This Confidentiality Policy establishes the commitment of Américo Coelho Relvas, Sucessores, SA (hereinafter referred to as ACRelvas) with its customers, suppliers and other interested parties, in terms of the protection of personal data, in order to strengthen and consolidate their relationship of trust and closeness. Through this Policy, ACRelvas informs its Clients, suppliers, and other interested parties regarding the treatment that it carries out to their personal data, as well as the rights that it recognizes them, as holders of personal data.

ACRelvas acts in strict compliance with the principles described in this policy, Regulation (EU) 2016/679 (General Data Protection Regulation - GDPR) and applicable data protection legislation, in all personal data processing activities that are of its responsibility. ACRelvas processes personal data through various operational and technical means that support its business activity.

This Policy provides important information in the following areas:

• RESPONSIBLE FOR DATA PROCESSING AND CONTACT

• OBJECTIVES

• SCOPE OF APPLICATION

• OUR COMMITMENT

• PERSONAL DATA AC RELVAS COLLECTS AND HOW IT DOES IT

• PURPOSES FOR THE PROCESSING OF PERSONAL DATA

• BIDDING FOR THE PROCESSING OF YOUR DATA

• PERSONAL DATA RETENTION PERIOD

• TRANSFER OF CUSTOMER'S PERSONAL DATA

RESPONSIBLE FOR DATA PROCESSING AND CONTACT

The entity responsible for the processing of your personal data is Américo Coelho Relvas, Sucessores, S. A.

Whenever you have any doubts about the processing of your personal data, we will be available to help you, by calling 22 747 02 80, email acrelvas@acrelvas.pt or letter.

OBJETIVES

The Privacy Policy, as a communication tool, has as main objectives:

• Reinforce and consolidate the relationship of trust and proximity of ACRelvas with its Customers, Suppliers and other interested parties

• Demonstrate transparency in the processing of personal data carried out by ACRelvas

• Inform Customers, Suppliers and other interested parties about their rights, as holders of personal data, and how they can exercise them

• Inform Customers, Suppliers and other interested parties about the ACRelvas Responsible to whom they can request the exercise of their rights, or clarify how their personal data are treated

SCOPE

The Privacy Policy applies to personal fdata and its treatment by ACRelvas, in the context of the intended purposes. For the purposes of this Privacy Policy, any personal information identified or identifiable (directly or indirectly) is considered personal data.

ACRelvas may collect personal data directly, that is, from the respective holder or through other sources, if this is legitimate and permitted by law. Collection sources may be:

• ACRelvas website: Websites and social networks.

• E-mail, text and other electronic messages: Electronic communications between customers, suppliers and other interested parties and AC Relvas.

• Telephone Calls: Calls made and received.

• Registration forms: Printed records and similar forms that AC Relvas collects.

OUR COMMITMENT

The protection of your personal data is a priority for ACRelvas. We are committed to only processing your personal data that is strictly necessary to provide you with the best services, ensuring transparency in information and application of best practices in the field of security and protection of personal data. Whenever your personal data is processed by contracted entities, ACRelvas will require that these entities present the same level of guarantee of privacy and security in terms of personal data protection. We want to deserve your trust and ensure you that your personal data is safe with us, as we will always be committed to protecting your privacy, taking, with great seriousness and commitment, our responsibilities with regard to the protection of your personal data.

PERSONAL DATA ACRELVAS COLLECTS AND HOW IT DOES IT

The General Data Protection Regulation establishes a more comprehensive definition of the concept of personal data. A personal data is any information, regardless of its nature and the support on which it is presented, capable of identifying a person. Examples of categories of personal data treated by ACRelvas are:

Personal contact details. This includes any information that allows AC Relvas to contact you, such as name, postal address, email address, and telephone number Information on the use of websites / communications. When you browse through the Websites, we use automatic data collection technologies to collect certain information about the user's actions. This information is captured using automated technologies such as Cookies. Image: Video surveillance systems (CCTV) are installed to ensure the safety of our employees and all those who visit us.

Payment and financial information. It includes any information needed to complete an order or for the customer to make a purchase including VAT number. Analysis of job applications. Includes name, postal address, email address, and phone / mobile number, date of birth, VAT and other data that may be mentioned in the Curriculum Vitae and in the Recruitment Registration Form - Spontaneous Candidacy of ACRelvas Situations in which we process your personal data:

At ACRelvas we process your personal data when you request a quote or information about our products / company and after-sales service, also when you place an order, when you send us data to follow up on your requests, when you submit a spontaneous application or when you use our site. This treatment can be done orally, in writing or through our website.

PURPOSES FOR THE PROCESSING OF PERSONAL

ACRelvas guarantees that your personal data are treated only for the purposes communicated to you, and are not used for any other purpose. Thus, we treat your personal data to guarantee the quality of the products / services we provide you and to be able to better respond to your needs. Some of the purposes for which we may use your personal data:

• Communication with Customers, suppliers, other interested parties

• Clarification of doubts

• Information requests processing

• Direct marketing communications (if you have consented to the processing of your personal data for this purpose)

• Request for services / products

• Video surveillance.

