1. Framework

This Privacy Policy establishes the commitment of ADIRA – METAL FORMING SOLUTIONS, SA (hereinafter ADIRA) with its stakeholders (eg customers, suppliers, employees) in the protection of personal data for which it is responsible, intending to contribute to strengthening and consolidating the relationship of trust and proximity that you have with them, through clear and transparent communication of what you do with this data and what rights you recognize to their respective holders and how they can exercise them.

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

The Privacy Policy is framed within ADIRA's personal data protection regulations, which includes standards and procedures for managing the security and privacy of personal data.

ADIRA processes personal data through various operational and technical means to support its business process activities.

The. Objectives

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

• Strengthen and consolidate ADIRA’s relationship of trust and proximity with all its stakeholders;
• Demonstrate transparency about the purposes and processing activities carried out by ADIRA, as well as the retention periods for the personal data involved;
• Inform holders of personal data of their rights in relation to their protection and how they can exercise them;
• Inform the holders of personal data who ADIRA is responsible for, who they can contact to exercise their rights or clarify how their personal data is processed.

B. Scope of application

The Privacy Policy applies exclusively to the processing of personal data carried out by ADIRA, in the context of the intended purposes. For the purposes of this policy, personal data is considered to be any information relating to an identified or identifiable natural person (data subject). The data subject who can be identified directly or indirectly, namely through an identification number or through specific characteristics of their physical, physiological, genetic, mental, economic, cultural or social identity, is identifiable.

w. Policy maintenance, communication and enforcement

The Privacy Policy must be reviewed annually by the Board of Directors, when there is a change in circumstances and whenever there are legislative changes, to validate that it remains current and appropriate in light of applicable regulations and laws. Proposals for reviewing the policy and supervising its application and compliance are the responsibility of the Board of Directors.

This policy must be known to all ADIRA 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).

2. Content of the Privacy Policy

The. Our Privacy Commitment

ADIRA works based on trust and transparency. This commitment is transposed into our day-to-day relationships with our shareholders, suppliers and employees. 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 with transparency and that is essential to provide you with the best services. We will inform you how we use your personal data and for what purposes with the guarantee that we collect, share and store your personal data with reference to best practices in the field of security and protection of personal data.

When your personal data is collected, stored, processed, transmitted or deleted by other entities, we demand the same level of privacy and security.

We want you to feel confident that your personal data is safe with us, as we are always committed to protecting your privacy, and we take our responsibilities with regard to the protection of your personal data with great seriousness and commitment.

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:

Email: adira@adira.pt

Address: Rua das Lages, no 67, 4410-272 Canelas

B. Who is Responsible for Your Personal Data

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

Your personal data may be transmitted and processed by any of the companies belonging to the Sonae Capital Industrials Group of which ADIRA is an integral part. The Sonae Capital Industrials Group means SC - SONAE CAPITAL INDUSTRIALS, SGPS, SA and all companies directly or indirectly controlled by it.

w. Personal Data We May Collect

In this Privacy Policy, the term “Personal Data” means the set of information that relates to you and that allows us to identify you, directly or indirectly. Your personal data may include, for example, your name, address, telephone number and email address.

We may also receive your personal data from other companies, particularly when they collect, process or store it within the scope of a service provision contract.

d. How and Why We Use Your Personal Data

We use your personal data, in particular, for the following purposes:

   i. Marketing - to inform you about news that may be of interest to you;

   ii. Website user management;

   iii. Compliance with legal obligations, among others, towards our customers, suppliers and employees;

   iv. Recruitment of employees;

   v. Fulfillment of obligations arising from the contracts we enter into with our partners.

It is. How Long Do We Keep Your Personal Data

We keep your personal data only for as long as necessary to fulfill the purposes defined in paragraph d) above and to comply with the law.

Once the maximum retention period has been reached, your personal data will be anonymized or destroyed/eliminated in a secure manner.

f. Who We May Share Your Personal Data With

Your personal data may be shared with companies in the SONAE CAPITAL INDUSTRIALS Group.

In some cases, we may also disclose your personal data to other entities, as part of the services they provide. In such cases, we require that appropriate security measures be in place to protect your personal data.

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

In the case of transfer or access to your personal data by a SONAE CAPITAL INDUSTRIALS Group company, suppliers or service providers based outside the European Union, we guarantee that your personal data is processed in accordance with appropriate security and protection measures, compatible with the that we use.

g. How You Can Exercise Your Personal Data Protection Rights

In certain circumstances provided for in the European Data Protection Regulation, you have the right to access or request from us:

   i. Additional information about our use of your personal data;

   ii. Your personal data;

   iii. That we transmit your personal data that you provided to us to another entity;

   iv. Updating your personal data;

   v. The erasure of your personal data;

   saw. Opposition to the processing of your personal data;

   viii. Limiting the way we use your personal data while correcting it or clarifying any doubts about its content or the use we make of it;

   viii. The provision of a channel so that you can 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 excepted when your personal data is used to safeguard the public interest, namely in cases of detection and prevention of crimes, 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 by the following means:

Address: Rua das Lages, no 67, 4410-272 Canelas

Email: adira@adira.pt

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 lodge a complaint with the National Data Protection Commission (CNPD) – Address: Rua de São Bento, 148 – 3o , 1200-821 Lisbon – Telephone: +351213928400 – Fax: +351213976832 – Email: geral@cnpd.pt.

H. How We Protect Your Personal Data

We have a variety of information security measures, aligned with the best national and international practices, in order to protect your personal data, including technological controls, administrative, technical, physical measures and procedures that guarantee the protection of your personal data, preventing its misuse, unauthorized access and disclosure, its loss, its improper or inadvertent alteration, or its unauthorized destruction. In terms of information security, we assume the same commitment to continuous improvement that we adhere to in our daily activities.

Among others, we highlight the following measures:

   i. Restricted access to your personal data only by those who need it 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 guarantee the safeguarding of the integrity and quality of your personal data;

   v. Permanent monitoring of information systems, with the aim of preventing, detecting and preventing the misuse of your personal data;

   saw. Redundancy of equipment for storing, processing and communicating 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 case our control over how your personal data is protected is limited.

i. Updates to this Privacy Policy

This Privacy Policy may be updated in due course, which will be disclosed through the following means www.adira.pt