Data Protection and Privacy Policy

We are fully committed to ensuring that any Personal Data is processed not only in an absolutely responsible manner but also in compliance with applicable data protection laws.

This Data Protection and Privacy Policy (“Privacy Policy”) provides information on how Vinci Group Companies process Personal Data of users who browse the website www.vinci-energies.pt or other websites belonging to the Vinci Group (“Website”) in accordance with applicable legislation regarding the protection of personal data and privacy.

A. Responsible for Processing the Data on the Website

VINCI ENERGIES PORTUGAL, S.A., with head office at Av. Dom João II 44 C Piso 5, 1990-095 Lisbon (hereinafter referred to as “VINCI ENERGIES”), individually or together with other companies in the Vinci Group, are responsible for processing your personal data for the purposes indicated in this Privacy Policy.

B. Personal Data, Handling of Personal Data and Owner of Data

Personal Data are all information and/or elements which, regardless of their means, may identify you or make you identifiable, directly or indirectly, to VINCI ENERGIES, in particular by reference to an identifier, such as a name, an identification number, your location data and/or identifiers by electronic means or to one or more elements specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

Processing of Personal Data means the operation or set of operations carried out on Personal Data of Data Subjects, by automated or non-automated means, from the collection of the information until its destruction. Within this cycle, among others, are included the registration, organization, structuring, conservation, adaptation or alteration, recovery, consultation, use, disclosure by transmission, dissemination or any other form of availability, comparison or interconnection, limitation, erasure.

Users of the Website will be qualified as Data Subjects, without limitation, investors, customers, and potential customers, suppliers, employees, and candidates for employees, members of corporate bodies, participants, visitors, or any other third parties who browse the Website for its various purposes.

C. Personal Data We Collect, For What Purposes and Legal Basis

The functionalities made available on the Website mean that VINCI ENERGIES processes Personal Data for specific, explicit purposes. In some cases, you will not be required to share your Personal Data, but if you choose not to share, VINCI ENERGIES may not be able to provide the services or products you wish to provide, to secure certain specialized features, or to respond effectively to any questions you may have.

Website Management

When you visit our Website, without providing us with additional information through our forms, we process your Personal Navigation Data as to your electronic identifier, connection start date/time, connection end date/time, web browsing location, URL visited, social network address or hostname. Without this Personal Data, we cannot communicate with the browser and display our Website on your device. This Personal Data is processed based on the performance of the contract whose terms are governed by the Terms and Conditions available on the Website.

Contact Management

We collect your Personal Data, such as your name, contact, and e-mail address, when you contact us through the Website and use it to answer your questions, complaints, or any other matter you wish to clarify with VINCI ENERGIES. The processing of your Personal Data is based on your unambiguous consent when you submit the form and contact us.

Recruitment and Selection of Workers

On the Website we may also collect your Personal Data when you submit the spontaneous application form for our analysis or intend to apply for the internal Selection and Recruitment process promoted by VINCI ENERGIES. We may process your Personal Data as the date of application, interview results, test/admission results, curriculum vitae or qualification certificate, Personal Data that we processed based on your consent when submitting the application form.

In cases where you apply for an internal Selection and Recruitment process promoted by VINCI ENERGIES, and you are not selected, we may continue to process your personal data in a compatible manner, for the purposes of the remaining internal Selection and Recruitment processes and/or for opportunities that may arise.

Commercial and Marketing Activity

Your Personal Data may also be processed in the context of our commercial and marketing activities when you subscribe to our newsletter to receive information about our products or services. For this purpose, it will be possible to collect your telephone number/mobile number, e-mail address, date/time of contact, place of origin of the contact or preferred contact, Personal Data, which will be processed on the basis of your express consent.

D. Sharing your Personal Data

Entities providing services to VINCI ENERGIES (“Data Processors“):

Your personal data may be provided to companies entrusted with providing services to VINCI ENERGIES under a written contract that binds the Data Processors only to process your Personal Data for the purposes set out in this Privacy Policy, and they are not authorized to process them, directly or indirectly, for any other purpose, for their benefit or a third party.

