WAY BEYOND is committed to respecting the privacy of users, as well as the protection and security of their personal data. The user should carefully read this privacy policy and freely decide whether to provide their personal data to WAY BEYOND before using its services.

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

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 consulting 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, under the terms of this Privacy Policy and in accordance with the principles and rules 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 governs the processing of personal data collected by WAY BEYOND, specifying the grounds for its collection, as well as the terms and manner in which it will be used and, eventually, transmitted to third parties.

WAY BEYOND is committed to protecting and maintaining the confidentiality of its users' personal data, having 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 data subjects, under and for the purposes of applicable law, namely by virtue of the application of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR").

We are committed to respecting the best practices in the field of security and protection of the personal data of our customers, 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 procedures adopted in the implementation of the rights of personal data holders.

Object of personal data processing

WAY BEYOND assumes responsibility for the collection and processing of personal data necessary for the fulfillment of the contract entered into – personal data is understood to be any information, of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable natural person.

For the execution of the different purposes, WAY BEYOND may process the following types of personal data:

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

• contact details (such as mobile phone, telephone, address or email);

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

• data related to remuneration;

• candidate assessment data within the scope of recruitment and selection processes for WAY BEYOND employees;

• bank details (necessary for operations involving the issuance of financial documents).

As part of our activity, personal data may be collected by WAY BEYOND in person, by telephone, by e-mail, through subscription to our newsletter or through the completion of registration/evaluation forms, or even when submitting a professional application, the treatment of which, under the terms of the legislation on the protection of personal data, complies with adequate technical and organizational security measures.

In some cases, WAY BEYOND may indirectly collect personal data. 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 first opportunity.

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

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:

• Send commercial and promotional communications;

• Transfer to third parties;

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

The personal data collected is processed electronically and in strict compliance with the aforementioned personal data protection legislation, being 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 consent was given by the data subject.

Fundamentals and purposes of personal data collection

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

• Consent of 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 relating to WAY BEYOND's activity and services. 

• Contract execution or pre-contractual diligences. This basis is applicable whenever WAY BEYOND processes personal data for the purpose of providing coaching and mentoring services.

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

• Legitimate interest. This basis of lawfulness for the processing of personal data will operate in cases where the processing proves necessary for the pursuit of legitimate interests of the entity responsible for the processing or of third parties, without prejudice to the rights and freedoms of its customers and/or users.

Website and Newsletter

Our website, located at waybeyond.pt, is owned by Centro Europeu de Coaching VSR, Lda., hereinafter referred to as WAY BEYOND, and its purpose is to present 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 identify the visitor during their online visit. This way, we can identify and maintain your preferences.

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

Through the website, you can subscribe to our newsletter by providing your email address, and you can cancel the subscription at any time.

Personal data retention period

The period during which data is stored and retained 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 they are processed.

Thus, and whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that motivated its collection.

After this period, your personal data will be deleted. However, this does not apply to cases where personal data is necessary for the controller (WAY BEYOND), or for subcontractors, to prove compliance with contractual or other obligations, in which case personal data may be kept until the limitation period for the corresponding rights has expired (for example, for invoicing purposes, where, in general terms, the personal data retention period is 10 years).

 Data Security

WAY BEYOND declares that it has implemented and will continue to implement the necessary technical and organizational security measures to ensure the security of the personal data provided to it, aiming 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 accessing personal data, WAY BEYOND is committed to:

• Store them through legally required security measures of a technical and organizational nature, which guarantee their security, thus preventing alteration, loss, treatment or unauthorized access, in accordance with the state of technology at each moment, 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 processed solely by employees whose involvement is necessary to fulfill the data subject's request, and that they are bound by a duty of secrecy and confidentiality. If there is a possibility that the information may be disclosed to third parties for the aforementioned purposes, these parties must be obliged to maintain due confidentiality in accordance with the provisions of this document.

Without prejudice to all the security mechanisms adopted and compliance with all personal data protection rules, the user must be aware that, if they do not have the necessary protection barriers in their access (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 advised to take appropriate security measures while using the Internet, namely ensuring that they use a browser that allows the use of secure communication.

Rights of the personal data subject

Personal data holders have the following rights at any time:

1. Right to transparency;

2. Right to information;

3. Right of access;

4. Right of rectification;

5. Right to be forgotten;

6. Right to restriction of processing;

7. Right to portability;

8. Right of opposition;

9. Right not to be subject to any automated decision-making;  

10. Right to not have sensitive data processed; 

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

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

Regarding the delivery of a copy of the citizen card or other document, it should be stated that it will only be used, after consent of the data subject for this purpose, for the aforementioned purpose (i.e., proof of the identity of the holder of the rights mentioned) and will be deleted if it is no longer necessary for the pursuit of the described purpose.

Provision of data to third-party entities

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

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

• Relevant parts for the services provided by WAY BEYOND;

• Public authorities, within the scope of fulfilling legal obligations;

• Subcontracted by WAY BEYOND, who process personal data on its behalf.

In carrying out our activities, we may use third parties to provide certain services, as mentioned. Sometimes, providing these services means these entities access personal data. When this happens, we take appropriate measures to ensure that the entities accessing the data are reputable and offer the highest guarantees, which will be duly established and protected in a contract to be signed with the service provider.

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

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