Privacy Policy

We are concerned with protecting your privacy, ensuring that your personal data is processed in accordance with the applicable legal provisions on data protection, namely the General Data Protection Regulation (“GDPR”)1 and Law No. 58/2019, of August 8, which ensures the implementation of the GDPR in the Portuguese legal system.

We therefore advise you to read this Privacy Policy, which covers the following topics:

The data controller
What personal data is collected and processed
How personal data is obtained
How personal data is used
On what basis we use personal data
How long we keep personal data
Who we share personal data with
How we protect personal data
To which countries we transfer personal data
Your rights in relation to your personal data

The data controller

Linto & Frade dos Santos - Sociedade de Advogados, SP, RL, with address at Rua 31 de Janeiro, 99B, 2500-118 Caldas da Rainha and registration number 5/24 with the Lisbon Regional Council of the Portuguese Bar Association (hereinafter referred to as LFS Advogados), will be responsible for collecting and processing your personal data. Linto & Frade dos Santos - Sociedade de Advogados, SP, RL decides which data is collected, the means of processing and the purposes for which your data is used.

If you have any questions about how we process the personal data you have provided us with, would like any clarification on this document or would like to exercise any of the rights mentioned in this document, you should send us an e-mail to geral@lfsadvogados.pt or, alternatively, write to us at: Rua 31 de Janeiro, 99B, 2500-118 Caldas da Rainha, Portugal

LFS Advogados would also like to inform you that a Privacy Officer has been appointed, who will be responsible for, among other duties, (i) monitoring the compliance of data processing with the applicable rules, (ii) being a point of contact with the holders of personal data to clarify issues related to the processing of their data by LFS Advogados, (iii) cooperating with the National Data Protection Commission (hereinafter referred to as “CNPD”), and (iv) providing information and advice to LFS Advogados on its obligations in the field of privacy and data protection.

If you wish to contact our Privacy Officer, you should send a written communication to the contacts listed in this policy.

What personal data is collected and processed

“Personal data” means any information of any nature and on any medium relating to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, for example by name, identification number, location data, an electronic identifier or other elements that make it possible to identify that natural person, such as specific elements of their physical, physiological, genetic or economic identity.

We may collect your personal data during the provision of our services, through the use of our website, when you contact or request information about LFS Advogados or as a result of contacts you may have with any of our employees or clients.

The personal data processed by LFS Advogados includes:

Identifying information, such as your name (including prefix or title), your company, title or position and your connection to a particular person;
Contact details, such as postal address, e-mail address and telephone numbers;
Financial information, such as tax identification number or payment methods;
Technical information, such as data about your visits to our website or in relation to materials and communications sent by LFS Advogados electronically;
Data you provide to us for scheduling meetings or attending events, including accessibility restrictions;
Background information provided by you or gathered as part of the client acceptance process, including financial, business administration and marketing details;
Information relating to processes;
Personal data obtained by LFS Advogados on its own behalf or generated by our clients as part of the provision of our services, including special categories of data;
Data obtained through the use of our website, namely cookies; and
Any other data you may provide us with.

How we obtain personal data

Your data may be collected as part of the procedure for contracting our services, extending to third parties as necessary in the course of providing legal services.

Through our IT tools and applications, including our website and electronic communications sent to LFS Advogados
When you provide them to us, or interact directly with us, such as through contacts with our employees
And through other means and sources, such as by using publicly available means to keep your data up to date.

How we use your personal data

LFS Advogados collects and processes your personal data in various ways, namely through the use of our website and our services. We use your data:

To provide our services, which may include processing the personal data of third parties on behalf of our clients;
To provide information that you request;
To promote our services by sending you news and publications and/or newsletters;
To promote events and/or seminars organized or co-organized by our office;
To guide and direct our relationship with you;
To comply with tax legislation and legislation on money laundering and terrorist financing, as well as to verify conflicts;
In the pursuit of our legal, regulatory and risk management obligations, including the exercise of rights or the defense of legal claims;
To provide and improve our website, including by auditing and monitoring its use;
For recruitment purposes.

On what basis we use your personal data

We use your personal data lawfully, fairly and transparently on the following grounds:

Upon your consent, in writing, orally or by validating an option, and in advance and if such consent is free, informed, specific and unambiguous;
In the steps prior to the formation of the contract or the declaration of the negotiating will, and in the execution of contractual obligations, namely through the provision of legal services;
To bring or defend legal actions or legal proceedings;
To comply with regulatory and legal obligations;
For legitimate business purposes. Please see “How personal data is used” for more details.

The communication of your personal data is entirely voluntary, however it is a mandatory requirement for the provision of our services.

How long we keep personal data

LFS Advogados processes and stores your personal data according to the purposes for which it is processed or whenever there is a specific legal and/or regulatory obligation to store it.

For example, there are cases in which the law requires data to be processed and stored for a minimum period of time, namely for (i) 10 years for data required for information to the Tax Authority for accounting or tax purposes or data relating to commercial bookkeeping; (ii) 7 years for the purpose of combating money laundering and terrorist financing; or (iii) during the term of office, plus a period of 20 years for data processed within the scope of the provision of legal services.