Other “Controllers” or “Third Parties” with whom VINCI ENERGIES may share your Personal Data:

If there is a legitimate interest in sharing your Personal Data within the group, VINCI ENERGIES may transmit your Personal Data to other companies within the Vinci Group for internal administrative purposes and guarantee that they have processed your Personal Data in accordance with this Privacy Policy.

At your request and with your consent, your Personal Data may also be shared with other entities with whom VINCI ENERGIES may not have a direct business relationship.

In compliance with legal and/or contractual obligations, Personal Data may also be transmitted to judicial, administrative, supervisory or regulatory authorities and to entities that lawfully carry out data collection actions, fraud prevention, and combat actions, market or statistical studies in an anonymous way.

E. Third Party Websites

We provide hyperlinks on the Website that allow access to other Third Party websites over which VINCI ENERGIES has no management control and assumes no responsibility.

When you choose to follow VINCI ENERGIES on social networks, your personal data may be processed by the respective management entities in accordance with their privacy policies, which we recommend you read before browsing the websites.

F. Retention Period of Your Personal Data

Your Personal Data will be kept for the period necessary for the performance of the purposes described in this Privacy Policy. In some cases and exceptionally, VINCI ENERGIES may be required to retain your Personal Data for a longer period:

– To fulfil legal obligations applicable to VINCI ENERGIES;

– Through contractual obligations to VINCI ENERGIES or other companies within the Vinci Group, to which limitation periods may be added under current legislation;

– In the event of any dispute, misdemeanour or legal action, up to 6 months after the final judgment has been passed; or,

– Guidelines issued by the competent data protection authorities.

G. How your Personal Data will be processed

During the retention period of your Personal Data, VINCI ENERGIES ensures that your Data is processed in accordance with this Privacy Policy.

For the security of your Personal Data, they will be processed in the context of the purposes identified, in accordance with the Vinci Group’s internal policy and rules and using appropriate technical and organisational measures to promote their security and integrity, in particular with regard to unauthorised or unlawful processing and the accidental loss, destruction or damage of your Personal Data.

Without limiting this, VINCI ENERGIES uses logical and physical security requirements and measures to ensure the protection of your Personal Data by preventing unauthorised access, ensures that the information is stored on secure computers in a closed and certified information centre and that it is encrypted whenever possible, implements audit and control procedures to ensure compliance with the Group Vinci security and privacy policies and periodically reviews our security policies and procedures to ensure that your systems are safe and secure.

However, because the transmission of information over the Internet is not completely secure, VINCI ENERGIES cannot guarantee the security of your Personal Data when transmitted over an open network.

VINCI ENERGIES does not sell, rent, distribute, commercially or otherwise make your Personal Data available to any third party except as identified in this Privacy Policy. VINCI ENERGIES preserves the confidentiality and integrity of your Personal Information and protects it in accordance with this Privacy Policy and all applicable laws.

H. International Transfers of Personal Data

VINCI ENERGIES may transfer your Personal Data outside the European Economic Area (“EEA”) and to countries which may not provide the same level of protection as that provided in the European Union.

In such cases, we may transfer your Personal Data for internal administrative purposes to Vinci Group companies when they are part of the Intra-Group Agreement on Personal Data Protection (“IGA”), ensuring the international transfer of Personal Data in accordance with the applicable legislation on personal data and privacy. The IGA parties are qualified as data controllers, or data controllers and processors, in accordance with applicable legislation.

We may also transfer your Personal Data on the basis of an adequacy decision or standard data protection clauses approved by the European Commission – standard contract clauses for Controllers (2004/915 /EC) and standard contract clauses for Data Processors (2010/87/EU).

Where none of the above options apply, but the law nevertheless allows such a transfer, for example, if it is necessary for the declaration, exercise or defence of a right in a legal proceeding.

