Version dated 25th September 2018

SRS Advogados (hereinafter referred to as "SRS"), as data controller, values your privacy and is concerned with the way your personal data is processed.

SRS recommends reading this Privacy Policy and its updates. In case of further changes to this Privacy Policy, the date of the latest version is as indicated above.

This policy addresses:

  • The data controller
  • Which personal data is collected and processed
  • How we obtain your personal data
  • How your personal data is used
  • On what basis we use your personal data
  • For how long we keep your personal data
  • With whom we share your personal data
  • How your personal data is protected
  • To which countries your personal data is      transferred
  • Your rights regarding your personal data

The data controller

SRS is responsible for collecting and processing your personal data, while providing you with legal services and in this context will decide which personal data is collected, the means of processing and the purposes for which the information is used.

Which personal data is collected and processed

Your personal data may be collected during the provision of our services, through the use of our website, by contacting or requesting information about SRS or as a result of the contacts you may have with any of our employees or clients.

Personal data processed by SRS includes:

  • Information relating to      your identity, such as your name (including prefix or title), your      business, your title or position and your connection to a particular      person;
  • Contact details, such as      postal address, e-mail address and telephone numbers;
  • Financial information,      such as your tax payer number or payment-related information;
  • Technical information,      such as information from your visits to our website or in relation to      materials and communications we send to you electronically;
  • Information you provide      for the scheduling of meetings or presence at events, including access      requirements;
  • Background information      provided by you or gathered as part of the client acceptance process;
  • Personal data obtained by      SRS, on behalf of or generated by our clients, for the purpose of      providing our services, including special categories of data;
  • Any other information      that you may provide us.

How we obtain your personal data

  • We collect data from you      as part of the procedure of contracting of our services, extending to      third parties as necessary, during the provision of legal services;
  • Through our computer      tools and services, including our website and electronic communications to      SRS;
  • When provided or through      interaction by you directly with us, such as through contacts with our      employees;
  • And through other means      and sources, such as keeping the data we already hold for you accurate and      up to date using publically available sources.

How your personal data is used

SRS gathers and processes your personal data in a number of ways, including through our website and our services. We use your information:

  • To provide our services,      which may include the processing of personal data of third parties on      behalf of our clients;
  • To provide information      requested by you;
  • To promote our services,      by sending news and publications, newsletters and details of events;
  • To guide and manage our      relationship with you;
  • In compliance of our      legal, regulatory and risk management obligations, including in the      exercise of rights or in defence of legal proceedings;
  • To improve and make our      website available, including by auditing and monitoring its use;
  • For recruitment purposes.

Using the SRS website

Several features on our website invite you to submit your personal data, as is the case of the Newsletter Registration at the foot of this page. The purpose of such features are those available on the page and, from the moment you provide your personal data, it will be used only for the purpose for which it was submitted.

Marketing and other emails

We collect and process your personal data so that we can contact you with information regarding the services we provide and the activities in which we participate through newsletters and other communications. We can use a relationship management tool to assess the strength of the relationship between SRS employees and clients or potential clients based on the frequency of contact by email between them. We use this information to evaluate, assess and improve the services we provide.

Meetings, events and seminars

We collect and process your personal data when you contact our offices or participate in any event or seminar organized or co-organized by SRS. We will only use or process special categories of personal data such as access requirements so that we can meet your needs and comply with any legal or regulatory obligations.

Legal and other services

We collect, store and use personal data during and in connection with the services provided to our clients. Identification and background information will be processed as part of our new client and subject acceptance processes, financial details, business management and marketing, including for compliance with tax legislation, anti-money laundering and terrorist financing regulations, as well as conflict verification. We also process personal data provided by or on behalf of our clients depending on the services for which we are hired. Such information may be disclosed to third parties when reasonably necessary in connection with such work. See also "Who we share personal data with" and "To which countries we transfer personal data" below.

On what basis we use your personal data

We use your personal data on the following grounds:

  • Upon your specific consent;
  • In proceedings prior to entering      into a contract or with the declaration of willingness to negotiate, and      in the execution of contractual obligations, in particular through the      provision of legal services;
  • To submit or defend legal      cases;
  • To comply with regulatory      and legal obligations;
  • For legitimate business      purposes. Please see "How your personal data is used" for further      details.

For how long do we keep personal data

SRS processes and stores your personal data according to the purposes for which it is processed. There are situations in which the law requires the processing and storage of data for a minimum period of time, in particular for 10 years in the case of data necessary for informing the Tax Authorities regarding accounting, tax purposes or information related to commercial bookkeeping; for 7 years for the purpose of combatting money-laundering and terrorist financing. Likewise, SRS will keep the data according to the deadlines applicable for taking legal action.

