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Privacy Policy

This Privacy Policy sets out how Zenter Parts uses the personal data of its customers and potential customers.

We understand that the use of your personal data requires your trust. We are subject to the highest standards of privacy and will only use your personal data for clearly identified purposes and in accordance with your data protection rights.

The confidentiality and integrity of your personal data is one of our main concerns.

1. GENERAL PART

1.1 COLLECTION AND PROCESSING OF USER DATA

The Personal Data collected and processed consists of information relating to name, email, and address, although other personal data may be collected that may be necessary or convenient for the provision of Services by Zenter Parts. After collecting Personal Data, Zenter Parts provides the User with detailed information about the nature of the data collected and about the purpose and processing that will be carried out in relation to the Personal Data.

Zenter Parts also collects and processes information about your device's hardware characteristics and browser/software characteristics, as well as information about the pages you visit on the Site. This information may include your browser type, domain name, access times, and hyperlinks through which you accessed the Site ("Usability Information"). We use this information only to improve the quality of your visit to our Site.

Usability Information and Personal Data are referred to in this Privacy Policy as "User Data".

For the purposes of this Privacy Policy, a contractual relationship means any and all contracts established between Zenter Parts and the entities that are related to it, regardless of their subject matter.

1.2 Subcontracted Entities

In the context of processing User Data, Zenter Parts uses or may use third-party entities, subcontracted by it, to process User Data on behalf of Zenter Parts and in accordance with its instructions, in accordance with the law and this Privacy Policy.

These subcontracted entities may not transmit User Data to other entities without the prior written authorization of Zenter Parts, and are also prohibited from contracting other entities without the prior authorization of Zenter Parts.

Zenter Parts undertakes to subcontract only entities that offer maximum security in the execution of appropriate technical and organizational measures, in order to guarantee the protection of the User's rights. All entities subcontracted by Zenter Parts are bound to the latter through a written contract which regulates, in particular, the object and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties.

After collecting personal data, Zenter Parts provides the User with information about the categories of subcontracted entities that, in the specific case, may process data on behalf of Zenter Parts.

1.3. DATA COLLECTION CHANNELS

Zenter Parts may collect data directly (i.e., directly from the User) or indirectly (i.e., through partner entities or third parties). Collection may be done through the following channels:

Direct collection: in person, by phone, by email and through the Website;

Indirect collection: through partners or group companies and official entities.

2. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA

In terms of general principles relating to the processing of personal data, Zenter Parts undertakes to ensure that the User Data it processes is:

Subject to treatment in accordance with the law, fair and transparent with respect to the User; Collected for specified, specific, legitimate purposes and not subsequently processed in a way that is incompatible with those purposes;

Adequate, justified and limited to what is necessary in relation to the purposes for which they are processed;

Accurate and up-to-date whenever necessary, with all necessary measures being taken to ensure that inaccurate data, taking into account the purposes for which they are processed, are erased or corrected without delay;

Stored in a way that allows the User to be identified only for the period necessary for the purposes for which the data is processed;

Processed in a manner that ensures their security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through appropriate technical or organizational measures;

The data processing carried out by Zenter Parts is permitted and legal when at least one of the following situations occurs:

The User has given, without any doubt, their consent to the processing of User Data for one or more specific purposes;

The processing is necessary for the performance of a contract to which the User is a party, or in order to take steps at the User's request prior to entering into a contract;

The processing is necessary for compliance with a legal obligation to which Zenter Parts is subject;

The processing is necessary to protect the vital interests of the User or of another individual;

Processing is necessary for the purposes of the legitimate interests pursued by Zenter Parts or by third parties (except where such interests are overridden by the interests or rights and freedoms of third parties). Zenter Parts undertakes to ensure that User Data is processed only under the conditions listed above and in accordance with the principles mentioned above.

When the processing of User Data is carried out by Zenter Parts based on the User's consent, the User has the right to withdraw their consent at any time. However, the withdrawal of consent does not compromise the legality of the processing carried out by Zenter Parts based on the consent previously given by the User.

The period of time during which data is stored and retained varies according to the purpose for which the information is processed. In effect, there are legal requirements that oblige data to be kept for a minimum period of time. Thus, and whenever there is no specific legal obligation, the data will be stored and retained only for the minimum period necessary for the purposes that motivated its collection or subsequent processing and, at the end of that period, it will be deleted.