Details about the transfer of your Personal Data to third countries, the measures taken to ensure the transfer, as well as a copy of the measures applied for that purpose, can be obtained by contacting us through the contacts provided in this Privacy Policy.

I. Cookies

We use cookies and similar technologies to ensure the access, operation, and adaptation of the Website to your preferences and those of third parties so that our Website functions properly, to customize content and advertisements based on your browsing habits. Whenever you use the Website, VINCI ENERGIES processes your Personal Data in accordance with our Cookie Policy, which you can consult HERE.

We encourage you to read our Cookie Policy to learn more about the processing of your Personal Data in the context of this activity.

J. “Minors” Privacy

The Website is intended for adults and not for children. With the exception of data provided by a Minor’s parent or guardian, VINCI ENERGIES does not voluntarily collect Personal Data from Data Subjects who are under the age of 18.

Should VINCI ENERGIES discover that it has inadvertently collected Personal Data from a Minor under the age of 18, it will immediately erase the records containing the Minor’s respective information.

K. Your rights and how to exercise them

As a Data Subject, and where applicable, data protection and privacy laws grant you the following rights:

Right to Information: You have the right to obtain clear, transparent and easily understandable information about how VINCI ENERGIES uses your Personal Data and what your rights are. It is because of this right that VINCI ENERGIES makes these Privacy Policies available to you.

Right of access: You have the right to obtain information about what Personal Data VINCI ENERGIES processes (if they are being processed) and certain information (similar to that provided in this Privacy Policy) about how your Personal Data is processed. This right allows you to confirm how we process your Personal Data in accordance with applicable law.

However, this right is not absolute, and VINCI ENERGIES may refuse to provide the information requested where, in order to do so, it is necessary to disclose another person’s Personal Data or the information negatively impacts their rights.

Right of rectification: If your Personal Data is incorrect or incomplete (for example, if your name or address is incorrect), you may ask VINCI ENERGIES to take the necessary and reasonable steps to correct it.

Right to erasure your Personal Data: This right is also known as the “right to be forgotten” and simply allows you to request the deletion or erasure of your Personal Data, provided that there are no valid grounds for VINCI ENERGIES to continue to use them or their use is unlawful. This is not a general right to erasure, as exceptions are permitted (e.g. where such Personal Data are necessary for the defence of a right in a legal proceeding).

Right to limitation of processing: You have the right to “block” or prevent future use of your Personal Data while VINCI ENERGIES assesses a request for rectification or as an alternative to erasure. Where the processing is limited, VINCI ENERGIES may still store your Personal Data but may not use it for other purposes.

Right to data portability: You have the right to obtain and reuse certain Personal Data for your own purposes in various organizations. This right applies only to the Personal Data you have provided to VINCI ENERGIES and which are processed with your consent and those processed by automated means.

Right to object: You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time, for the legitimate interest of VINCI ENERGIES or Third Parties. VINCI ENERGIES may continue to process such Personal Data if it can provide evidence of ‘overriding legitimate reasons for the processing that override its interests, rights and freedoms’ or if such Personal Data is necessary for the establishment, exercise or defence of a right in a legal proceeding.

Right to complain: you also have the right to complain to the competent supervisory authority – in Portugal, the Comissão Nacional de Proteção de Dados (“CNPD”) – or obtain redress and/or compensation if you consider that the processing carried out violates your rights and/or applicable personal data protection and privacy legislation.

You may at any time, in writing, exercise the rights enshrined in data protection and privacy legislation by e-mailing privacidade.axianspt@axians.com.

Alternatively, you may exercise these rights by post, in the care of VINCI ENERGIES, to the following address:

Av. Dom João II 44 C Piso 5, 1990-095 Lisboa.

L. Changes to this Data Protection and Privacy Policy

VINCI ENERGIES may at any time amend this Privacy Policy in accordance with new legal or regulatory requirements or update it as appropriate. We encourage you to review this Privacy Policy regularly to check the most current versions.