Privacy Policy

NEWCO Corporate Services, S. A. (henceforth referred to as ‘NEWCO’ and further identified below) is dedicated to guaranteeing its Clients and potential Clients not only full compliance with all legal obligations, but also complete privacy for all personal data, in accordance with best market practices.

For all legal intents and purposes, please find below full identification and contact information of the Data Controller entity responsible for processing personal data:

• Name: NEWCO Corporate Services, S. A. 
• Legal Person Tax Number/Commercial Registry Number: 511 037 570
• Head office and postal address: Rua Dr. Brito Câmara, n.º 20, 1.º Andar, 9000-039 Funchal
• Commercial Registry: Funchal
• E-mail address: info@newco.pro 
• Telephone number: +351 291 210 200

NEWCO will process your personal data in accordance with the following terms:

1. Data Controller

NEWCO is the Data Controller entity responsible for processing personal data that are supplied via the website https://www.newco.pro/ (‘website’) or through the contractual relationship that is established with NEWCO.

2. Purposes and legal grounds for processing personal data

Depending on your interaction with NEWCO, your personal data may be processed for different purposes. Below, we identify those purposes and the applicable legal grounds:

• If you are not yet a Client of ours, if you want us to send you commercial notifications via e-mail regarding our activity, you must give us your consent. You may therefore choose to receive commercial notifications related to NEWCO services. As previously mentioned, in this case, the legal grounds that apply to the processing of your personal data shall be your consent. This consent may be revoked at any time without making illegal the processing of personal data that has taken place on the basis of that consent up until the date said consent has been revoked. In such a case, failure to give your consent will prevent us from sending you commercial notifications related to our activity.
   
• If you are our Client, we wish to keep you updated at all times regarding any news about our services. As such, barring any opposition on your part, we will send you commercial notifications via e-mail regarding our activity. Our legitimate interest in keeping you updated regarding the latest news about our services, and thus be able to offer you quality service, constitutes the legal grounds applicable to the processing of your personal data.

As a result of the services we provide, we will process your data for the following purposes:

• Statistical analysis;
• Sending of personalised relevant updates.

As regards the purposes mentioned here, the legal grounds that apply to the processing of personal data are the execution of a contract in which the data subject is a party, and the fulfilment of our legal obligations, seeing as your personal data are essential for executing the contract in question.

• To provide you with information via the chatbot on our website. In this case, the legal grounds applicable to the processing of personal data shall be NEWCO’s legitimate interest in supplying you with all the information you need.

3. Time during which data is stored

The time during which we store your personal data may vary depending on the purpose for which the data were processed. As such, we shall store your personal data for the following duration:

• Sending of commercial notifications: until you exercise your right to object or you revoke your consent, depending on which case applies.
• For the purposes associated with the services we provide: 
  • for the amount of time necessary to ensure complete fulfilment of the contract signed with you, including, but not limited to, for the purposes of the warranty and after-sales assistance;
  • for the legally applicable amount of time.
• In order to supply you with information via the chatbot available on the website
  • for the amount of time necessary to ensure that we provide you with all requested information.

4. Cookies

What are cookies?

Cookies are small text files stored on the browser of the user’s equipment or mobile device (henceforth collectively referred to as ‘equipment’). Cookies allow a website to recognise your device the next time you visit the website. When we use the term cookies in this policy we are referring to all files that collect information in this manner. 

We use various types of cookies on the website. If you would like more information regarding the various types of cookies, their purposes and respective storage period, please see section four. 

Depending on the type of cookies, refusal to install them may impede access to some of your areas or prevent you from receiving personalised information. 

Via your browser, you may decide at any time to be notified regarding the reception of cookies, as well as block their respective installation on your equipment.

Which entity is responsible for cookies?

The entity responsible for cookies may vary, depending on where the cookies come from. As such, the website uses the following types of cookies, depending on the responsible entity:

• Own cookies: These cookies are sent to the user’s equipment from the party that is responsible for the website, namely NEWCO;
• Third-party cookies: These cookies are sent to the user’s equipment from a computer or domain that is not managed by NEWCO, but by another entity that processes the data obtained via cookies.

You can find out which entity is responsible for each cookie in Section four.

How long are cookies stored?

As regards the amount of time during which cookies are stored on your equipment, the following cookies must be taken into account:

• Session cookies: These are collected and stored when the user accesses the website. They are normally used to store information for the purpose of supplying the service requested by the user on a single occasion (for instance, a list of acquired products) and they disappear at the end of the session.
   
• Persistent cookies: With these cookies the data remain stored on the user’s equipment and they can be accessed and processed during a period of time stipulated by the entities that are responsible for the cookie, which can vary between a few minutes and several years.

