1.1. COLLECTION AND TREATMENT OF USER DATA
In the context of making the website hosted at www.casinhasdelisboa.com (“Site”) available, entering into any contracts (such as hosting services, vouchers, treatments and Spa products), providing information, content, including newsletter, users, or any telephone contacts (together, the “Services”) to their users (“User”) and other related entities, the members of the Casinhas de Portugal Group represented here by T-Dreams LDA, sole proprietorship headquartered at Rua das Flores nº105 3D, 1200-194 Lisboa, registered with the Lisbon Commercial Registry Office under the unique registration and corporate number 510987826 (hereinafter “Casinhas de Portugal”) you may request the User to provide personal data, this is,information provided by the User that enables Casinhas de Portugal to identify and / or contact you (“Personal Data”).
As a rule, Personal Data is requested when you request contact and / or newsletters, subscribe to a certain service, provide or request information, purchase a product or establish a contractual relationship with Casinhas de Portugal.
Personal Data collected and processed consists primarily of information regarding name, gender, date of birth, telephone, mobile phone, email, address, tax ID, credit card data (collected for billing purposes only), although it may come from to be collected other Personal Data that may be necessary or convenient for the provision or collection of Services by Casinhas de Portugal.
After collecting the Personal Data, Casinhas de Portugal will provide the User with detailed information about the nature of the collected data and about the purpose and processing of the Personal Data, as well as the information mentioned in clause 8
. Casinhas de Portugal also collects and processes information about the device characteristics of your hardware and the characteristics of browser / software as well as information about the pages visited by the User within the Site. This information may include your browser type, domain name, access times and hyperlinks through which you accessed the Site (“Usability Information”). We use this information only to improve the quality of your visit to our Site.
These subcontracting entities may not transmit User Data to other entities without Casinhas de Portugal having given prior written authorization to do so, and may not contract other entities without prior authorization from Casinhas de Portugal.
Casinhas de Portugal undertakes to subcontract only entities that offer maximum security in the execution of appropriate technical and organizational measures, in order to guarantee the protection of the user’s rights. All entities subcontracted by Casinhas de Portugal are bound by the latter by means of a written contract which regulates, in particular, the object and duration of processing, the nature and purpose of processing, the type of personal data, the categories of the holders. data and the rights and obligations of the parties.
After collecting personal data, Casinhas de Portugal provides the User with information about the categories of subcontractors that, in this case, may process data on behalf of Casinhas de Portugal.
1.3. DATA COLLECTION CHANNELS Casinhas de Portugal may collect data either directly (ie, directly from the User) or indirectly (ie, through partner entities or third parties). Collection can be done through the following channels: Direct collection: in person, by phone, by email and through the Site; Indirect collection: through partners or group companies and official entities.
2. GENERAL PRINCIPLES APPLICABLE TO USER DATA PROCESSING In terms of general principles concerning the processing of personal data, Casinhas de Portugal undertakes to ensure that the User Data processed by you is:
Subject to processing in accordance with the law, fair and transparent to the User;
Collected for specified, objective and legitimate purposes and not further treated in a manner contrary to those purposes;
Adequate, justified and limited to what is necessary for the purposes for which they are treated;
Accurate and up to date as necessary and all necessary steps are taken to ensure that inaccurate data, taking into account the purposes for which they are processed, are deleted or corrected without delay.
Retained in a manner that permits User identification only for the period necessary for the purposes for which the data are processed;
Treated in a manner that ensures their safety, including protection against unauthorized or unlawful treatment and loss, destruction or unforeseen damage, and appropriate technical or organizational measures shall be taken.
Data processing by Casinhas de Portugal is permitted and legal when at least one of the following situations occurs:
1 – The User has without any doubt given his or her consent to the processing of User Data for one or more specific purposes;
2 – The treatment is necessary for the execution of a contract to which the User is party, or for pre-contractual procedures at the request of the User;
3 – The treatment is necessary for the fulfillment of a legal obligation to which the Casinhas de Portugal are subject;
4 – The treatment is necessary for the defense of the fundamental interests of the User or another individual person;
5 – The processing is necessary for the purpose of the legal interests pursued by Casinhas de Portugal or third parties (except if the interests or fundamental rights and freedoms of the User that require the protection of personal data prevail).
Casinhas de Portugal undertakes to ensure that the processing of User Data is only done under the conditions listed above and with respect for the principles mentioned above.
When processing your User Data, Casinhas de Portugal based on your agreement, you have the right to withdraw your consent at any time. The withdrawal of consent, however, does not compromise the legality of the treatment made by Casinhas de Portugal based on the consent previously given by the User.
