Privacy Policy

July 14th, 2023

Privacy Policy of Crowe in Portugal

Crowe in Portugal comprising the companies Crowe & Associados, SROC, Crowe JV - Consultoria fiscal e de gestão, Lda., Crowe Accountify - Management Solutions, Lda. and Crowe Advisory PT, Lda., under the aegis of Crowe Global, does hereby inform you on its Privacy Policy, as well as on your own rights establishsing how your personal data is collected and used.

At Crowe we are committed to use your personal data exclusively for specify identified purposes. We have adopted several technical and organizational safety measures in order to protect the personal data made available to us against its disclosure, loss, misuse, alteration, process or unauthorized access, as well as against any other form of unlawfull processing.

1. Entity Responsible for Processing Personal Data

Each one of the Crowe companies identified below is responsible for processing the personal data transmitted to it, since it is up to each one of them to define which data is collected, the means of processing and the purposes for which they are collected, processed and/or used.

Crowe & Associados, SROC, com sede na Rua do Vilar, nº 235, 2º andar - 4050-626 Porto
Crowe JV - Consultoria fiscal e de gestão, Lda., com sede na Rua do Vilar, nº 235, 2º andar - 4050-626 Porto
Crowe Accountify - Management Solutions, Lda., com sede no Ed. Atlantis, Av. D. João II, n.º 44C, piso 1, esc. 1.4, 1990-095 Lisboa
Crowe Advisory PT, Lda., com sede no Ed. Atlantis, Av. D. João II, n.º 44C, piso 1, esc. 1.4, 1990-095 Lisboa

2. Personal data, data subject, categories and form of personal data collection

2.1 What is personal data?

According to the General Data Protection Regulation approved by EU Regulation 2016/679 of the European Parliament and of the Council of 27 April (hereinafter RGPD) personal data means 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, an identification number, location data, an online identifiers or to one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2.2 Who are the data subjects?

The client or potential client, natural person or the representatives of a legal person, to whom the personal data relates to and who enjoys or intends to enjoy the products or services offered by the companies of Crowe in Portugal.

2.3 What categories of personal data are processed at Crowe in Portugal?

Civil identification data	e.g. name, marital status, property status, married, gender, date of birth, signature
Tax identification data	e.g. Tax ID number, Tax office id code
Personal situation data	e.g. Emigrant, non-resident, non-habitual resident (Tax number and country), retired
Personal and contact information	Telephone contact, e-mail address, among others.
Data on purchase and services	History of services purchased.
Client history	Information and service purchase agreement; responses to satisfaction surveys; proposals received; campaign history; participation in events; history of complaints.

2.4 How and when is your personal data collected?

Your personal data may be collected under the following circumstances:

For the purposes of elaborating a proposal, awarding of services, entering into and executing contracts, in particular when purchasing a service to be provided by Crowe companies in Portugal.
Through the website www.crowe.pt or through any other Crowe website addresses, when you make (i) the request for proposal, (ii) the scheduling of meetings, (iii) when you complete an inquiry.
When you subscribe our newsletters, giving us your express and explicit consent for this purpose.
When you participate in events organized by Crowe in Portugal, or by other member companies of Crowe Global, and through express consent, you provide us with your personal data for the purposes indicated in the request for consent.
Through online searches, business prospecting and business development activities of legitimate interest to Crowe, using public information and contacts published on websites of companies publicly disclosed to a B2B relation to propose services related with the activity of Crowe and companies in part.

3. Basis, purposes and duration of the processing of personal data

The grounds justifying the processing of your personal data by Crowe in Portugal are as follows:

Consent: your personal data may be processed by means of a free, express, informed and explicit expression of your consent, according to which you accept, through a statement or unequivocal positive act, that your personal data is processed for the purposes indicated to.

Pre-contractual procedures and / or execution of service contract: your personal data may be necessary to clarify doubts, to present a proposal for contract handling, execution and management of services contracted or to contract with companies of Crowe in Portugal.

Compliance with legal obligation: your data may be necessary to fulfill a legal obligation to which the controller, in this case Crowe companies in Portugal, is subject to.

Legitimate interest of Crowe in Portugal: your personal data may also be used to develop the services available from Crowe in Portugal and to defend the lawfull protected rights and interests of Crowe in Portugal, which includes, notably, improving and monitoring the quality of services provided, e.g. analysis and processing of information regarding the quality and performance of the various means and processes of providing services, handling complaints or complying with a legal obligation of Crowe in Portugal.

