Privacy policy

SPGM - Sociedade de Investimento, S.A.

Version: 25th May 2018


SPGM – Sociedade de Investimento, S.A. is the holding company of the Portuguese Mutual Guarantee System that supports Micro, Small and Medium Enterprises (SME). The Mutual Guarantee consists fundamentally of providing financial guarantees to assist companies in obtaining credit in conditions that are suitable for their investments and activity cycles. The companies of the Mutual Guarantee System respect your privacy, and are committed to maintaining a relationship based on transparency and trust with their clients. This Privacy Policy describes who we are, for what purposes we may use your data, how we process it, who we share it with, for how long we store it, as well as how you can contact us and exercise your rights.


Your data will be processed i) by SPGM – Sociedade de Investimento, S.A., corporate number 503271055, headquartered at Rua Professor Mota Pinto, n.º 42-f, 2.º andar, sala 2.11, hereinafter abbreviated to "SPGM” or "we”.

SPGM is responsible for processing the personal data it collects and processes, in the sense in which these expressions are defined by the General Data Protection Regulation.



We only process personal data when it is required for any legal purposes that apply to us, or if we need it to fulfil a contract, or for any pre-contractual steps associated with it. These are the most significant and relevant situations in which we process data, including personal data, and cover a considerable part of our activity. We may also process information if we have a legitimate interest in doing so, provided that, in each case, our interest is compliant with the applicable legislation and with your rights as data owner; this may occur, namely in order to:

•Communicate with our clients;

•Recruit employees;

•Develop and maintain our website;

•Provide technical assistance;

•Prevent and detect fraud;

•Ensure the security of our networks and information;

•Provide information on SPGM activities, including the sending of Newsletters.

When none of the remaining conditions is appropriate for supporting the data processing operation, we shall only process information if we have obtained your consent to process your personal data for specific, explicit and legitimate purposes. Consent is a legal basis, which, in the context of SPGM’s activities, only applies to occasional and specific situations.

SPGM does not make random communications ("spam”) or those whose purpose and pertinence have not been validated by the organisation. SPGM ensures you as data owners that you may, at any time, exercise, among others, your rights of access, rectification, opposition and erasure, under the legal terms, and under the conditions described in this Privacy Policy.



We only store personal data for the time necessary to fulfil the purposes for which it was collected. In certain cases, data storage may occur for longer periods, namely when the Law so imposes.



The security of information and the protection of personal data is a priority for SPGM. We implement and guarantee to maintain adequate means of protection so that our internal procedures for personal data protection are compliant with current regulations. We also take all the necessary steps to ensure that third-party entities that work with us under contract, in the capacity of partners or service providers, guarantee adequate data protection of the personal data to which they have access. We limit access to personal data to specific employees, and only when their contact with such data is justified, within the scope of their functions.

We take all the necessary measures to ensure the safe processing of personal data. In particular, we take cautionary measures to protect personal data against loss and abuse, and we use security procedures to avoid unauthorised access to this personal data. All the personal data we collect is stored in servers that offer security safeguards. We submit our security systems and policies to periodic analyses so as to ensure that the data is secure and protected. 

We also respect the confidentiality of your information.

As such, we do not sell, distribute, or in any other way make your information commercially available to any third party. SPGM undertakes to keep your information confidential in accordance with this Privacy Policy and under the terms of the applicable legislation. 



At any time, as data owner, you may:

  • Request access to information – you have the right to obtain confirmation that your data is or not subject to processing and, when this is the case, to access your personal data and access the information established in the law.
  • Request rectification of the information if it is inaccurate or incomplete – you have the right to ensure that SPGM, without undue delay, rectifies the inaccurate or incomplete data that refers to you.
  • Request erasure of your personal data – you have the right to request that SPGM erases your data, without undue delay, and the latter is obliged to erasure the personal data, without undue delay, when one of the following reasons applies, namely:

1.    the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

2.    the data subject objects to the processing and there are no overriding legitimate grounds for the processing; or

3.    the data subject withdraws consent for data processing (in cases in which processing is based on consent) and where there is no other legal ground for the processing.

  • Request restriction of the processing of your personal data – you have the right to request that SPGM limit the processing of your data if one of the following situations apply, namely:

1.    the accuracy of the personal data is contested by the data subject, for a period enabling SPGM to verify the accuracy of the personal data;

2.    the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

3.    SPGM no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

4.    the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

  • Oppose the processing of your personal data – 1) in cases in which data is processed for the purpose of the legitimate interests pursued by SPGM; or 2) the data is processed for the purposes of direct marketing; or 3) profiling; you may also, at any time, oppose the processing of your personal data.
  • If processing depends on your consent, you have the right to withdraw it – if consent is legally necessary for the processing of personal data, you have the right to withdraw consent at any time, though this right does not compromise the legality of the processing carried out on the basis of previously given consent, nor later processing of the same data, on other legal grounds, such as the case of fulfilment of contract or legal obligation to which SPGM may be subject.

You may, at any time, exercise your rights, via email or letter addressed to Rua Prof. Mota Pinto, 42 F - 2º - Sala 211, 4100-353 Porto.

Your requests will be processed carefully so that we can ensure the effectiveness of your rights. You may be asked to prove your identity to ensure that personal data is only shared with you. You should remember that in certain cases (for example, due to legal requirements) your request may not be dealt with immediately. In any event, you shall be informed of the measures taken, within one month of the request being made.

You also have the right to present a claim to the Portuguese Data Protection Commission


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