3. USE AND PURPOSES OF PROCESSING USER DATA

In general terms, Zenter Parts uses User Data for the following purposes:

User contact management;

To inform the User, upon their request, of new products and services available on the Site, special offers and campaigns, updated information about the activities of Zenter Parts and, in general, for marketing purposes of Zenter Parts and through any means of communication, including electronic media or social networks;

Allow access to restricted areas of the Site, such as the online store;

To ensure that the Site meets the User's needs, through the development and publication of content that is as tailored as possible to the User's requests and type, the improvement of the Site's search capabilities and functionalities, and the obtaining of associated or statistical information regarding the typical User profile (analysis of consumption profiles);

Provision of Services, and other services, such as newsletters, opinion surveys, or other information or products requested or purchased by the User;

Sending out satisfaction surveys;

Zenter Parts may combine Usability Information with anonymous demographic information for research purposes, and may use the result of this combination to provide more relevant content on the Site. In certain restricted areas of the Site, Zenter Parts may combine Personal Data with Usability Information to provide the User with more personalized content.

User Data collected by Zenter Parts is not shared with third parties without the User's consent, except in the situations mentioned in the following paragraph. However, if the User contracts services from Zenter Parts that are provided by other entities responsible for processing personal data, the User's Data may be consulted or accessed by those entities, to the extent that this is necessary for the provision of said services, and the User will be informed of this.

Under applicable law, Zenter Parts may transmit or communicate User Data to other entities if such transmission or communication is necessary for the performance of the contract established between the User and Zenter Parts, or for pre-contractual steps at the User's request, if necessary for compliance with a legal obligation to which Zenter Parts is subject, or if necessary to pursue the legitimate interests of Zenter Parts or a third party. If User Data is transmitted to third parties, reasonable efforts will be made to ensure that the recipient uses the transmitted User Data in accordance with this Privacy Policy.

4. TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES IMPLEMENTED

To guarantee the security of User Data and maximum confidentiality, Zenter Parts treats the information you provide us with absolute confidentiality, in accordance with its internal security and confidentiality policies and procedures, which are updated periodically as needed, as well as with the legally established terms and conditions.

Due to the nature, scope, context and purposes of the data processing, as well as the risks arising from the processing for the rights and freedoms of the User, Zenter Parts undertakes to apply, both at the time of determining the means of processing and at the time of the processing itself, the necessary and appropriate technical and organizational measures to protect the User's Data and to comply with legal requirements.

It also undertakes to ensure that, by default, only the data necessary for each specific processing purpose is processed and that this data is not made available to an indeterminate number of people without human intervention.

Communication between the user's device and Zenter Parts is carried out through secure channels and communications that use the HTTPS protocol and the SSL security standard.

Nevertheless, in terms of general measures, Zenter Parts adopts the following:

Regular audits aimed at identifying the effectiveness of the technical and organizational measures implemented;

Raising awareness and providing training for staff involved in data processing operations;

Pseudonymization and encoding of personal data;

Mechanisms capable of ensuring the ongoing confidentiality, availability, and resilience of information systems;

Mechanisms that ensure the rapid restoration of information systems and access to personal data in the event of a physical or technical incident.

5. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

The site does not transfer your personal data to recipients located in countries outside the European Union.

6. USE OF COOKIES

When you visit our website, a small text file (cookie) is created and saved on your computer's hard drive. Consequently, by browsing the Site, you are accepting the installation of this text file on your device. This file will allow you easier and faster access to the Site, as well as its personalization according to your preferences.

If you wish to delete them or set them to be blocked automatically, you can find instructions on how to do this in your browser's "Help" menu. However, if you do not allow the use of cookies, some Site functionalities may not be available.

By browsing our Site, you are allowing the collection and storage of small text files called cookies, which contain information and are downloaded to your computer or other devices via a server. These text files will allow for a more personalized and efficient browsing experience. On each visit to the Site, your internet browser sends these cookies back to the Site, allowing the recognition and memorization of your identity, as well as your usage preferences.

For more information, please see our cookie policy here.

