Privacy Policy
Bullet Solutions – Information Systems, S.A. (hereinafter, Bullet Solutions), corporate entity no. 507491300, headquartered at Rua de Júlio Dinis, no. 728, 9th Right, Room 911, 4050 – 012 Porto, as the data controller, is committed to protecting the privacy and rights of personal data subjects.
We have developed this Privacy Policy to explain how, as data controllers, we process users' personal data when they visit our website, in accordance with the General Data Protection Regulation (Regulation (EU) No. 679/2016 of the European Parliament and of the Council of 27 April, hereinafter "GDPR") and other applicable data protection legislation.
Through this policy, we aim to inform you about the collection and processing of personal data, cases where the provision of personal data is necessary, the periods for which we retain personal data, the categories of personal data we process, their purposes and legal grounds, data transmission and international transfers, the rights available to data subjects, and how you can contact us.
Processing of Personal Data
The GDPR defines "personal data" as any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, electronic identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Data subjects are the individuals to whom the personal data relates.
Bullet Solutions is responsible for processing the personal data listed in this Privacy Policy, as it decides which personal data is collected, the purposes for which it is collected, and the means of processing such data.
Bullet Solutions is committed to keeping your data properly protected, implementing technical and organizational measures to ensure its security and prevent its dissemination, loss, and misuse, as well as against its processing, unauthorized access, or any other form of unlawful processing, such as the creation and implementation of data protection policies and the adoption of IT and network security solutions.
However, users should adopt additional security measures, namely, ensuring they use properly configured electronic devices and browsers, with active firewall, antivirus, and/or other forms of logical or even physical security.
Required Information
Access to and use of the Bullet Solutions website does not depend on the provision of personal data by users. You will only need to provide personal data if you wish to contact us, either through the forms available on our website or through the contacts we provide. Fields marked with an asterisk (*) in the forms are mandatory, so if you choose not to provide them, we may not be able to provide the services or information or clarifications requested.
In some cases, you may also provide your consent for additional processing of personal data (or some of that data, where applicable). In this case, we will specifically inform the user about the scope of consent and the purposes pursued with the processing activities.
Retention Periods
Bullet Solutions retains personal data in an identifiable format for the shortest period necessary to fulfill the purposes pursued through personal data processing. After this period, we will cease processing personal data, which we will delete at periodic intervals, unless the continuity of processing and data storage is required by law or the user grants us consent for such purpose.
Categories of Data, Purposes and Legal Grounds for Processing
1. To respond to communications addressed by the user to Bullet Solutions
If you communicate with us, particularly to request information or clarifications, providing personal data voluntarily, in person, by fax, telephone, email, postal mail, or by sending private messages through the company website, we will process your personal data for the purpose of responding to your request, with legal basis in our legitimate interest in managing the established contract and corresponding to your request, as well as, when applicable, in pursuing pre-contractual measures at the request of data subjects.
The data in question includes identification data (name and surname), contact data (email address and, possibly, telephone contact), other information necessary to complete the request and the content of the communication addressed by the user to Bullet Solutions.
If you provide us with your contacts and your consent for such purpose, Bullet Solutions may contact you for marketing purposes related to its services. This consent can be expressed by filling out the contact space on the Bullet Solutions website, and you can oppose this processing at any time. Newsletter subscription can be canceled by following the cancellation instructions included at the bottom of each email, consulting the Bullet Solutions website, or sending an email to geral@bulletsolutions.com.
Consent can be changed or withdrawn at any time by the personal data subject, with effects for the future.
To withdraw your consent statements, the individual can send an email to geral@bulletsolutions.com, indicating their new consent preferences. The last expression of will shall prevail over previous ones.
We will retain this personal data during the processing of the request/communication and until the moment when personal data is no longer necessary for fulfilling these purposes. If the request is made by a client, we may retain personal data during the maintenance of the contractual relationship or for a longer period, up to 10 years, if necessary to comply with legal obligations.
2. For recruitment purposes
We may process personal data for recruitment purposes if you send us an application or respond to job advertisements placed by Bullet Solutions, with legal basis in pursuing pre-contractual measures at the request of data subjects, our legitimate interest in managing applications sent to us, compliance with legal obligations and, in some cases, your consent.
