Social Media Policy

Retail Consult is committed to ensuring the security of personal data. 
As a result, Retail Consult has prepared this Privacy Notice for Social Networks, to make known the terms by which it collects and processes personal data, in accordance with Regulation (EU) 2016/769 of the European Parliament and of the Council, of 27 April 2016 – henceforth GDPR – and other personal data protection legislation. The processing of personal data described in this Notice concerns the processing of your data carried out on our pages on social networks. In this sense, we will explain how your data is processed, how we protect it and how you can exercise your rights. 


Who Is Responsible for Processing Your Data?
Retail Consult is the entity responsible for processing the data, under the terms of the GDPR, and can be contacted via privacy@retail-consult.com or by visiting one of our facilities. For certain data processing, we and the operators of social media platforms are jointly liable as outlined in article 26 of the GDPR. 

At Retail Consult, we operate on the following social media pages: 

  • Facebook: https://www.facebook.com/retailconsult 
  • YouTube: https://www.youtube.com/channel/UCdpwd9wgHtNR2al0DSVaUXw 
  • LinkedIn: https://www.linkedin.com/company/retail-consult-sa/ 
  • Twitte: https://twitter.com/retailconsult_ 
  • Instagram: https://www.instagram.com/retailconsult_/  
  • TikTok: https://www.tiktok.com/@retailconsult_ 


Responsibility of operators of social media platforms

Our organization has limited influence over the processing of data carried out by operators of social networks (eg member management and general information management). In situations where we have no influence, we try to ensure, as far as possible, that social media operators act in accordance with the privacy and data protection requirements required by the GDPR. However, in many cases, we have no influence on this data processing carried out by the operators of social networks and we do not have clear knowledge of the data being processed on certain occasions. 

Social network operators manage the entire IT infrastructure of the service, applying their own privacy and data protection rules and, in addition, maintain their own relationships with users (insofar as they are registered users on the social network). The operators of the social networks are solely responsible for questions regarding your profile data (from the page you created within the social network), so Retail Consult does not have access to this information, and cannot intervene in any possible alteration, replacement, or deletion, of the information in question. 

For more information on the processing of data carried out by the social media operator, see the respective Privacy Policies: 

  • Facebook: https://www.facebook.com/privacy/policy
  • YouTube: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/
  • ​LinkedIn: https://br.linkedin.com/legal/privacy-policy
  • Twitter: https://twitter.com/en/privacy 
  • Instagram: https://privacycenter.instagram.com/policy 
  • TikTok: https://www.tiktok.com/legal/page/eea/privacy-policy/en  

In relation to the use of social media platforms, your personal data will be processed and stored on servers located in third countries, in particular the USA. For this treatment, the operators of the social networks in question will be solely responsible, as established and defined in the policies. 


What are the purposes that precede the collection of your personal data and what is the basis for its treatment? 

a. Legitimate interest for our presence on Social Media: 
Inform our users/customers about products, services, job offers, market prospecting and news from the Organization, interact with other visitors to social media pages on these matters and reply to questions, praise and criticism. 
We may share your content on our social media pages and contact you through such platforms if they have such functionality. 
If, as mentioned above, the social media operator allows this possibility, we will ensure that our pages comply, as far as possible, with the applicable data protection regulations. Comments, videos, photographs, likes and public messages, among other data that you enter on our pages, will be published by social networks and will not be used or processed by us for any other purpose at any time. 
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b. Consent for sending newsletters 
You can also subscribe to our newsletter via our social media pages. If you agree to receive our newsletter, we will use your email and, if applicable, your name to send you information (as personalized as possible) about products, job vacancies, events and news from our organization. 

c. Legitimate Interest of the Organization for Social Listening and Social Media Monitoring 
We use “Social Listening” and “Social Media Monitoring” to understand the perception that exists regarding our products and services, evaluate our marketing activities, and identify possible needs for improvement. In this specific case, this analysis is carried out considering publications on our social networks (for example: engagement, reach and visits). In this case, only messages that are published without restrictions by users are considered. 
The amount of data collected mainly depends on the nature and content of the publication. For example, they can be publications in text or media format. Furthermore, in some cases, user identification may be relevant if Retail Consult wants to help solve a particular problem. We may also receive information from social media operators about the reach of a particular post. 