7. USER RIGHTS (DATA SUBJECTS)

7.1 RIGHT TO INFORMATION

7.1.1 Information provided to the User by Zenter Parts (when data is collected directly from the User):

The identity and contact details of Zenter Parts and the data controller;

Contact details for the Data Protection Officer;

The purposes of the processing for which the personal data are intended, as well as, if applicable, the legal basis for the processing;

If the data processing is based on the legitimate interests of Zenter Parts or a third party, an indication of those interests;

If applicable, the recipients or categories of recipients of the personal data;

If applicable, an indication that personal data will be transferred to a third country or an international organization, and whether or not an adequacy decision has been adopted by the Commission or a reference to appropriate or suitable transfer safeguards;

Retention period for personal data;

The right to request from Zenter Parts access to personal data, as well as its correction, deletion or limitation, the right to object to processing and the right to data accessibility;

If the data processing is based on the User's consent, the right to withdraw it at any time, without compromising the legality of the processing carried out based on the consent previously given;

The right to lodge a complaint with the CNPD or another supervisory authority;

Indication of whether or not the communication of personal data constitutes a legal or contractual obligation, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and the possible consequences of not providing such data;

If applicable, the existence of automated decisions, including profiling, and information regarding the underlying principle, as well as the significance and envisaged consequences of such processing for the data subject.

If User Data is not collected directly by Zenter Parts from the User, in addition to the information mentioned above, the User is also informed about the categories of personal data being processed, as well as the origin of the data and, if applicable, whether it comes from publicly accessible sources.

If Zenter Parts intends to process User Data for a purpose other than that for which the data was collected, Zenter Parts will provide the User with information about that purpose and any other relevant information prior to such processing, as described above.

7.2. Procedures and measures implemented to ensure compliance with the right to information.

The information referred to in 7.1 is provided in writing (including by electronic means) by Zenter Parts to the User prior to the processing of the personal data in question.

Under applicable law, Zenter Parts is not obligated to provide the User with the information mentioned in section 7.1 when and to the extent that the User is already aware of it.

The information is provided by Zenter Parts free of charge.

8. RIGHT OF ACCESS TO PERSONAL DATA

Zenter Parts guarantees the means that allow the User to consult their Personal Data. The User has the right to obtain from Zenter Parts confirmation as to whether or not personal data concerning them is being processed and, if so, the right to access their personal data and the following information:

The purposes of data processing;

The categories of personal data in question;

The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or belonging to international organizations;

The retention period for personal data;

Right to request from Zenter Parts the correction, erasure or restriction of the processing of personal data, or the right to prevent such processing;

Right to lodge a complaint with the CNPD or another supervisory authority;

If the data has not been collected from the User, the available information about the origin of that data;

The existence of automated decisions, including profiling, and information regarding the underlying logic, as well as the significance and envisaged consequences of such processing for the data subject;

Right to be informed about the appropriate safeguards associated with the transfer of data to third countries or international organizations.

Upon request, Zenter Parts will provide the User, free of charge, with a copy of the User Data that is being processed. Providing other copies requested by the User may incur administrative costs.

9. RIGHT TO RECTIFICATION OF PERSONAL DATA

The User has the right to request, at any time, the rectification of their Personal Data, as well as the right to have their incomplete personal data completed, including by means of an additional statement.

In the event of data rectification, Zenter Parts will notify each recipient to whom the data has been transmitted of the respective rectification, unless such communication is considered impossible or involves a disproportionate effort for Zenter Parts.

10. RIGHT TO ERASE PERSONAL DATA ("RIGHT TO BE FORGOTTEN")

The User has the right to obtain from Zenter Parts the deletion of their data when one of the following reasons applies:

User Data is no longer necessary for the purpose that motivated its collection or processing;

The User withdraws the consent on which the data processing is based, and there is no other legal basis for said processing;

The User objects to the processing under the right to object and there are no overriding legitimate interests that justify the processing;

In case User Data is processed unlawfully;

If User Data needs to be deleted to comply with a legal obligation to which Zenter Parts is subject;

Under applicable law, Zenter Parts is not obligated to delete User Data to the extent that processing is necessary for compliance with a legal obligation to which Zenter Parts is subject or for the establishment, exercise or defense of a legal claim by Zenter Parts in legal proceedings.

In the event of data deletion, Zenter Parts will notify each recipient/entity to whom the data has been transmitted of the respective deletion, unless such notification proves impossible or involves a disproportionate effort for Zenter Parts.

When Zenter Parts has made User Data public and is obliged to delete it under the right to erasure, Zenter Parts undertakes to ensure reasonable measures, including technical measures, taking into account available technology and the costs of its implementation, to inform those responsible for the actual processing of personal data that the User has requested the erasure of links to such personal data, as well as copies or reproductions thereof.