Thus, Crowe in Portugal will process your personal data, according to the following:

Legal Ground	Purposes
Consent	We process the personal data of clients and potential clients, with their express consent, for commercial and marketing purposes, notably: marketing campaigns, events, promotions, information on new or current services, satisfaction surveys on the services provided by Crowe in Portugal.
Pre-contractual procedures and / or execution of service contract	We process personal data for the purpose of concluding, executing and managing the contract concluded between the client and Crowe in Portugal, notably for the preparation of a proposal and/or a contract; in the context of a complaint; for scheduling meetings; in the scope of the service provision.
Compliance with legal obligation	When processing is necessary to fulfill legal obligations, your personal data will be transmitted to official entities, for billing purposes, among others.
Legitimate interest	TWe process personal data based on a legitimate interest, notably for monitoring and managing the business; in the context of the client’s request for contact via website, social networks, telephone or e-mail; to reply to complaints made in response to requests / complaints made through the complaint portal or through direct contact with Crowe in Portugal and also when we need to contact the representative of a legal person in connection with the execution of a complaint, contract or pre-contractual diligence.

If the Client is a legal person, and in order to fulfill its contractual obligations, Crowe in Portugal needs to collect some personal data (name, email and telephone) of the representative or employee of that company, for the purposes of the proper performance of that contract.

In this case, the corporate Client must ensure that the data collected from its representatives / employees is collected and transmitted to Crowe in Portugal in a lawfull manner (under one of the grounds of lawfulness provided for in applicable legislation), providing to the data subject, its representatives or employees, the right to information on the processing of such data.

3.1 Personal data retention period

Crowe in Portugal keeps the personal data of the data subjects only for the period strictly necessary for the purposes for which such personal data was collected.

In certain cases, the law requires the retention of data for a specific period, in particular in the case of data related to the Tax Authority, which will be kept for 10 years, in accordance with current legislation.

We will also keep your data for as long as you have a contractual relationship with Crowe in Portugal. However, we may maintain your personal data for periods longer than the duration of the service contracts established, based on your consent, to ensure rights and duties relating to situations where there is a legitimate interest of Crowe in Portugal, always respecting the period necessary for the purposes for which such data was collected.

In the absence of a specific legal obligation, your data will only be processed for the necessary period to fulfill the purposes for which it was collected, and for and as long as there are legitimate grounds for its conservation by Crowe in Portugal.

Once the retention period has been reached, the personal data will be irrevocably anonymised (anonymised data may be stored) or destroyed in a secure way.

4. Transmission of your personal data

Crowe in Portugal transmits your personal data to the companies in it's group, identified above for the purposes described above, namely to provide services requested by you and for the dissemination of marketing actions with the provision of associated and complementary services.

Crowe's suppliers and / or service providers in Portugal are contractually subject to the same terms and conditions of processing of personal data as this one. In this sense, they are expressly prohibited from using, processing, transferring, divulging or registering the personal data of the subject for any purposes other than those for which they were specifically contracted, whether or not the express consent of the data subject applies, depending on whether it is data whose process is subject to the consent regime.

The above-identified Crowe companies in Portugal, depending on their area of activity, are bound to comply with certain legal obligations that entail the processing of personal data without the consent of the respective data subject. In this sense, compliance with these legal obligations may imply the need to process personal data, such as:

i) compliance with legal, regulatory and / or administrative provisions;

ii) compliance with legal obligations related to the reporting or responses to public authorities or agencies entrusted with the development of public functions;

iii) fulfillment of obligations related to statistical purposes;

(iv) preventing and combating fraud and / or money laundering and financial crimes.

5. Link to other websites

Please be advised that Crowe in Portugal is not responsible for the privacy practices of third parties whose websites have a hyperlink on our website and it cannot also guarantee or be responsible for any reason for the accuracy or authenticity of the information therein. Therefore, we encourage you to carefully read the privacy policies of any other website linked to the Crowe website.

Crowe does not guarantee the accuracy, completeness or authenticity of the information contained in any hyperlink or other Internet site. Personal data entered on other Internet sites that are linked to the Crowe site will be of the sole responsibility of the data subject or of the owner of the concerned site.

6. Rights of the personal data subjects and response to the requests of the personal data subjects

Crowe in Portugal guarantees the applicability and fulfillment of all rights of the subject of the personal data foreseen in the GDPR and the legislation in force.

6.1 Right of access

You have the right to obtain confirmation from Crowe in Portugal that your personal data is being processed and, if so, the right to access to your personal data and its processing, for example, may require an exact copy of your compilation and request additional information about the process performed.

6.2 Right of rectification

You also have the right to obtain, without undue delay, from Crowe in Portugal the rectification of inaccurate personal data concerning you, including the right to correct or complete your personal data.

