Privacy and

Data Protection Policy

Privacy and Data Protection Policy

Prior comment:

The Privacy and Data Protection Policy reveals the company’s commitment to the privacy of the data it handles.

Its adoption enables compliance with the duty of transparency required by the RGPD, as well as with the duty of information that it imposes.

Under the terms of the RGPD (General Data Protection Regulation), Warpcom must report on:

  • The identity and contact details of the controller and, where applicable, its representative;
  • The contact details of the data protection officer, where applicable;
  • The purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
  • Where the processing is based on point (f) of Article 6(1), the legitimate interests of the controller or a third party;
  • The recipients or categories of recipients of the personal data, if any;
  • Where applicable, the fact that the controller intends to transfer personal data to a third country or an international organisation;
  • The period for which the personal data will be stored, or, where that is not possible, the criteria used to determine that period;
  • The existence of the right to request from the controller access to and rectification or erasure of personal data concerning the data subject, and restriction of processing in respect of the data subject, or the right to object to processing, as well as the right to data portability;
  • Where processing of the data is based on consent, the existence of the right to withdraw consent at any time, without undermining the lawfulness of processing based on consent previously given;
  • The right to lodge a complaint with a supervisory authority.

This Privacy and Data Protection Policy describes how Warpcom Services, SA collects, processes, uses, discloses, transfers, and retains your information.

Warpcom Services, SA is committed to differentiation by the service it provides to its customers. In this sense it has developed a procedural approach, which is materialised in the development of an Integrated Management System supported in five normative references of excellence, namely ISO 9001, ISO 14001, ISO 45001, ISO/IEC 20000-1, and ISO/IEC 27001, as well as defined in its policies, the commitments assumed with its CUSTOMERS, suppliers, and other stakeholders.

Warpcom Services, SA declares its respect for and compliance with the provisions of Law no. 58/2019, of 08 August which ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 of the Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Warpcom Services, SA, in the development of its business and in the relationship, it establishes with its CLIENTS, adopts the appropriate technical and organizational measures to ensure confidentiality, integrity and data security.

  • Personal Data

Personal data shall mean any information of any nature whatsoever, in any medium (sound or image), concerning an identified or identifiable living person, or a combination of separate pieces of information which could lead to the identification of a specific person.

An identifiable person is one who can be identified, directly or indirectly, for example by his or her name, identification number, location data, electronic identifier or other element allowing that natural person to be identified.

Personal data that has been de-identified, coded or pseudonymised, but which can be used to re-identify a person, remains personal data and falls within the scope of the RGPD.

Some examples of personal data: first and last name, address of a residence, email, identification card number, location data, IP address, records in health institutions.

  • Legal basis and purpose of the processing

The collection and processing of personal data takes place:

-During the contractual relationship between Warpcom Services, SA and the data subject, for full compliance with the same;

-In accordance with the data subject’s consent, which may be withdrawn at any time. Withdrawal of consent shall not affect the processing carried out on the basis of the consent previously given;

– When necessary to comply with our legal obligations;

– to protect the vital interests of the data subject or the vital interests of third parties;

– As necessary in accordance with the public interest; and

– As necessary for our (or third parties’) legitimate interests, including our interests in providing an innovative, personalised, safe, and cost-effective service to our customers and partners, except where your interests or fundamental rights and freedoms requiring protection of personal data prevail.

  • Collection and Use of Non-Personal Data

“Non-personal data” is information that cannot be attributed to a specific natural person, for example: a company registration number; an email address such as [email protected]; anonymized data

Warpcom Services, SA may collect, use, disclose, transfer, retain and disclose non-personal information for any purpose, such as:

  • Better understand customer behaviour;
  • Improve products, services, and communication;
  • Guarantee the quality of our services.

Where ‘personal data’ is combined with ‘non-personal data’, the combined information will be processed as ‘personal data’ for as long as it remains combined.

  • Rights of the Personal Data Subject

What are the rights of the holders of Personal Data:

  • Right to information about the processing of your personal data;
  • Right of access to personal data stored concerning them;
  • Right to rectification of incorrect, inaccurate, or incomplete personal data;
  • Right to erasure of data or “Right to be forgotten” of personal data that is no longer needed or if its processing is unlawful;
  • Right to object to the processing of your personal data for marketing purposes or for reasons relating to your particular situation;
  • Right to limit the processing of your personal data in specific cases;
  • Right to Portability, receive your personal data in machine-readable format and send it to another controller (“data portability”);
  • Right to request that decisions based on automated processing which concern them or significantly affect them, and which are based on their personal data be taken by natural persons and not only by computers.

Warpcom Services, SA reserves the right to refuse access to requests that are unfounded, prejudicial to the privacy of third parties, or impractical.

Requests for access, rectification, erasure, limitation, portability, and opposition can be made via email: [email protected].

  • Data Storage

Warpcom Services, SA stores data until it is no longer needed to provide our products and services or until the right to erasure or “right to be forgotten” is legitimately exercised, whichever comes first. This is a case-by-case determination that depends on factors such as the nature of the data, the reason it is collected and processed, and relevant operational or legal retention needs.

The storage of data by Warpcom Services, SA is done with respect for the principles of purpose limitation, minimization, security, confidentiality, and integrity.

  •  Children or Minors 

Warpcom Services, SA does not intend in any way to collect data from children or minors.

  • Cookies

“Cookies” are small text files containing relevant information that the visitor’s access device loads, via the internet browser, when a website is visited by the user.

Warpcom Services, SA uses cookies on its website to improve the performance and navigation experience of its users.

The information collected through cookies is non-personal data. Where information collected through cookies relates to an identified or identifiable natural person, or is considered personal data by applicable law, such information will be processed as personal data.

  • Data Sharing 

In order to fulfil the purposes for which they were collected, Warpcom Services, SA may share your data with, in particular: business partners, suppliers or service providers, competent authorities in compliance with applicable law or, if necessary, to comply with judicial or governmental orders.

All entities with whom Warpcom Services, SA shares your personal data are contractually or legally obliged to implement technical and organizational data security measures and are prohibited from processing the data for purposes other than those on which access is based.

  • Links to other websites

As an added value service for the user, Warpcom Services, SA provides links to other websites on its website. Warpcom Services, SA seeks to select web pages that meet its high standards. However, Warpcom Services, SA cannot guarantee these levels in all the links it proposes, nor can it explicitly or implicitly guarantee the accuracy of the information contained therein.

Warpcom Services, SA accepts no responsibility for the content and use of data by these same web pages outside Warpcom Services, SA.

  • Other Information

It may be necessary by law, legal process, litigation and/or requests from public and governmental authorities for Warpcom Services, SA to disclose your personal data.

You also have the right to lodge a complaint with Warpcom Services, SA’s main supervisory authority, the National Commission for Data Protection (CNPD), or your local supervisory authority.

For further information, namely the way Warpcom Services, SA, cares / treats and processes personal data of its Customers, Partners and Other interested parties, you should send your communications to: [email protected]


Warpcom Services, SA

Estrada de Alfragide, 67, Alfrapark – Edifício F, piso 3

2610-008 Amadora

Amendment to the Privacy and Data Protection Policy

The terms of this policy, which you should read carefully, may be changed, considering that the changes are effective from the date of its publication on this site, making express reference to the date of update.

Date of update 


IMP-140-DG (Rv01 – 202202)