This Privacy Policy applies to any and all processing of personal data carried out by Masterlink.
The subjects of the personal data processed by Masterlink to which this Policy applies may be clients, employees, candidates, suppliers, service providers, or any third party with whom Masterlink interacts within the scope of its business activity.
The rules and procedures referred to in this policy may be further detailed in other internal policies.
To clarify any doubts regarding the application of this Privacy Policy, please contact us via email at solutions@masterlink.pt
Whenever necessary, Masterlink will amend this Privacy Policy in accordance with laws, regulations, and best practices. These changes will be notified to employees, clients, and interested parties via email or notices as most appropriate.
These changes shall be notified by Masterlink to its employees, data subjects, and other recipients through the following communication channels:
Masterlink is committed to the confidentiality and protection of the personal data of its Clients, Employees, Service Providers, and Suppliers, under legal terms and in compliance with the General Data Protection Regulation (GDPR).
Within the scope of its activity, Masterlink may, by automated or non-automated means, proceed with the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of availability, erasure, or destruction of the personal data of its clients and employees.
Masterlink will collect and process personal data for specific, explicit, and legitimate purposes, and it cannot be subsequently processed in a manner incompatible with those purposes.
The data collected will be only those necessary and appropriate for the fulfillment of the described purposes and will be kept only as long as necessary and in an updated manner.
Personal data shall be kept for a predefined or definable period of time, taking into account the purposes of the processing, and must be deleted or perfectly anonymized after the retention period has elapsed.
Masterlink will use a system for the systematic review and updating of personal data present in its own systems, as well as in those of third parties with whom it relates as a data controller, joint controller, or processor.
Masterlink undertakes to use internal security systems and procedures for the protection of the personal data of its Clients, Employees, Service Providers, and Suppliers that guarantee its integrity and confidentiality.
Masterlink undertakes to maintain fair and transparent processing of the personal data in its possession.
The processing of personal data is governed by the Data Protection Law approved internally and by the General Data Protection Regulation 2016/679 (the “GDPR”), or other applicable legislation.
Masterlink uses the personal data provided by its Clients, Employees, Service Providers, and Suppliers of other data subjects with whom it relates in the scope of its professional activity, in order to comply with its contractual obligations.
The data generally collected from our Clients include, among other possibilities, the name of the contact person, address, email, telephone contact, tax identification number, and IBAN.
The data usually collected from our Employees include, among other possibilities:
Other data may be collected from our clients and employees if necessary and will be processed in accordance with all legal obligations.
In accordance with legal and regulatory requirements regarding data protection, Masterlink guarantees that personal data subjects can exercise their rights regarding how their personal data is processed and stored.
To exercise their rights, subjects must contact Masterlink through the contacts provided below for this purpose, and these requests will be forwarded according to legal requirements.
Masterlink may, before processing the request, proceed with the prior verification of the applicant’s identity whenever it has doubts about the identity of the person who submitted the request.
Requests to exercise rights will be answered without undue delay and within a maximum period of one month from the date of receipt of the request. Given a high complexity of the request or number of requests made, the response period may be extended up to two months. If the response period is extended, Masterlink will inform the data subject, within a maximum period of one month after the date of receipt of the request, of the reasons for the delay in responding to the request.
Masterlink seeks to respond to all requests, with all requests being subject to analysis to verify if their fulfillment is in accordance with applicable legal and regulatory requirements. Whenever there is a legal and/or regulatory framework that prevents the data subject from exercising an invoked right, Masterlink reserves the right not to grant the request. In such situations, Masterlink will communicate to the data subject, within a maximum period of one month from the date of receipt of the request, the reasons why the request will not be satisfied and the possibility of complaining to a supervisory authority and seeking judicial action.
When requests submitted are manifestly unfounded or excessive, Masterlink also reserves the right to demand the payment of a reasonable fee taking into account the administrative costs of providing the information or communication, or of taking the requested measures.
The rights that can be invoked are set out in the following points as defined in the applicable legal and regulatory standards, noting their main particularities. Masterlink provides preferred communication channels to invoke them. Requests to invoke the rights of Masterlink Employees within the scope of their professional relationship must be placed via email to suporte@masterlink.pt. For situations not covered in the next sections, the data subject may invoke their right through one of the channels presented in the Contact section.
At any time, you can contact Masterlink to request confirmation as to whether or not personal data concerning you is being processed by Masterlink, as well as to be informed about the personal data in question, the justifying reasons for the processing of that information, the recipients to whom the personal data has been or will be disclosed, the information available about their origin and, if possible, the respective retention period. If requested, you can receive a copy of the personal data undergoing processing.
The data subject may, taking into account the purposes of the processing, correct their personal data if it is incorrect or incomplete, as well as update it whenever it is outdated.
Every data subject has the right to request the erasure of personal data whenever it is found, for example, that it is no longer necessary for the purpose that motivated its collection or processing, or when the data subject withdraws their consent, in cases where this is applicable, provided that there is no other legal basis for said processing, prevailing legitimate interests that justify the processing, or the processing is necessary for the purposes of declaring or defending a right in a judicial process.
