The protection and confidentiality of personal data constitutes a fundamental commitment of eProseed within its business activities.
This document contains information on how eProseed collects, uses and processes personal information data regarding its customers when doing business with us and the users of the eProseed webpage (www.eproseed.com), when contacting us or applying to our career opportunities.
The Controller - which is the entity responsible for processing personal data - is the company of the eProseed group which provides the service or supplies the product and who in that context determines which data is collected and how it is processed.
All eProseed companies’ contacts can be found in the end of this document.
- Data Protection Data Officer
eProseed appointed a Data Protection Officer (DPO), who is responsible for monitoring the compliance with all data protection regulation, including the GDPR, and with the policies of the Controller or processor in relation to the protection of personal data.
The DPO also provides advice and guidance where requested regarding data protection, cooperates with the supervisory authority, and acts as the contact point for the supervisory authority or for customers on issues relating to processing of personal data.
You can contact the DPO through the following address:
Att: Data Protection Officer (DPO)
rue de l´Industrie, 13,
Or by email: firstname.lastname@example.org
- What personal information do we collect?
“Personal information” or “personal data” means any information relating to an identified or identifiable natural person, the data subject. 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 identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal information can be collected from users of eProseed’s webpage when applying for a career with us or throughout our business activities when contacting us or by subscribing our products and services. We therefore process personal data like names, addresses, email addresses or phone numbers.
- On what grounds is the personal data processed by eProseed?
The personal data can be processed with the following grounds:
- For the negotiation and execution of contracts, whether of employment or of supply of products and services.
- The processing of data collected may also be based on eProseed's legitimate interest, for example, for fraud prevention, to ensure the security of its webpage and internal network or to improve the services provided.
- For compliance with legal obligations to which eProseed is obliged, such as compliance with accounting, tax or social security obligations.
- Personal data may also be processed when you have consented for that purpose, which may be withdrawn at any time.
- With what purpose do we process your personal data?
Your personal data is processed by eProseed only for the following purposes:
- Provision of services and products: for providing our IT solutions and consultancy services. The processing of this data does not include automated processing or profiling.
- Billing, payment and accounting records: All data necessary to manage invoices, payments and to keep accounting records.
- Contact management, information and complaints: eProseed will also process data to manage the relationship with its customers, respond to complaints and improve the experience of the services provided.
- Marketing communication of products and services: eProseed may email you advertising communications about its products and services.
- Subcontracting the processing of personal data
eProseed may use subcontractors (Processors) which will also process your personal data, and these entities are obliged to develop the technical and organisational measures appropriate to the protection of data and to ensure the protection of the data subject’s rights.
- Under what circumstances can your personal data be transmitted to other entities, sub-contractors or third parties?
Your personal data can be transmitted to Processors so that they can use it for and on behalf of eProseed. In that case, eProseed shall take all necessary contractual measures to ensure that the Processors respect and protect the client’s personal data.
The data can also be transmitted to third parties as affiliate companies within eProseed group, companies with which eProseed has built partnerships, when the client has given his consent or entities to which data has to be transmitted due to legal requirements, such as the tax authorities.
- Under what circumstances can eProseed transfer your data to a third party outside the EU?
eProseed may have to transfer your personal data to a third party country outside the European Union and which is not part of the list of countries that the EU considers to have adequate levels of protection of personal data. Under these circumstances, eProseed will ensure that any data transfers are done in strict compliance with applicable legal regulations.
- What are the time limits for the processing and storing of personal data?
As long as we have you as a client of eProseed we will process and store your personal data and data regarding the use of our Services.
There are cases where the law requires the processing and retention of data for a minimum period of time (e.g. 10 years for information regarding accounting for tax purposes). But where there is no specific legal obligation, then the data will be processed and stored only for the necessary period, for the fulfillment of the purposes that motivated its collection and preservation and always in accordance with the law, the guidelines and decisions of the National Data Protection Commission (CNPD).
Whenever you cancel all your services with eProseed, we will retain your personal data for a period of 6 months, excepts when the law requires to retain a lesser or longer period.
- What rights do you have?
