AIRBAGSZENTRUM - SOCIEDADE UNIPESSOAL, LDA., a legal entity no. 508263069, with its registered office at R. 10, Zona Industrial de Rio Meão, no. 356, 452-475 Rio Meão, Portugal (hereinafter referred to as Zentrum), in its capacity as the data controller, undertakes the commitment to protect the privacy and rights of personal data subjects.
We have developed this Privacy Policy to explain how, as data controllers, we process users’ personal data when they visit our website, in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) No. 679/2016 of the European Parliament and of the Council of 27 April, hereinafter referred to as “GDPR”) and other applicable legislation on the protection of personal data.
Through this policy, we aim to inform you about the collection and processing of personal data, the cases in which the provision of personal data is necessary, the periods for which we retain personal data, the categories of personal data we process, their purposes and legal bases, the transmission of data and international transfers, the rights available to data subjects, and how you can contact us.
Processing of personal data
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, contact details, location data, online identifiers, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Data subjects are the individuals to whom the personal data relate.
Zentrum is responsible for the processing of personal data listed in this Privacy and Personal Data Processing Policy, as it determines which data are collected, the purposes for which they are collected, and the means by which such data are processed.
Zentrum is committed to keeping your data properly protected by implementing technical and organizational measures designed to ensure their security and to prevent their disclosure, loss, or misuse, as well as to protect against unauthorized access or any other unlawful form of processing, such as the creation and enforcement of data protection policies and the adoption of IT and network security solutions.
However, users should adopt additional security measures, namely ensuring that they use properly configured electronic devices and browsers with an active firewall, antivirus software, and/or other forms of logical or even physical security.
Required information
Access to and use of our website do not depend on the provision of personal data by users. You will only be required to provide personal data if you wish to create an account, make a purchase or book a service, submit an application through the contacts available on our website, subscribe to our newsletter, or contact us. The fields marked on the forms, except for the message field, are mandatory; therefore, if you choose not to provide them, we may be unable to provide the requested services, information, or clarifications.
In some cases, you may also provide your consent for the additional processing of personal data (or some of those data, when applicable). In such cases, we will specifically inform the user about the scope of the consent and the purposes pursued by the processing activities.
Retention periods
Zentrum retains personal data in an identifiable format for the minimum period necessary to fulfill the purposes pursued through the processing of personal data. After this period, we will cease processing the personal data, which we will delete at regular intervals, unless the continuation of processing and storage is required by law or the user has granted consent for that purpose.
Categories of data, purposes, and legal bases for processing
1. To respond to communications sent by the user to Zentrum
If you contact us, namely to request information or clarifications, as well as to schedule a service, through the telephone contacts or email address we provide, the forms made available for that purpose, or through the AI Assistant Chat, we will process your personal data for the purpose of responding to your request, based on our legitimate interest in managing the established contact and responding to your request, as well as, when applicable, in pursuing pre-contractual or even contractual steps at the data subject’s request.
The data concerned include identification data (first and last name), contact data (email address and, where applicable, telephone contact), other information necessary to complete the request (time, brand, model, year, and car part), and the content of the communication sent by the user to Zentrum (including attachments).
We will retain such personal data for the duration of the request/communication process and until the personal data are no longer necessary for fulfilling these purposes. If the request is made by a client, we may retain personal data for the duration of the contractual relationship or for a longer period, up to 10 years, if necessary to comply with a legal obligation, particularly, but not exclusively, of a tax nature.
It should be noted that the submission of the user’s communication through the forms is subject to their acceptance of the Website Terms and Conditions, as well as the use of the Online AI Assistant Chat being subject to the acceptance of the Terms of Use. Therefore, if you do not agree with them, Zentrum may not be able to provide the requested service(s).
2. For recruitment purposes
We may process personal data for recruitment purposes if you send us a spontaneous application through the contact form or the contacts available on our website, even if they are not specifically intended for that purpose. The processing of personal data in this context is carried out on the legal basis of performing pre-contractual measures at the request of the data subject, on our legitimate interest in managing the applications received, in compliance with legal obligations, and, in some cases, based on your consent.
The data included may cover identification data (first and last name; date of birth; civil identification number/validity of the identification document; tax identification number; social security number), contact data (address, email address, and telephone contact), and data relating to academic qualifications and professional experience (for example, qualifications, certifications, personal and professional experience; curriculum vitae).
We will retain such personal data for as long as your application is under review, until the conclusion of the recruitment process, for a period of two years if you are not selected, or until you withdraw your consent, where applicable.
We may also process other personal data based on our compliance with legal obligations to which we are bound and for the periods established by applicable legislation.
3. For registration and account creation purposes
If you register to create an account through the designated form on our website, we will process your personal data for the purpose of responding to your request, based on our legitimate interest in managing the established contract and fulfilling your request, as well as, where applicable, in pursuing pre-contractual measures at the request of the data subject.
