1. OUR COMMITMENT
The protection of your personal data is a priority for GOLDEN WEALTH MANAGEMENT (composed of Golden Assets - Sociedade Gestora de Patrimônios, SA and Golden Broker - Sociedade Corretora SA), which has adopted common principles to all entities that are part of it, which are disclosed by this "Data Protection Policy".
This document reflects GOLDEN WEALTH MANAGEMENT's commitment to providing detailed information regarding (i) the processing of your personal data; (ii) how we protect the security and privacy of your personal data; and (iii) the rights and obligations laid down in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 - General Regulation on Data Protection (hereinafter referred to as the RGPD).
Additional information may be made available to those described in this Data Protection Policy, in cases of contracting services.
If you are a Customer, potential customer, or otherwise related to GOLDEN WEALTH MANAGEMENT by providing us with your personal data (collectively referred to as CLIENT), we recommend reading this document.
2. WHO WE ARE
The data may be processed by GOLDEN ASSETS - SOCIEDADE GESTORA DE PATRIMÓNIOS, SA, a company headquartered at Avenida da Boavista, 2429, 4100-135 Porto, and registered at the competent Commercial Registry under NIPC 502538430, as well as by GOLDEN BROKER - SOCIEDADE CORRETORA SA, a company with registered office at Avenida da Boavista, 2429, 4100-135 Porto, and registered at the Commercial Registry Office under NIPC 506396878.
Each of these companies are "Responsible for the Treatment of Personal Data" within the meaning of the General Regulation on Data Protection (hereinafter referred to as "RGPD"), of its CLIENT and, in this context, decides what data is collected, means of treatment and the purposes for which the data is processed.
3. WHAT PERSONAL DATA WE COLLECT AND TREAT
A personal data is any information relating to an identified or identifiable natural person and is identifiable whenever a natural person can be identified, directly or indirectly, in particular by reference to an identifier.
To the extent necessary for the development of our activities and in order to achieve a high standard of personalization of the services offered in order to maximize their satisfaction, we collect a set of personal data of the CLIENT.
Thus, we collect various types of personal data, namely:
CATEGORY OF PERSONAL DATA - (EXAMPLES)
• Identification and contacts (Name, identification document numbers, nationality, address, e-mail address, telephone number);
• Biographical Data (date of birth, gender, nationality, naturalness, marital status, household information, academic qualifications, or data on the profession, identification of the employer);
• Financial data (financial assets, liabilities in the financial sector, remunerations, type of investments made, type of assets held);
• Bank Data (Identification of bank accounts, number of debit / credit cards, movements and history of bank movements);
• Data on the Real Estate Property (Type and value of own housing or other properties, housing charges, seniority of the same.);
• Segments and profiles (Business segment, investor profile or propensity to purchase financial products);
• Opinions and Preferences (Comments on the presence of GOLDEN WEALTH MANAGEMENT, or answers to satisfaction questionnaires);
• Use of sites and applications (IP address, geographic location);
• Content (Information contained in written communications between GOLDEN WEALTH MANAGEMENT and Customer, recorded calls or video surveillance images);
• Access Accounts (CUSTOMER Account, CUSTOMER authentication credentials).
In the context of the contractual relations established with GOLDEN WEALTH MANAGEMENT, it is mandatory to collect and process personal data of the CLIENT for the purpose of fulfilling contractual obligations, pre-contractual, legal or regulatory procedures. The refusal to supply these data will therefore prevent the conclusion of a contract with GOLDEN WEALTH MANAGEMENT or termination of the agreement by resolution.
4. INDIRECT COLLECTION OF PERSONAL DATA
The collection of personal data of the CLIENT may be done directly or indirectly (i.e. through partner entities or third parties).
As an example, the indirect collection of your personal data can be done through the following forms:
5. WHY AND WITH WHAT BASIS DO WE USE YOUR PERSONAL DATA?
Data processing involves an operation or a set of operations carried out on personal data or on personal data sets, by automated or non-automated means, such as collection, registration, organization, structuring, preservation, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of disclosure, comparison or interconnection, limitation, erasure or destruction
At GOLDEN WEALTH MANAGEMENT we treat your data in a lawful, fair and transparent manner for specific purposes framed on a basis of lawfulness.
Your personal data may therefore be collected and processed by GOLDEN WEALTH MANAGEMENT on the following grounds and in particular for the following purposes:
a) Compliance with our legal and regulatory obligations to which GOLDEN WEALTH MANAGEMENT is bound
• Prevention of money laundering and terrorist financing; Compliance with legislation related to sanctions and embargoes; Combating tax evasion and compliance with declaratory obligations and fiscal control; Compliance with banking and financial regulations through which: (i) we implement security measures to prevent abuse and fraud; (ii) we detect transactions that deviate from the normal pattern; (iii) we monitor and report risks we may incur.