The length of time data is stored and stored varies according to the purpose for which the information is processed.
Indeed, there are legal requirements that require us to keep data for a minimum period of time. Thus, and where there is no specific legal obligation, data will be stored and retained only for the minimum period necessary for the purposes that led to its collection or further processing, which will eventually be deleted.
3. USE AND PURPOSE OF USER DATA PROCESSING In general terms, Casinhas de Portugal uses User Data for the following purposes: • Provision of hotel services and associated services (restaurants, bars, Spa, etc.);
• Contact management with the User;
• User billing and billing;
• User Registration on the Site;
• Inform the User, upon request, of new products and services made available on the Site and / or accommodation units, special offers and campaigns, updated information on the activity of Casinhas de Portugal and, generally, for the purpose of marketing of Casinhas de Portugal and its accommodation units, by any means of communication, including electronic support;
• Allow access to restricted areas of the Site, in accordance with previously established terms;
• Ensure that the Site meets User needs by developing and publishing content as appropriate as possible to User requests and type, improving Site search capabilities and functionality, and obtaining associated or statistical information. regarding the user’s profile type (consumption profile analysis);
• Provision of Services, and other services, such as newsletters, opinion polls, or other information or products requested or purchased by the User;
• Recording of telephone calls that may be made in connection with the solicitation or provision of information about reservations, vouchers and other products or services and their business and usage conditions as well as the establishment of any contractual relationship, either at the contract formation stage. either during its duration;
• Casinhas de Portugal may combine Usability Information with anonymous demographic information for search purposes, and may use the result of such combination to provide more relevant content on the Site. In certain restricted areas of the Site, Casinhas de Portugal may combine Personal Data with Usability Information to provide you with more personalized content.
The User Data collected by Casinhas de Portugal is not shared with third parties without your consent, except for the situations mentioned in the following paragraph. However, in the event that the User engages with Casinhas de Portugal services provided by other entities responsible for the processing of personal data, the User Data may be consulted or accessed by those entities, to the extent necessary to provide of those services.
4. IMPLEMENTED TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES In order to guarantee the security of User Data and the utmost confidentiality, Casinhas de Portugal treats the information you have provided to us in a completely confidential manner, in accordance with its internal security policies and procedures. confidentiality, which are periodically updated as necessary, as well as with the legally provided terms and conditions.
Depending on the nature, scope, context and purposes of the processing of data, as well as the risks arising from the processing of the rights and freedoms of the user, Casinhas de Portugal undertake to apply, both when defining the means as at the time of the processing itself, the technical and organizational measures necessary and appropriate to the protection of User Data and the compliance with legal requirements.
It also undertakes to ensure that, by default, only data that are necessary for each specific treatment purpose are processed and that such data is not made available without human intervention to an undetermined number of persons.
Communication between the user’s device and the Casinhas de Lisboa website is via secure channels and communications using the HTTPS protocol and the SSL security standard. Still, in terms of general measures, the Casinhas de Portugal adopt the following:
Regular audits to identify the competence of the technical and organizational measures implemented;
Sensitization and training of personnel involved in data processing operations;
Pseudonymization and coding of personal data;
Mechanisms capable of ensuring the continuing confidentiality, availability and resilience of information systems;
Mechanisms to ensure the rapid restoration of information systems and access to personal data in the event of a physical or technical incident;
5. DATA TRANSFER OUTSIDE THE EUROPEAN UNION Personal data collected and used by Casinhas de Portugal is not made available to third parties established outside the European Union. If in the future such transfer occurs for the reasons mentioned above, Casinhas de Portugal undertake to ensure that the transfer complies with the applicable legal provisions, in particular as regards the determination of the suitability of such country with regard to data protection and the requirements applicable to such transfers.
B. USERS RIGHTS (DATA HOLDERS) 7. RIGHT TO INFORMATION
7.1. Information provided to you by Casinhas de Portugal (when data is collected directly from the User):
• The identity and contact details of Casinhas de Portugal, the controller and, if applicable, their representative;
• Contacts of the Data Protection Officer;
• The purposes of the processing for which the personal data are intended, as well as, if applicable, the legal reasons for the processing;
• If the processing of data is based on legitimate interests of Casinhas de Portugal or a third party, indication of such interests;
• If applicable, the recipients or categories of recipients of personal data;
• If applicable, an indication that personal data will be transferred to a third country or an international organization, and whether or not there is an adequacy decision taken by the Commission or reference to appropriate or appropriate transfer guarantees;
• Term of retention of personal data;
• The right to request from Casinhas de Portugal the permission of personal data, as well as its correction, deletion or limitation, the right to oppose the processing and the right to accessibility of data;
• If the processing of the data is based on the consent of the User, the right to withdraw it at any time, without compromising the legality of the processing based on the previously given consent;
• The right to complain to the CNPD or other supervisory authority;
• Indication of whether or not the communication of personal data is a legal or contractual obligation, or a necessary requirement to enter into a contract, as well as whether the holder is required to provide personal data and the possible consequences of not providing such data;
• If applicable, the existence of automatic decisions, including profiling, and background information, as well as the significance and expected consequences of such processing for the data subject.
