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PRIVACY POLICY

Information about our privacy policy

This is a website operated by MEDWAY S.A. (hereinafter “MEDWAY,” “we,” “our,” or “us”). MEDWAY is registered in Portugal, Avenida da República Nr.66, 1050-197 Lisboa.

MEDWAY is committed to protecting your privacy. This Privacy Policy accounts for the Personal Information collected, processed, and used via the https://www.medway-iberia.com/ website (hereinafter “Website”).

By using this Website, you agree to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy, where and as permitted by applicable law.  If you do not consent to the collection, use and disclosure of your Personal Information as set forth in this Privacy Policy, please refrain from visiting this Website.

WHAT PERSONAL INFORMATION WE COLLECT

MEDWAY collects and processes certain Personal Information from you and your devices.

For the purposes of this Privacy Policy, “Personal Information” means information or data that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular naturally identified or identifiable person, consumer, device or in some circumstances household. It does not include de-identified, anonymized or aggregate information.

On our Website, the Personal Information collected will depend on which of our services you utilize. Most of our services provided via the Website do not require any form of registration, allowing you to visit our Website without providing Personal information.

However, some of our services offered via the Website may require you to provide us with your Personal Information.

If you sign up to receive communications including news, updates and promotions from MEDWAY, we will ask for a first and last name, country, city, email address and telephone number(s) (optional). https://www.medway-iberia.com/en/forms/contact-us

We may also post job opportunities, so that anyone can apply and submit a job application. To ensure that your profile matches the advertised position, MEDWAY processes your personal data for the recruitment process, including but not limited to your first and last name, country, district, city, address, postcode, e-mail address and telephone number, date of birth, gender, educational background and CV (only supported in PDF format) https://www.medway-iberia.com/en/forms/application-form .

From time to time, we may also collect your Personal Information on landing pages for specific promotions or targeted events. In this case, we will request your first and last name, region, country, email address and telephone number.

COOKIES

Like many other websites, MEDWAY and its service providers use cookies to collect information about visitors’ use of the Website.  Our Website uses cookies to distinguish you from other users of our Website.

Cookies are small text files assigned to your browser to collect internet log on and visitor tracking information (including IP address, browsing history, and geolocation data, where and as allowed by applicable law).

The information is used to track visitor use of the Website to compile statistical reports on Website activity. This helps us to provide you with a positive experience when you browse our Website and also allows us to improve our Website. We also may use cookies to provide you with information on products or services that may be of interest to you, where and as allowed by law. You may delete cookie files from the device you use to access our Website at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser. Please note that in a few cases some of our Website features may not function if you remove the cookies from your browser. For detailed information on the cookies we use and the purposes we use them for, you may consult our Cookie policy.

USES MADE/PURPOSE OF COLLECTION OF THE PERSONAL INFORMATION

We use the information about you for the following business purposes:

  • To ensure that content from our Website is presented in the most effective manner for you and your computer;
  • To notify you about any changes to our Website or services;
  • To provide you with our services;
  • To process your requests and inquiries;
  • To send you communications including news, updates and promotions at your request (Newsletter);
  • To attend your application to specialised training studies (e.g. Driving Licence Course);
  • To process your online job application (Candidates);
  • To confirm your identity;
  • To debug, identify, and repair errors that impair existing intended functionality of the Website;
  • To comply with legal obligations and respond to court orders;
  • To prevent or investigate fraud or other unlawful activities, detect security incidents;
  • To protect the security and integrity of the Website.

MARKETING

We will send you relevant updates, news and promotions about our services via email or SMS, but only if you have previously agreed to receive these communications, which may include marketing communications.

We also like to hear your views to help us improve our Services, so we may contact you with questionnaires. You always have the choice about whether to take part in our questionnaires.

OPTING OUT OF MARKETING ACTIVITY

You may choose to unsubscribe at any time from such communications by either clicking the unsubscribe link, or the link to edit your email preferences in the footer of the email you receive, or by following the opt-out options at the end of the SMS you receive. You may also email our marketing department directly at: prt-marketing@medway.com 

When an opt-out request is made, your details are marked in our database with an unsubscribe ‘flag’ so that you do not receive further direct marketing from us. If we know your postal address, it will be added to a suppression list to be excluded from any future posted direct marketing. Opt-out requests exclude any non-marketing communications that we deliver (by email, post, phone calls, SMS, or other means) that are related to you as our customer or any other the previous consents that you have signed with us (e.g. Shipping updates, Career updates, Promotional updates…).

REMARKETING

Remarketing consists of creating personalized ad campaigns for those users who have already visited our websites or registered our newsletter services by previously consenting this purpose.

