Privacy Policy

Trust – Gestão Integrada de Saúde, S.A. guarantees the protection of the personal data made available to it through this website, continuously optimising the set of procedures and techniques designed to ensure compliance with the General Data Protection Regulation – GDPR – approved by Regulation (EU) 2016/679 of 26 April 2016 and other applicable legislation.

This Policy is intended to inform Users of how their personal data will be processed when browsing this website. Each time you use this website, your personal data will be processed in accordance with the Privacy Policy in force at the relevant time, and regular consultation of this Policy is therefore recommended.

Data Controller
The Controller of your data is Trust – Gestão Integrada de Saúde, S.A., corporate tax number 509 697 437, with registered office at Rua de Ceuta, no. 47, 4050-191 Porto, hereinafter "TRUST".
Data Collected, Purpose and Legal Basis
During the use of the website, TRUST collects both personal and non-personal information. "Personal data" means any information relating to an identified or identifiable natural person.

In the table below, you can see which personal data are collected and processed by TRUST, as well as the associated purposes and legal bases.

Purpose	Personal Data	Legal Basis
Management of and response to contact requests	Name; e-mail; telephone contact; any personal information the User chooses to include in the contact form.	Pre-contractual steps at the request of the data subject; legitimate interest of TRUST (Article 6(1)(b) and (f) GDPR);
Booking of consultations/services through the automated WhatsApp conversational tool (1)	Name, tax number, telephone contact and e-mail	Pre-contractual steps at the request of the data subject; legitimate interest of TRUST (Article 6(1)(b) and (f) GDPR);
Sending of newsletters and promotional campaigns (2)	Name, e-mail and SMS	Consent of the data subject (Article 6(1)(a) GDPR).

(1) TRUST provides an automated channel to support the booking of consultations through the WhatsApp application, which allows the user to provide essential data (name, tax number, telephone contact) and choose services by means of interactive menus or conversation. The sole purpose of this functionality is to facilitate the booking and management of consultations, without involving decisions based solely on automated processing that produce legal or significant effects. Whenever necessary, the user is directed to a human operator. The data processing carried out in this context falls within the purposes and legal bases referred to above. Should the user not have access to WhatsApp, the personal data collected (name, tax number and telephone contact) may be used to send an SMS with a direct link for booking consultations. TRUST uses this channel on the basis of its legitimate interest in ensuring that the booking process is accessible to all users, regardless of the platform used.

(2) Before the first marketing communication is sent to you, your express consent to the sending of communications will be requested. In each communication you will be given the opportunity to withdraw your consent.

Your personal data may also be processed whenever there is another legal basis that legitimises such processing, namely:

Legal obligation of TRUST (Article 6(1)(c) GDPR);
Legitimate interest of TRUST, provided that such interest does not override your fundamental rights and freedoms (Article 6(1)(f) GDPR);
Protection of your vital interests or those of a third party (Article 6(1)(d)).
In addition to the personal data listed above, when browsing this website, other data will also be collected in order to ensure the technical functionality of the website and to guarantee the stability and security of browsing, such as:

The user's IP address;
The date and time of the request or registration;
The content of the request (specific page);
The volume of data and the page transmitted;
The origin of the request;
The type of browser;
The user's operating system;
The language and software version of the browser;
Referral URLs;
Websites visited by the user's system through our website.
Most of the data listed above is collected through the use of cookies. For detailed information on what cookies are and how we use them, please consult our Cookie Policy.

Data Retention Period
TRUST will store your personal data for the time strictly necessary to achieve the purpose for which it was collected, and may also retain some of your personal data insofar as this is necessary to comply with its legal obligations, as well as to manage or enforce its rights.

Once the retention periods referred to above have elapsed, the personal data will be permanently deleted from our databases.

Data Sharing
TRUST may share your personal data with third-party entities involved in the provision of the contracted services, to the extent necessary for the pursuit of its activity, namely payment management and processing entities. Whenever this occurs, TRUST will ensure that such entities are able to comply with their obligations regarding privacy and the protection of personal data.

