At MyRenegade, we are committed to conducting our business with the highest standards of integrity, transparency, and compliance. To support this commitment, and in accordance with Portuguese Law No. 93/2021 and EU Directive 2019/1937, we have established a secure internal reporting system.
This channel allows employees, suppliers, contractors, and other third parties to report suspicions of misconduct safely and confidentially.
You may use this channel to report serious infractions, including but not limited to:
We offer several channels to facilitate your report. You may choose the one most
comfortable for you:
We take your privacy seriously.
MyRenegade has a zero-tolerance policy regarding retaliation. We strictly prohibit dismissal, demotion, harassment, or any form of discrimination against anyone who reports a concern in good faith.
While we encourage you to use our internal channels first to allow us to address the issue quickly, you have the legal right to report directly to competent external authorities if necessary, including:
Privacy Notice regarding Whistleblowing Reports Personal data collected through this channel is processed by MyRenegade, Unipessoal Lda for the sole purpose of assessing and investigating reports of misconduct, in compliance with the GDPR and Law No. 93/2021. * Access: Access to data is restricted to authorized personnel involved in the investigation.
Retention: Data regarding unfounded reports is deleted promptly. Data related to ongoing investigations is retained only as long as necessary to resolve the case or comply with legal obligations.
Rights: You have the right to access, rectify, or request the deletion of your personal data, provided it does not hinder the investigation. Contact our DPO at [email protected] for inquiries.
Since the procedure explicitly mentions the DPO (Data Protection Officer) and strict adherence to GDPR, we need a dedicated document or popup text for this.
1. Data Controller
The entity responsible for processing your personal data is MYRENEGADE, UNIPESSOAL LDA("Company"), with registered office at Rua Joshua Benoliel Nº1, 6º D, 1250-273 Lisboa, Portugal.
2. Purpose and Legal Basis
We process personal data for the purpose of receiving, assessing, investigating, and following up on whistleblowing reports, including taking any necessary corrective or legal measures, in accordance with Portuguese Law No. 93/2021 and EU Directive 2019/1937. The processing is necessary for compliance with a legal obligation to which the Company is subject (Article 6(1)(c) GDPR) and, where applicable, for the purposes of the Company’s legitimate interests in preventing misconduct and protecting the organisation (Article 6(1)(f) GDPR).
3. Types of Data Collected
4. Confidentiality and Recipients
Your data will be treated with the strictest confidentiality. Access is restricted to authorized personnel involved in the investigation, specifically the Chief Compliance Officer (CCO), the investigation team, and, if necessary, external legal counsel or the DPO. We do not share your data with third parties unless required by law (e.g., sharing with the Public Prosecutor's Office or Banco de Portugal).
5. Data Retention
6. Security Measures
We apply appropriate technical and organisational measures to protect whistleblowing data against unauthorised access, disclosure, alteration, or loss. Such measures include restricted access to reports on a need-to-know basis, secure storage, confidentiality obligations, and documented handling procedures. Where electronic communication is used, encryption and access controls are applied where appropriate.
7. Your Rights
Under the GDPR, you have the right to access, rectify, or erase your personal data, and to restrict or object to its processing. However, these rights may be limited if they jeopardize the confidentiality of the investigation or the protection of other involved parties. To exercise these rights, please contact our Data Protection Officer (DPO) at: [email protected].
8. Right to Complain
You have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD) if you believe your data rights have been violated.
9. Internal Data Transfers
We do not intentionally transfer whistleblowing personal data outside the European Economic Area (EEA). Where service providers may process data outside the EEA, we ensure that appropriate safeguards are in place in accordance with GDPR requirements (e.g., EU Standard Contractual Clauses).
10. Provision of Data
Providing personal data is voluntary. You may submit a report anonymously. However, providing contact details may facilitate follow-up and feedback