Privacy Policy

WHO ARE WE?
Elastron, S.A. is a company engaged in the wholesale and retail trade for supplies of fabrics, leather and microfibers for upholstery.
Elastron, S.A. respects the rules of privacy and personal data protection of those it has relations with (customers, suppliers, employees, among others). In this Privacy Policy, we explain who we are, what personal data we collect, how we protect it, what purposes we may use it for, its grounds, how long we keep it for, whom we share it with, as well as how to contact us and exercise your rights.

WHY THIS PRIVACY POLICY?
This Privacy Policy arises because we intend to make known to our partners, as well as to all those with whom we relate, the general rules of privacy and processing of their personal data, which we collect and treat in strict respect and compliance with the Law of Protection of Personal data.
Elastron, S.A. respects the best practices in the field of security and protection of personal data, having approved for that purpose a policy that can protect the data that is made available to us by all those who in any way relate to the Company.
Please read this Privacy Policy carefully because, if you are accessing the availability of your personal data our website, this implies knowledge and acceptance of the conditions contained herein. Thus, when making your personal data available, you are authorising its collection, use and disclosure in accordance with the rules defined herein.

WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy applies exclusively to the collection and processing of personal data carried out by Elastron, S.A.

WHAT IS PERSONAL DATA?
When we refer to personal data we refer to any information, of any nature and regardless of its support, including sound and image, relating to an identified or identifiable individual.
A person is considered identifiable when he/she can be identified directly or indirectly, namely by reference to an identification number or to one or more specific elements of his/her physical, physiological, psychic, economic, cultural or social identity.
The DPGR applies only to data of individuals and does not cover the data of legal persons.

WHO IS RESPONSIBLE FOR DATA PROCESSING?
The one responsible for the collection and processing of personal data is Elastron, S.A., Rua da Recta de Gomil nº 354, A2, 4595-144 Frazão, Paços de Ferreira; Tel: 227624043 which, in the context, decides what data is collected, the means of processing the data and what purposes it is used for.
Elastron, S.A. has appointed a Data Protection Officer (DPO) whose primary function is to ensure compliance with all legal obligations of the DPGR by the Company, that can be contacted at Rua da Recta de Gomil nº 354, A2, 4595-144 Frazão, Paços de Ferreira, Tel: 227624043; email: dpo@elastrongroup.com.

WHAT TYPE OF PERSONAL DATA DO WE COLLECT?
Within the scope of its activity, Elastron, S.A. collects and processes the personal data necessary for the provision of services and/or the supply of products, therefore processing data such as name, address, telephone number, e-mail, TIN and citizen card number.

WHEN AND HOW DO WE COLLECT YOUR DATA?
Elastron, S.A. collects your data by phone, email, in person, in writing or through its websites, with your consent. As a rule, personal data is collected when the Customer subscribes to one of our products or services.
Some personal data is mandatory and in case of lack or insufficiency of such data, Elastron, S.A. cannot provide the product or service in question and the Company will inform the Customers of the mandatory nature of providing the data.
If you are not a Customer of Elastron, S.A., your data will only be processed if you make them available to the Company, in particular if you consent to the sending of newsletters and the contact for any marketing campaigns that the Company may carry out, in which case the rules of this Privacy Policy will apply.
The personal data collected is processed in a computerised manner and in strict compliance with the legislation for the protection of personal data and is stored in a specific database created for this purpose and, in no case, will the data collected be used for any purpose other than that for which the consent of the data holder was given.

WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA?
In general, the personal data collected is intended for the management of the contractual relationship, the provision of contracted services, the adequacy of the services to the needs and interests of the Customer, information and marketing actions.
You may, however, make personal data available to us for other purposes, such as for the purposes of sending complaints and suggestions, disclosure of the Company's institutional information and/or advertising campaigns, promotions, publicity and news about the products and/or services of the Company, to carry out market studies, evaluation surveys, as well as for the transfer to companies/institutions with which the Company deals directly, in a close contractual relationship, where your personal data is necessarily required.
At the time of collection of the data you will be provided with more detailed information on the use we give to your data.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?
The period during which the data is stored and kept varies according to the purpose for which the information is processed.
In fact, there are legal requirements that require keeping the data for a minimum period. Thus, and whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that led to their collection or subsequent processing or, for the period authorised by the National Data Protection Commission, at the end of which it will be deleted.

