some cases, COS may not be able to provide the services or products you want, provide certain specialized features, or respond effectively to a question you may have.

Why we treat your information

The development and performance of the various activities pursued by COS means that there is a relevant set of specific, explicit and legitimate purposes for the processing of personal data, such as: provision of services, sending communications, administrative, economic and accounting management, selection and recruitment of job applicants and compliance with reporting obligations.

What we treat your information for

By reference to the "Lawfulness Principle" enshrined in the RGPD, in developing and carrying out its activities, COS only processes personal data when there is a basis of lawfulness that legitimizes the processing, namely:

- Consent

COS will only treat personal data if it consents to the respective treatment through a free, specific, informed and explicit manifestation of will, by which it accepts, through a declaration (written or oral) or unequivocal positive act, that the personal data be the object of treatment.

- Pre-contractual steps or execution of a contract

COS may process personal data if they are necessary, without limitation, for the performance of a contract to provide services and/or supply products to which it is a party as an employee, client and/or supplier, or to carry out pre-contractual procedures upon request.

- Compliance with a legal obligation

COS may process personal data to ensure and guarantee compliance with legal obligations to which it is subject under the laws of a Member State and/or the European Union.

- Legitimate Interests

COS, other Controllers or Third Parties may process your personal data provided that such processing does not override the interests or fundamental rights and freedoms of the Data Controller.

How long we keep personal data

The data are kept for until the purpose or administrative obligation is fulfilled or for as long as necessary to comply with the legal obligations that are applicable in each case. If the basis of the processing is consent, the data is kept until the consent is revoked. During the personal data processing period, COS guarantees that they are processed in accordance with this Privacy Policy. As soon as the data is no longer necessary for the pursuit of the purpose, COS will securely delete it.

Sharing personal data with third parties

Personal data may be shared with entities responsible for providing services to COS.

The companies responsible for providing services are bound to COS by a written contract, and may only process the personal data for the purposes specifically established and are not authorized to process the personal data, directly or indirectly, for any other purpose, for their own benefit or for that of a third party.

Personal data may be shared internally with other COS companies which will comply with the applicable data protection rules depending on the purposes of the processing performed.

Upon request and with due consent, 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, supervisory or regulatory authorities and also to entities that lawfully carry out data compilation, fraud prevention and combat actions, market or statistical studies.

Transfers across the EEA

COS does not transfer personal data outside the European Economic Area (EEA).

What are the rights of the Data Controller?

As the Holder of the personal data processed by COS, he/she has the right to access, rectification, limitation, portability, erasure and the right to oppose the processing of personal data, under certain circumstances, which can be exercised under the terms of this chapter of the Privacy Policy.

- Right to Information

You have the right to obtain clear, transparent and easily understandable information about how COS uses personal data and what your rights are. That is why COS makes all of this information available to you in this Privacy Policy.

- Right of Access

You have the right to obtain information about what Personal Data COS is handling (if any) and certain information (similar to that provided in this Privacy Policy) about how that data is handled. This right lets you know and confirm that we use your data in compliance with data protection laws.

COS may refuse to provide the information requested where to do so would require COS to disclose another person's personal data or the information would adversely impact another person's rights.

- Right of rectification

If your data is incorrect or incomplete (for example, if your name or address is wrong), you may ask COS to take reasonable steps to correct it.

- Right to erasure of data

This right is also known as the "right to be forgotten" and, in simple terms, allows you to request the erasure or deletion of your data, provided that there are no valid grounds for COS to continue using it or its use is unlawful. This is not a generic right to erasure, as exceptions are allowed (for example, whenever such data is necessary for the defense of a right in legal proceedings).

- Right to restriction of processing

You have the right to "block" or prevent the further use of your data while COS evaluates a request for rectification or as an alternative to erasure. Where processing is limited, COS may still store your data, but may not use it further. COS maintains a list of data subjects who have requested "blocking" of the 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 organizations. This right applies only to your own data that you have provided to COS and which COS processes with your consent and those processed by automated means.

- Right to object

You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time when such processing is carried out for the legitimate interest of COS or a third party. COS may continue to process such data if it can prove "compelling legitimate grounds for the processing which override your interests, rights and freedoms" or if such data is necessary for the establishment, exercise or defence of legal claims.