Likewise, LFS Advogados will retain data in accordance with the limitation periods for bringing legal proceedings.

Once the maximum retention period has been reached, your personal data will be irreversibly anonymized (the anonymized data may be retained) or securely destroyed.

Who we share your personal data with

We may share your personal data with third parties in accordance with the contractual and legal provisions in force, including:

Competent governmental and judicial authorities, such as the Courts or the Tax Authority;
Our lawyers, consultants and professional auditors;
Suppliers with whom LFS Advogados contracts certain support services, such as word processing, translations, copies, document reviews;
IT service providers;
Third parties involved in the course of the services we provide to clients and with their prior consent, such as lawyers, enforcement agents, local consultants and others;
Entities involved in or co-hosting events or seminars.

Whenever your data is transmitted to subcontractors, LFS Advogados will take the necessary contractual measures to ensure that the subcontractors respect and protect your personal data, only using subcontractors that provide sufficient guarantees that they have implemented appropriate technical and organizational measures for this purpose.

Where necessary, or for the reasons set out in this policy, personal data may also be shared with regulatory authorities, courts and official bodies. Although unlikely, we may be required to disclose your data to comply with legal requirements. We will make reasonable efforts to notify you prior to such sharing, unless we are legally prevented from doing so.

If, in the future, we reorganize or transfer all or part of our business, we may need to transfer your personal data to new entities connected to LFS Advogados or to third parties through which LFS Advogados' services will be provided.

LFS Advogados may use social networks such as LinkedIn, Instagram and Facebook. If you are a user of these services, you should review their privacy policy for more information on how they handle your personal data.

LFS Advogados does not sell, rent or otherwise make personal data commercially available to third parties.

How we protect your personal data

We use a variety of technical and organizational security measures to help protect your personal data against unauthorized destruction, loss, alteration, disclosure and access, in accordance with applicable data protection laws.

To which countries we transfer your personal data

In order to provide our services, it may be necessary to transfer your personal data to locations outside Portugal - this will only happen if the nature of the services requires it.

Therefore, LFS Advogados may have to transfer your personal data to a third country outside the European Economic Area (“EEA”) and which is not on the list of countries that the European Commission has already considered to have adequate levels of personal data protection. In such cases, LFS Advogados will ensure that data transfers are carried out in strict compliance with the applicable legal rules, namely Chapter V of the GDPR.

Your rights concerning your personal data

As a data subject processed by LFS Advogados, you may, at any time, within the legal limits, exercise the rights identified below by sending a written communication to LFS Advogados at geral@lfsadvogados.pt .

Right of Access - the right to obtain confirmation of what personal data is being processed and information about it, such as the purposes for which it is being processed, the retention periods, etc;
Right of Rectification - the right to request the rectification of inaccurate personal data or to request that incomplete personal data be completed, such as address, VAT number, e-mail address, telephone contact details, etc;
Right to erasure of data or “right to be forgotten” - the right to have your personal data erased if there are no valid grounds for keeping it, such as when LFS Advogados has to keep the data to comply with a legal obligation or because legal proceedings are underway;
Right to Portability - the right to receive the data you have provided us with in a commonly used, machine-readable digital format or to request the direct transmission of your data to another entity that becomes the new controller of your personal data, but in this case only if technically possible;
Right to Withdraw Consent - the right to withdraw your consent at any time to the processing of personal data, such as the processing of data for marketing purposes, without compromising the lawfulness of the processing carried out on the basis of the consent previously given;
Right to object - the right to object to data processing at any time, provided that there are no legitimate interests that prevail over your interests, rights and freedoms, such as defending a right in legal proceedings; and
Right of Limitation - the right to request the limitation of the processing of your personal data, in the form of: (i) suspension of processing or (ii) limitation of the scope of processing to certain categories of data or processing purposes.

The aforementioned communication must contain your full name, a copy of your ID card or other official identification document, or that of the person representing you, in accordance with the applicable legal terms, the address for notification purposes and the specific request.

The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged considering the costs that may be involved.

The information must be provided in writing, but may be provided orally if requested. In this case, LFS Advogados must verify your identity by means other than oral.

As a rule, requests must be answered within a maximum of 30 days, unless the request is particularly complex or there is a multiplicity of requests.

In addition to the aforementioned rights, LFS Advogados informs you that you also have the Right to Complain, i.e. the right to submit a complaint to the supervisory authority, the CNPD (www.cnpd.pt), if you consider that LFS Advogados has not complied with the requirements of the GDPR or applicable national legislation with regard to your personal data.

In addition, you have the right to take legal action, without prejudice to any other administrative or extrajudicial remedy against LFS Advogados or its subcontractor, if you consider that your rights have been violated.

Please note that LFS Advogados will occasionally update this Privacy Policy. We ask that you periodically review this document to keep up to date.