WHAT MEASURES HAVE BEEN ADOPTED BY ELASTRON, S.A.TO ENSURE THE SECURITY OF YOUR PERSONAL DATA?
Elastron, S.A. is committed to guaranteeing the protection of the personal data that is made available to us, and has adopted and implemented strict rules in this regard. Compliance with these rules is an undeniable obligation of all those who legally access it.
Considering the great concern and commitment that Elastron, S.A. reveals in defence of privacy issues, a number of technical and organisational security measures have been adopted in order to protect the personal data that is made available to us against its disclosure, loss, misuse, alteration, processing or unauthorized access as well as against any other form of unlawful processing.
In this regard, all the personal data that you give us about yourself is stored securely in the Elastron systems that, in turn, are in the Company’s own Datacentre under cover of all physical and logical security measures, which we believe to be essential for the protection of your personal data.
Notwithstanding the security measures adopted by Elastron, we are obliged to alert all Internet users that they should take additional security measures, to ensure that they use an updated PC and Browser in terms of properly configured security patches, active firewall, anti-virus and anti-spyware, and make sure of the authenticity of the websites you visit on the internet, avoiding websites whose reputation you do not trust.
Elastron stores its personal data in its datacentre located in national territory and in datacentres located in European Union territory.
This data and its infrastructures are protected and maintained in accordance with security standards and in compliance with the applicable privacy laws.

UNDER WHAT CIRCUMSTANCES IS THERE COMMUNICATION OF DATA TO OTHER ENTITIES (THIRD-PARTIES AND SUBCONTRACTORS)?
Elastron, SA, in the scope of its activity, may resort to third parties for the provision of certain services. Sometimes the provision of these services implies access by these entities to the personal data of our customers, suppliers, service providers or employees. When this happens, Elastron, S.A. takes the appropriate measures, in order to ensure that the entities that have access to the data are reputable and offer the highest guarantees at this level, which will be duly established and safeguarded in a contract to be signed between Elastron, S.A. and the third-party entity(ies).
Thus, any entity subcontracted by Elastron, S.A. will process the personal data of our customers, suppliers, service providers or employees in the name and on behalf of Elastron, S.A. under the obligation to adopt the necessary technical and organisational measures in order to protect the data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access and against any other form of unlawful processing.
There may also be a need for the transfer of personal data to the other companies of the Group, namely Elastron Spain and Elastron Deutschland, always with the proper safeguarding of security and data protection on both sides.
In any case, Elastron, S.A. remains responsible for the personal data that it makes available.

IN WHICH CIRCUMSTANCES DO WE TRANSFER YOUR PERSONAL DATA?
The provision of certain services by Elastron, S.A. may imply the transfer of its data out of Portugal, namely in the use of the Company's services and/or products to other Group companies (Elastron Spain and Elastron Deutschland) and international institutions.
In such a case, Elastron, S.A. will strictly comply with the applicable legal provisions, in particular as to the determination of the suitability of such Country with regard to the protection of personal data and the requirements applicable to such transfers.

HOW DO WE USE THE COOKIES?
Cookies are small labels of software that are stored on your computer through the browser, retaining only information related to your preferences, not including, as such, your personal data.
If you wish, you can disable all cookies if you prefer not to receive them.
You can also have your computer notify you about the use of cookies. In both cases you must adjust your browser settings (such as Internet Explorer).

PRIVACY OF MINORS (CHILDREN AND YOUNG PEOPLE)
Elastron, S.A.is committed to protecting the privacy of children and does not intend to collect personal information from minors under the age of 16. If you are a minor under the age of 16 and you attempt to submit your registration, it will be rejected and will be informed that we do not accept registrations from children under the age of 16.
We encourage parents and guardians of minors under the age of 16 to regularly monitor and supervise the use of email and other online activities for children.

HOW YOU CAN EXERCISE YOUR RIGHTS UNDER THE DPGR
Within the scope of the DPGR, you can directly perform the updating or rectification of your personal information or define some of your preferences, such as receiving newsletters. You can also request some specific rights such as:
- Additional information about the use of your data;
- A copy of the data stored in our databases;
- Limitation on the processing or forgetfulness of your personal data.
If you want to exercise any of the rights above, we will analyse them and respond within the legally required deadlines (maximum of 30 days). We may need to verify or that you prove your identity before performing these rights.
If you have any questions regarding our use of your personal data or our privacy policy, you may at any time contact our Customer Care service or directly contact our Data Protection Officer via the email: dpo@elastrongroup.com.
If you are dissatisfied with our use of your personal data or with our response after exercising any of these rights, you have the right to submit a complaint to the national supervisory authority (National Commission for Data Protection – NCDP) | Rua de São Bento, no. 148, 3º, 1200-821 Lisbon | Tel: 351 213928400 | Fax: +351 213976832 | e-mail: geral@cnpd.pt

CONSENT OF THE DATA HOLDER
By using our web site, you confirm that you accept the terms of this Privacy Policy.
If you do not wish to receive promotion actions for new products or services or communications, you may, at any time, object to the use of your data for marketing purposes, for sending information communications or inclusion in lists or information services.
If you do not agree with the terms of our Privacy Policy, you are requested not to provide us with personal information and to cease using our web site.

HOW YOU CAN GET TO KNOW OF ANY CHANGES TO THE PRIVACY POLICY OF ELASTRON, S.A.
Elastron, S.A. reserves the right, at any time, to make adjustments or changes to this Privacy Policy; these changes are duly publicized and communicated to our customers, suppliers and service providers, among others.

ONLINE PRIVACY POLICY
The Online Privacy Policy applies only to information collected through our web site and not to information collected offline.