WAY BEYOND is committed to respecting users' privacy and to protecting and securing their personal data. Users should read this privacy policy carefully and decide freely whether they wish to provide their personal data to WAY BEYOND before using its services.

The user guarantees that he/she is of legal age and that the data provided is true, accurate, complete and current, and is responsible for any non-compliance. If the data communicated belongs to a third party, the user guarantees that they have informed the third party of the conditions set out in this document and that they have obtained their authorization to provide their data to WAY BEYOND for the purposes indicated.

About the company

WAY BEYOND is a Portuguese company based at Rua do Centro Cultural, 6A, 1700-107 Lisbon, dedicated to providing coaching, mentoring and consultancy services.

In the performance of its activity, WAY BEYOND is the entity responsible for the processing of personal data and will ensure the protection of the personal data of its users, in accordance with the provisions of this Privacy Policy and in accordance with the principles and standards established in the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016) and in the Data Protection Law (Law no. 58/2019, of August 8).

About this Privacy Policy

This Privacy Policy regulates the processing of personal data collected by WAY BEYOND, specifying the reasons for its collection, as well as the terms and manner in which it will be used and, if necessary, transmitted to third parties.

WAY BEYOND is committed to the protection and confidentiality of its users' personal data and has adopted the measures it deems appropriate to ensure the accuracy, integrity and confidentiality of personal data, as well as all other rights of the respective holders, under the terms and for the purposes of the applicable legislation, in particular by virtue of the application of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 ("GDPR").

We are committed to respecting the best practices in the field of security and protection of our clients' personal data, ensuring that all those who entrust us with the collection and processing of their personal data are aware of the purpose for which they are collected, as well as all the procedures adopted to fulfill the rights of the holders of the personal data.

Purpose of processing personal data

WAY BEYOND assumes responsibility for collecting and processing the personal data necessary to fulfill the contract entered into - personal data means any information of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable natural person.

In order to fulfill its various purposes, WAY BEYOND may process the following types of personal data:

• identification data (such as name, nationality, ID card, tax number, date of birth);

• contact details (such as mobile, telephone, address or e-mail);

• data relating to professional activity (such as profession and place of work);

• compensation data;

• candidate assessment data as part of recruitment and selection processes for WAY BEYOND employees;

• bank details (necessary for issuing financial documents).

Within the scope of our activity, personal data may be collected by WAY BEYOND in person, by telephone, by e-mail, by subscribing to our newsletter or by filling in registration/evaluation forms, or even when submitting a professional application, the processing of which under the terms of the legislation on the protection of personal data complies with the appropriate technical and organizational security measures.

In some cases, WAY BEYOND may collect personal data indirectly. When WAY BEYOND processes personal data that it has collected indirectly, it will provide all information regarding the processing of such data to the respective data subjects at the earliest opportunity.

Under no circumstances will personal data on racial or ethnic origin, political opinions, religious or philosophical beliefs, political opinions, trade union membership, data relating to health and sex life, genetic data, biometric data or data relating to sex life or sexual orientation be requested.

Under no circumstances will WAY BEYOND carry out any of the following activities with the personal data provided through its website, in person or by telephone, without the prior express consent of the data subject:

• Sending commercial and promotional communications;

• Giving in to third parties;

• Transferring personal data outside the European Economic Area (EEA).

The personal data collected is processed by computer and in strict compliance with the aforementioned legislation on the protection of personal data. It is stored in specific databases created for this purpose and, under no circumstances, will the data collected be used for any purpose other than that for which the data subject has given their consent.

Grounds and purposes for collecting personal data

All data collected and processed by WAY BEYOND is based on one of the following conditions of legitimacy:

• Consent from the data subject to process their personal data for specific, explicit and legitimate purposes, namely purposes related to sending newsletters, carrying out marketing actions and sending advertising information regarding WAY BEYOND's activity and services. 

• Execution of a contract or pre-contractual steps. This ground applies whenever WAY BEYOND processes personal data for the purpose of providing coaching and mentoring services.

• Compliance with legal obligations. Basis applicable when processing is necessary for compliance with a legal obligation, such as communicating data to other public administrative, tax or judicial bodies.

• Legitimate interest. This ground for lawful processing of personal data will operate in cases where the processing is necessary for the pursuit of the legitimate interests of the entity responsible for the processing or of third parties, without harming the rights and freedoms of its clients and/or users.

