PRIVACY POLICY

THE NAVIGATOR COMPANY is strongly committed to the respect of users’ privacy and the protection and safety of your personal data. To that effect, users are hereby informed on how Navigator collects, processes and protects personal data provided through its online platforms.

Users should carefully read this Privacy Policy, which was written in a clear and simple manner, so that users may understand it clearly and decide freely whether they wish to provide their data to THE NAVIGATOR COMPANY.

The user guarantees that he/she is of age, that data provided is true, correct, complete and updated, and that the user is responsible for any direct or indirect harm or damages, which may result in breach of these obligations. Should the data belong to a third party, the user guarantees that he has informed such party of the information provided in this Privacy Policy and obtained authorization to transfer the data to THE NAVIGATOR COMPANY.

1. INTRODUCTION

This Privacy Policy applies to all personal data collected by THE NAVIGATOR COMPANY through its online platforms. The following companies in the Navigator Group are controllers of data processing:

• The Navigator Company, S.A., Península da Mitrena, Sado parish, Setúbal municipality;
• Navigator Added Value, S.A., Península da Mitrena, Sado parish, Setúbal municipality;
• Navigator Sales & Marketing, S.A., Avenue Pasteur 6H, 1300 Wavre, Belgium.

These companies have jointly determined the purposes and means for the processing of personal data pertaining to users and have entered into an agreement whereby they regulate the functions and responsibilities required to comply with applicable data protection laws and regulations.

To contact these companies on any issue concerning this Privacy Policy, the user may contact the Data Protection Officer of THE NAVIGATOR COMPANY by e-mail to dpo@thenavigatorcompany.com.

2. PURPOSES OF THE PROCESSING AND LEGAL BASIS

THE NAVIGATOR COMPANY shall process your data in a manual and automated manner, for the following specific purposes:

• Collected in the website of THE NAVIGATOR COMPANY: name and e-mail address;
• Collected in the forest management system: name of owner(s) or tenant(s) and plot area;
• Obtained via login in Facebook, Instagram and other social networks: social profile;
• Collected through the recruitment platform: name, e-mail, telephone, address, nationality, date of birth, gender, professional experience, academic qualifications, other training deemed appropriate for the function to which the candidate applies, knowledge of foreign languages, photograph and additional details according to the EUROPASS template;
• In requests for institutional and school trips: name, telephone, e-mail, subject, function, objectives and institution or school of the person who is responsible for the trip.

In addition, and with the user’s consent, THE NAVIGATOR COMPANY shall process contact data and data on preferences, browsing and behaviour history and location, for the following purposes:

• Information and marketing measures, campaigns and advertising contests;
• Market surveys or assessment inquiries;
• Activating communication services, including newsletters or alerts;
• Defining and communicating personalized and/or geo segmented offers, in campaigns and/or commercial campaigns.

In general, the collection of personal data is based on the performance and management of a contract, the execution of steps prior to entering a contract, the provision of a service at the request of the user, consent of the data subject, the adaptation of services to the needs of the data subject, notably for information, publicity and updates on products and/or services provided by THE NAVIGATOR COMPANY.

Data processing for said purposes is required for the provision of services by THE NAVIGATOR COMPANY. Such processing shall be made with your consent, except where THE NAVIGATOR COMPANY needs the data for the performance of a legal obligation that requires its processing, or the execution of a contract or preliminary steps.

3. DATA COMMUNICATION

Please be informed that your personal data may be transferred to subsidiaries wholly owned by THE NAVIGATOR COMPANY and identified in this link, which undertake to process such data solely and exclusively for complying with the above mentioned obligations.

4. PROCESSORS

Personal data of users may be processed by a reputed processor, engaged by THE NAVIGATOR COMPANY. Such services provider shall only process data for the purposes defined by THE NAVIGATOR COMPANY and in accordance with its specific instructions, in strict complying with rules governing the protection of personal data, information security and additional applicable legislation.

5. INTERNATIONAL DATA TRANSERS

THE NAVIGATOR COMPANY will process users’ data in the territory of the European Economic Space, and accordingly it does not anticipate that it will make international data transfers.

6. STORAGE PERIODS

THE NAVIGATOR COMPANY will only store users’ data during the period which is necessary to achieve the objectives for which the data was collected.

7. USERS’ RIGHTS

Users may, at any time and freely, exercise their rights of access, rectification, erasure, opposition, limitation and portability of their data, by request sent by e-mail to dpo@thenavigatorcompany.com, in accordance with the applicable legislation. Users are also informed that, should they consider that THE NAVIGATOR COMPANY has or may breach their rights under data protection laws, they may file a complaint with the National Data Protection Commission (CNPD) by phone (00351 213928400) or e-mail (geral@cnpd.pt).

8. REVOCATION OF CONSENT

Users’ acceptance of the processing and transfer of their data may be revoked, without retrospective effects. To revoke their consent, users may contact THE NAVIGATOR COMPANY by e-mail to dpo@thenavigatorcompany.com.

9. NECESSARY DATA

Data which is marked with an asterisk (*) in online forms available on digital platforms of THE NAVIGATOR COMPANY is necessary to achieve the legally or contractually established purposes. Accordingly, if the user does not provide such data, THE NAVIGATOR COMPANY may not fulfil his/her request.

10. AUTOMATED DECISIONS

THE NAVIGATOR COMPANY may make users profiles, which may enable taking automated decisions, taking into consideration personal characteristics, preferences, behavior history and location (in this case, to allow participating in promotions). In these cases, the use shall have the right to obtain human intervention in the decision, to express his/her opinion and to challenge the decision taken by THE NAVIGATOR COMPANY.

11. DATA PROTECTION MEASURES

THE NAVIGATOR COMPANY uses different technical and organizational measures in order to protect users’ personal data, including the use of secure servers, firewalls, and data encryption for applications and communications.

12. USE OF COOKIES

The cookie policy of THE NAVIGATOR COMPANY is available here.