We use third party vendors to design and run advertising campaigns on online platforms. Third party vendors, including Google, show our ads on sites across the internet by using cookies to generate ads based on your past visits to our Website (Google Analytics). These advertising campaigns may appear on your phone or device to show information about MEDWAY’s products and services. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings.

For more information click here: https://support.google.com/ads/answer/2662922?hl=en-GB

If you want to permanently opt out of Google’s or any vendors cookies, you will need to modify your preferences in the cookies settings  or delete, block or disable cookies via your web browser settings. please check out our Cookie Policy  for more information

SOCIAL MEDIA

MEDWAY may engage with customers or prospective customers through social media channels such as Facebook, YouTube, Instagram, LinkedIn, Twitter, etc, however no personal information is collected by us through these channels, unless explicit consent is provided by you.

INFORMATION WE COLLECT FROM OTHER SOURCES

From time to time, we may obtain information about you from third-party sources and third-party data providers. We make best efforts to ensure such third parties are legally and contractually permitted to disclose such information to us. Examples of the information we receive from other sources include demographic information, device information, location, and online behavioural data (such as information about use of other websites, page view information, search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant updates, news, promotions, features and services.

WE DO NOT SELL PERSONAL INFORMATION

We will not sell and have not sold within the past 12 months the Personal Information we collect through this Website. 

HOW PERSONAL INFORMATION IS SECURED AND RETAINED

Personal Information will be collected and stored in good faith, in a proportionate manner, for the business purposes indicated above. In order to protect the Personal Information, we have implemented state-of-the-art technical and organizational measures. We will retain your Personal Information for no longer than is necessary to fulfil the business purposes for which it was collected. The precise period will depend on the reason why it was collected.

Those periods are also based on the requirements of applicable data protection laws, applicable legal and regulatory requirements and periods relating to the commencement of legal actions.

DISCLOSURE OF THE INFORMATION

We may disclose your Personal Information to MEDWAY’s agents worldwide or to third parties who act on our behalf, such as our Website analytics provider. This is done in order to process the Personal Information for the business purposes outlined above. Such third parties, or agents are contractually bound to comply with similar and equally stringent undertakings of privacy, security and confidentiality.

We may also disclose your Personal Information to a third party if necessary to fulfil a request you have made or transaction you have initiated, if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary to support any criminal or legal investigation or proceeding.

DATA TRANSFER ABROAD

The Personal Information submitted to us may be transferred and processed for the business purposes described above to locations outside the country in which you are viewing this Website. This will definitely include Lisbon, Portugal, where our headquarters are located. This also potentially includes countries which may not require an adequate level of protection for your Personal Information compared with that provided by your country. By accepting this Privacy Policy, you consent to the transfer as described in this section, where and as permitted by applicable law.

SECURITY AND PRIVACY

MEDWAY takes every precaution to protect the confidentiality and security of the Personal Information of Website visitors or registered users by implementing industry-standard security safeguards, such as firewalls, or SSL certification coupled with carefully developed security procedures by our IT department. These measures are designed to protect visitors and registered users information from loss, misuse or unauthorised alteration. Using physical, electronic and procedural safeguards, we restrict access to Personal Information to employees on a “need-to-know” basis for business purposes.

LINKS

Our Website may, from time to time, contain links to and from websites of our partners’ networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to the websites.  MEDWAY does not endorse or make any representations about third-party websites. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy.

CHILDREN

We are committed to protecting the privacy of children. Our Website is not designed or intended to attract children under the age of 16. Our Website does not collect Personal Information from any person we actually know is under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that Personal Information from our servers.

DO-NOT-TRACK DISCLOSURE AND THIRD-PARTY TRACKING

Certain mechanisms may allow you to send web browser signals, known as “Do Not Track” (“DNT”) signals, indicating your choice to disable tracking on the Website. We do not respond to browser do not track signals at this time. We may not be aware of or able to honor and respond to every such mechanism. More information about “do not track” is available at www.allaboutdnt.org.

CONTACT

If you wish to exercise the following rights:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to object

Please fill out this form, or
Please contact us at the following address:

MEDWAY S.A.
Corporate Legal Department
Portugal, Avenida da República Nr.66, 1050-197 Lisboa.

If you are a resident of California or a resident or citizen of the European Union, please also refer below if you wish to know about your specific rights.

CHANGES

We may revise this Privacy Policy at any time by amending this page and changes will be effective upon being posted unless we advise otherwise. If we make any material changes to this Privacy Policy, we will notify you by means of a notice on our Website prior to the change becoming effective. By continuing to use the Website after changes are made to this Privacy Policy, you agree to such changes. We encourage you to check this page from time to time to take notice of any changes we make. If you do not accept the terms of this Privacy Policy, we ask that you exit our Website immediately.