6.3 Data erasure or “Right to be forgotten”

You may exercise the right to request the erase of your personal data by Crowe in Portugal and without undue delay provided that: (i) personal data are no longer necessary for the purposes for which they were processed; (ii) upon withdrawal of consent and no other valid basis for its conservation; (iii) when oppossing to the processing and there are no prevailing legitimate interests, to evaluate case by case that justifies the processing; (iv) personal data must be erased under a legal obligation to which Crowe in Portugal is bound to; (v) the personal data has been treated unlawfully, as well as in other cases legally foreseen.

The right to erasure does not apply where the processing of personal data is necessary to provide the exercise of freedom of expression and information; to fulfill a legal obligation that requires processing; for reasons of public interest, for public health motives; for the purposes of archiving of public interest, for scientific, historical or statistical research, where the exercise of the right to erasure is likely to seriously and irreversibly impair the attainment of the objectives of the same processing or, exercise or defense of a right in the course of legal proceedings.

6.4 Right of portability of data

When the processing of personal data is based on the express consent of the data subject or for the performance of a contract or is carried out by automated means, the subject of the personal data is entitled to receive the personal data relating to him/her and which it has been provided to Crowe in Portugal in a structured, current and automatic reading format and the right to transmit such data to another controller (if technically possible), and if the processing is based on consent or a contract and if the process is performed by automated means.

6.5 Right to withdraw consent

The subject of the personal data may at any time change his consent, restrict it to certain types of process or withdraw its, however, withdrawal of consent does not compromise the lawfulness of the previous process made on the basis of a prior consent . Therefore, in the case of withdrawal of consent, your personal data will no longer be dealt by Crowe in Portugal unless, under the terms of the law, there is another ground that can validly justify such processing.

6.6 Right to object

You shall have the right to objecto to processing your personal data at any time, whenever there are no grounding and legitimate reasons for the processing which prevail over your interests, rights and freedoms, or for the purposes of declaration, exercise or defense of a right in a judicial procedure.

It should also be added that you have the right to object at any time to the processing of your personal data for the purposes of direct marketing, including the definition of profiles that is related to such direct marketing / marketing. In this case, Crowe in Portugal undertakes to cease processing your personal data for this purposes.

6.7 Right to restrictions of processing

In certain situations you have the right to obtain from Crowe in Portugal the limitation of the processing of your personal data, in particular if (i) you challenge the accuracy of your personal data during a period that allows Crowe in Portugal to verify its accuracy, in cases where personal data are no longer necessary for the purposes of processing but are required by the data subject for the purposes of declaration, exercise or defense of a right in a judicial procedure and even when opposing the processing, the motives of legitimate interest of Crowe in Portugal prevail, as well as in the other cases legally foreseen.

6.8 Right not to be subject to any automated decision

You have the right not to be subject to any decision made solely on the basis of automated processing of your personal data, including the definition of profiles that have legal effects or significantly affect you in a similar way.

6.9 Exercise of your rights

You may exercise your rights, free of charge, except in the case of a manifestly groundless or excessive request, in which case a reasonable fee may be levied in consideration of the costs generated by your application.

We will respond to your requests within a maximum delay of 30 days, except in cases of more complex requests.

You can exercise your rights through the following addresses:

Horwath & Associados, SROC, Lda.
- Letter: Rua do Vilar, nº 235, 2º andar - 4050-626 Porto
- E-mail: [email protected]

Crowe JV - Consultoria Fiscal e de Gestão, Lda.
- Letter: Rua do Vilar, nº 235, 2º andar - 4050-626 Porto
- E-mail: [email protected]

Crowe Advisory PT, Lda.
- Letter: Ed. Atlantis, Av. D. João II, n.º 44C, piso 1, esc. 1.4, 1990-095 Lisboa
- E-mail: [email protected]

Crowe Accountify - Management Solutions, Lda.
- Letter: Ed. Atlantis, Av. D. João II, n.º 44C, piso 1, esc. 1.4, 1990-095 Lisboa
- E-mail: [email protected]

However, if you are not satisfied with our response after exercising any of these rights, you have the right to complain to the National Data Protection Commission (CNPD – Comissão Nacional de Proteção de Dados) regarding matters relating to the processing of your data.

7. Procedural and safety measures

Crowe in Portugal makes use of appropriate physical, technological and organizational security measures to protect your personal data in order to protect the personal data that is made available to us against its disclosure, loss, misuse, alteration, processing or access, authorized, as well as against any other form of unlawfull processing.

Therefore, Crowe in Portugal applies technical and organizational measures to ensure a level of security appropriate to the risk of keeping the personal data in archive and during the transmission thereof.

Crowe in Portugal has a computer system with the capacity to withstand, with a high level of confidence, accidental events or malicious or illegal actions that compromise the availability, integrity and confidentiality of the personal data stored or transmitted.

