POCINHAS Sàrl
POCINHAS Sàrl is committed to doing everything in its power, on the one hand, to protect the privacy of its clients, employees, and other contacts whose images are recorded by the video surveillance system when passing in front of cameras located on the company’s premises, and on the other hand, to comply with the provisions of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter “GDPR”).
POCINHAS Sàrl is responsible for the processing of data, particularly the personal images collected through the video surveillance system installed on the company’s premises, notably in the sales area.
This data is processed by POCINHAS Sàrl, established and with its registered office at L-8008 Strassen, 140 route d’Arlon, registered with the Luxembourg Trade and Companies Register under number B187476, represented by its current manager, Mr. Luis Miguel NEVES DE CARVALHO, phone: 691 640 890, email: info@gsmpcsolutions.lu.
Purposes and legal basis of processing
By implementing the video surveillance system, POCINHAS Sàrl pursues the following objectives:
- Ensure the protection of goods sold by POCINHAS Sàrl
- Ensure the safety and protection of people (clients, employees, or other contacts) present on the company’s premises
- Respond to an express request from employees for their safety and ease of work, saving frustration and facilitating the search for products and components
These measures aim to limit or even prevent any burglaries, physical assaults, thefts, or other acts of violence to which these people are exposed due to the availability of highly sought-after IT equipment (GSMs, laptops, tablets, etc.) and high-value-added electronic components on the sales sites.
These images can also serve to improve, optimize, and/or organize the work of employees.
Category of data processed
Images collected through the video surveillance system installed on the company’s premises.
Transmission/Transfer of collected data and images
These video surveillance data will not be transmitted to third parties, except in cases of burglary, physical assault, theft, or any other act of violence. In such cases, the images may be transferred to the competent public authorities (such as the Judicial Police), any other competent judicial body, or any insurance company that requires them.
Data retention
The data is recorded and retained for a maximum of 8 days, after which it is automatically deleted from the computer servers.
However, in the event of burglary, assault, or any other act of violence, these data will be retained for as long as the investigation by the competent public authorities (such as the Judicial Police) lasts and/or for any resulting legal procedures.
Similarly, these data and images may be retained for up to one month for any other specific and exceptional reason (such as resolving an internal organizational problem or an issue with accessing the video surveillance software).
It is important to note that, in cases of burglary, attackers often plan their actions well in advance, and deleting the data after 8 days may be detrimental to any future investigation that may be required.
IT security of personal data
POCINHAS Sàrl implements appropriate technical and organizational measures to ensure a level of security appropriate to the risks presented by the data processing, including protection against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access to personal data transmitted, stored, or otherwise processed.
POCINHAS Sàrl regularly conducts analysis and evaluation of the effectiveness of the technical and organizational measures.
Rights relating to personal data
Any person (client, employee, or other contact) has the following rights, upon simple request by email to the data controller of POCINHAS Sàrl, Mr. Luis Miguel NEVES DE CARVALHO, via the email address: info@gsmpcsolutions.lu:
- Right to information
- Right of access, i.e., to obtain at any time and upon request, confirmation as to whether or not your data is being processed
- Right to rectification, i.e., to obtain from the controller the correction of inaccurate personal data as soon as possible
- Right to erasure/right to be forgotten, i.e., to obtain the erasure of data from the controller as soon as possible, unless the retention of the data is legally required in cases of burglary, physical assault, theft, or other acts of violence
- Right to restriction of processing
- Right to data portability
- Right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) of the GDPR, including profiling based on those provisions, except in cases of burglary, physical assault, theft, or other acts of violence
- Right not to be subject to automated decision-making
- Right to withdraw consent easily and at any time without affecting the lawfulness of processing based on consent before its withdrawal, except in cases of burglary, physical assault, theft, or other acts of violence
- Right to lodge a complaint with a supervisory authority, particularly with the CNPD