Masterlink will analyze the request and, if considered valid in light of the applicable legal and regulatory standards, will confirm if the data was deleted or the reason why this was not possible.
The data subject may request the restriction of the processing of their data if one of the legal conditions is met:
With the exception of storage, when processing has been restricted, personal data will only be processed by Masterlink with the subject’s consent, for the purposes of declaring, exercising, or defending a right in a judicial process to defend the rights of another natural or legal person, or for compelling reasons of public interest.
In case of cancellation of the restriction granted to the processing of personal data, Masterlink will inform the data subject in advance.
The personal data subject has the right to request at any time that Masterlink cease the processing of their personal data. After receiving your request, Masterlink will analyze the request and, if considered valid in light of the applicable legal and regulatory standards, Masterlink will cease the processing in question. If no decision is made regarding the feasibility of the request within a maximum period of one month, Masterlink will suspend the processing or treatments in question, as far as possible, until the final decision is made.
In general, Masterlink processes the personal data of subjects in the following contexts, with the following purposes and legal grounds in mind:
The personal data subject has the right to request that Masterlink transfer or deliver in a structured, commonly used, and machine-readable format the subject’s personal data whenever it is in Masterlink’s possession, under applicable legal terms, and whenever the data processing is carried out by automated means and is based on their consent or is necessary for the execution of a contract to which the subject is a party or for pre-contractual measures at the request of the data subject.
Masterlink will comply with the request, where feasible to do so, within one month of receiving it.
Masterlink shall refuse portability requests whenever these harm the rights and freedoms of third parties, or if another limitation established in applicable legal or regulatory standards applies.
The data subject may, if they consider that their data has not been processed according to legal provisions, lodge a complaint with the supervisory authority.
Currently, the authority with supervisory functions for data protection purposes in Portuguese territory is the National Data Protection Commission (“CNPD”), to whom you may address any questions or lodge complaints if you find non-compliance with standards relating to the protection of personal data.
The CNPD can, at this date, be contacted in the following way:
Information Request Form:
https://www.cnpd.pt/bin/duvidas/duvidas_frm.aspx
Complaint/Claim Submission Form:
https://www.cnpd.pt/bin/duvidas/queixas_frm.aspx
Rua de São Bento n.º 148-3º 1200-821 Lisboa
Tel: +351 213928400 / Fax: +351 213976832
geral@cnpd.pt
In general, Masterlink processes the personal data of subjects in the following contexts, with the following purposes and legal grounds in mind:
Within the scope of Employee recruitment processes, Masterlink will only request from candidates the data strictly necessary for the purposes of the recruitment process, ensuring the communication of legally required information to the candidate.
Masterlink processes its Employees’ data with a view to the execution of the employment contract or the fulfillment of its legal obligations as an employer, namely to perform salary processing, to comply with obligations related to health, safety, and hygiene at work, occupational medicine, etc.
This information will be collected in person or via email, being provided by the employee and stored in Masterlink’s computer system and paper files.
The identification and contact data of employees may be sent to entities subcontracted by Masterlink, always with the guarantee of compliance with applicable legal and regulatory standards.
Any data of a special category will be processed in strict respect for the applicable legal and regulatory standards, and should not, in particular, be subject to use for purposes other than those for which they were collected or used by a person who should not have access to them, and technical and organizational measures being implemented to guarantee the segregation of access to the data.
By legal obligation, Masterlink must retain its Employees’ data even after the termination of the contractual link, until the prescription of legal rights or obligations.
Upon signing the employment contract, all employees must sign a confidentiality agreement, undertaking not to disclose any information to which they have access during their duties, especially personal data of other subjects, and to obey this policy, according to the terms applicable at each moment as a result of any change made to it.
Within the scope of the training provided to its Employees, Masterlink may collect, in addition to the identity of the trainees, information relating to the training received by them.
Within the scope of training actions, the names of Employees may be transmitted to training service provider entities contracted by Masterlink.
Employees will be previously informed regarding the transmission of personal data, its recipients, and the purposes for which such transmission is intended, as well as regarding other information that must be transmitted to them under the legal and regulatory terms in force.
In accordance with applicable legal and regulatory standards, employees must be ensured the guarantees provided for in matters of occupational medicine and health and safety at work (HST). In this context, identification and health data about Employees are collected, and the collection and processing of data must be carried out under legally provided terms.
The data collected are recorded in a medical fitness file, which may be requested by a supervisory authority within the scope of HST.
This information may be collected and processed by occupational medicine and health and safety at work service providers contracted by Masterlink, always in strict compliance with applicable standards.
Masterlink ensures that it knows and fully complies with all requirements regarding the processing of personal data for the purposes of occupational medicine and health and safety at work.
Within the scope of the conclusion and execution of some legally mandatory insurance contracts or those that Masterlink, as the policyholder, offers to its employees, special personal data of employees as insured persons and their beneficiaries may be communicated. Such communications must be made directly from the employees to the insurance company with which the insurance contract is concluded.
Within the scope of the conclusion and execution of insurance contracts that do not require the transmission of special category data, Masterlink may, eventually, intervene in the processing of the data, always according to the principle of data minimization.