The data concerned include identification data (first and last name, and date of birth), contact data (email address, telephone number, and full address), tax data (name and tax identification number), the login credentials chosen by the user, and other information necessary to complete the request.
The personal data provided in this context will be used to respond to information requests, process orders and offers, or authorize access to specific information. The user has the right to modify or delete all personal information found on the “My Account” page.
We will retain such personal data for as long as the user’s account remains active and until the personal data are no longer necessary to fulfill these purposes. Since the request is made by the data subject with a view to entering into an agreement with Zentrum, we may retain the personal data for the duration of the contractual relationship or for a longer period, up to 10 years, if required to comply with a legal obligation, particularly, but not exclusively, of a tax nature.
It should be noted that, given the specific nature of this activity and the fact that the data subject registers as a Zentrum user, in addition to the legal bases already mentioned, Zentrum understands that by registering, the data subject is expressly consenting to the provision of their personal data on the website or through any other appropriate means of dissemination operated by Zentrum. This consent may be withdrawn at any time.
It should also be noted that the submission of user communications through the forms is subject to their acceptance of the Website Terms and Conditions and this Privacy and Personal Data Processing Policy. Therefore, if you do not agree with them, Zentrum may not be able to provide the requested service(s). Additionally, the user may also choose to receive offers from Zentrum’s partners, by expressly declaring their consent for their data to be collected for that purpose.
4. For the purpose of processing your purchase order for one of the available products
If you submit a product purchase order through the form available on our website or the contacts we provide, we will process your personal data for the purpose of responding to your request and carrying out the sale of such products, based on our legitimate interest in managing the established contract and fulfilling your request, as well as, where applicable, in pursuing pre-contractual measures and executing a contract at the data subject’s request.
The data in question include identification data (first and last name, and full address), contact data (email address and phone number), and other optional information necessary for completing the order, such as date of birth, tax identification number, and company name, where applicable. In this context, users’ banking data may also be collected to finalize their respective purchases, as Zentrum uses external service providers to process payments and, as such, cannot be held responsible for any improper use of data in that context.
We will retain such personal data during the order processing and until the personal data are no longer necessary for the fulfillment of the purposes described above. Since the request is made by a client, we may retain the personal data for the duration of the contractual relationship or for a longer period, up to 10 years, if required to comply with a legal obligation, particularly, but not exclusively, of a tax nature.
It should be noted that the submission of the user’s purchase order through the form is subject to their acceptance of the Website Terms and Conditions, and if you do not agree with them, Zentrum may not be able to provide the requested order and/or services.
5. For newsletter subscription purposes
If you provide us with your data (name and email address) and your consent for this purpose, Zentrum may contact you for marketing purposes related to its services, namely through a periodic newsletter, based on our legitimate interest in promoting our services and products. This consent may be given by completing the dedicated form available on our website. You may object to this processing at any time by clicking the designated button for that purpose.
6. To ensure access to our services and to our website
our website (Cookies)
Based on our legitimate interests, namely ensuring the proper functioning of the services and our website and preventing misuse, we may process access data, such as the date and time of the user’s visit to our service, for the purpose of assessing the level of access and traffic on the website. For the purpose of preventing harm through interference with information systems, we may process data to detect attacks on our website due to unusual activity, failure diagnosis, and the prevention and detection of fraud.
All data are pseudonymized, which means that the processing is carried out in such a way that they cannot be attributed to a specific person without the use of additional information.
The collection of this information is, as a rule, also recorded through cookies.
Data subjects are hereby informed that Zentrum collects cookies when browsing the website. These technologies allow Zentrum to provide a better browsing experience when users use the website.
Zentrum ensures that, except for essential Cookies, website users can change their computer or mobile device settings at any time and restrict the acceptance of Cookies, namely through the Cookie preference settings option. However, we warn that depending on the selections made, the use of some website features may be affected, even if only partially.
Due to the technical procedures of transmitting information over the Internet, it is inevitable that access data will be transmitted to external content service providers. External content service providers are responsible for ensuring that the information technology systems they use comply with legal privacy requirements.
For more information, please consult our Cookie Policy
Disclosure of personal data and international transfers
Zentrum may disclose your personal data to third parties, namely if the disclosure is necessary for us to provide the services rendered to you, for statistical purposes, or to comply with legal obligations to which we are subject.
We may share website users’ personal data, namely with providers of IT, legal, and administrative advisory services, website hosting, website content provision, and information technology security services, as well as with public authorities for compliance with legal obligations. Whenever Zentrum shares website users’ personal data with external service providers, as well as with public authorities in compliance with legal obligations, it undertakes to assess the level of protection implemented by such third parties in these matters and, if deemed necessary, to enter into a data protection agreement with them.
