BASE CAPITAL is committed to protecting the privacy of all users of its website (hereinafter ‘Website’) and has developed this privacy policy to demonstrate its commitment to and respect for the personal data of its users. It has also adopted best practices with regard to security techniques and the protection of personal data (the ‘Privacy Policy’), as described in more detail below.

BASE CAPITAL clarifies to Users that simply browsing or accessing the Website does not necessarily imply the collection of their personal data. Nevertheless, we would like to point out that the Website also uses cookies, for which it has a Cookies Policy, which you should consult.

1. Our commitment

We ensure compliance with the obligations arising from Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter ‘GDPR’), Law No. 58/2019 of 8 August (Personal Data Protection Law) and other applicable personal data protection legislation.

Respect for your privacy, the protection of your personal data and compliance with the applicable legal obligations in this area is a priority for us, which is why we are committed to only processing your personal data that is strictly necessary to provide you with the best service, ensuring respect for your privacy, transparency in information and the application of best practices in the field of security and personal data protection.

2. Data Controller

The entity responsible for processing Users’ personal data is BAS3INV CAPITAL, S.A., with registered office at Rua Soares Carneiro, n.º 2, 2760-796 Amadora, with unique registration and corporate entity number 503 368 784 (hereinafter referred to as ‘BASE CAPITAL’).

If you need to contact us, you can do so via the following email address: privacidade@bcapital.pt

3. Purposes of processing, legal basis and retention periods

Users may access, browse and use this website without necessarily having to provide personal information. However, the use of certain tools on the website may require the provision of personal data. In this regard, please consult our Cookies Policy

In this context, the processing of your personal data has the following purposes, legal bases and retention periods:

a) Website management

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This data (such as, for example, IP addresses, operating system used, type of device and browser used for connection) is not accompanied by any additional personal information.

Your data will be kept for up to six (6) months after your last visit to the website, in accordance with the information provided in the Cookie Policy.

b) Contact management

The processing of this data is necessary for receiving, analysing, following up on and responding to requests for information. This processing is based on BASE CAPITAL’s legitimate interest in following up on your requests.

Your data will be kept for up to one (1) year after the last contact interaction, in the case of requests for information, and for a period of three (3) years for complaint management.

c) Recruitment

BASE CAPITAL may use the Website to advertise job vacancies, and candidates may also submit their CVs as unsolicited applications. This processing is based on pre-contractual procedures and the consent of the data subject.

The data is only kept for as long as is strictly necessary for the management and fulfilment of the purposes for which it is collected, in accordance with current regulations and legal obligations.

In any case, BASE CAPITAL adopts procedures that prevent the storage of data for an indefinite period, limiting the storage period in accordance with the principle of data minimisation and storage limitation. Once the defined retention period has expired, we undertake to delete, destroy or anonymise your personal data, with the exception of data that we are required by law to retain for a longer period, as determined by law.

Your data will be retained for up to 12 (twelve) months after receipt of your application.

 4. Categories of personal data

In the context of the purposes set out above, we only process data that is strictly necessary for the pursuit of those purposes, namely:

Personal identification and contact details (e.g. full name, email address, telephone number, address); and/or
Academic qualifications (and other information that the User enters when submitting CVs);
Traffic data (through cookies).

BASE CAPITAL does not process sensitive data categories that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, nor does it process genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health or data concerning a person’s sex life or sexual orientation.

5. Sharing of personal data

The data collected is processed by internal employees, designated for this purpose and authorised to process the data in accordance with specific instructions given in accordance with the legislation in force.

In certain cases, we may disclose your personal data, within the limits of what is strictly necessary, to third parties who provide services to us (‘Subcontractors’) for the purposes mentioned above, under the terms of the service agreements entered into with them.

If your personal data has to be shared with service providers located outside the European Union, we ensure that your personal data benefits from a high level of protection in accordance with applicable personal data legislation, promoting the transfer under an adequacy decision by the European Commission or standard data protection clauses (or similar), approved by the European Commission.

Your data may also be communicated to authorities when the transmission is carried out in compliance with a legal obligation, a decision of the National Data Protection Commission (‘CNPD’), another relevant supervisory authority and/or to comply with a court order.

Under no circumstances will BASE CAPITAL process Users’ personal data for purposes not provided for in this Policy and/or without a legal basis to support its processing, in accordance with applicable legislation.

6. Data Subject Rights

Under applicable law, Users, as data subjects, may at any time request the right to access, rectify, erase their personal data, restrict processing, portability, object and not be subject to automated decisions, as applicable.

In cases where you have given your consent to certain processing of your personal data, you may withdraw it at any time.

To exercise any of these rights, you must do so by sending a request to the following email address: privacidade@csantosvp.pt.

You may also contact us on all matters relating to the processing of your data and the exercise of your rights under applicable law and, in particular, under this Privacy Policy, via the email address provided.

Without prejudice to any other administrative or judicial remedy, you may also lodge a complaint with the CNPD (www.cnpd.pt) if you believe that our processing of your personal data violates the legal regime in force.

7. Cookies

We recommend that you read our Cookie Policy, which forms an integral part of this policy, to learn more about how your personal data is processed through this feature.

8. Security Measures

We have a range of information security measures in place, in line with national and international best practices, to protect your personal data, including technological controls, administrative, technical and physical measures, and procedures that ensure the protection of your personal data, preventing its misuse, unauthorised access, disclosure, loss, improper or inadvertent alteration, or destruction.

We are committed to continuous improvement in information security, just as we are in our daily activities.

Among others, we highlight the following measures:

1. Restricted access to your personal data;
2. Secure storage and transmission of your personal data;
3. Protection of information systems through devices that prevent unauthorised access to your personal data;
4. Implementation of mechanisms that guarantee the safeguarding of the integrity and quality of your personal data;
5. Permanent monitoring of information systems, with the aim of preventing, detecting and impeding the misuse of your personal data;
6. Protection of equipment used for the storage, processing and communication of personal data, to prevent loss of availability.

However, it is the responsibility of Users to ensure and guarantee that the devices and equipment used to access this website are adequately protected against harmful software, computer viruses, and worms.

9. Links to other websites

We may provide links to other websites of interest, social networks and others. BASE CAPITAL is not responsible for the privacy policy, cookie policy or terms of use of these third-party websites and platforms.

The User acknowledges that when accessing other websites through the links provided, the entities managing those websites may collect information about them. We recommend that the User consult all information and conditions in advance when accessing other websites.

10. Updates to the Privacy Policy

This Privacy Policy may be revised and updated at any time, and such changes will be duly publicised and communicated on the website.

Lisbon, 12 June 2025