This Privacy Notice sets forth Vanguardeagle Asset Management, Lda.’s (“Vanguard Properties”) processing terms and conditions regarding the personal data of applicants to job openings at Vanguard Properties (hereinafter, “Applicant” or “Applicants”), collected through Vanguard Properties’ Careers Website (hereinafter “Website”).
This Privacy Notice applies only to the processing of any Applicant’s personal data strictly as provided for herein, but not to the processing of personal data processed by CVW as part of the CVW platform use for its own purposes.
When Applicants submit an application form for a job opening at Vanguard Properties and consequently provide personal data, they acknowledge that they are aware of and agree to the conditions set out in this Privacy Notice.
2. PERSONAL DATA COLLECTION AND PROCESSING
Applicants must complete this form with their personal data, otherwise they will be unable to submit their application to a job opening at Vanguard Properties.
Vanguard Properties, with registered offices at Avenida da Liberdade, 180 A, 7.º, 1250-146 Lisboa, will process the personal data as data controller.
3. DATA PROCESSING PURPOSES AND LEGAL BASIS
Personal data will solely be processed for selection and recruitment purposes. The legal basis for such processing is the need to process the data as part of pre-contractual arrangements and in order to take steps at the request of the data subject prior to entering into a contract.
Where Applicants submit applications to be considered in future Vanguard Properties recruitment processes (general applications, and not to specific job openings at Vanguard), their data will be processed on the basis of their consent, which will be duly requested by Vanguard Properties for such purpose.
If the Applicant is hired, any data collected as part of the recruitment process will be used to manage the subsequent contractual relation, ensure the performance of legal obligations, and provide employees the resources required to perform their professional duties.
4. SHARING OF PERSONAL DATA
Vanguard Properties may transmit Applicant’s data to processors for recruitment purposes or receive data from processors pursuant to agreements in place with them. CVW, Lda. is one of such processors that will process personal data on behalf of Vanguard Properties (as data processor) as part of the services provided to Vanguard Properties.
Vanguard Properties may further transfer Applicant’s personal data to third-party entities where it deems such data transfers as required or adequate: (i) under applicable law; (ii) to perform legal obligations/court orders; or (iii) to comply with any requests of public or governmental entities.
Vanguard Properties will endeavor to ensure that the personal data is processed within the European Economic Area (EEA). However, if Applicant’s personal data is transferred outside the EEA – including in cases where Vanguard Properties engages service providers located outside the EEA - Vanguard Properties will ensure that the transfer will occur only if there is an adequacy decision of the European Commission or only if appropriate safeguards are adopted to secure the Applicant’s data pursuant to the GDPR and other applicable legislation.
5. PERSONAL DATA RETENTION
Any personal data collected as part of the recruitment process will be kept for one (1) year after the end of the selection and recruitment process to which the Applicant applied, subject to such deadline being extended for the duration of any court case and up to six (6) months after the transit in res judicata of the relevant judgement.
Personal data collected on the basis of the Applicant’s consent will be processed until Applicant withdraws the consent or within a maximum period of 2 years from the collection, subject to such deadline being extended for the duration of any court case and up to six (6) months after the transit in res judicata of the relevant judgement.
6. SECURITY MEASURES
Taking into account the state of the art, the costs of implementation and the nature, scope context and purposes of the data processing, as well as the risks of varying likelihood and severity to the rights and freedoms of the data subjects, Vanguard Properties adopts the appropriate technical and organizational measures to ensure a level of security appropriate to such risks.
7. APPLICANTS’ RIGHTS REGARDING THE PROCESSING OF THEIR PERSONAL DATA
Under the applicable legislation, Applicants may at any time request access to their personal data, as well as the data rectification, erasure, or restriction of processing, data portability, or oppose to the processing.
In the case where personal data is processed on the basis of consent, Applicants are also entitled to withdraw their consent at any time. However, the withdrawal of consent shall not affect the lawfulness of the processing based on the consent before its withdrawal.
To exercise any of the above rights Applicants shall submit a written request to Vanguard Properties addressed to:
E-mail: [email protected]
Address: Avenida da Liberdade, 180 A, 7.º, 1250-146 Lisboa
Applicants are also entitled to file a complaint to the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados or “CNPD”) in addition to any other administrative or court appeals available to them, if they consider that Vanguard Properties is processing their personal data unlawfully.
8. AMENDMENTS TO THIS PRIVACY NOTICE
Vanguard Properties reserves the right to amend or update this Privacy Notice from time to time. Any amendments and updates will be published on the Website and, if they should affect the way Applicants’ personal data is processed, Vanguard Properties will notify the amendments directly to the Applicants, using the contact details provided by them.
Date of the latest update: 30th March 2022