Masterlink may make computer and telephone equipment available to its employees whenever this is justified and necessary for the normal performance of their duties. The use of this equipment, owned by Masterlink, will be limited to professional purposes.
If the equipment provided is or may be subject to monitoring by the operator or supplier company, such processing must be communicated to the employee at the time of delivery of the equipment.
Such monitoring will be preceded by due analysis from a legal and regulatory point of view, as well as a prior impact analysis.
Masterlink may collect identification and contact data for purposes not related to the provision of work or services in question when justified by valid purposes and legal grounds.
The collection and processing of identification and contact data to congratulate or support employees in personal situations, such as the celebration of birthdays or weddings of employees or for support in the event of the death of an employee’s relative, may be carried out based on the valid prior consent of such employee for the purposes of making personal communications.
Masterlink may collect and process identification data or proceed with the recording of video surveillance images in its own facilities, for the purpose of controlling access to them or criminal prevention, based on Masterlink’s legitimate interests.
In any case, the processing of such data for the indicated purposes must be preceded by legal analysis and prior impact analysis, and all measures must be taken with a view to compliance with the legal and regulatory standards in force.
In the development of its activity, Masterlink also processes personal data of clients necessary for contractual execution and/or for the fulfillment of legal obligations, with a view to managing the contractual relationship, including, but not limited to, registration as a new Client, sending communications for the purposes of contractual execution and management and/or marketing campaigns, when consented to by the Client, responding to any communications sent by mail, telephone, email, or other means, and also the management and collection of payments, fees, and/or applicable charges.
The use of data provided by these subjects is generally done within the context of the contractual link and for the execution of the contract or for the fulfillment of a legal obligation to which Masterlink is subject, unless the subject consents to explicit purposes or in cases where another ground provided for in a legal or regulatory standard applies.
In some cases, by legal obligation, Masterlink must retain the data of these subjects after the termination of the contractual link, in which case the subject will be informed, at the time of collection, about the applicable retention periods or the criteria according to which they can be identified.
Upon signing the contract, Employees, Suppliers, or Service Providers will sign a confidentiality agreement, undertaking not to disclose any information to which they have access during the contractual link with Masterlink, especially personal data of other subjects, and to obey this Policy, according to the terms applicable at each moment as a result of any change made to it.
In some cases, by legal obligation, Masterlink must retain the data of these subjects after the termination of the contractual link, in which case the subject will be informed, at the time of collection, about the applicable retention periods or the criteria according to which they can be identified.
Within the scope of the Newsletter subscription, Masterlink uses the data provided by users to send email communications with product and service news from Masterlink, news related to our company, communication of events and training activities, informative and opinion articles about our areas of activity, or other communications about the market where we operate.
Your data may be processed manually or automatically for these purposes, and you can cancel your subscription at any time through the links provided in all the newsletters we send.
The newsletters contain a user activity tracking code, in order to obtain statistics such as: open rate and clicks on the links sent, user interest regarding the contents and campaigns of the newsletters, and user interaction with our website and social networks derived from the newsletters.
Masterlink may need to share your personal data with third parties acting on its behalf or providing services to it. Your personal data will be kept secure at all times and will only be shared with such third parties when strictly necessary. Your personal data may, in particular, be disclosed to the following entities:
For contractual reasons, Masterlink holds some of your personal data, namely for the management of the contractual relationship. This means that we are responsible to you for the treatment we give to it.
Masterlink will treat all personal data for which it is the data controller with the utmost confidentiality, complying and ensuring compliance, within its capabilities and responsibility, with its unlawful use.
Masterlink workers who do not comply with the terms and conditions of this Privacy Policy, or other internal standards on personal data protection that implement it, are subject to the initiation of disciplinary proceedings.
Personal data are kept in strict compliance with legal provisions or for the period indispensable for the fulfillment of the purpose that motivated its collection and processing, during the activity carried out by Masterlink.
Masterlink complies with all legal obligations, also regarding the retention and updating of personal data. The storage and destruction of data are carried out in a secure manner. The data collected are strictly necessary and protected from loss, misuse, unauthorized access, or exposure.
Masterlink ensures the security of your data and compliance with all legal obligations in case of a security breach.
To guarantee the security of personal data, Masterlink has implemented a set of technical and technological measures and procedures.
Masterlink will use a range of data security controls, defined according to business needs and security policies, and will actively monitor these controls to detect failures or violations, including the review of access authorizations to personal data, its own or those of third parties, by personal data subjects and Masterlink employees.
Should it be necessary to process your data for a new purpose, not covered by this document, Masterlink will send you a notification explaining the reason and the conditions of processing.
On our website, we use Cookies that collect some data.
International data transfer
Masterlink will not transfer personal data outside the European Union or to an international organization without adequate safeguards being implemented to ensure that personal data is kept secure, such as Standard Data Protection Clauses or Adequacy Decisions of the European Commission.
Please contact Masterlink regarding this Privacy Notice or your personal data:
Masterlink
Email: solutions@masterlink.pt
Telephone: +351 213 156 660 – Call to national fixed network
Update date: 2025-10-18