8. Cookies

Crowe uses 'cookie' technology to enable you to track the routes you have taken to this site, to help Crowe to record user activity on this site and to evaluate and improve the site to make it more useful for Yes. Through this technology, Crowe does not record information about individual users. Do not forget that you can preset your browser not to accept or to reject cookies or to warn you if cookies are sent.

What are cookies?

Cookies are small text files stored on the user's computer when visiting certain websites. In some cases, they are eliminated after the visit. In others they are kept for later visits. The use of cookies on accessing websites is a common practice and the various browsers allow each user to refuse their use, as well as eliminate those that have already been created.

Crowe websites and some of their applications may use cookies to improve user navigation on Crowe's various websites, as well as better understand their behavior, tastes and interests (globally). It is thus possible to improve the use and visualization of websites, making it simpler and faster, enabling a more interesting and dynamic browsing experience.

You can learn how to inhibit cookies in your browser by following the instructions below. You can also learn more about Crowe's use of cookies. Note that important features of Crowe's websites and applications may stop working while cookies are locked.

Manage cookies in multiple browsers

To disable cookies on your browser you can follow these instructions. It should be noted that, given the high number of browsers and their versions, these instructions are not exhaustive. You can also consult the specific help pages of your browser or a generic page on this topic.

All About Cookies:

http://www.aboutcookies.org/default.aspx?page=1

Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Chrome:

https://support.google.com/chrome/answer/95647?hl=en

Internet explorer:

http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-10

Types of cookies

What types of cookies are used and why?

Cookies on the Crowe website and online services fall into the following categories:

Category 1 - essential cookies for the provision of service

These cookies are essential to enable you to use Crowe's websites and their features, as well as take advantage of their features such as accessing secure areas and exclusive access content, etc.

Category 2 - primary service analysis cookies

These cookies collect information about how Crowe's websites and services are used, such as which pages are most visited. This information can be used to help Crowe improve the pages and make them easier to use. These cookies also let you know if visits to Crowe websites come from campaigns that Crowe Group companies carry out. These cookies do not collect information that identifies the user since all the information collected is aggregated into non-personal indicators and therefore anonymous and is intended only for the purpose indicated above. They are used only for internal purposes.

Category 3 - performance and functionality cookies

These cookies allow the Crowe website to recognize the users' choices while they use the services of Crowe Group companies, such as:

Performance cookies - collect information about the visit and use of the site; for example, which pages are visited most frequently and if webpage error messages are sent. These cookies do not collect information that may identify a user. All information collected by these cookies are anonymous and are used only to improve the operation of the site.

Functionality Cookies - allow a site to remember user choices (such as name, language, or region) and provide enhanced personal features. These cookies are not able to track browsing activity on other sites. We do not collect user information that may be used for advertising or to remember which other sites you have visited other than ours.

The information that these cookies collect does not allow you to identify yourself personally nor does it allow you to monitor your browsing activity on non-Crowe websites. They are used only for internal purposes.

Category 4 - Advertising Cookies and Social Media

Advertising and Social Media Cookies are used to (1) display advertisements more relevant to the user and in accordance with their interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of an advertising campaign; and (4) perceive the behavior of the user after seeing certain advertising. Cookies are usually placed on demand from ad networks with the permission of the site operator. They remember that the user has visited one site and will often be linked to the functionality of the site provided by the other organization. This may affect the content and messages that the user will see. If the user does not allow any of these cookies, you may not be able to use or view these sharing tools or reproduce certain videos on our site.

Crowe does not use Targeting Cookies to promote our users.

Whenever you want more detailed information about the cookies used in our site we request your contact contact through the email form.

9. Using Crowe website

9.1 With regard to the use of the materials on the Crowe website, information, text, figures or graphics contained therein, may only be used for your personal use, and never for commercial purposes, nor shall reproduce, modify, transmit, authorize or publish such information, text, figures or graphics, in whole or in part, for any purpose without the prior written consent of Crowe.

9.2.With respect to the use and risk of its use, Crowe specifically disclaims any liability for direct, indirect, incidental, consequential or special damages arising out of or in any way connected with your access to or use of this site, affecting your computer equipment, or your confidence in the information obtained through the Crowe website.

9.3.The information on the website should be seen in its information section. Although Crowe's efforts to keep the content up-to-date and accurate, these may contain inaccuracies, typographical errors or out-of-date, and may be changed at any time without Crowe being required to give prior notice.

10. Privacy Policy Update

Crowe in Portugal reserves the right to update this policy at any time, according to the legal requirements and / or needs of the commercial activity. You are hereby invited to visit from time to time this page in order to verify our privacy policy.

This Privacy Policy was updated on July 14th, 2023.