Response to requests for information from official entities such as Banco de Portugal, CMVM - Securities Market Commission and other judicial, police and sectoral authorities;
b) Execution of a contract with you or for pre-contractual procedures at your request
Provision of information regarding the contract and our services, including real-time contacts with the CLIENT; Information prior to the conclusion of the contract, namely for evaluation of the patrimony and profile of the CLIENT; Management of the contractual relationship, including the development of ancillary activities to support the financing activity; Data update; Provision of assistance and response to your requests; Management of complaints;
c) Fulfillment of the legitimate interest of GOLDEN WEALTH MANAGEMENT or third party
Management of Litigation, namely for the exercise of contractual or legal rights and defense in case of judicial and extrajudicial litigation; Satisfaction evaluation and Quality of Service, through questionnaires to evaluate the satisfaction of the CLIENT regarding the quality of the services provided; Development of services, with the purpose of better serving specific purposes of Customers; Proof of transactions; For the purpose of establishing individual statistical models, based, for example, on the analysis of transactions, to contribute to the mitigation of BCFT risk; Train employees and improve service through call recording; Offer of differentiated prices, based on the economic and commercial interest in order to rationalize the offer and in order to offer you the best service; Profiling of Clients, namely for the creation of customer risk profiles, prevention of fraud and prevention of BCFT, for example, by sending personalized offers to Clients, including real-time contact, under contract management; Fraud prevention - database to monitor and improve our processes and services, in order to prevent and detect fraudulent situations that will give a greater protection of the interests of Customers. Carrying out marketing actions and promotional actions, including real-time contact with the Customer, our services or third parties with whom we have established a partnership (including marketing profiles related to this purpose).
d. Consent for a specific purpose
Evidence of information or instructions transmitted by telephone, by recording calls / video calls in the context of a pre-contractual or contractual relationship; Monitoring the quality of service provided to the customer through the recording of calls; For the purposes of market research; Personalization of the experience on the websites and applications of GOLDEN WEALTH MANAGEMENT, through the use of persistent cookies for activity registration and customer preferences.
GOLDEN WEALTH MANAGEMENT only processes data duly authorized and subject to prior information of the respective CLIENT. Additional treatments will only be performed when compatible with specific purposes authorized and communicated to the CLIENT or, when it has given specific and explicit consent.
6. WITH WHOM WE CAN SHARE YOUR PERSONAL DATA?
GOLDEN WEALTH MANAGEMENT may have to transmit certain personal data of the CLIENT, for the purpose of fulfilling legal, contractual or pre-contractual obligations, and may therefore have to make data available to some third parties, namely:
THIRD PARTY INSTITUTIONS - (EXAMPLES)
• Group companies (Golden Assets - Sociedade Gestora de Patrimônios, SA, Golden Broker - Sociedade Corretora, SA and SGF - Sociedad Gestora de Fundos de Pensões, SA, with whom we work in partnership in the provision of financial services so that, of the group's full range of services, for administrative and financial management purposes at group level);
• Credit institutions and financial services (banking entities, financial intermediaries);
• Public bodies and supervisory bodies (Banco de Portugal, CMVM - Securities Market Commission, courts, criminal police bodies, or other official authorities or bodies);
• Subcontracting entities (Mail and document transport services, IT services, digital communication and marketing services and archiving services, at our service; Lawyers);
7. TRANSFERS OF PERSONAL DATA OUT OF THE EUROPEAN UNION
Whenever necessary, GOLDEN WEALTH MANAGEMENT may have to transmit data from the CLIENT to countries or organizations outside the European Union, in accordance with the applicable legislation, in particular for the purposes of data hosting or storage, technical subcontracting of treatment, back-up and recovery of hosted data, development of services.
For transfers to third countries or international organizations for which the European Commission has not recognized an adequate level of protection, the transfer of data by GOLDEN WEALTH MANAGEMENT will depend on a derogation applicable to the specific situation (for example, if the transfer of data takes place through an order requested by the CLIENT, such as when ordering an international transfer of securities).
For additional information on this subject or details on where it is available, you may send a written request to any of the channels and contacts indicated in point 10.
8. DURING HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Without prejudice to legal provisions or regulations to the contrary, the personal data collected will be kept only for the minimum period necessary for the purposes that led to their collection or subsequent processing.
The personal data of the CLIENT, collected by GOLDEN WEALTH MANAGEMENT, may be preserved, for the following periods:
REASON FOR CONSERVATION - (TIME OF CONSERVATION)
Duration of the contract: GOLDEN WEALTH MANAGEMENT may maintain the CLIENT's personal data for a longer period based on the consent, to ensure rights or duties related to the contract, or based on legitimate interests that support it, namely the defense of GOLDEN WEALTH MANAGEMENT in legal proceedings).
Legal or fiscal legal obligation - (Relevant statutory deadlines, or for the periods specified in special legislation, namely for the purposes of the law on prevention and money laundering and terrorist financing).