The data included here may cover identification data (name and surname; Identification Number/Validity of Identification Document; Tax ID; date of birth), contact data (email and telephone contact) and data relating to academic training and professional experience (for example, qualifications, certifications, personal and professional experience, curricula vitae).
We will retain this personal data during the period your application is under analysis, until the conclusion of the recruitment process, for a period of two years if you are not selected, or until you revoke your consent, in applicable cases.
We may also process other personal data based on compliance with legal obligations to which we are bound and for the periods imposed by applicable legislation.
3. To ensure access to our services and our website
Based on our legitimate interests, namely, to ensure the proper functioning of services and our website, to establish connection with the user, prevention of misuse, prevention of damage through interference in information systems, presenting service content, detecting attacks on our website due to unusual activities, fault diagnosis, fraud prevention and detection, we may process access data, such as the date and time of the user's visit to our service, the page from which the system accessed our website, pages visited during the session, session identification data (session ID), as well as the following information regarding the computer system accessing the service: internet protocol (IP) address, browser type and version, device type, operating system and similar technical information. This data is pseudonymized, which means that data processing is carried out in such a way that it cannot be attributed to a specific person without resorting to additional information.
Regarding accounting, tax and administrative management, examples of data collected are identification data (name and surname; Tax ID; address) and contact data (email). Regarding customer management and service provision, the data included here may cover identification data (name and surname), contact data (email and telephone contact) and data relating to profession (name of the institution where they work and position held in that institution; institutional address).
The Bullet Solutions website uses purely functional cookies, not collecting personal data. If these cookies were not used, the website would not function properly, affecting navigation.
Due to technical procedures for transmitting information over the Internet, it is inevitable to transmit access data to external content service providers. External content service providers are responsible for ensuring that the information technology systems they use comply with legal privacy requirements.
Transmission of Personal Data and International Transfers
Bullet Solutions does not transmit your personal data to third parties, except if transmission is necessary for us to provide you with contracted services or to comply with legal obligations to which we are subject.
We may share personal data of website users, namely, with providers of computer, legal, administrative advisory services, website hosting, website content provision and information technology security services, as well as with public authorities in compliance with legal obligations.
This website may contain social media links such as Facebook, Twitter and LinkedIn, owned by third parties, and which present a button through which messages can be sent to the corresponding social network for various purposes, such as evaluation, recommendation or content sharing. The legal basis for data transmission in this case is Bullet Solutions' legitimate interests in advertising its services. The service providers concerned are responsible for ensuring that the processing of transmitted personal data occurs in accordance with privacy requirements.
The personal data subject is expressly warned that by disclosing personal data in Bullet Solutions' public media, such as on its Facebook, Twitter, YouTube and LinkedIn pages, this information may be viewed and used by third parties.
Bullet Solutions may send data to third countries, i.e., countries outside the European Union, within the scope of the purposes provided for in this Privacy Policy and in strict compliance with legal conditions. Transmission will be made if we believe, in good faith, in such necessity, for reasons related to legal requirements, with the protection of our customers, for example, to avoid spam or attempts to defraud users, or even to help avoid serious injury or loss of life, with the operability and maintenance of the security of our services, including avoiding or preventing an attack on our computer systems or networks.
In any case, data transmission to third countries will be made with respect for the fundamental rights, freedoms and interests of personal data subjects, and based on one of the following reasons: if transmission serves the purpose of executing the contract with the user, if we obtain user consent, if transmission is required for the declaration, exercise or defense of a right, if any of the derogations provided for in article 49 of the GDPR is applicable, if there is an adequacy decision by the European Commission or if adequate guarantees are ensured, in compliance with legal provisions.
Bullet Solutions also warns that the website may contain links (hyperlinks) to websites, products or services of third parties, which are not covered by this Privacy Policy. Bullet Solutions cannot therefore be held responsible, under any circumstances, for the content, accuracy, veracity or legitimacy of these websites or for the misuse of data collected or processed through them.
Bullet Solutions alerts its customers and the general public to this fact and to the need, before using such websites, to carefully read the rules regarding the processing of personal data defined by these third parties.
Bullet Solutions advises:
- Not to include personal, confidential and/or sensitive data in communications sent to it (e.g.: credit card numbers);
- Prudence in exposing personal data and in circulating such data over the Internet;
- Not browsing websites of dubious reputation;
- Control of sending personal data by minors, by their parents or legal guardians.