- Right to withdraw consent

When the basis of lawfulness is consent, you have the right to revoke consent at any time.

- Right to lodge a complaint

You have the right to lodge a complaint with the competent supervisory authority, the Comissão Nacional de Proteção de Dados - CNPD (National Commission for Data Protection), if you consider that the processing performed on your personal data violates your rights and/or the applicable data protection laws. You may do so through the website

Security and confidentiality

The personal data will be processed by COS, in the context of the purposes identified in this Policy, in accordance with other policies, procedures and internal rules of COS and using techniques and organizational measures adequate to promote their availability, confidentiality and integrity, namely in relation to the unauthorized or illicit processing of the personal data and their accidental loss, destruction or damage.

However, because transmission of information over the Internet is not completely secure, COS cannot guarantee data security when transmitted over an open network.

COS recognizes that the information you provide to us may be confidential. COS does not sell, rent, distribute, or otherwise commercially or commercially available personal data to any third party, except where it needs to share information with Service Providers for the purposes set out in this Privacy Policy. COS preserves the confidentiality and integrity of data and protects it in accordance with this Privacy Policy and applicable laws.

Use of cookies

COS automatically collects information whenever someone visits the Websites. COS obtains information from the user's computer and assigns a "cookie" (a small package of information about that user) when someone visits its web site. This data is not supplied by the user - it is collected automatically as a means of facilitating links to and use of the Websites.

We only use cookies that are strictly necessary to provide the website (technical cookies) which are not shared with third parties.

In case of doubt or for exercising rights

If you have any questions or would like more information about how we treat personal data or about our information security practices, please feel free to contact us at our address or at

You may at any time, in writing, exercise the rights enshrined in the GDPR by using the contacts listed above.

For the exercise of rights, if necessary, you must attach a copy of an identification document proving the identity of the holder. The exercise of rights is free of charge, except in the case of a manifestly unfounded, excessive or repeated request.

Changes to this Privacy Policy

COS may periodically update this Privacy Policy, as well as any other specific privacy and data protection statement. When we make changes to this Privacy Policy, we will add a new update date. We encourage you to check it whenever you visit us.