Preservation of call recording for proof of contract - (Term of validity of the contract plus the limitation and expiry period).
Preservation of call recording for quality of service - (30 days)
Conservation of video surveillance images - (30 days)
The deadlines for the preservation of the personal data foreseen may be prolonged, for reasons of legal action, criminal or administrative proceedings, up to six (6) months after the transfer of the data to the Entities responsible for the respective procedures, or until the final verdict.
9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE?
In accordance with the applicable standards, data subjects have the following rights:
RIGHT OF THE HOLDER - (DESCRIPTION):
• Information and access: (The CLIENT can obtain information regarding the treatment made regarding your data and obtain a copy of the same).
• Rectification: (Whenever the CLIENT considers that their personal data are inaccurate or incomplete, you may request rectification thereof accordingly.)
• Deletion: (CUSTOMER may request the deletion of your personal data, to the extent legally permissible).
• Limitation: (The CUSTOMER may request the limitation of the processing of your personal data).
• Opposition: (The CLIENT may oppose the processing of his / her personal data, in particular on the basis of legitimate interests or for reasons related to his / her particular situation.) The CLIENT may oppose at any time, when the data is processed for of direct marketing, including the definition of profiles related to said direct marketing).
• Automatic decisions: (When applicable, the CLIENT has the right to obtain human intervention from the person in charge, to express his point of view and to challenge automatic decisions, including the definition of profiles).
• Withdraw consent: (In cases where the CUSTOMER has given their consent to the processing of personal data, you may withdraw it at any time).
• Portability: (When legally admissible, the CUSTOMER has the right to the return of the personal data that concern him and has provided us, or, if technically possible, the transfer of the same to third parties).
• Complain with the CNPD: (The CLIENT shall also have the right to submit a complaint to the National Data Protection Commission or other control authority to whom this competence is attributed, whose contacts can be consulted at www.cnpd.pt ).
If requests by the CLIENT are manifestly unfounded or excessive, in particular because of their repetitive nature, GOLDEN WEALTH MANAGEMENT may require payment of a reasonable fee, taking into account the administrative costs of providing information or communications, or of taking the requested action , or refuse to comply with the request.
10. HOW TO CONTACT US?
For any question related to the protection of personal data, including the exercise of the rights referred to in the previous number, you can contact us directly in one of the following ways:
Name / Name:
Golden Assets - Sociedade Gestora de Patrimônios, SA - Tax Identification Number: 502 538 430
Golden Broker - Sociedade Corretora, SA - Tax Identification Number: 506 396 878
Address: Avenida da Boavista, 2429 | 4100-135 Porto
Email address of the Data Protection Officer: compliance@goldenwm.pt
GOLDEN WEALTH MANAGEMENT will respond to requests within a maximum of 30 days, except in cases of exceptionally complex requests. In such situations, the CUSTOMER will be informed of the need to extend the response time for a maximum additional period of 30 days and the respective justification.
For the purposes of communications with GOLDEN WEALTH MANAGEMENT, the CLIENT shall proceed with their identification.
11. HOW CAN THE INFORMATION BE KEPT OUT OF THIS AMENDMENT?
GOLDEN WEALTH MANAGEMENT may, at any time, make changes to this Data Protection Policy.
You can check the updated version of the GOLDEN WEALTH MANAGEMENT Data Protection Policy always available online at www.goldenwm.pt.
In the case of relevant changes, GOLDEN WEALTH MANAGEMENT shall make reasonable and reasonable efforts to inform the CLIENT through its normal channels and mechanisms of contact.
Last updated November 15, 2018
COOKIES POLICY
Golden views the privacy of its customers and users very seriously, complying with the European legislation in force in terms of the processing of personal data and privacy.
Golden uses best practices to protect user data against unauthorized access and unauthorized use.
The data collected on this website are intended to:
Customize the website according to your location / language preferences so that it is more convenient for users to browse this website. Respond to requests for contact from users Collect and analyze anonymous traffic data, via external statistics services, that allow us to improve this website.
The data collected on this website are not provided by Golden to external entities and are used only to satisfy user requests, respond to contacts or product communication.
COOKIES
Cookies are small text files stored on a user's device when visiting certain websites. On subsequent visits, the file is sent back to the website that originated it, thereby allowing you to identify a user's preferences. The use of cookies is now common practice on most websites, especially since the rise of e-commerce.
On this website, when authorized by the user, we use the following cookies:
Customization cookies - allow us to remember your preferences for your location / language. Thus, on subsequent visits the user will not have to be always selecting these options, making the visit easier.
Statistics Cookies - let us understand by collecting usage statistics, how users navigate our website and how we can improve your website experience and functionality. We use Google Analytics, one of the most commonly used and reliable statistics services, to help us collect this information. The information collected, such as pages visited or time spent on the website, does not allow to identify specific users since the visits are anonymous.