How long do we keep your personal data? 
Personal data is kept, given its purpose, in compliance with the applicable legal deadlines. In cases where a legal period does not apply with regard to the conservation and storage of personal data, such data will only be stored and kept for the appropriate period and to the extent necessary, taking into account the purposes for which they were collected, unless, in at any time, the holder of the personal data, within the legal limits, exercise their rights of opposition or erasure, or withdraw their consent.
All posts you make on our pages will remain on our pages indefinitely, unless we delete them as part of a topic update, if you violate any law or our guidelines, or if you delete your posts.
As for the data of social network operators, we have no influence over their deletion. Therefore, in these situations, the Privacy Policy of the operators of social networks in question is applied.

Joint responsibility (Article 26.º, Nº1 GDPR) 
A relationship of joint responsibility for data processing is established with the following social media operators, pursuant to Article 26º. nº1 of the GDPR: 

  • Facebook: https://pt-pt.facebook.com/legal/terms/page_controller_addendum 
  • YouTube: https://policies.google.com/privacy?hl=pt-PT 
  • LinkedIn: https://legal.linkedin.com/pages-joint-controller-addendum
  • Twitter: https://gdpr.twitter.com/en/controller-to-controller-transfers.html
  • Instagram: https://help.instagram.com/2000935033561463 
  • TikTok: https://ads.tiktok.com/i18n/official/policy/controller-to-controller 

The organization and social media operators establish joint responsibility through online monitoring methods implemented on their respective platforms. This online monitoring can also be carried out regardless of whether the user is logged in or registered on the platform. As mentioned above, we have no influence over the online monitoring methods used by social media. For example, we have no way to disable these methods. 
The legal basis for the aforementioned online monitoring methods is your consent in accordance with Article 6º. nº1, subparagraph a) of the GDPR. 
You can consult the Privacy Policies of the operators of social networks for more information on the criteria for defining the recipients of the data or the categories of recipients, as well as the retention periods, over which, it is worth noting, we have no influence. 
The possibility to exercise your rights to deactivate these online monitoring methods or to withdraw your consent are described in the Privacy Policy of the operators of social networks. You can also contact social media operators using the contact details set out in their legal information. 
Also note that social media operators may use your profile data and behavioral data, in accordance with their Terms of Use and Privacy Policy, to analyze your routines, personal relationships and preferences. Also in this matter, we have no influence on the processing or transmission of your data by the operators of the social networks. 


Under what circumstances do we transfer your personal data to third countries? 

The activities carried out by Retail Consult may involve the transfer of your personal data to third countries, located outside the European Union or that do not belong to the European Economic Area. 
In such cases, all necessary and appropriate measures will be taken to ensure the security of your personal data. 
The European Commission, through the adoption of adequacy decisions, will determine which third countries offer an equivalent level of data protection compared to the European Economic Area. If a particular country does not offer an equivalent level of data protection, we will ensure that adequate protection is ensured through other measures. This can be done through Binding Corporate Rules, Standard Data Protection Clauses adopted by the European Commission and officially recognized Certificates and Codes of Conduct. 
Your use of social networks may also result, consequently, in the processing of your data in a third country (located outside the European Economic Area). For more information on the processing of your data in third countries (over which we have no influence), please consult the Privacy Policy of social network operators, as set out in chapter 3. 


What are the rights of the holders of personal data? 
Pursuant to applicable law, you may exercise the following rights: 

  • Right of Access: obtain confirmation that your personal data are being processed or not and if so, access them.
  • Right of Rectification: obtain the rectification of inaccurate personal data concerning you and request that your incomplete personal data be completed;
  • ​Right to erasure: obtain the erasure of your personal data, except in cases where there are grounds that validate its conservation;
  • Right to Limitation of Treatment: obtain the limitation of the processing of your personal data when they concern certain categories of data or purposes of treatment;
  • Right of Portability: to receive the personal data you have provided to us, in a structured format for current use and automatic reading, as well as to request the transmission of your personal data to another person responsible for the treatment;
  • Right of Opposition: to object, at any time, to certain processing of your personal data, for example, in the case of the processing of personal data for the purposes of direct marketing;
  • Right of Non-Subject to Automated Individual Decisions, including Profiling: not to be subject to any decision taken exclusively on the basis of automated processing, including profiling, that has effects in your legal sphere or that significantly affects you in a way similar.
  • Right to withdraw consent: The withdrawal of consent does not, however, invalidate the treatment carried out up to the date of withdrawal. 

In order to exercise your rights, you must contact us via email: privacy@retail-consult.com

The holder of personal data also has the right to file a complaint with the National Data Protection Commission - CNPD -, or other competent supervisory authority, as well as to resort to any other judicial remedy, if he considers that his Personal data are not subject to lawful processing by Retail Consult, under the terms of current legislation and this notice. 

Contact Us 
If you have any questions about how Retail Consult collects and processes your personal data, you can contact us at privacy@retail-consult.com.