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    Our commitment

    Green Angle Capital, Lda. (Green Angle) is strongly committed to the privacy and rights of data subjects and acts in accordance with the provisions of the General Data Protection Regulation (GDPR) and other applicable legislation.

    We want you to be familiar with the way Green Angle processes your personal data and with your rights as data subject.

    1. What data does Green Angle process, who does it concern and how is it collected?

    Personal data is 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 identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

    Green Angle may process the following categories of personal data:


    a) Identification data (e.g., name, date of birth, gender, address, contact details, citizen’s card data, passport data, tax number, nationality);
    b) Data relating to education and work experience (e.g., education, qualifications, certifications, curriculum vitae, information from previous employer);
    c) Professional data (e.g., title, position, job description, company, office address);
    d) Professional activity data (e.g., business activities, information about cases and briefs, experience;
    e) Invoicing and expenses data (e.g., fees, client-related travelling and communications expenses); and
    f) Recorded image and sound data (e.g., photographic and video images).

    Data subjects are the individuals to whom the data refers.

    The personal data categories listed above may belong to different categories of data subjects, such as clients, employees of corporate clients, counterparties or applicants of Green Angle.

    Green Angle collects personal data in various ways and at different times, including when you send us an e-mail or reply to an invitation, when you give us your visiting card, when you sign up for our information or events, when you apply for a position with us or when you engage our services.

    In some cases, Green Angle may collect personal data indirectly from public sources. When Green Angle processes personal data that has been collected indirectly, it will provide all the information about the processing of that data to the relevant data subject at the earliest opportunity.

    2. For what purposes and on what lawful basis does Green Angle process personal data?

    Green Angle may process personal data for the following purposes and on the following lawful bases:


    a) Provision of consultancy services, which may include:

    • Opening a client dossier;
    • Keeping a record of services proposals received;
    • Communications with the client, other parties and/or public bodies; and
    • Keeping documents on file in digital and physical formats.

    The lawful basis is contractual performance and legitimate interest:

    • Green Angle interest in processing clients’ information in a sustained and efficient manner, which ensures its quality and integrity and enables the provision of excellent services; and
    • Interest of the clients represented and advised by Green Angle.

    b) Communications and sending of information, including the dissemination of information (e.g. newsletters, briefings, legal alerts);


    The lawful basis is legitimate interest:

    • Reply to requests from persons that fill in the Green Angle website forms with the relevant suitable correspondence;
    • Contribute to the development of sustainability related matters and play an important role in the ESG community; and

    c) Event management, which includes:


    • Sending invitations for events and registering event participants; and
    • Publicising events within and outside the Company.

    The lawful basis for this management are legitimate interest and consent (*):


    • Reply to requests from persons that fill in the Green Angle website forms with the relevant suitable correspondence;
    • Contribute to the development of sustainability related matters and play an important role in the ESG community; and
    • Publicize events arranged by Green Angle.

    d) Protection of persons and goods.

    The lawful basis is legitimate interest, in order to ensure the protection of the Green Angle premises and the persons on those premises.

    e) Complying with statutory compliance obligations

    The lawful basis is compliance with statutory obligation.

    f) Invoicing and accounts management, which includes:


    • Booking expenses, monitoring costs and refunds (e.g. travelling and mobile communications expenses to be paid by clients);
    • Invoicing and management of current accounts; and
    • Keeping accounting records and supporting documents on file.

    The lawful basis includes contractual performance; legitimate interest; and compliance with statutory obligation: manage efficiency, invoice the services provided correctly and in a timely fashion, and ensure compliance with the applicable statutory obligations.

    g) Judicial and non-judicial claims, which includes the collection and recovery of amounts owed by clients.

    The lawful basis is legitimate interest: Green Angle has a legal interest in satisfying its debt- claims and defending its rights.

    j) Recruitment and selection, which includes analysing applications and CVs, as well as the internal selection process for lawyers and staff according to the Company needs.


    The lawful basis is pre-contractual audit at the request of the data subject and legitimate interest: the Green Angle interest in analyzing applications and having applicants undergo an internal selection process, in accordance with pre-defined criteria.


    (*) The data subject’s prior consent will be requested in cases where sound or image recordings are made or if photographs are taken.

    3. How long do we keep your personal data for?

    Green Angle will only keep your data for the period necessary to achieve the purposes established in this Policy or during the period required by the applicable legislation or regulations.

    The personal data storage periods, depending on each processing purpose, are as follows:

    Processing purpose > Storage period

    • Provision of consultancy services > For the duration of the client/company relationship, plus 20 years.
    • Communications and sending of information > Until the data subject objects.
    • Event management > five years from the contact date or attendance at the event (as the case may be) if there is no contact or attendance at another event by the data subject.
    • Protection of persons and goods > 30 days.
    • Complying with statutory compliance obligations > seven years from the time the client’s identification is processed or, in the case of business relationships, after the end of the same.
    • Invoicing and accounts management > 10 years.
    • Judicial and non-judicial collection and complaints > Until payment of the amounts in debt or settlement of the dispute, whichever is applicable.
    • Recruitment and selection > two years from the time the application or CV is received if the applicant (staff) is not selected); three years from the time the application or CV is received if the applicant (lawyer) is not selected; and


    For the duration of the professional relationship with Green Angle in the remaining cases.

