Privacy Policy

PRIVACY POLICY

Effective date: September 1, 2026 Version: Rev-0.0

1. Who we are

KOZATTI Prestação de Serviços e Comércio, Lda. (“KOZATTI”, “we”, “us” or “our”) is an Angolan company providing industrial procurement and supply, temporary manpower and related maintenance support. Our registered office is at Ingombota, Rua Miguel Bernardo Mingo, Nº01, Luanda-Angola with NIF No. 5002152517

For the processing described in this Policy, KOZATTI will generally act as the entity responsible for determining why and how personal data is processed. In some client engagements, KOZATTI may process data on documented instructions from a client; the applicable contract will define the parties’ respective roles.

2. Scope of this Policy

This Policy explains how KOZATTI collects, uses, stores, shares and protects personal data relating to:

  • website visitors and users of our online catalogue, contact forms and portals;
  • customers, prospective customers and their employees or representatives;
  • suppliers, manufacturers, logistics providers, subcontractors, partners and their representatives;
  • job applicants, candidates, referees, emergency contacts and individuals included in our talent database;
  • temporary, contract and assigned personnel, consultants and former personnel;
  • visitors to our offices, warehouses, project sites, events and training activities; and
  • other individuals who communicate or interact with KOZATTI.

This Policy should be read with any specific notice provided when we collect data, our Cookie Policy, Website Terms and Conditions, and any applicable employment, manpower or services agreement. A specific notice or contract may provide additional information for a particular processing activity.

3. Our privacy principles

KOZATTI seeks to process personal data lawfully, fairly and transparently. We aim to collect only data that is adequate, relevant and not excessive; use it for specified and legitimate purposes; keep it accurate; retain it only as long as necessary; and protect it with proportionate organisational, physical and technical safeguards.

We apply access on a need-to-know basis and expect personnel and service providers handling personal data to maintain confidentiality and comply with applicable instructions and law.

4. Personal data we collect

Category Examples
Identity and contact Name, photograph, signature, date of birth, nationality, address, telephone, email, passport, identity document, visa, work permit, NIF and social-security identifiers.
Professional and recruitment CV, employment history, education, skills, trade tests, licences, certificates, references, interview notes, availability, salary expectations, rotation and mobility preferences.
Employment and assignment Contract, job title, payroll and bank details, attendance, timesheets, leave, performance, training, disciplinary and grievance records, mobilisation and demobilisation information.
HSE and competence Site inductions, BOSIET/HUET or other training, competency assessments, PPE requirements, permits, exposure records, incident participation, fitness-to-work status and emergency response information.
Commercial and compliance RFQs, quotations, orders, delivery records, invoicing, payment contacts, company affiliation, beneficial ownership or screening results, conflicts and due-diligence records.
Technical and digital IP address, device and browser data, login records, pages viewed, form activity, security logs, approximate location and cookie identifiers.
Communications and visits Emails, messages, meeting notes, event attendance, access logs and CCTV images where CCTV is lawfully used and clearly signposted.

 

5. Sensitive and safety-critical personal data

Where necessary and permitted by law, KOZATTI may process sensitive data, including health or disability information, offshore or occupational medical status, drug and alcohol test outcomes, biometric identifiers, trade-union information, and information concerning alleged or proven offences. We do not request sensitive data merely because it may be useful.

For industrial and oil-and-gas assignments, medical and HSE information may be required to confirm fitness, protect life and health, make appropriate workplace arrangements, meet client or legal requirements, investigate incidents, manage exposure or arrange emergency response. Wherever practicable, KOZATTI will share only the result needed for the decision – for example, “fit”, “fit with restrictions” or “not fit” – rather than a detailed diagnosis.

Access to sensitive data is restricted. Processing will rely on an appropriate legal basis, additional safeguards and any notification, registration or authorisation required by the Angolan Data Protection Agency.

6. How we collect personal data

We may collect personal data:

  • directly from you through forms, CVs, emails, interviews, calls, meetings, orders, site access, timesheets, training, medical or mobilisation processes;
  • from your employer, client, recruitment agency, referee, previous employer, educational or certification body, occupational-health provider, insurer or training provider;
  • from public and professional sources such as company websites, professional directories, sanctions lists and LinkedIn;
  • from government, immigration, tax, social-security, judicial or regulatory authorities where permitted;
  • from clients, operators, project partners and subcontractors involved in a tender, assignment or service;
  • automatically through website logs, security tools, cookies and similar technologies; and
  • from third parties you authorise to provide information to us.

If you provide data about another person, such as a referee, dependant or emergency contact, you confirm that you are authorised to do so and will direct that person to this Policy where appropriate.