• In the event that the User Data is not collected directly by Casinhas de Portugal from the User, in addition to the information mentioned above, the User is also informed about the categories of personal data being processed, as well as about the origin of the data. and eventually if they are from sources accessible to the public.
• If Casinhas de Portugal intends to further process User Data for a purpose other than that for which the data was collected, Casinhas de Portugal will provide the User with information about that purpose and any other information of interest prior to such processing. , as referred to above.
7.2. Procedures and measures implemented to enforce the right to information.
The information referred to in 7.1. is provided in writing (including by electronic means) by Casinhas de Portugal to the User prior to the processing of personal data in question. Under applicable law, Casinhas de Portugal is under no obligation to provide the User with the information mentioned in 7.1 when and to the extent that the User is already aware of it.
The information is provided by Casinhas de Portugal at no cost.
8. RIGHT TO ACCESS TO PERSONAL DATA Casinhas de Portugal guarantees the means by which the user can consult his personal data.
The User has the right to obtain from Casinhas de Portugal confirmation that the personal data concerning him or her are or are not processed and, if applicable, the right to access their personal data and the following information:
1 – The purposes of data processing;
2 – The categories of personal data in question;
3 – Recipients or categories of recipients to whom personal data have been or will be disclosed, namely recipients established in third countries or belonging to international organizations;
4 – The term of retention of personal data;
5 – The right to request from Casinhas de Portugal the correction, deletion or limitation of the processing of personal data, or the right to prevent such processing;
6 – Right to file a complaint with the CNPD or other supervisory authority;
7 – If the data has not been collected from the User, the available information about the origin of such data;
8 – The existence of automated decisions, including profiling, and information regarding the underlying logic, as well as the significance and expected consequences of such processing for the data subject;
9 – Right to be informed about appropriate safeguards associated with the transfer of data to third countries or international organizations.
10 – Upon request, Casinhas de Portugal will provide the User, free of charge, with a copy of the User Data that are being processed. Providing other copies requested by the User may incur administrative costs.
9. RIGHT TO RETIFY PERSONAL DATA You have the right at any time to request the rectification of your Personal Data, as well as the right for your incomplete personal data to be completed, including by means of an additional statement. .
In the event of rectification of the data, Casinhas de Portugal shall communicate to each recipient to whom the data have been transmitted to their rectification, unless such communication is deemed impossible or implies a disproportionate effort for the Casinhas de Portugal.
10. RIGHT TO DELETE PERSONAL DATA (“RIGHT TO BE FORGOTTEN”) You have the right to have Casinhas de Portugal delete your data when one of the following reasons applies: ü
1 – Your Data Users are no longer necessary for the purpose that motivated their collection or treatment;
2 – The User withdraws the consent on which the processing of data is based and there is no other legal basis for such processing;
3 – The User opposes the treatment under the right of opposition and there are no prevailing legitimate interests that justify the treatment;
4 – If the User Data is treated illegally;
5 – Should the User Data have to be deleted to fulfill a legal obligation to which Casinhas de Portugal is subject;
6 – Under applicable law, Casinhas de Portugal is under no obligation to delete User Data to the extent that processing is necessary to comply with a legal obligation to Casinhas de Portugal or for the purposes of declaration, exercise or defense of a right of the Casinhas de Portugal in a court case.
In the event of deletion of data, Casinhas de Portugal shall communicate to each recipient / entity to whom the data has been transmitted for deletion, unless such communication proves impossible or entails a disproportionate effort for Casinhas de Portugal.
When Casinhas de Portugal has made User Data public and is obliged to delete them under the right of such deletion, Casinhas de Portugal undertakes to take reasonable measures, including technical measures, taking into account the available technology and the costs of its application, to inform those responsible for the effective processing of personal data that the User has requested them to delete links to such personal data as well as copies or reproductions thereof.
