We want you to know how ARGO processes your personal data, as well as your rights as a data subject.
Argotalents, S.A., a joint-stock company located at Avª de Berna, No. 24 - 6th Floor, 1050-041 Lisbon, registered in the Commercial Registry of Lisbon under registration number and NIPC 507114876, referred to as ARGO, is responsible for data processing.
With this Policy, we aim to provide answers to the following questions:
What data does ARGO process, who does it pertain to, and how is it collected?
For what purposes and on what legal basis does ARGO process personal data?
What are the retention periods for personal data?
To whom does ARGO transmit personal data?
What rights do you have as a data subject?
How can you exercise your rights?
How can you contact us?
How can you stay informed about the processing of personal data?
1. What data does ARGO process, who does it pertain to, and how is it collected?
Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier, such as a name, an identification number, location data, electronic identifiers, or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
ARGO may process the following categories of personal data: a) Identification data (e.g., name, date of birth, gender, address, contact details, citizen card data, passport and tax identification number, nationality); b) Education and professional experience data (e.g., education, qualifications, certifications, languages, resumes, former employer information); c) Professional data (e.g., job title, role, job description, company, office address); d) Professional activity data (e.g., business activities, information related to processes and files); e) Billing and expense data (e.g., fees, travel expenses, and communications on behalf of the client); and f) Image and sound recording data (e.g., photographic and video images).
Data subjects are individuals to whom the data pertains.
The above-mentioned categories of personal data may belong to different categories of data subjects, such as candidates, clients, client employees (companies), or ARGO's suppliers.
ARGO collects personal data through various means and at different times, including when a candidate applies for a job or when a client engages our human resources recruitment and selection services, when you send us an email, or when you register on the ARGO website.
In some cases, ARGO may indirectly collect personal data, particularly through public sources such as LinkedIn. When ARGO processes personal data that it has collected indirectly, it will provide all relevant information regarding the processing of this data to the respective data subjects at the earliest opportunity.
2. For what purposes and on what legal basis does ARGO process personal data?
ARGO may process personal data for the following purposes and legal bases:
a) To provide human resources recruitment and selection services to clients, which may include:
Opening client accounts and files;
Recording service proposals submitted;
Communications with the client, other parties, and/or public entities; and
Archiving documentation in digital and physical formats.
The legal basis in this case is the execution of a contract and legitimate interest:
ARGO's interest in processing its clients' information in a sustainable and efficient manner, ensuring its quality and integrity and enabling the provision of excellent services; and
The interest of ARGO's clients in the execution of human resources recruitment and selection services.
b) For the recruitment and selection of candidates, which includes collecting and analyzing applications and resumes, as well as the recruitment and selection process at the request of the data subject (candidates).
The legal basis is the consent of the data subject (candidate).
c) For communications and the sending of information, including the disclosure of information about human resources recruitment and selection (e.g., newsletters, briefings).
The legal basis is the legitimate interest in responding to the requests of subscribers to ARGO website forms and tailoring communication accordingly.
d) For event management, which includes:
Sending invitations to events and registering event participants; and
Internal and external promotion of events.
The applicable legal bases are legitimate interest and consent (*):
Responding to requests from subscribers to ARGO's website forms and tailoring communication accordingly;
Promoting events organized by ARGO.
e) For billing and accounting management, which includes:
Expense accounting, cost control, and reimbursements (e.g., travel and other expenses to be borne by clients);
Invoicing and management of accounts; and
Maintenance of accounting records and supporting documentation.
The legal basis is the execution of a contract, legitimate interest, and compliance with a legal obligation:
Maintain efficient management control, invoice services in a timely manner, and ensure compliance with applicable legal obligations.
f) For debt collection and judicial and extrajudicial claims, including the collection and recovery of amounts owed by clients.
The legal basis is legitimate interest, as it is in ARGO's legal interest to satisfy its claims and defend its rights.
g) For the recruitment and selection of human resources for ARGO, which includes collecting and analyzing applications and resumes, as well as the recruitment and selection process for employees and collaborators based on ARGO's identified needs.
The legal bases are pre-contractual diligence at the request of the data subject and legitimate interest, with ARGO's interest in analyzing applications and subjecting candidates to an internal selection process based on pre-defined criteria.
(*) Prior consent of the data subject will be sought in cases where the event is recorded, whether in sound or image, or if photographs are taken.
3. What are the retention periods for which we keep personal data?
ARGO will only retain your data for as long as necessary to fulfill the purposes defined in this Policy or as required by applicable legal or regulatory requirements.
The retention periods for personal data, according to each processing purpose, are as follows: Processing Purpose > Retention Period
Provision of human resources recruitment and selection services to clients > Duration of the contractual relationship, plus 20 years.
Recruitment and selection of candidates > 3 years from the submission of the application or curriculum vitae, in the case that the candidate is not selected.