However, when there is no specific legal obligation, the information will be processed only for the necessary period of time to fulfil the purposes that led to their processing and retention and always in accordance with the law, guidelines and decisions of the CNPD – Comissão Nacional de Protecção de Dados (“CNPD”).

Given the above

SRS will process and maintain your personal data for the period during which we have a contractual relationship.

As far as video surveillance of our premises is concerned, SRS will only keep recordings of images and personal data for a maximum period of 30 days.

SRS may keep other personal data for periods longer than the extent of the contractual relationship, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests that justify it, but always for the period strictly necessary for the fulfilment of the respective purposes and in accordance with the guidelines and decisions of the CNPD.

With whom we share your personal data

We may share your personal data with third parties in accordance with the contractual provisions in force, including:

  • Our professional      consultants and auditors;
  • Suppliers with whom SRS      contracts certain support services, such as word processing, translations,      copies, document reviews;
  • IT service providers;
  • Third parties involved in      the provision of services we provide to clients and with their prior      consent, such as lawyers, enforcement agents, local consultants and others;
  • Entities involved in the organization      of events or seminars or co-hosts thereof.

Where necessary, or for the reasons set out in this policy, personal data may also be shared with regulatory authorities, courts and official entities. Although unlikely, we may be required to disclose your data to comply with legal or regulatory requirements. We will make reasonable efforts to notify you prior to such sharing, unless we are legally prevented from doing so.

If, in the future, we reorganize or transfer all or part of our business, we may need to transfer your personal data to new entities linked to SRS or to third parties through which SRS’ services will be provided.

SRS can use social networks such as LinkedIn and Twitter. If you are a user of these services, you should review their privacy policy for more information about how they handle your personal data.

SRS will not commercially sell, rent or dispose of personal data to any third party.

How your personal data is protected

We use a variety of technical and organizational measures to help protect your personal data from unauthorized access, disclosure, alteration, loss or destruction in accordance with applicable data protection laws.


To which countries is your personal data transferred

In order to provide our services, it may be necessary to transfer your personal data to places outside of Portugal.

Therefore, SRS may have to transfer personal data to a third country outside the European Union and not included in the list of countries that the European Union has already considered to meet adequate levels of personal data protection. In such cases, SRS will ensure that data transfers are carried out in strict compliance with applicable legal standards.

Your rights regarding your personal data

The General Data Protection Regulation and other applicable data protection laws protect certain rights for data subjects. In particular:

Right of Access – the right to obtain confirmation as to which of your personal data is processed and information about it; for instance, inter alia, what are the purposes of the processing and what are the retention periods, amongst others;

Right of Rectification – the right to request modification of your personal data that is inaccurate or request to fill out personal data that is lacking, such as address, VAT number, email, telephone contacts, or others;

Right to Erasure or "right to be forgotten" – the right to obtain erasure of your personal data, provided that there are no valid grounds for its retention, for example in cases where SRS has to keep the data to comply with legal obligations or because a court case is in progress;

Right to Data Portability – the right to receive the data you have provided in a digital, machine-readable format of current use or to request the direct transmission of your data to another entity that becomes the new data controller of your personal data, however only if technically feasible;

Right to Withdraw Consent – the right to withdraw your consent, at any time, for a personal data processing activity, such as for the purpose of direct marketing, without affecting the lawfulness of the processing based on prior consent;

Right to Objection – the right to object, at any time, to a processing activity based on a legitimate interest, provided that no legitimate reasons prevail over your interests, rights and freedoms, such as defending legal claims;

Right to Restriction of Processing – the right to request the restriction of processing of your personal data, in the form of: (i) suspension of processing or (ii) limitation of the scope of processing to certain categories of data or purposes of processing;

Profiling and automated individual decision-making – when the processing of personal data, including profiling, is exclusively automated (without human intervention) and may produce legal effects or significantly affect you, you shall have the right not to remain subject to any decision based on such automated processing, except as otherwise provided by law, you shall have the right that SRS takes appropriate measures to safeguard your rights, freedoms and legitimate interests, including the right to obtain human intervention in decision making by SRS, the right to express your point of view or contest the decision taken on the basis of automated individual information processing;

Right to Submit a Claim – the right to complain to the supervisory authority, CNPD, in addition to SRS.

The exercise of these rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged in consideration of the costs.

The information must be provided in writing, but may be given orally if requested. In this case, SRS shall verify your identity by other means.

The response to the requests shall be provided, as a rule, within a maximum period of 30 days, unless it is a particularly complex request or a multitude of requests.

Exercise your rights through the following e-mail address:

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