TRUST does not transfer or store your personal data in geographical regions that do not ensure the same level of data protection as that ensured by entities located in the European Economic Area (EEA).

All data transfers are carried out in accordance with the applicable legislation, using the mechanisms legally provided for this purpose.

TRUST holds public profiles on various social networks, with the aim of interacting with active users, stakeholders and clients, as well as providing them with information about its services. On this website, links to the social network profiles may be found.

The data of users collected through social network platforms, such as Instagram, LinkedIn and Facebook, may be processed in third countries, namely in the United States of America.

If you are logged in to your social network account and access TRUST's pages, the social network operator may associate that visit with your user account.

For more information on this subject, you should consult the privacy policies and terms and conditions available on the websites of the respective social networks.

In addition, the use of the customer service channel through the WhatsApp application, operated by Meta Platforms Ireland Ltd., may involve the sharing of personal data (name, tax number and telephone contact) with this entity, to the extent strictly necessary to enable the use of the chatbot and the booking of consultations. This sharing arises from TRUST's legitimate interest in providing a prompt and accessible service to its patients, with compliance with the requirements of the GDPR being ensured, including the conclusion of standard contractual clauses whenever this proves necessary for international data transfers.

Rights of Data Subjects
In accordance with the legislation in force regarding the protection of personal data, TRUST guarantees you the following rights as a data subject:

Right to be informed: at the time of collection of the personal data:

Of the contact details of the data controller;
Of the purpose(s) of processing;
Of the retention period;
Of your rights as a data subject;
Of the possibility of applying to the supervisory authority to lodge a complaint (and its contact details);
Of the (possible) existence of automated decisions and/or profiling;
To know where your data is stored and how it is processed;
To be informed of how the Data Controller complies with its data protection obligations.
Right of access: you may access your personal data; confirm whether or not your data is being processed and request a copy of it.
Right to object to processing: you may object to the processing on grounds relating to your particular situation.
Right to rectification: you may rectify your personal data if it is incorrect, out of date or incomplete.
Right to erasure: you may request the erasure of your data provided that, in the specific case, all the requirements are met.
Right to Portability: you may request the personal data concerning you that you have provided, in a structured, commonly used and machine-readable format; and the right to transmit that data to another Data Controller whenever:
The processing is based on consent or on a contract; and
The processing is carried out by automated means.
Right to restriction of processing: in certain situations, which must be considered on a case-by-case basis, you have the right to request the restriction of the processing of your data.
The exercise of rights by data subjects may be carried out through the e-mail address dpo@trustsaude.pt, or in writing to TRUST's postal address, in which you provide your identification and indicate the situation that is the subject of your request, to:

FAO: Data Protection
Address: Rua de Ceuta, no. 47, 4050-191 Porto

You may also lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Protecção de Dados – CNPD) and/or obtain redress and/or compensation, should you consider that the processing carried out infringes your rights and/or the applicable legislation on the protection of personal data and privacy.

Data Security
TRUST uses a set of appropriate security technologies and procedures to protect your personal data from unauthorised access, use or disclosure, such as: access control; logging of user activity; and penetration testing.

Your personal data is stored for hosting and backup on servers located in Portugal, in a secure environment, protected from unauthorised access.

As a user, you should protect your devices against viruses or other threats that may compromise their security, using programs specifically designed for this purpose.

Data Protection Officer
TRUST has appointed a Data Protection Officer, whose duties are as follows:

To monitor the compliance of personal data processing operations with the applicable legislation in force;
To provide advice on matters of privacy and personal data protection;
To cooperate with the CNPD;
To act as a point of contact with the CNPD, with the Supervisory Authorities of other European Union Member States, and with data subjects.
For clarification of any matter relating to your privacy and the protection of your personal data, you may contact the Data Protection Officer through the e-mail address dpo@trustsaude.pt.