Website and Newsletter

Our website, located at waybeyond.pt, is the property of Centro Europeu de Coaching VSR, Lda., hereinafter referred to as WAY BEYOND, and its purpose is to publicize its services and portfolio, as well as to enable contact with current and potential clients, and is subject to cookies.

Cookies are small units of information needed to be able to identify the visitor during their online visit. In this way, we can identify and maintain your preferences.

Cookies do not store any personal or confidential information relating to the user, so only information relating to the pages visited is stored.

You can subscribe to our newsletter via the website by providing your e-mail address, and you can unsubscribe at any time.

Term of conservation of personal data

The period for which the data is stored and kept varies according to the purpose for which the information is collected and processed - WAY BEYOND will keep the personal data collected only for the period necessary for the purposes for which it is processed.

Therefore, and whenever there is no specific legal requirement, the data will only be stored and kept for the minimum period necessary for the purposes for which it was collected.

After this period, your personal data will be deleted. However, there are cases in which the personal data is necessary for the data controller (WAY BEYOND), or for subcontractors, to prove compliance with contractual or other obligations, in which case the personal data may be retained for as long as the limitation period for the corresponding rights has not elapsed (for example, for billing purposes, where, in general terms, the retention period for personal data is 10 years).

 Data Security

WAY BEYOND declares that it has implemented and will continue to implement the security measures of a technical and organizational nature necessary to guarantee the security of the personal data provided to it, in order to prevent its alteration, loss, processing and/or unauthorized access, taking into account the current state of technology, the nature of the data stored and the risks to which they are exposed.

Whenever it accesses personal data, WAY BEYOND undertakes to:

• To store them by means of legally required security measures of a technical and organizational nature that guarantee their security, thus preventing alteration, loss, processing or unauthorized access, in accordance with the state of the technology at any given time, the nature of the data and the possible risks to which they are exposed;

• Use the data exclusively for the purposes previously defined;

• Ensure that the data is only processed by employees whose intervention is necessary to satisfy the data subject's request, and that they are bound by the duty of secrecy and confidentiality. If it is possible for the information to be disclosed to third parties for these purposes, they must be obliged to keep it confidential in accordance with the provisions of this document.

Without prejudice to all the security mechanisms adopted and compliance with all personal data protection rules, users should be aware that if they do not have the necessary protection barriers (e.g. anti-virus, firewall, anti-spyware) when browsing the Internet, their personal data may be seen and used by unauthorized third parties.

In this context, all users are warned to take appropriate security measures when using the Internet, in particular by ensuring that they use a browser that allows the use of secure communication.

Rights of the data subject

Personal data subjects have the following rights at any time:

1. Right to transparency;

2. Right to information;

3. Right of access;

4. Right to rectification;

5. The right to be forgotten;

6. Right to restriction of treatment;

7. Portability rights;

8. Right to object;

9. The right not to be subject to any automated decision;  

10. Right not to have sensitive data processed; 

11. Right to lodge a complaint with the competent supervisory authority (in this case, the National Data Protection Commission).

All the rights referred to herein, expressly provided for in the GDPR, must be exercised by identifying their holders (by means of a copy of their ID card or other identification document) to WAY BEYOND's address or email address rgpd@waybeyond.pt.

With regard to the delivery of a copy of a citizen's ID card or other document, it should be stated that this will only be used, after the data subject has consented to this, for the aforementioned purpose (i.e. proving the identity of the holder of the aforementioned rights) and will be deleted if it is no longer necessary to pursue the aforementioned purpose.

Provision of data to third parties

WAY BEYOND does not disclose any of its users' personal data to third parties without their consent, except when this is necessary for the purposes of executing the contracts granted (communication of data to service providers or suppliers) or if this is required by law, namely to comply with the legal obligation to communicate to official bodies, such as judicial, tax and regulatory authorities.

WAY BEYOND may share the personal data collected with the following entities:

• Parties relevant to the services provided by WAY BEYOND;

• Public authorities, as part of compliance with legal obligations;

• Subcontractors of WAY BEYOND, who process personal data on its behalf.

In the course of our business, we may use third parties to provide certain services, as mentioned above. Sometimes, the provision of these services implies that these entities have access to personal data. When this happens, we take appropriate measures to ensure that the entities that have access to the data are reputable and offer the highest guarantees at this level, which will be duly enshrined and safeguarded in the contract to be signed with the service provider.

We may be forced to disclose your personal data in compliance with a court order or other legal or regulatory requirements. If this happens, we will take all steps to notify you before we disclose it, unless we are legally prevented from doing so.

We reserve the right to make updates to this Privacy Policy, where appropriate.