7. Why we use personal data

Purpose Typical activities
Enquiries and business development Responding to enquiries, understanding requirements, preparing proposals and RFQs, managing contacts, events and requested communications.
Customer and supplier management Due diligence, onboarding, contracting, sourcing, order fulfilment, logistics, quality records, invoicing, payment, audit and relationship management.
Recruitment and talent management Receiving applications, matching candidates, interviews, assessment, references, identity and qualification checks, offers and talent-pool management.
Manpower and mobilisation Role matching, client submission, employment or assignment administration, timesheets, payroll, tax, social security, travel, visas, accommodation, training, medicals and demobilisation.
HSE, security and quality Competence assurance, access control, fitness confirmation, incident response and investigation, emergency management, fraud prevention, cybersecurity and quality control.
Legal and regulatory compliance Employment, immigration, tax, social-security, data-protection, local-content, sanctions, anti-bribery, court and regulatory obligations.
Operations and improvement Service delivery, internal reporting, audits, complaints, system administration, business continuity, anonymised analysis and improvement of our processes and Website.

 

8. Legal grounds for processing

Depending on the circumstances and applicable law, KOZATTI processes personal data where one or more of the following grounds applies:

  • the individual has given prior, informed and valid consent for a specified purpose;
  • processing is required to take steps requested before a contract or to perform a contract;
  • processing is required to comply with a legal, regulatory, tax, employment, social-security, immigration, HSE, local-content or judicial obligation;
  • processing is necessary to protect vital interests, including in an emergency;
  • processing is necessary for a legitimate business purpose, provided the individual’s rights and interests are appropriately considered; or
  • another ground is permitted by applicable Angolan law.

Where consent is used, it may be withdrawn for future processing. Withdrawal does not affect processing already carried out or processing supported by another lawful ground.

9. Recruitment and candidate database

KOZATTI uses candidate data to assess suitability, communicate about roles, verify qualifications and references, meet legal requirements and, where appropriate, submit a profile to a potential client. Registration does not guarantee an interview, assignment or employment.

Before sharing an identifiable CV or candidate profile with a client, KOZATTI will normally inform the candidate of the opportunity or otherwise rely on an appropriate and transparent basis. Clients may conduct their own assessment and may become independently responsible for their use of candidate data.

If you do not provide information needed to verify identity, qualifications, fitness or legal right to work, KOZATTI may be unable to progress your application or mobilisation. Optional information will be identified where appropriate.

Unsuccessful candidates may choose to remain in KOZATTI’s talent pool for future opportunities. Vacancy alerts and talent-pool retention should be based on a clear choice and may be stopped at any time.

10. Assigned personnel and oil-and-gas operations

For temporary or project personnel, KOZATTI may share proportionate data with the relevant client, operator, joint-venture participant, site controller, travel or logistics provider, clinic, training body, insurer or regulator to support mobilisation, access, competence assurance, HSE, payroll and assignment management.

Oil-and-gas clients may require identity documents, verified certificates, medical fitness, training records, local-content information, work history, rotation data and site-access details. KOZATTI will seek to limit disclosure to what is reasonably required for the role, project and applicable law. Clients must handle the information under their own legal and contractual responsibilities.

Incident and emergency records may include information about witnesses, injured persons, medical response and corrective actions. Such information will be access-controlled and used for safety, legal, insurance and improvement purposes, not unrelated employment decisions.

11. Compliance screening and verification

KOZATTI may verify identity, work history, qualifications, references, certifications, right to work, company ownership, sanctions exposure, conflicts of interest and adverse information where relevant and permitted. Checks will be proportionate to the role, transaction, client requirement and risk.

Criminal-record or similar sensitive checks will be conducted only where lawful, necessary and supported by appropriate safeguards. You may be asked to provide clarification where a check produces an uncertain or potentially inaccurate match.

12. Who we share personal data with

KOZATTI does not sell personal data. We may share the minimum information reasonably necessary with:

  • customers, prospective customers, operators, site controllers and project partners evaluating or receiving our supplies or manpower services;
  • manufacturers, suppliers, inspection bodies, logistics providers and subcontractors involved in delivering a product or service;
  • recruitment partners, candidate-management platforms, payroll providers, banks, insurers, clinics, occupational-health providers, travel agents, accommodation providers and training centres;
  • IT, cloud hosting, email, cybersecurity, analytics, document-management and technical-support providers;
  • professional advisers, auditors and insurers;
  • tax, social-security, labour, immigration, judicial, law-enforcement, petroleum-sector and data-protection authorities where required or permitted; and
  • a buyer, investor or successor in connection with a genuine corporate transaction, subject to appropriate confidentiality and legal controls.

Service providers acting for KOZATTI are expected to process personal data only for authorised purposes, maintain confidentiality and implement appropriate security. Some recipients, including clients, authorities and healthcare providers, may independently determine how they use data.

13. International transfers

KOZATTI’s procurement and manpower activities may involve international manufacturers, recruitment partners, clients, cloud providers or advisers. Personal data may therefore be accessed from or transferred to countries outside Angola, including countries whose legal protections differ from those in Angola.

KOZATTI will conduct international transfers only where permitted by Angolan law and will use appropriate safeguards, such as a lawful transfer mechanism, contractual confidentiality and security obligations, data minimisation, restricted access, encryption where appropriate, and any required approval or authorisation from the Angolan Data Protection Agency.

Where practicable, candidates will be informed before their profiles are disclosed to an overseas client or partner. Contact us if you require information about the safeguards relevant to a particular transfer, subject to confidentiality and legal limitations.

