Privacy and Personal Data Protection Policy

We have adopted a new Privacy and Protection Policy for Personal Data.

The person responsible for processing personal data is Gradualbusiness - Serviços de Gestão Lda., hereinafter referred to as Gradual.


1. Data collected, purpose of collection, validity and recipients

1.1 Potential customers, customers and suppliers

Data collected

The personal data collected includes the name, telephone number, e-mail address and position.

Bank data are processed from individual customers and suppliers, namely the NIB / bank account number.

The personal data of the trainees are processed to issue training certificates in the SIGO Platform.

Purpose of treatment

Personal data is collected for the preparation of proposals, business contacts, service provision, billing, quality control and training management.

Retention time

Personal data of holders belonging to "Client Organizations" or "Supplier Organizations" are kept for 10 years after the date of the last contact with the Organization.

The personal data of Customers and singular Suppliers are kept for 10 after the date of the last contact with the holder.

Basis for treatment

The processing of personal data is based on:

  • Compliance with legal obligation.
  • Execution of the contract or for pre-contractual procedures at the request of the data subject.
  • Legual marketing interests of Gradual services and quality control.
Data sharing

The personal data of trainees are communicated to the SIGO Platform. The personal data of other data holders belonging to Client or Supplier Organizations are not communicated to external entities. The personal data of individual Customers and Suppliers are communicated to the Accounting, Tax Authority and Entity service providers.

1.2 Site users

No personal data are collected during the navigation on the site

1.3 Candidatos (processos de recrutamento e candidaturas espontâneas)

Data collected

Personal data collected includes: name, photograph, date of birth, address, telephone number and e-mail address, and data on training, professional experience and professional competences, as well as those that candidates include in the CV.

Purpose of treatment

Personal data is used to identify and contact the candidate and to evaluate the professional skills to occupy a vacancy.

Spontaneous application: Spontaneous applications are kept active for 1 year, and the candidate can be contacted during this period.

Application for vacancy: Applications are only used for the recruitment process for a specific vacancy.

Retention time

The personal data of the candidates are eliminated after the deadline to comply with the legal requirements (5 years).

Basis for treatment
  • Compliance with legal obligation - Labor Code;
  • Legitimate interest in the management of workers' occupational skills;
  • Consent of the holder
Data sharing

Personal data may be shared with Government Entities such as IEFP. The candidate's CV can be shared with Gradual's clients, in the scope of recruitment processes, provided that the data subject has given his / her explicit consent.


2. Data transfer

Personal data are not transferred to companies or countries outside the Community.


3. Legal rights

The holder of personal data has the right to access, rectification, elimination, limitation, portability and opposition of personal data.

Right of access, rectification and elimination
The data subject can access the data that he has given us, ask for rectification, change, or elimination, and we will commit to follow up within a maximum period of 30 days. The right to disposal is subject to the absence of valid grounds for the preservation of personal data.
Portability of personal data

The data subject has the right to ask Gradual to proceed with the sending of personal data processed by automated means to another organization, without resulting costs, unless the information, by its extension and complexity, imply the use means whose costs are significant.

Right to Opposition

The data subject may oppose the processing of your data. We undertake to cease treatment, within a maximum of 30 days, unless there are legitimate reasons for continued treatment.

It is the responsibility of the National Data Protection Authority ( to receive complaints from the holders of personal data.


4. Exercise of rights

If you wish, at any time, the data subject can exercise his rights to:

E-mail - This email address is being protected from spambots. You need JavaScript enabled to view it.

Letter - Gradualbusiness - Serviços de Gestão Lda., Estrada de Benfica, n.º 381, 3º Dto, 1500-076 Lisboa

May 24, 2018