1. PRESENTATION AND LEGAL FRAMEWORK

ITSCRED – INFORMATION TECHNOLOGY, S.A., traded corporation, with its head office in Estr. da Circunvalação 12252 2nd Floor - Room 202, 4460-282 Sra. da Hora, registered in the Conservatory of the Commercial Registry of Porto, under the no. 514829320, with a share capital of 100.000 Euros, intends, by providing and complying with the present Policy Privacy, to correspond to the Regulation guidelines (UE) 2016/679, of the European Parliament and of the Council of the 27TH of April of 2016 - General Regulation on the Protection of Personal Data, and also to the assortment of the Portuguese laws which regulate the theme of the protection of personal data.

2. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

ITSCREDIT ensures that the data which is processed is:

- Object to lawful, fair, and transparent processing regarding the data subject;
- Collected for specific, explicit, and legitimate purposes, and not further processed in a manner incompatible with those purposes;
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date;
- Kept in a form which permits identification of data subjects for no longer than is necessary;
- Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage.

3. LAWFULNESS OF PROCESSING PERSONAL DATA

The processing of data by ITSCREDIT is lawful when at least one of the following conditions is met:

- The data subject has given explicit consent for one or more specific purposes;
- Processing is necessary for the performance of a contract to which the data subject is party, or to take steps at the request of the data subject prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation;
- Processing is necessary to protect the vital interests of the data subject or another natural person;
- Processing is necessary for the purposes of legitimate interests pursued by ITSCREDIT or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

When processing is based on consent, the data subject has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

4. TYPES OF DATA COLLECTED

Depending on how users interact with the site, ITSCREDIT may collect:

- Identification and contact data (e.g. name, email, phone number);
- Professional data (e.g. CVs, LinkedIn profiles, job titles);
- Commercial or contractual data (e.g. company name, invoicing data);
- Technical data (e.g. IP address, cookies, browser data);
- Other information provided voluntarily via forms or email.

5. PURPOSES OF DATA PROCESSING

ITSCREDIT collects and processes personal data for the following purposes:

- Responding to contact or demo requests;
- Managing commercial or contractual relationships;
- Sending marketing communications, newsletters, or product updates (based on consent);
- Recruitment and evaluation of job applications (see section 6);
- Security of facilities and systems;
- Website usage analytics and performance optimization.

6. RECRUITMENT AND JOB APPLICATIONS

When users submit CVs or apply through our Careers page or contact forms:

- Data is processed solely for recruitment purposes;
- Only authorized HR personnel and directly involved hiring managers will have access;
- CVs and application materials are stored securely within our systems and are restricted to authorized Human Resources personnel only. While administrative user roles may have broader technical access within the system, appropriate access control policies are in place, and access to recruitment data by non-HR staff is strictly prohibited and regularly reviewed in accordance with our internal data protection
- Data is kept for a maximum of 12 months, unless the applicant withdraws consent earlier or provides permission to retain it longer.

7. COOKIES AND TRACKING TECHNOLOGIES

ITSCREDIT uses cookies to improve user experience and collect anonymous analytics:

- Essential cookies – Required for site functionality;
- Analytics cookies – Help measure traffic and improve performance;
- Marketing cookies – Used for remarketing or campaign tracking.

Users may manage cookie preferences through their browser or via the cookie consent banner.

8. SECURITY MEASURES

ITSCREDIT adopts appropriate technical and organizational measures to safeguard personal data, including:

- Role-based access control;
- Encrypted data transmission and secure hosting;
- Regular backups and vulnerability audits;
- Staff training and confidentiality protocols.

9. DATA SHARING AND THIRD PARTIES

Data may be shared with:

- Service providers (e.g. hosting, email infrastructure) under strict data processing agreements;
- Legal or regulatory authorities where required;
- Buyers or entities in case of a merger, acquisition, or corporate restructuring, under adequate safeguards.

We do not sell personal data to third parties.

10. DATA RETENTION

Retention periods vary by purpose:

Purpose	Retention Period
Recruitment data (CVs, applications)	Up to 12 months
Marketing data	Until consent is withdrawn
Contractual and invoicing data	Up to 10 years (legal obligation)
General contact form submissions	Until consent is withdrawn

Data may be anonymized for statistical or analytical purposes beyond the above periods.

11. INTERNATIONAL DATA TRANSFERS

ITSCREDIT does not transfer personal data outside the European Economic Area (EEA), unless adequate safeguards are in place (e.g. Standard Contractual Clauses, adequacy decisions).

12. DATA SUBJECT RIGHTS

Data subjects may request:

- Access to their personal data;
- Rectification of inaccurate or outdated information;
- Erasure (“right to be forgotten”);
- Restriction of processing;
- Data portability;
- Objection to processing based on legitimate interests or direct marketing.

Requests may be submitted to: info@itscredit.com

13. UPDATES TO THIS POLICY

This policy may be updated to reflect legal, technical, or business changes. All updates will be posted on this page and dated accordingly.

Last updated: June 5th, 2025