11. RIGHT TO RESTRICTION OF THE PROCESSING OF PERSONAL DATA

The User has the right to obtain from Zenter Parts the restriction of the processing of the User's Data if one of the following situations applies (the restriction consists of inserting a mark in the personal data stored in order to limit its processing in the future):

If you contest the accuracy of your personal data, for a period that allows Zenter Parts to verify its accuracy;

If the processing is unlawful and the User objects to the deletion of the data, requesting instead the restriction of its use;

If Zenter Parts no longer needs the User's Data for processing purposes, but this data is required by the User for the establishment, exercise or defense of a legal claim;

If the User has objected to the processing, until it is verified that the legitimate reasons of Zenter Parts prevail over those of the User.

When User Data is subject to restriction, it may only be processed, with the exception of storage, with the User's consent or for the purposes of establishing, exercising or defending a legal claim, protecting the rights of another natural or legal person, or for reasons of public interest legally provided for.

Users who have obtained a restriction on the processing of their data in the cases mentioned above will be informed by Zenter Parts before the restriction on processing is lifted.

In the event of a restriction on the processing of data, Zenter Parts will communicate the respective restriction to each recipient to whom the data has been transmitted, unless such communication proves impossible or involves a disproportionate effort for Zenter Parts.

12. RIGHT TO PORTABILITY OF PERSONAL DATA

The User has the right to receive the personal data concerning him or her that he or she has provided to Zenter Parts, in a structured, commonly used and machine-readable format, and the right to transmit this data to another data controller, if:

The processing is based on consent or on a contract to which the User is a party; and

The treatment was carried out by automated means.

The right to data portability does not include inferred data, nor derived data, i.e., personal data generated by Zenter Parts as a consequence or result of the analysis of the data being processed.

The User has the right to have their personal data transmitted directly between data controllers, whenever technically feasible.

13. RIGHT TO OBJECT TO TREATMENT

The User has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is based on the legitimate interests pursued by Zenter Parts, or when the processing is carried out for purposes other than those for which the personal data were collected, including profiling, or when the personal data are processed for statistical purposes.

Zenter Parts will cease processing User Data unless it presents compelling legitimate grounds for such processing that override the User's interests, rights and freedoms, or for the establishment, exercise or defense of a legal claim by Zenter Parts in legal proceedings.

When User Data is processed for direct marketing purposes, the User has the right to object at any time to the processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. If the User objects to the processing of his or her data for direct marketing purposes, Zenter Parts will cease processing the data for that purpose.

The User also has the right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision:

Necessary for the conclusion or execution of a contract between the User and Zenter Parts;

As authorized by legislation to which Zenter Parts is subject; or

Based on the User's explicit consent.

14. PROCEDURES FOR EXERCISING USER RIGHTS

The right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability and the right to object may be exercised by the User by contacting the Data Protection Officer of Zenter Parts or via email at dpo@zenterparts.com.

Zenter Parts will respond in writing (including by electronic means) to the User's request within a maximum period of one month from receipt of the request, except in cases of particular complexity, in which this period may be extended to two months.

If the requests submitted by the User are manifestly unjustified or excessive, particularly due to their repetitive nature, Zenter Parts reserves the right to charge administrative costs or refuse to process the request.

15. PERSONAL DATA BREACHES

In the event of a data breach, and insofar as such a breach is likely to pose a high risk to the rights and freedoms of the User, Zenter Parts undertakes to notify the User concerned of the personal data breach within 72 hours of becoming aware of the incident.

Under the law, notification to the User is not required in the following cases:

If Zenter Parts has implemented appropriate technical and organizational protection measures, and these measures have been applied to the personal data affected by the personal data breach, especially measures that render the personal data unintelligible to any person not authorized to access that data, such as encryption;

If Zenter Parts has taken subsequent measures to ensure that the high risk to the User's rights and freedoms is no longer likely to materialize; or

If communicating with the User would involve a disproportionate effort for Zenter Parts, Zenter Parts will make a public announcement or take a similar measure to inform the User. To exercise any of these rights, you can fill out the form.

16. FINAL PART

16.1 CHANGES TO THE PRIVACY POLICY

Zenter Parts reserves the right to change this Privacy Policy at any time. In case of modification of the Privacy Policy, the date of the last change, available at the end of this page, is also updated. If the change is substantial, a notice will be posted on the Site.

17. APPLICABLE LAW AND JURISDICTION

The Privacy Policy, as well as the collection, processing or transmission of User Data, are governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and by the applicable legislation and regulations in Portugal, namely Law 58/2019.

Any disputes arising from the validity, interpretation or execution of this Privacy Policy, or related to the collection, processing or transmission of User Data, shall be submitted exclusively to the jurisdiction of the courts of the district of Porto Este, without prejudice to applicable mandatory legal provisions.