For how long do we process your personal data?
Your personal data are used by NOS only for the time necessary to achieve the purpose defined or, depending on what is applicable, until you exercise your right of objection, the right to be forgotten or you withdraw your agreement.
Following the respective retention period, NOS will delete or make the data anonymous, whenever this data should not be retained for the specific purpose that may continue to exist.
For what purposes do we process your personal data?
| Purposes | Examples of purposes (not exhaustive) |
|---|---|
| Communication of Products and Services and Sales | - Communication or sale of products or services, such as electronic communications, cinema, insurance, alarms or others that may come to be included in the product and service portfolio of NOS Group companies - Communication or sale of third-party products or services - Displaying advertising on NOS's own online channels and on social networks - Adaptation and development of new products or services - Research and processing of analytical information (Big Data Analytics) - Research and processing of statistical information (Big Data Analytics) |
| Insurance Mediation and Distribution | - Promotion of insurance products - Proposal to take out insurance contracts - Complaints management - Management of claims referral |
| Customer Management and Service Provision | - Management of contacts, information or requests - Management of installation, activation or disconnections - Management of complaints and faults - Management of customer experience - Management of invoicing, debt recovery and payments - Provision of communications services - Provision of data center services - Provision of audiovisual and TV services - Provision of alarm services - Recording of calls to prove communications related to the contractual relationship - Recording of calls to monitor service quality |
| Accounting, Tax and Administrative Management | - Accounting and tax management - Management of commissions and incentives - Management of insurance commissions - Sending tax information to the Tax Authority |
| Litigation Management | - Judicial and extrajudicial debt collection - Management of other conflicts |
| Detection of fraud, protection of revenue and auditing | - Detection of fraud and illicit practices - Protection and control of revenues - Credit risk management - Control, audit and investigation |
| Network and systems management | - Support and improvement of networks and applications that support service - Monitoring, improvement and support of the service |
| Operator management | - Management of interconnection and roaming services |
| Compliance with legal obligations | - Location of calls for emergency services - Management of judicial requests for interception of communications - Responses to judicial, regulatory and supervisory entities - Recording of calls to comply with a legal obligation - Reporting to regulatory and supervisory entities |
| Security control | - Management of accesses, logs - Management of backups - Management of security incidents |
| Physical security control | - Video surveillance for the security of people and property, such as in stores or cinemas |
Under what circumstances may NOS establish partnerships with third-party entities that are not part of the NOS Group?
NOS may, at any time, establish partnerships with third-party entities that are not part of the NOS Group. In such cases, the purpose of the data processing carried out under these partnerships will essentially relate to the marketing of joint product or service offers, which will allow Customers, upon taking up the products and services of both parties, to benefit from the advantages resulting from the partnership entered into between NOS and the partner company. In any case, within the scope of these partnerships, the necessary legal basis for the processing of personal data carried out in that context will also be ensured.
Under what circumstances does the research and processing of analytical and statistical information (Big Data Analytics) take place, and when is artificial intelligence (AI) used?
Within the scope of research and processing of analytical information, NOS may build your profile based, for example, on your preferences, personal interests, service usage, location, etc., namely to provide services, increase the quality and experience of products and services, and tailor communications about products and services, provided that such processing is necessary for the conclusion or performance of the contract between the data subject and NOS, for the pursuit of NOS's legitimate interests, or is based on the data subject's agreement.
In the research and processing of statistical information, NOS may analyse a set of data to identify behavioural patterns or trends, or for statistical analysis purposes. This data will be encrypted or anonymised at the most appropriate stage of the process and may be used for market studies, research and statistical analysis, or to provide reports to third parties. These reports will not contain personal data, will not identify any Customer, and will be used or sent to NOS partners to support projects in areas such as social development, health, transport, among others.
NOS uses AI with the aim of improving and optimising its products, services and processes and, consequently, the experience of its customers. Specifically, NOS's use of AI serves various purposes, including optimising the customer service and contact experience, personalising offers according to customer preferences, detecting and correcting anomalies in the services provided, increasing energy efficiency, automating processes and, in general, increasing productivity and efficiency.
For how long will your personal data be processed and retained?
Your personal data will be processed by NOS only for the time necessary to fulfil the defined purpose or, as applicable, until you exercise your right to object, your right to be forgotten, or withdraw your agreement, and always in accordance with the law and with the guidelines and decisions of the National Data Protection Commission (“CNPD”). Once the respective retention period has elapsed, NOS will delete or anonymise the data whenever it should not be retained for a different purpose that may still exist.
As a general rule, NOS will process and retain your personal data for as long as a contractual relationship is maintained with the Customer.
There are cases in which the law requires data to be processed and retained for a minimum period of time, namely, for 10 years, data necessary for reporting to the Tax Authority for accounting or tax purposes.
With regard to usage data required for invoicing, such as the destination and origin numbers of calls made, the date/time of the communication, the duration of the communication, the IP address and the mac address, this data will only be kept for a maximum period of 6 months from the date on which it was generated.
With regard to call recording, NOS will retain call recordings:
- to prove communications related to the contractual relationship, based on the other party's agreement, for a maximum period of 7 months;
- to monitor service quality, based on the other party's agreement, for a maximum period of 30 days;
- related to contract termination, for the legally established period.
In cases where calls are recorded, the corresponding audio may be processed by an artificial intelligence system for the purpose of automatic transcription. These transcripts may subsequently be processed, for example, to generate summaries of the interactions between NOS and the Customer, which will be associated with the Customer's account. Full transcripts will be kept for the period associated with their respective purpose, and the summaries will be retained for the duration of the contractual relationship.
Regarding video surveillance at its premises, cinemas and stores, NOS will only retain image recordings and the related personal data for a maximum period of 30 days.
NOS may keep personal data for periods in excess of the duration of the contractual relationship, either based on your agreement, or to ensure rights or obligations related to the contract, or because it has legitimate interests that support doing so, but always for the period of time strictly necessary to achieve the respective purposes and in accordance with the guidelines and decisions of the CNPD. Examples are: contact for purposes of communications about products and services, sales, the preservation of data as part of invoice complaint processes, the exercise of guarantee rights, the collection of equipment after disconnection of the Customer, or legal proceedings, for as long as these are pending.
What channels may NOS use to communicate Products and Services?
To communicate products and services to you, NOS may use SMS, instant messages, e-mails, telemarketing calls, IVR calls or post, as well as digital channels such as websites, mobile apps and social networks.