    4. Who does Green Angle transfer your personal data to?

    Green Angle does not transfer your personal data to third parties, except in cases where this proves to be necessary for the provision of the services you have engaged or for compliance with the obligations to which Green Angle is subject.


    The transfer of data to third parties is carried out in accordance with the applicable data protection legislation and within the limits of the purposes and lawful bases established in this Policy.

    Green Angle may share your personal data with the following entities:


    • Relevant parties for the advisory services we provide, for example, counterparties, regulatory authorities, government institutions;
    • Public authorities;
    • Service providers that supply services to Green Angle for the purposes described above, such as Information Technologies (IT) providers, communications services, translation services and digital and physical archive services.


    In cases where the transfer of personal data to the above-mentioned entities involves an international transfer of personal data (i.e. outside of the European Union), Green Angle:


    i) will carry out this transfer on the basis of a Commission adequacy decision, according to which the country or international organization in question guarantees a level of personal data protection equivalent to that under European Union law; or


    (ii) if there is no Commission adequacy decision, it will ensure that such transfers are made in stringent compliance with the law and that appropriate guarantees are implemented to ensure the protection of your personal data.

    The existing adequacy decisions are available at www.eur-lex.europa.eu.

    5. Is your personal data safe?

    Green Angle has a very strict security policy, from a technical and organization viewpoint, in order to protect your personal data from unauthorized destruction, loss, alteration, disclosure or access and against any other form of unlawful or abusive treatment.


    The technical and organizational security measures created and implemented by Green Angle are also required of the Green Angle service providers that may process personal data on their own behalf.


    If you have any questions about this matter, or if you would like more details about our data security, or if you know of any inappropriate situation, please contact us through either of the channels in point 9. below.

    6. What rights do you have as data subject?

    As data subject, you have the following rights:


    • Right of access

    You may ask Green Angle at any time for confirmation as to whether it processes your data, for access to your personal data and for information about that processing.

    You may also obtain a copy of the personal data that is processed.


    • Right to rectification

    If your personal data is incorrect or incomplete, you may ask for it to be rectified or completed.


    • Right to erasure or to be forgotten

    In certain situations, you have the right to request the erasure of your personal data.


    This right may be restricted in certain situations if the processing of the data is necessary for compliance with statutory obligations to which Green Angle is subject or when the processing is necessary for the purposes of declaring, exercising, or defending a right in legal proceedings.


    • Right to restrict processing

    In certain situations, you may ask Green Angle to limit access to personal data or suspend processing activities. This will happen, for example, in cases where you dispute the accuracy of your personal data, for a period of time which enables Green Angle to check its accuracy, or in
    cases where you have objected to the processing, until it is verified whether the legitimate interests of Green Angle or of a third party prevail over yours.


    • Right to data portability

    In cases where the processing of data is based on a contract to which you are a party or on your consent, you may ask Green Angle to hand over to you the data you supplied in a structured, current and automatic reading format. You may also ask Green Angle to transfer this data to other data controllers, as long as this is technically possible.


    • Right to object

    When the data processing is based on the Green Angle legitimate interest or when it is carried out for purposes other than those for which the data was gathered, but which are compatible with the same, you have the right to object to the processing of your data for reasons related to your own personal situation.


    Green Angle will cease to process your personal data in such cases unless it has legitimate reasons to carry out this processing and these reasons prevail over your interests.


    • Right not to be subject to automated decision-making

    Green Angle make no automated individual decisions, including profiling, which influence your legal status or significantly affect it in a similar way.


    • Right to withdraw consent

    In cases where the processing of the data is based on your consent, you may withdraw your consent at any time.


    If you withdraw your consent, your personal data will no longer be processed, unless there is another lawful basis that permits processing.


    • Right to lodge a complaint with the supervisory authority

     You have the right to lodge a complaint with the relevant supervisory authority about matters related to the processing of your personal data.


    In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados [National Data Protection Commission).

    For more information, visit www.cnpd.pt.


    Please note that the exercise of the above-mentioned rights may be restricted by virtue of third-party rights and freedoms, statutory obligations or confidentiality obligations or the prevailing legitimate interests of Green Angle or a third party.

    7. How can you exercise your rights?

    You may exercise your right in either of the following ways:

    • E-mail to [email protected]; or
    • Letter addressed to DPO, Green Angle Capital, Lda., Avenida Bombeiros Voluntários, n.º 52, 12.º direito, 1495-022 Algés.


    Exercising your rights is free from charges.

    8. How can you contact us?

    If you have any questions or need more information about the processing of your personal data or your rights as data subject, please contact us at the addresses below:


    • E-mail to [email protected]; or
    • Letter addressed to DPO, Green Angle Capital, Lda., Avenida Bombeiros Voluntários, n.º 52, 12.º direito, 1495-022 Algés.

    9. How can you stay informed about the processing of your personal data?

    The Privacy Policy may be updated from time to time and we recommend that you check it regularly for any changes.

    You can obtain more information about personal data processing from the Cookie Policy available on the Terms and Conditions of our website.