• Recruitment processes, in the case of spontaneous applications

LEGITIMACY FOR ROCESSING YOUR DATA

These are the circumstances that allow us to process your personal data: Your express consent either in writing, or orally, for example, for direct marketing purposes, so you can receive emails or SMS messages from ACRelvas Personnel recruitment and selection The execution of a contract which you entered into with ACRelvas, for example, a contract for the purchase of products purchased from ACRelvas, an employment contract,… Compliance with a legal obligation The legitimate interest of ACRelvas for example, arising from the collection of suggestions / complaints, for the purpose of improving the quality of the service ACRelvas undertakes to treat your personal data in order to guarantee the confidentiality, security and protection of such data against its unauthorized or unlawful treatment and against its loss, destruction or damage.

PERSONAL DATA RETENTION PERIOD

We only keep your personal data for the period strictly necessary to fulfill the objectives identified above, within the legal limits. After the expiration date, ACRelvas undertakes to delete, destroy or anonymize your personal data. In general, ACRelvas keeps transaction data, as well as the respective supporting documents, for a period of 12 years, this being the term defined by law. Spontaneous application data will be kept for a maximum period of 2 years, changing to 5 years if they have been used in recruitment processes. Regarding video surveillance, we only keep your personal data for a period of 30 days, as required by law. Other data that arrives to us that do not fit in the activity of ACRelvas, will be eliminated after the verification of its non-compliance.

You can ask us for additional information regarding the retention periods of your personal data, via email acrelvas@acrrelvas.pt, by telephone 22 747 02 80 or letter.

T TRANSFER OF CUSTOMER'S PERSONAL DATA

Whenever necessary, ACRelvas may transmit your personal data to third parties - partner companies of ACRelvas, for example, freight transport companies - only and exclusively for the purpose of performing a service you have contracted, such as delivering a product at your premises; the temporary work company for issuing the contract and activities associated with it, such as processing and payment of salaries. Your personal data can also be communicated, in compliance with the law, to State entities, such as the Tax Authority.

i) What are your personal data protection rights and how can you exercise them? Right of access to information: You can obtain confirmation of which of your personal data is processed by ACRelvas, as well as the respective information about the purposes of the processing or the periods of conservation of that data. Right of rectification: You can ask to change your personal data that is incorrect or incomplete. Right of deletion: You can request the deletion of your personal data, as long as there are no legal requirements for its conservation. Right to portability: You can receive the personal data you have provided to us in a structured way in a digital machine-readable format. Right of opposition: You can object to or withdraw the consent you previously gave to the processing of your personal data. Right to limitation of treatment: You can request to limit the processing of your personal data, in the form of: a) Suspension of treatment; b) Limiting the scope of processing to certain categories of data or processing purposes. You can exercise these rights in writing, via email acrelvas@acrelvas.pt, or by phone 22 747 02 80 or by letter. ACRelvas will proceed with a careful analysis of the requests, assessing their legitimacy and relevance, committing to respond in a timely manner. If necessary, the holder of personal data may also file a complaint with the National Data Protection Commission (CNPD).

j) Cookies/similar Technologies place all types of cookies

ACRelvas uses cookies on its Websites to improve the performance and browsing experience of our users, increasing, on the one hand, the speed and efficiency of response and, on the other, eliminating the need to repeatedly enter the same information. The placement of cookies not only helps websites to recognize the user's device the next time they visit us, but it will also be essential for their functioning. The cookies used by ACRelvas, on all of its Websites, do not collect personal information that allows the user to be identified, only saving generic information, namely, the user's form and / or location of access and the way he uses the Websites. Cookies only retain information related to the User's preferences. Session cookies: These are temporary cookies that remain in the browser's cookie file until the browser leaves the website, so there is no record on the user's hard drive. The information collected by these cookies serves to analyze website traffic patterns. Ultimately, this allows us to improve the content and improve the usability of the website.

Analysis cookies: Those that are treated well by us or by third parties, allow us to quantify the number of users and perform the measurement and statistical analysis of how users use the service offered. We examine your navigation on our website, with the aim of improving the supply of products or services that we offer you. Advertising cookies: These are those that are treated well by us or by third parties, allow us to more effectively manage the offer of advertising spaces that exist on the website, being able to analyze your browsing habits and show you advertising related to your navigation profile

k) How do we protect your personal data?

ACRelvas has a variety of information security measures, in line with the best national and international practices, in order to protect your personal data, including technological controls, administrative, technical, physical and procedural measures that guarantee the protection of your data personal data, preventing their misuse, unauthorized access and disclosure, their loss, their improper or inadvertent alteration, or their unauthorized destruction.

We assume, in terms of information security, the same commitment to continuous improvement by which we are guided in our daily activity. Among others, we highlight the following measures:

• Restricted access to your personal data

• Securely storing and transmitting personal data

• Protection of information systems through devices that prevent unauthorized access to your personal

• Implementation of mechanisms that guarantee the safeguarding of the integrity and quality of your personal data

• Regular monitoring of information systems, with the aim of preventing, detecting and preventing the misuse of your personal data

• Redundancy of equipment for the storage, processing and communication of personal data, to avoid loss of availability

l) Policy Changes

This Privacy Policy can be revised and updated, which will be disclosed through our websites.