11. RIGHT TO LIMITATION OF PROCESSING OF PERSONAL DATA The User has the right to obtain, from Casinhas de Portugal, the limitation of the processing of User Data if one of the following applies (the limitation is to insert a mark in the personal data retained for the purpose of limiting its processing in the future):
1 – If you contest the accuracy of personal data, for a period that allows Casinhas de Portugal to verify its accuracy;
2 – If the processing is unlawful and the User opposes the deletion of the data, requesting, in return, the limitation of its use;
3 – If Casinhas de Portugal no longer needs User Data for processing purposes, but such data is required by the User for the purpose of declaring, exercising or defending a right in a judicial process;
4 – If the User has objected to the treatment, until it appears that the legitimate motives of Casinhas de Portugal prevail over those of the User.
Where User Data is subject to limitation, it may only, with the exception of retention, be processed with the consent of the User or for the purpose of asserting, exercising or defending a right in court proceedings, defending the rights of another individual or or for reasons of public interest legally provided for.
The User who has obtained the limitation of the processing of his data in the above cases will be informed by Casinhas de Portugal before the limitation to the treatment is canceled.
In the event that data processing is limited, Casinhas de Portugal will communicate to each recipient to whom the data has been transmitted, unless such communication proves impossible or involves a disproportionate effort for Casinhas de Portugal.
12. RIGHT TO PORTABILITY OF PERSONAL DATA The User has the right to receive personal data concerning him that he has provided to Casinhas de Portugal, in a structured format, of ordinary use and automatic reading, and the right to transmit such data. to another controller if:
1 – Treatment is based on the consent or agreement to which the User is a party;
2 – The treatment is performed by automated means.
The right to portability does not include inferred data or derived data, ie personal data that is generated by Casinhas de Portugal as a result of or analysis of the data being processed.
The User has the right to have their personal data transmitted directly between the controllers, whenever technically possible.
13. Right of Opposition to Treatment The User has the right to oppose, at any time, for reasons related to his particular situation, to the processing of personal data concerning him based on the exercise of legitimate interests pursued by Casinhas de Portugal or when the processing is carried out for personal purposes. other than those for which personal data were collected, including profiling, or when personal data are processed for statistical purposes.
Casinhas de Portugal will finalize the processing of User Data, unless there are urgent and legitimate reasons for such processing that prevail over the interests, rights and freedoms of the User, or for the purpose of declaring, exercising or defending a right of Casinhas de Portugal in a court case.
When User Data is processed for the purpose of direct marketing (Marketing), the User has the right to object at any time to the processing of data concerning him for the purposes of such marketing, which includes the definition of profiles in the insofar as it relates to direct marketing. If you object to the processing of your data for the purpose of direct marketing, Casinhas de Portugal ceases to process the data for that purpose.
You also have the right not to be subject to any decision made solely on the basis of automated processing, including profiling, which has effects in your legal sphere or that significantly affects you, unless the decision:
• Is necessary for the conclusion or execution of a contract between the User and Casinhas de Portugal
• Is authorized by legislation to which Casinhas de Portugal is subject;
• It is based on your explicit consent.
13. PROCEDURES FOR USER’S EXERCISE RIGHTS The right of access, the right of rectification, the right of limitation, the right to limit, the right to portability and the right to object may be exercised by the User through contact with the Charge. Data Protection Policy of Casinhas de Portugal, via email email@example.com and / or through the page available on the Site.
Casinhas de Portugal will respond in writing (including by electronic means) to the user’s request within a maximum period of one month from the receipt of the request, except in cases of special complexity, which may be extended up to two months.
If the requests submitted by the User are manifestly unjustified or excessive, namely due to its repetitive nature, Casinhas de Portugal reserves the right to charge administrative costs or refuse to comply with the request.
14. PERSONAL DATA VIOLATIONS In the event of a data breach and to the extent that such breach is likely to pose a high risk to the rights and freedoms of the User, Casinhas de Portugal undertakes to report the breach of personal data to the User concerned within 72 hours. hours from the knowledge of the incident.
According to the law, communication to the User is not required in the following cases:
• If Casinhas de Portugal has applied appropriate protective measures, both technical and organizational, and these measures have been applied to personal data affected by the violation of personal data, especially measures that make personal data incomprehensible to anyone not authorized to access such data, such as encryption;
• If Casinhas de Portugal has taken subsequent measures to ensure that the high risk to the rights and freedoms of the User is no longer likely to materialize; or
• If the communication to the User implies a disproportionate effort for the Portugal Homes. In that case, Casinhas de Portugal will make a public communication or take a similar measure by which the User will be informed.