The Website and the Contents of COS were generated for its users (customers, suppliers, employees, authorities, associations and media, among other).  
Website users are strictly prohibited from: 
a) Transferring, copying or re-transmitting any or all of the COS Website or Contents without its written consent;  
b) Using any methods for data collection or extraction; 
c) Using the COS Website or Contents for purposes other than those agreed; 
d) Creating or introducing in this website any types of virus, worms, Trojans, scripts or any other code or program containing destructive or damaging properties, or advising others to do  so; 
e) Using the website for illegal purposes or purposes which may damage the rights of COS or third parties and, in particular, using the website to distribute illegal or harmful information, or information considered unpleasant, discriminatory or offensive to COS or third parties;  
Such unauthorized use may also violate applicable laws including, but not limited to, laws concerning copyright and trademark.
The user declares and guarantees compliance with all applicable laws and regulations including those relating to the Internet, data, email and privacy.
Should the user not comply with these obligations, COS reserves the right to immediately prohibit and terminate access to its website and to its network without right to any compensation, without prejudice to the verification of any liabilities under general law. 
The Website is owned by COS. 
Unless when stated otherwise, all content featured or displayed on the Website, including, but not limited to, text, graphics, data, photographs, images, videos and other, are property of COS, or of its licensors.
All elements of the website are protected by copyright, trademark and other legislation related to the rights of protection of intellectual property. 
Please note that other company names, brands, products or services displayed on the website may be trademarks of their respective holders. 
The user is granted no right or license to use any trademarks, and thus, the user agrees not to modify, rent, loan, sell, distribute or create derivative works based on the content of the website and/or the products and services made available on the website wholly or partially. 
According to the Code of Copyright and Related Rights and other applicable laws, COS reserves the right to terminate the accounts of users who infringe the intellectual property rights of COS or of third parties, as well as to act judicially under appropriate circumstances and at the sole discretion of OS against those who infringe such intellectual property rights.
If you believe that any material on the website infringes upon any copyright you own or control, you may file a complaint of such violation to the following address: Estrada Nacional n.º 12 - Estrada da Circunvalação n.º 14037 – P – 4100-179 PORTO/PORTUGAL, or if you prefer to the following e-mail:
CUDELL ®, GUSTAVO CUDELL ®, CUDELL – Outdoor Solutions ®, Loja de Rega ®, Loja de Rega (name of establishment) ®, LA TIENDA DEL RIEGO ®, CUDELL – Engenharia & Serviços ®, SYMPERTEK ®, INPULS IMOBILIA ®, Logótipo DINAMIC ® and any other name or slogan of product or service included in the website are trademarks in companies of the DINAMIC Holding, SGPS, S.A. group and may not be copied, imitated or used, wholly or partially, without its prior written consent.
Furthermore, the design of the website, including all page headers, graphics, tables, drawings, projects and icons are proprietary and may not be copied or used, wholly or partially, without the corresponding prior written consent.
All other trademarks, product names and company names or logos mentioned in the website belong to the respective owners. 
Breach arising from the use, reproduction, copying of the contents of the website infringing or allegedly infringing the Terms of the website forces the user to adequate compensation for the damage caused, as well as costs, liabilities and expenses arising from the breach of the rights of COS.
The website and the contents of COS and its administrators, directors, employees, agents and branches exclude, in so far as is permitted by law, all warranties, express or implied, including but not limited to any implied warranties of commercial use, satisfactory quality or adequacy for certain purposes. 
COS will not be liable for any damages resulting from use of the website, contents or unavailability of the website, including but not limited to lost profits and direct, indirect, incidental, punitive and additional damages. 
COS does not guarantee the accuracy, quality, safety, legality or legitimacy, including compliance with rules relating to copyright and related rights and industrial property rights, of the contents, products or services contained on this website which have been provided by commercial partners, as well as of any information contained on websites of third entities to which it establishes connections.
COS does not offer any guarantee that the website or the contents included therein are free from infection of viruses or anything with contaminating or destructive properties.  
Under no circumstances shall COS, its administrators, directors or employees be liable for any direct or indirect damages or any other damages of any nature, including but not limited to loss of use, loss of profits or loss of data, or other, arising from or connected in any way with the use of this website and of the contents of COS.
It will equally not be responsible for materials contained in or accessed through the website, including any damages caused or resulting from reliance by the user on any information obtained through COS or resulting from mistakes, omissions, interruptions, deletion of files or emails, errors, defects, viruses, delays in operation or transmission of any failure in operation, whether or not resulting from force majeure, communications failure, theft, destruction or unauthorized access to COS records, programs or services. 
OS may use "cookies" to enable the connection to our services and to help you personalize and improve your online experience. 
A cookie is a small text file that is placed on your hard drive or device. 
Cookies contain information, including personal information, that may later be read by a web server in the domain that issued the cookie to the user. 
Information collected by cookies include the date and time of your visit, your registration information as well as your navigation and purchase history. 
The user has the power to turn off his/her cookies, in the browser options, and this option may change the way of interacting with our website.
COS has links to other websites, which, from our point of view, may contain useful information for our visitors. 
Our privacy policy does not apply to third party websites, therefore should you visit another website through ours you should read its privacy policy.
We are not responsible for the privacy policy or contents present in those websites.  
Any difference related in any way to the use of the website or the contents of COS will be, in case of dispute, submitted to the District Court of Porto / Portugal (Portuguese law) with express waiver of any other. 
COS reserves the right to change any terms or conditions contained in the terms of the website or any policy or guideline of the website, at any time and at its sole discretion. 
When changes are made, the date of the last update displayed in the upper part of the terms of the website will be reviewed. 
Any changes will be effective immediately upon posting on the website. 
Continued use of the Website following the posting of changes will constitute your acceptance of such changes. 
We recommend consulting the terms of the website whenever you visit us.
Any questions or comments about the website or the Terms of the website may be addressed to CUDELL – Outdoor Solutions, S.A. to the address Estrada Nacional n.º 12 - Estrada da Circunvalação n.º 14037 – P – 4100-179 PORTO/PORTUGAL or through the e-mail or the telephone number +351 969 025 676

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