The law confers the data subject the following rights:
- Right of access: Right to obtain confirmation of what personal data is being processed and information about it, such as the purposes of the processing, the retention periods, among others;
- Right to rectification: Right to request rectification of your personal data whenever it is inaccurate or request to complete incomplete personal data;
- Right to erasure data or "right to be forgotten": Right to obtain the erasure of your personal data, provided that there are no valid grounds for its retention, such as cases where the data has to be retained to comply with a legal obligation;
- Right to restriction of processing: Right to obtain from the controller restriction of processing or limitation of the scope of processing to certain categories of data or processing purposes;
- Right to portability: Right to receive the data you have provided to us in digital format of current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new person responsible for your personal data, if technically possible;
- Right to object: Right to oppose or withdraw your consent at any time to a data processing, such as in the case of data processing for marketing communications, provided that there are no legitimate interests prevailing over your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims;
- Right to complain: the right to lodge a complaint before CNPD.
Cookies are small data files that are installed on your computer or any other device when you visit a website and are used to record information about your browsing in order to facilitate and make it more enjoyable. These files are stored in the user's terminal, contain anonymous data, and do not damage your computer. They are used to record user preferences, such as the selected language, access data or page customization, either during navigation or on future visits.
The web server records and stores only the information by default usually recorded by the server: the Internet Protocol address by which the user had internet access; the date and duration of the access to eProseed's webpage; the website address from which the user accessed directly to the eProseed webpage.
The cookies used on eProseed's webpage are the following:
- Analytical cookies: these cookies make it possible to collect statistical data about website usage and to obtain information about how to improve our offering. The information transferred (e.g. IP address and browser type) is saved and processed by Google Analytics. This software is dedicated to the statistical monitoring of website traffic.
The information collected through eProseed's webpage aims to calculate the number of visits to the different pages that compose the webpage, which will allows eProseed to make it, for example, more useful and intuitive to its users.
This information is not used by eProseed to track or collect any personal information from visitors, including by connecting the IP address to the computer user's identity, or for any purpose other than the aforementioned purpose.
According to the law, the storage of information and the possibility to access the information stored on a user's terminal equipment (namely through cookies) are only carried out by eProseed if you have given your prior and express consent to the installation of cookies on your device for those purposes.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.
- Security and Confidentiality
eProseed is committed to keeping your personal information secure and we have implemented appropriate rules and technical measures to protect the personal information that we have under our control from unauthorized access, accidental loss, improper use or disclosure, unauthorized modification and unlawful destruction.
We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
All of our partners, employees, consultants and data processors, when applicable, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of such personal information.
Any questions or questions about this policy, about how we process your personal data or if you wish to exercise any of your rights concerning personal data protection can be sent by email to email@example.com or to the respective Controller to the following addresses:
eProseed Europe, S.A
rue de l´Industrie, 13, 8399 Windhof, Luxembourg
eProseed Cloud, S.A.
rue de l´Industrie, 13, 8399 Windhof, Luxembourg
eProseed Portugal, LDA.
Rotunda Engenheiro Edgar Cardoso, n.º 23, 5º 4400-676 Vila Nova de Gaia, Portugal
eProseed Eastern Europe, L.L.C.
Bucureşti Sectorul 1, Strada Grigore Alexandrescu, Nr. 89-97, SUPR 165.84MP, CORP B, ET.5 ARIPA DE EST
eProseed UK, LTD.
37-38 Long Acre, London, United Kingdom, WC2E 9JT
eProseed NL B.V.
Rembrandtlaan 22 C, 3723BJ Bilthoven, The Netherlands
eProseed Solutions F.Z.E.
Technohub, Dubai Technology Entrepreneur Centre, DSO-THUB-G-D-FLEX-G107, DSOTHUB-G-D-FLEX-G114B, Dubai Silicon Oasis, Dubai, United Arab Emirates, 126936, +971565225615
eProseed Central America, S.A.
5TA. AVENIDA 12-31 OF. 501 ZONA 9 5TO Nivel Edificio El Cortez Guatemala
eProseed Danişmanlik Hizmetleri Limited Şirketi
Maslak Mahallesi Taş Yoncası Sokak T4 Apt. No: 1 U / B36 Sarıyer / Istambul
eProseed Solutions L.L.C.
Office 102, Regus Al Arjan
National Bank Building, Defence Road
Abu Dhabi, UAE