You can check the storage period of each cookie in Section four.

What are cookies for? 

Cookies are used to help determine website usefulness, interest and number of uses, thereby allowing quicker and more efficient browsing and eliminating the need to repeatedly insert the same information. 
Next, you can find information regarding the types of cookies that are used on the website, along with the specific cookies that are used according to each type.

• Necessary cookies: These cookies are essential for browsing and using the website. The information collected is related to the website’s regular management.

To summarise, these cookies allow us to ensure that we provide the service that we are asked to provide, and without these cookies it would not be possible to do so.

• Preference and personalised cookies: These cookies allow information to be memorised, thereby enabling the user to access the website with certain characteristics that can differentiate his or her experience from that of other users, such as language, appearance or website content.

• Analytics cookies: These cookies allow us to track and analyse the behaviour of website users, including quantifying the impact of advertisements. The information collected through cookies of this type is used to measure website activity, in order to make improvements by analysing the usage data of the website users.

• Advertising (behavioural) cookies: These cookies store information regarding users’ behaviour through their browsing of the website, which allows a specific profile to be developed and advertising to be targeted according to said profile.

How can I deactivate cookies?

Even if you consent to having cookies installed, you may deactivate part or all of them at any time. 

All browsers allow the user to accept, refuse or delete cookies, namely by selecting the appropriate settings in the respective browser. You can configure the cookies in the ‘options’ or ‘preferences’ menu of your browser. You should keep in mind, however, that by deactivating the cookies you may be preventing some of the website services from functioning properly, thus partially or fully affecting website browsing.

For more information about cookies, including what they are, how to manage them and how to delete them, visit www.allaboutcookies.org, which also includes information on how to manage your settings for the various browser types. 

Transmission of personal data

We may communicate your personal data to third-party entities in view of complying with the legal obligations that are applicable in each case or when such is deemed necessary in providing the hired services.

Whenever personal data are to be processed by external service providers, who act as subcontractors, said service providers are selected on the basis of rigorous selection criteria, with a view to complying with their data protection obligations, and we undertake to sign a data processing agreement with them.

We would like to point out that some of the service providers that we use are located outside of the European Economic Area (‘EEA’) and in such cases the following paragraphs apply.

During relationships established with the providers of the services that we offer we shall transmit your personal data to the following entities:

As such, in the two previous situations, your data may be transmitted to entities that are located outside the EEA with legislation on data protection that may not ensure protection equivalent to that guaranteed within the EEA.

In cases where your data are transmitted outside of the EEA, in addition to ensuring that your personal data will always be treated in compliance with the provisions of this Privacy Policy, we shall take the necessary precautions to ensure that those transmissions comply with applicable legislation. We shall thus implement the appropriate safeguards in view of protecting your privacy, fundamental rights and freedoms, as is the case within the EEA, namely through the application of standard contractual clauses adopted by the European Commission. You may request a copy of these safeguards by contacting us via e-mail address info@newco.pro

Rights of the data subject

As the data subject, you have the following rights with respect to the processing of your personal data:

• Access: You have the right to obtain information if we are processing your data, and you may consult your personal data that has been included in the files of this company.
   
• Rectification: You have the right to change your personal data when they are incorrect and complete them when they are incomplete.
   
• Erasure: You may request erasure of your personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
   
• Objection: In certain situations you may request that your personal data cease to be processed. We shall cease processing your personal data, except when there are legitimate reasons not to or for the purpose of declaring, exercising or defending rights as part of administrative, judicial or extrajudicial proceedings.
   
• Restriction of processing: You may request restriction of the processing of your personal data under the following circumstances: (a) when contesting the accuracy of your personal data; (b) when the processing is illegal and you have objected to it and requested restriction of use of your personal data; (c) when we no longer need to process your personal data, but we need them to exercise or defend rights in administrative, judicial or extrajudicial proceedings; (d) when you have objected to the processing of your personal data in order to comply with an obligation of public interest or in order to satisfy legitimate interest, as long as those legitimate reasons for processing prevail over your reasons.
   
• Portability: In certain situations you shall have the right to receive in a structured, commonly-used and machine-readable format the personal data that you have provided us with and those data that have been obtained through your relationship with us, and have the right to transmit those data to another entity.

If you have any questions or wish to exercise these rights, you can send an e-mail to info@newco.pro. In order to exercise your rights, if necessary, we may request that you send us a document proving your identity. You must also indicate the right that you wish to exercise. Exercising your rights is free of charge, unless the request is manifestly groundless, excessive or reiterated.

Lastly, we would like to mention that you may file a complaint with the relevant supervisory authority (Portuguese Data Protection Authority) at www.cnpd.pt.