Privacy Policy

This Privacy Policy sets out the commitment of RACE – Refrigeration & Air Conditioning Engineering, S.A. (hereinafter RACE) to its stakeholders (e.g. customers, employees, suppliers) to protect the personal data for which it is responsible, and aims to contribute to strengthening and consolidating the relationship of trust and closeness it maintains with them, through clear and transparent communication about what it does with such data, which rights it recognizes for the respective data subjects, and how they may exercise them.

RACE operates in strict compliance with the principles described in this policy, Regulation (EU) 2016/679 (General Data Protection Regulation) and the applicable data protection legislation, in all activities involving the processing of personal data under its responsibility.

The Privacy Policy is framed within RACE’s regulatory body for the protection of personal data, which includes rules and procedures for managing the security and privacy of personal data.

RACE processes personal data through various operational and technical means to support the activities of its business processes.

a. Objectives

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

• To strengthen and consolidate RACE’s relationship of trust and closeness with all its stakeholders;

• To demonstrate transparency regarding the purposes and processing activities carried out by RACE, as well as the retention periods of the personal data involved therein;

• To inform personal data subjects of their rights regarding the protection of their data and how they may exercise them;

• To inform personal data subjects who the responsible parties at RACE are to whom they may address requests to exercise their rights or clarify how their personal data are processed.

b. Scope of application

The Privacy Policy applies exclusively to the processing of personal data carried out by RACE, within the context of the intended purposes. For the purposes of this policy, personal data means any information relating to an identified or identifiable natural person (data subject). A data subject is considered identifiable if they can be identified, directly or indirectly, namely by reference to an identification number or to one or more elements specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

c. Maintenance, communication and application of the policy

The Privacy Policy must be reviewed annually by the Board of Directors, whenever there is a change in circumstances and whenever there are legislative changes, in order to validate that it remains up to date and appropriate in light of the applicable regulations and laws. Proposals for revision of the policy and supervision of its application and compliance are the responsibility of the Board of Directors. This policy must be known to all RACE employees and must be made available to its stakeholders, whenever the processing of their personal data is involved, through appropriate channels, namely the internet (websites, Apps) and customer support services (contact centers and physical locations).
 

1. Content of the Privacy Policy
a. Our Privacy Commitment

RACE operates on the basis of trust and transparency. This commitment extends to the day-to-day relationship with our customers, employees and suppliers. The privacy and security of the data you entrust to us are a priority for us.

It is our commitment to only collect, store, process, transmit or delete your personal data transparently and only when essential to provide you with the best services. We will inform you of how we use your personal data and for what purposes, with the guarantee that we collect, share and store your personal data by reference to best practices in the field of personal data security and protection.

Whenever your personal data are collected, stored, processed, transmitted or deleted by other entities, we require the same level of privacy and security. We want you to feel confident that your personal data are safe with us, as we are always committed to protecting your privacy, and we take our responsibilities regarding the protection of your personal data with great seriousness and dedication.

Whenever you have any questions about the use we make of your personal data, we will be available to help you through the means we make available to you: e-mail: rgpd@race.com.pt; address: Rua Monte dos Pipos Armazém 7, 4460-059 Guifões Matosinhos; telephone +351 229 571 160.

b. Who Is Responsible for Your Personal Data

RACE is responsible for the processing of your personal data under the terms of the General Data Protection Regulation and the complementary legislation on the protection of personal data in force in the countries in which it operates.

RACE is part of a Group of Companies (SKK Group), and therefore your personal data may be transmitted and processed by any of the companies belonging to that Group.

c. Personal Data We May Collect

In this Privacy Policy, the term “Personal Data” means the set of information relating to you that allows us to identify you, directly or indirectly. Your personal data may include, for example, your name, your contact details (physical or electronic).

We may also receive your personal data from other companies, namely when they collect, process or store them under a service provision contract.

