Privacy Policy

1.WHO ARE WE?

Admar SCR S.A. is an asset management founded in 2020, whose mission is to raise investors, through private equity funds that allow the development of a strategy investment in companies with high profitability potential in a structured way, professional and with very strict Governance and Compliance rules that allow creating a link of total trust between entrepreneurs, entrepreneurs and qualified investors. Ours main values are efficiency, professionalism and transparency throughout the chain of value, both in the search for investments and in the management and support of the day-to-day activities of all subsidiaries, as well as in the relationship and reporting to Investors and related entities. In this sense, this Policy is in line with Admar’s values and mission, having for the purpose of describing the processing of personal data carried out by Admar.


2. GOAL OF THIS PRIVACY POLICY

This Privacy Policy describes the purposes of the personal data processing carried out by Admar, how it is processed and stored, with whom it is shares, for how long it is kept and what the rights of the data subjects are.

3.PURPOSES OF PROCESSING

Admar needs to process personal data for the following purposes:

    1. Answering to requests related to Admar’s activity from any data subject.
    2. Managing proposals from investors.
    3. Managing proposals from suppliers.
    4. Managing access, electronic communications, and IT infrastructure.
    5. Administrative, accounting and tax management.
    6. Human Resources management.
    7. Compliance with legal obligations, particularly regarding the prevention of money laundering and terrorism financing.
    8. Managing legal proceedings and other legal diligences.
    9. Monitoring the quality of services provided.

During the processing of personal data, Admar ensures that access will be limited to people in the universe of Admar who need to know it, for the exercise of their functions and only if strictly necessary for the pursuit of the purposes for which the personal data were collected, or for purposes compatible with the initial one(s).


4. LEGAL BASIS FOR PROCESSING PERSONAL DATA

Admar is the data controller of the processing of personal data in the sense that such expression is defined in the General Data Protection Regulation (“GDPR”). The processing of personal data may occur in the following circumstances:

  1. When it is necessary to comply with legal obligations to which Admar is bound;
  2. When the processing of personal data is necessary for the performance of a contract or pre-contractual diligences associated with it, or to comply with requests made by the data subject in this regard;
  3. When the free, specific, informed and explicit consent of the data subject has been collected;

Admar may also process personal data if it has a legitimate interest in doing so, provided that, in each case, such interest is not overridden by the interests or fundamental rights and freedoms of the data subject which require their protection.

Admar only processes personal data for the purposes for which it collects, except when it considers that such data is necessary for another purpose and this purpose is compatible with the original one, especially for scientific or historical research purposes or statistical purposes. It may process such data for new purposes that are compatible with its original purpose, without communicating such processing to the data subjects, except where prohibited by law.

5.WHAT SECURITY MEASURES HAVE BEEN ADOPTED IN ORDER TO PROTECT YOUR PERSONAL DATA?

Information security and personal data protection are priorities for Admar. Therefore, Admar has implemented a set of technical and organizational measures that, taking into account the most advanced techniques, the costs of implementation, the nature, scope, context and purposes of each processing of personal data, allow to mitigate the risks to the data subject and prevent the occurrence of personal data breaches and security incidents in general.

In particular, the following measures, among others, are:

  • Making the necessary efforts to ensure that third parties collaborating with Admar guarantee adequate protection of the personal data to which they have access;
  • Limiting access to personal data to specific employees, and only when their contact with such personal data is justified within the scope of their duties;
  • Storage of all personal data processed by Admar in servers that offer security guarantees, including encryption, access control and backups;
  • Subjecting the systems and security policies to periodic reviews to ensure that the data is safe and protected;

    6. SHARING AND TRANSFER OF PERSONAL DATA

To comply with legal obligations that apply to Admar, for the performance of a contract or related to pre-contractual diligences, for the pursuit of its legitimate interests, or to carry out processing operations to which the data subjects have consented, Admar may share the personal data it processes with authorities, public entities, and processors.

Any sharing or transfer of personal data will only be made to third parties who ensure adequate protection of the personal data to which they have access, or who act exclusively under the direction of Admar (processors) and who comply with technical and organizational measures like those to which Admar is subject. Sharing which does not comply with applicable law and the rights of the data subjects will not be carried out. Sharing which does not comply with applicable law and the rights of the data subjects will not be carried out.

7. DATA RETENTION PERIODS

Admar only keeps personal data for the period necessary for the purposes for which they were collected. In certain cases, the data may be stored for longer periods, particularly when required by law or for statistical purposes. The periods for storing personal data are set out in the retention schedule adopted by Admar.

8. WHAT ARE THE RIGHTS OF THE DATA SUBJECTS?

Data subjects may at any time exercise their rights under applicable data protection legislation, and in particular:

  • obtain confirmation as to whether data concerning them is being processed and, where appropriate, request access to their personal data and the information provided by law.
  • To request the rectification, without undue delay, of inaccurate or incomplete data concerning them;
  • To request the erasure, without undue delay, of their personal data to the extent that they are no longer necessary for the purpose for which they were collected or processed or when Admar is no longer legally authorized to process them;
  • Request the limitation of the processing of their personal data, when legally applicable.
      1. Object to the processing of their personal data, in cases where this is carried out for the purposes of the legitimate interests pursued by Admar.
      2. Withdraw consent if the processing of the data in question depends on it. However, this right does not affect the lawfulness of the processing carried out based on the consent previously given, nor the subsequent processing of the same data based on another legal ground.
      3. To request the erasure, without undue delay, of their personal data to the extent that they are no longer necessary for the purpose for which they were collected or processed or when Admar is no longer legally authorized to process them;
      4. Request the limitation of the processing of their personal data, when legally applicable.
  • Object to the processing of their personal data,in cases where this is carried out for the purposes of the legitimate interests pursued by Admar.
  • Withdraw consent if the processing of the data in question depends on it. However, this right does not affect the lawfulness of the processing carried out based on the consent previously given, nor the subsequent processing of the same data based on another legal ground.

The data subjects may then exercise the aforementioned rights by sending an e-mail to Admar privacidade@admarscr.pt or by letter to the postal address: Avenida São Pedro, 33, 2765-446 Estoril.

The data subjects should be aware that in certain cases (e.g., due to legal requirements), their requests may not be granted. In any case, they will be informed of the measures taken to this effect within one month of the request being made.

If you feel that your rights have not been respected, you may also lodge a complaint with Comissão Nacional de Proteção de Dados (CNPD), through the email address: geral@cnpd.pt.

In any case, they will be informed of the measures taken to this effect within one month of the request being made.