This website may contain links to social networks such as Facebook, Instagram, WhatsApp, YouTube, LinkedIn, among others, owned by third parties, which display a button through which messages can be sent to the corresponding social network for various purposes, such as communications, recommendations, or content sharing. The legal basis for the transmission of data in this case is Zentrum’s legitimate interests in advertising its services. The service providers in question are responsible for ensuring that the processing of the personal data transmitted takes place in compliance with privacy requirements.
Data subjects are expressly warned that by disclosing personal data on Zentrum’s public platforms, such as its Facebook, Instagram, WhatsApp, YouTube, LinkedIn pages, among others, that information may be viewed and used by third parties.
Zentrum further warns that the website may contain links (hyperlinks) to third-party websites, products, or services that are not covered by this Privacy Policy. Zentrum cannot, therefore, be held responsible, under any circumstances, for the content, accuracy, truthfulness, or legitimacy of those websites or for the misuse of data collected or processed through them.
Zentrum alerts its customers and the general public to this fact and to the need, before using such websites, to carefully read the rules on the processing of personal data defined by those third parties.
Zentrum advises:
o Not including personal, confidential and/or sensitive data in communications sent to you (e.g., bank card numbers);
o Exercising caution when exposing personal data and circulating such data over the internet;
o Avoiding browsing websites of dubious reputation;
o Ensuring that the sending of personal data by minors is supervised by their parents or legal guardians.
Zentrum is not responsible for unsolicited personal data or other information sent to it in any publicly accessible area that it administers or manages, and will normally delete it insofar as it is not adequate, relevant, and limited to the purposes it pursues.
Rights of data subjects
As the data subject, you have the following rights:
1. Right of access
At any time, you have the right to obtain our confirmation as to whether personal data concerning you are being processed and, if so, to access such data and the information provided for by law.
2. Right to rectification
As the data subject, you have the right to obtain the rectification of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of an additional statement.
3. Right to erasure (“right to be forgotten”)
You have the right to obtain the erasure of your personal data without undue delay in certain circumstances provided for by law, including where your personal data are no longer necessary in relation to the purpose for which they were collected or processed, or where you decide to withdraw consent (if that is the legal basis for the processing and there is no other basis allowing it). This right may be limited in certain situations, including the need for processing for the establishment, exercise, or defense of legal claims and compliance with a legal obligation that requires processing.
4. Right to restriction of processing
In certain situations provided for by law, you have the right to obtain the restriction of the processing of your personal data. These include cases where you contest the accuracy of your personal data, for a period enabling Zentrum to verify their accuracy, and cases where you have objected to processing, pending verification of whether Zentrum’s legitimate grounds override yours.
5. Right to data portability
If the processing is based on consent or on a contract to which the data subject is a party, the data subject has the right to receive the personal data they have provided to us in a structured, commonly used and machine-readable format. They also have the right to request that their data be transmitted directly by us to another controller, where technically feasible.
6. Right to object
If we process your personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing, including profiling to the extent that it is related to direct marketing, with effect for the future. In this case, personal data will no longer be processed for this purpose.
The data subject also has the right, at any time, with effect for the future and on grounds relating to their particular situation, to object to the processing of personal data based on the legitimate interests of Zentrum or third parties. In this case, we will cease processing unless there are compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing is necessary for the establishment, exercise or defense of legal claims.
7. Right to withdraw consent
If the 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. In this case, and unless there is another legal basis that requires or permits it, such as compliance with a legal obligation or a contract to which the data subject is a party, your personal data will no longer be processed.
8. Right to lodge a complaint
The data subject also has the right to lodge a complaint with the competent supervisory authority, the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados), at https://www.cnpd.pt/cidadaos/participacoes/.
You may exercise your rights freely and at no cost by sending us a communication through the contact details indicated below. For this purpose, we may require proof of your status as the data subject exercising these rights.
How can you contact us?
You may request any information you consider necessary regarding the processing of your data through the contact form available on our website, or by email at: geral@zentrum-group.com.
You may also contact our Data Protection Officer:
E-mail: info@hedadpo.pt
Mail: HEDA – DATA PROTECTION OFFICERS, Rua de João Ramalho, no. 141, 4200-342 Porto
The exercise of data subject rights is free of charge, except where a request is manifestly unfounded or excessive, in which case a reasonable fee may be charged, taking into account the administrative costs incurred.
If the data subject exercises any of their rights, Zentrum will review the request and respond, in principle, within one (1) month.
Information is provided in writing, but may also be given orally if requested by the data subject. Zentrum verifies the identity of the data subject before responding to their requests. If requests are deemed unfounded or excessive, Zentrum reserves the right to charge a fee for the response.
Updates
This Privacy Policy may be subject to periodic updates, and Zentrum advises that it be consulted regularly.
Version 2, dated September 5, 2025.