RACE may collect the following categories of personal data:

i. Customer data – full name, address, telephone number, e-mail and tax identification number – when you purchase our products or services;
ii. Data of users registered on websites:
    a. User identification data – name, e-mail, address, telephone contact – when you create an account on our website;
iii. Customer data for equipment under repair – name, address, telephone contact, e-mail, purchase details, product warranty – when you request the repair of an item;
iv. Services provided – name, address, telephone, e-mail, tax identification number, service identification.

d. How and Why We Use Your Personal Data

We use your personal data for the following purposes:
i. Transaction management – for issuing invoices for the purchase of goods and services;
ii. Marketing and direct marketing – to inform you about news and offers that may be of interest to you;
iii. Management of website or application users;
iv. Warranties and after-sales support – to allow you to access repair services for the products you have purchased under warranty and to enable us to carry out their repair;
v. Service management – to provide you with the service you have contracted with us.

e. How Long We Retain Your Personal Data

We retain your personal data only for the period necessary to fulfil the purposes defined in point d) above and to comply with the law.

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

f. With Whom We May Share Your Personal Data

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

Your personal data may be shared with companies in our Group. When required by law, we may have to disclose your personal data to authorities or third parties, in which cases our control over how your personal data are protected is limited. In the event of transfer or access to your personal data by companies in our Group, suppliers or service providers based outside the European Union, we ensure that your personal data are processed in accordance with appropriate security and protection measures, compatible with those we use.

g. How You Can Exercise Your Personal Data Protection Rights

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

i. Additional information about the use we make of your personal data;
ii. Your personal data;
iii. That we transmit your personal data you have provided to another entity;
iv. The updating of your personal data;
v. The erasure of your personal data;
vi. Objection to the processing of your personal data;
vii. Limitation of the way we use your personal data while we correct them or clarify any doubts about their content or about the use we make of them;
viii. The provision of a channel through which you may contest decisions that were based on your 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 excluded when your personal data are used to safeguard the public interest, namely 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 the use we make of your personal data, you should contact us through the means referred to in point 1 above.

If you are dissatisfied with the way we use your personal data or with our response to your request to exercise your rights, you may submit a complaint to the National Data Protection Commission (CNPD) – Address: Rua de São Bento, 148 – 3rd Floor, 1200-821 Lisbon – Telephone: +351 213 928 400 – Fax: +351 213 976 832 – E-mail address: geral@cnpd.pt.

h. Cookies

RACE uses cookies on its Websites that allow it to improve performance and the browsing experience of our users, increasing, on the one hand, speed and efficiency of response and, on the other, eliminating the need to repeatedly enter the same information. The placement of cookies not only helps the Websites recognize the user’s device the next time they visit us, but is also essential for their operation. The cookies used by RACE, on all its Websites, do not collect personal information that allows the user to be identified, storing only generic information, namely the form and/or place of access by the user and the way in which they use the Websites. Cookies retain only information related to the User’s preferences.
 

Google Analytics	Google application that allows the storage of browsing data by users on the Race.com.pt website.
Own – Confirmation	Confirmation that the submission of forms was made from the page itself, and not from spam systems.
Own – Session	Intended to keep the backoffice session active.
Own – Cookies	Allows the informational cookie pop-up to no longer be displayed after acceptance of the terms and conditions.

i. How We Protect Your Personal Data

We have a range of information security measures, aligned with national and international best practices, in order to protect your personal data, including technological controls, administrative, technical and physical measures, and procedures that ensure the protection of your personal data, preventing their misuse, unauthorized access and disclosure, loss, improper or inadvertent alteration, or unauthorized destruction. We assume in matters of information security the same commitment to continuous improvement that guides us in our daily activity.

Among others, we highlight the following measures:

i. Restricted access to your personal data only by those who need them for the purposes set out above;
ii. Storage and transfer of personal data only in a secure manner;
iii. Protection of information systems through devices that prevent unauthorized access to your personal data;
iv. Implementation of mechanisms that ensure the safeguarding of the integrity and quality of your personal data;
v. Continuous monitoring of information systems, with the aim of preventing, detecting and stopping misuse of your personal data;
vi. Redundancy of equipment for storage, processing and communication of personal data, to avoid loss of availability.

When required by law, we may have to disclose your personal data to authorities or third parties, in which cases our control over how your personal data are protected is limited.

j. Updates to this Privacy Policy

This Privacy Policy may be updated in due course.