The Privacy Policy published on our Website is kept up to date.

NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their Personal Information.

California User Rights

Right to Know and Access Personal Information Collected, Disclosed, or Sold

California residents may have the right to request that a business that collects Personal Information disclose the following: 1) categories of Personal Information collected about you within the past 12 months, as well as the related purposes for collection and the sources of the Personal Information; 2) specific pieces of Personal Information about you collected within the past 12 months; and 3) categories of Personal Information about you disclosed for a business purpose within the past 12 months.

You may make a verifiable consumer request for access or data portability from us twice within a 12-month period, free of charge.

Right to Request Deletion of Personal Information

California residents may have the right to request that a business that collects Personal Information about you delete that Personal Information, unless an exception in the CCPA applies. If MEDWAY cannot grant your deletion request, we will specify the basis for denial.

Right to Opt-Out of Sale of Personal Information

As noted above, we will not sell and have not sold within the past 12 months the Personal Information we collect through this Website.

Right to Non-Discrimination

MEDWAY will not discriminate against you for exercising any of your rights under the CCPA.

How to Exercise Your Rights

If you have the rights described above, you may exercise those rights by submitting a verifiable consumer request to us by filling out this form or by contacting us by phone (+351) 211 026 708. Only you or an authorized agent (as described below) may make a verifiable consumer request related to your Personal Information.

How to Authorize an Agent

An authorized agent may submit a request on your behalf, but only if the authorized agent also submits your written permission and a copy of the agent’s registration with the California Secretary of State.

How We Verify Your Request

To respond to your request under the CCPA we must verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us.

To allow us to verify your consumer request, please include the following information: name, address, phone number and email address. We will verify your consumer request by comparing the information you provide, with information already in our possession, and taking additional steps to minimize the risk of fraud, including asking for your identification document.

If you make contact with us in regards to any of the rights outlined above, we will respond within 30 days. If we require additional time to process your request, we will notify you within these first 30 days.

NOTICE ON LIABILITY IN THE UNITED STATES OF AMERICA

As mentioned above, we ensure a high level of security in order to protect your Personal Information. To the maximum extent allowed by applicable law, citizens of the United States agree and acknowledge that MEDWAY will not be liable or responsible if any Personal Information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security of your communications or Personal Information has been compromised, please notify us immediately using the contact information above.

NOTICE TO USERS WITHIN THE EUROPEAN ECONOMIC AREA AND CITIZENS OF THE EUROPEAN UNION

When you use the Website, we collect, store, use and otherwise process your Personal Information as described in this Privacy Policy.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

We rely on a number of legal grounds to process your Personal Information, including where: (i) necessary for our legitimate interests in providing and improving the Website including offering you content and advertising that may be of interest to you; (ii) necessary for our legitimate interest in keeping our Website safe and secure; (iii) necessary for the legitimate interests of our service providers and partners; (iv) necessary to perform our contractual obligations in the MEDWAY Terms & Conditions; (v) you have consented to the processing of your Personal Information, which you can revoke at any time (however a revocation does not affect the lawfulness of the processing of your Personal Information that occurred prior to the date of revocation); (vi) necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena or court order or to exercise or defend legal claims; and (vii) necessary to protect your vital interests, or those of others.

TRANSFER OF PERSONAL INFORMATION TO OUTSIDE OF THE EEA

Any transfer of your Personal Information (“EEA”) to an area outside of the EEA considered a non-adequate jurisdiction will only be made where appropriate safeguards have been put in place.

EEA RESIDENTS AND CITIZENS USER RIGHTS

EEA residents and citizens have the right to:

  1. Access the Personal Information we have about you;
  2. Have your Personal Information provided to you in a structured, commonly used and machine-readable format;
  3. Have your Personal Information corrected, restricted or deleted;
  4. Under certain circumstances, you can object to the processing of your Personal Information and we will discontinue such processing unless we have compelling legitimate grounds to continue;
  5. Withdraw the consent you previously provided (a withdrawal does not affect the lawfulness of the processing that occurred prior to the date of withdrawal); or
  6. Lodge a complaint with your local supervisory authority.

If you wish to inquire as to whether we maintain any Personal Information about you, and you wish to exercise any of the rights that are available to you with respect to such Personal Information, please contact us. In all cases we shall endeavor to respond to your request within 30 days. If we require more time in order to process your request, we shall inform you.

To allow us to verify your request, please include the following information: name, address, phone number, email address and a piece of identification.

Privacy policy last updated in January 2023

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