Bullet Solutions is not responsible for personal data or other unsolicited information sent to it by email, in forums, comment areas or any other accessible public area it administers or manages, deleting them, as a rule, insofar as they are not adequate, relevant and limited to the purposes it pursues.
Data Subject Rights
As a personal data subject, you have the following rights:
1. Right of Access
At any time, you have the right to obtain our confirmation as to whether personal data concerning you is being processed and, if so, to access such data and the information provided by law.
2. Right of Rectification
As a personal data subject, you have the right to obtain rectification of inaccurate personal data concerning you, without undue delay. Taking into account the purposes of processing, the user has the right to have incomplete personal data completed, including by means of an additional statement.
3. Right to Erasure ("right to be forgotten")
You have the right to obtain erasure of your personal data, without undue delay, in some circumstances provided by law, including the fact that your personal data is no longer necessary for the purpose that motivated its collection or processing or the fact that you decide to withdraw consent (if that is the legal basis for processing and there is no other that allows it). This right may be limited in certain situations, including the need for processing for purposes of declaration, exercise or defense of a right in legal proceedings and compliance with legal obligation that requires processing.
4. Right to Restriction of Processing
In certain situations provided by law, you have the right to obtain restriction of processing of your personal data in some situations provided by law. Among these situations are cases where you contest the accuracy of your personal data, for a period that allows Bullet Solutions to verify its accuracy and cases where you have objected to processing, until it is verified whether Bullet Solutions' legitimate reasons prevail over yours.
5. Right to Data Portability
If processing is based on consent or on a contract of which the data subject is a party, the data subject has the right to receive the personal data provided to us, in a structured, commonly used and machine-readable format. You also have the right to request that your data be directly transmitted by us to another data controller, when this is technically feasible.
6. Right to Object
If we process your personal data for direct marketing purposes, the data subject has the right to object, at any time, to the processing of personal data for marketing purposes concerning them, with effects for the future, including profiling, insofar as it is related to direct marketing. In this case, personal data will no longer be processed for this purpose.
The data subject also has the right, at any time, with effects for the future and for reasons related to their particular situation, to object to the processing of personal data based on the legitimate interests of Bullet Solutions or third parties. In this case, we will cease processing, unless there are compelling legitimate reasons for such processing that prevail over the interests, rights and freedoms of the data subject, or processing is necessary for purposes of declaration, exercise or defense of a right in legal proceedings.
7. Right to Withdraw Consent
If processing is based on consent, the data subject has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent until the moment of its revocation. In this case, and unless there is another legal basis that imposes or allows it, such as compliance with a legal obligation or a contract of which the data subject is a party, your personal data will no longer be processed.
8. Right to Lodge a Complaint
The data subject also has the right to lodge a complaint with the competent supervisory authority, the National Data Protection Commission, at https://www.cnpd.pt/cidadaos/participacoes/.
You may exercise your rights freely and free of charge, by addressing us through the contacts indicated below. For this purpose, we may require elements that prove your quality as a personal data subject who intends to exercise their rights.
How can you contact us?
You can request any information you consider necessary regarding the processing of your data through the following contacts:
Email: geral@bulletsolutions.com
Mail: Bullet Solutions – Information Systems, S.A., Edifício Roma – Parque Itália, Rua Júlio Dinis, 728, Room 911, 4050-012, Porto, Portugal
Phone: (+351) 226 099 612
Fax: (+351) 220 167 048
You can also contact our Data Protection Officer:
Email: info@hedadpo.pt
Mail: HEDA – DATA PROTECTION OFFICERS, Rua de João Ramalho, no. 141, 4200-292 Porto
The exercise of personal data subject rights is free of charge, except if it concerns a manifestly unfounded or excessive request, in which case a reasonable fee may be charged, taking into account the costs incurred.
If a personal data subject exercises any of their rights, Bullet Solutions proceeds to the respective analysis and responds, predictably, within 1 (one) month.
Information is provided in writing but may also be provided orally if the subject requests it. Bullet Solutions verifies the identity of the data subject before responding to their requests.
Updates
This Privacy Policy may be subject to periodic updates, so Bullet Solutions recommends that it be consulted regularly.