14. Data retention

KOZATTI retains personal data only for as long as reasonably required for the purpose collected, applicable legal and regulatory duties, audits, dispute resolution, safety obligations and the establishment or defence of legal claims. The following periods are operational targets and must be validated before publication:

Record type Proposed retention approach
General enquiries and prospects Up to 24 months after the last meaningful interaction, unless a longer active relationship or legal need applies.
Unsuccessful candidate data Up to 24 months after the last application or meaningful update when the candidate chooses talent-pool retention; otherwise a shorter recruitment close-out period.
Vacancy-alert preferences Until withdrawal or after 12 months without reconfirmation or meaningful engagement.
Customer, supplier and transaction records Normally up to 10 years after the transaction or end of the relationship where required for contractual, tax, accounting, audit or legal purposes.
Worker, payroll and assignment records For the assignment or employment period and the applicable statutory limitation, tax, social-security, audit and claim periods.
HSE, medical, exposure and incident records For the period required by occupational-health, safety, insurance, client or other applicable rules; some safety records may require extended retention.
CCTV, if used Normally up to 30 days unless footage is required for an incident, investigation or legal claim.
Website and security logs For a proportionate security and diagnostic period based on system risk and configuration.

 

When retention ends, KOZATTI will securely delete, destroy or anonymise the data, unless preservation is required or permitted by law. Anonymised information that no longer identifies a person may be retained for statistics, planning and service improvement.

15. Security and incident management

KOZATTI uses proportionate administrative, physical and technical measures designed to protect personal data against accidental or unlawful loss, destruction, alteration, disclosure or access. Measures may include role-based access, confidentiality commitments, secure configuration, backups, malware protection, encryption where appropriate, vendor controls, access reviews, staff awareness and incident-response procedures.

No internet or storage system is completely secure. If a personal-data incident occurs, KOZATTI will investigate, contain and remediate it and will notify affected individuals and the competent authority where required by law. Individuals should promptly report suspected compromise to the privacy contact in Clause 22.

16. Cookies and website analytics

The Website may use strictly necessary cookies and, depending on the deployed configuration and your choices, functional, performance, analytics or advertising technologies. Non-essential cookies should not be activated until the required consent has been obtained.

A separate Cookie Policy and consent tool should identify the actual cookie name, provider, purpose and duration and explain how preferences can be changed. Browser settings may also block or delete cookies, although this may affect Website functionality.

17. Marketing communications

KOZATTI may send information about relevant services, products, tenders, events or vacancies where permitted by law and consistent with your preferences. You may opt out of marketing at any time by using the unsubscribe method provided or contacting us. We may still send necessary operational communications about an enquiry, order, application, assignment or legal matter.

18. Artificial intelligence and automated decisions

KOZATTI may use digital tools to organise, search or match product, commercial or candidate information. KOZATTI will not make a decision producing legal or similarly significant effects about an individual solely through automated processing without prior transparency, a lawful basis and appropriate safeguards, including human review where required.

KOZATTI will not knowingly provide identifiable personal data to a third-party generative-AI provider for training its public models unless there is a lawful basis, appropriate notice and contractual protection. Sensitive candidate, medical, client and HSE information must not be entered into unapproved public AI tools.

19. Your rights

Subject to the conditions and limitations of Angolan law, you may have the right to:

  • be informed about the processing of your personal data;
  • request access to personal data held about you and information about its processing;
  • request correction or updating of inaccurate or incomplete data;
  • object to or request cessation of certain processing, including direct marketing;
  • withdraw consent for future processing where consent is the applicable basis;
  • request deletion, blocking or restriction where the legal conditions are met;
  • challenge a significant decision based solely on automated processing and request appropriate human intervention where applicable;
  • receive or transfer data in an available structured format where such a right applies; and
  • complain to KOZATTI or the Angolan Data Protection Agency.

To protect confidentiality, KOZATTI may request proof of identity and sufficient information to locate the relevant records. We will respond within the period required by applicable law. Rights may be limited where disclosure would affect another person’s rights, legal privilege, safety, regulatory duties or the establishment or defence of claims.

20. Children

The Website and KOZATTI’s services are not directed to children. We do not knowingly collect personal data from minors except where necessary for a lawful internship, apprenticeship, dependant, benefit or emergency purpose and with the authorisation or safeguards required by law. If you believe a minor has submitted data inappropriately, please contact us.

21. Accuracy and changes to this Policy

Please keep your personal data accurate and notify KOZATTI of material changes. We may update this Policy to reflect changes in law, systems or operations. The current version and effective date will be published on the Website, and material changes may be communicated through an appropriate additional notice.

22. Contact and complaints

Questions, rights requests or complaints should be sent to:

Please state that your request concerns privacy and provide enough information for us to understand it. We will seek to resolve concerns directly. You may also submit a complaint to the Agência de Protecção de Dados (APD), Rua do MAT, Complexo Administrativo Clássicos de Talatona, 3rd Building, 7th Floor, Luanda, Angola; email: geral@apd.ao; telephone/WhatsApp: +244 937 930 788. Authority details should be checked before publication.