Communications and sending of information > Until the data subject expresses opposition.
Event management > 2 years from contact or participation in the event (whichever is applicable), if there is no further contact or participation in another event by the data subject.
Billing and accounting management > 10 years.
Debt collection and judicial and extrajudicial claims > Until payment of the amounts owed or resolution of the dispute, as applicable.
Recruitment and selection of human resources for ARGO > 3 years from the submission of the application or curriculum vitae, in the case that the candidate is not selected; and, when applicable, for the duration of the contractual relationship with ARGO.
4. To whom does ARGO transmit personal data?
ARGO does not transmit your personal data to third parties, except when necessary to provide the services you have contracted or to comply with legal obligations to which ARGO is subject.
The transmission of data to third parties is carried out in accordance with applicable data protection legislation and within the limits of the purposes and legal bases defined in this Policy.
ARGO may share personal data with the following entities:
Clients who contract human resources recruitment and selection services, as well as relevant parties for the services we provide, such as counterparties, regulatory authorities, government institutions, or attorneys;
Any company belonging to ARGO's group of companies;
Service providers who provide services to ARGO for the purposes described above, such as IT providers, communications services, translation services and digital and physical archiving services.
In cases where the transmission of personal data to the aforementioned entities involves an international transfer of the personal data (i.e. outside the European Union), ARGO will:
(i) carry out such transfer based on an adequacy decision by the Commission, pursuant to which the country or international organization concerned guarantees a level of protection of personal data equivalent to that resulting from European Union law; or,
(ii) where there is no adequacy decision by the Commission, it will ensure that such data transfers take place in strict compliance with legal provisions and that adequate safeguards are put in place to ensure the protection of personal data.
You can consult the existing adequacy decisions at www.eur-lex.europa.eu.
5. What rights do you have as a data subject?
As a data subject, you have the following rights:
Right to access
At any time, you can request confirmation if ARGO processes your data, access to your personal data, and information about their processing. You may also obtain a copy of the processed personal data.
Right to rectification
If your personal data is incorrect or incomplete, you can request that it be rectified or completed.
Right to erasure
In certain situations, you have the right to request the erasure of your personal data. This right may be limited in specific cases, such as when data processing is necessary to comply with legal obligations that ARGO is subject to, or when processing is necessary for the assertion, exercise, or defense of a legal right in a judicial proceeding.
Right to restriction of processing
In certain situations, you can request that ARGO restrict access to your personal data or suspend processing activities. This may occur, for example, when you contest the accuracy of your personal data, for a period that allows ARGO to verify its accuracy, or when you have objected to processing until it is determined whether ARGO's or a third party's legitimate interests prevail over yours.
Right to data portability
In cases where data processing is based on a contract to which you are a party or on your consent, you can request that ARGO provide you with the data you have provided in a structured, commonly used, and machine-readable format. You can also request that ARGO, where technically feasible, transmit this data to other data controllers.
Right to object
When data processing is based on ARGO's legitimate interest or is carried out for purposes other than those for which the data was collected but is compatible with the original purpose, you have the right to object to the processing of your personal data for reasons related to your particular situation.
In such cases, ARGO will cease processing your personal data unless there are legitimate grounds for such processing that override your interests.
Right not to be subject to automated individual decision-making
ARGO does not make automated individual decisions, including profiling, that have legal effects on you or significantly affect you in a similar manner.
Right to withdraw consent
In cases where data processing is based on your consent, you may withdraw your consent at any time. If you withdraw your consent, your personal data will no longer be processed unless there is another legal basis for such processing.
• Right to lodge a complaint with the supervisory authority
You have the right to lodge complaints with the competent supervisory authority regarding matters related to the processing of your personal data.
In Portugal, the competent supervisory authority is the National Data Protection Commission (Comissão Nacional de Proteção de Dados).
For more information, visit www.cnpd.pt.
ARGO cautions that the exercise of the above-mentioned rights may be limited due to the existence of third-party rights and freedoms, legal obligations, confidentiality, and ARGO's or a third party's prevailing legitimate interests.
6. How can you exercise your rights?
You can exercise your rights through any of the following channels:
Email: You can exercise your rights via email at RGPD@argopartners.pt; or
Letter: You can exercise your rights by sending a letter addressed to Fernanda Rodrigues, ArgoTalents, S.A., at the following address: Avenida de Berna, No. 24 – 6th Floor, 1050-041 Lisbon, Portugal.
The exercise of your rights is free of charge.
7. How can you contact us?
If you have any questions or need further information regarding the processing of personal data or the rights you enjoy as a data subject, please contact us through the following channels:
Email: Send an email to RGPD@argopartners.pt; or
Letter: Address a letter to Fernanda Rodrigues, ArgoTalents, S.A., at the following address: Avenida de Berna, No. 24 – 6th Floor, 1050-041 Lisbon, Portugal.
8. How can you stay updated about the processing of personal data?