Legal Notice
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Data Protection and Privacy
Data Protection and Privacy Commitment
Vilamoura Properties complies with all applicable EU and national legal standards in the field of data protection, privacy and information security.
Vilamoura Properties is implementing a Personal Data Protection System and an Information Security System, in order to ensure regulatory compliance and the demonstration or evidence of institutional responsibility in terms of data protection and information security. implementing all the necessary technical and organizational measures, both to comply with the general legal regime of the Data Protection Law in force, and to comply with the special legal regime of the General Data Protection Regulation, applicable from 25 May 2018.
For any clarification or additional information or to exercise rights in this area, please contact the Vilamoura Properties Data Protection Office via email info@vilamouraproperties.pt .
Definitions
"Personal data"
"Personal data" means information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier. Personal identifiers include, for example, a name, an identification number, location data, online identifiers or one or more elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing of Personal Data"
'processing' means an operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, broadcast or otherwise making available, alignment or combination, limitation, erasure or destruction.
"Cookies"
"Cookies" are small text files with information considered relevant that the devices used for access (computers, mobile phones or portable mobile devices) load, through the internet browser, when a website is visited by the Client or User.
Entity Responsible for the Processing
"Smiling Dolphin, Lda.", headquartered at Buganvilia Plaza 1, Quinta do Lago, Almancil, registered at the Commercial Registry Office of Loulé, under the single registration and legal person number 513.587.802, with a share capital of € 5.000,00, hereinafter referred to as Vilamoura Properties, is the entity responsible for the websites www.vilamouraproperties.pt and www.vilamouraproperties.com , as well as by computerised applications, hereinafter referred to as channels or applications, through which Users, Service Recipients or Customers have remote access to Vilamoura Properties' services and products that are presented, marketed or provided, at any time, through them.
The use of the channels or applications by any User, Service Recipient or Customer may imply the performance of personal data processing operations, whose protection, privacy and security by Vilamoura Properties, as the entity responsible for the respective processing, is ensured, in accordance with the terms of this Data Protection and Privacy Policy.
Contacts of the Data Controller
For the purpose of contacting the Vilamoura Properties Data Protection Office, please send an email to info@vilamouraproperties.pt, describing the subject of the request and indicating an email address, a telephone contact address or a mailing address.
For any other purpose, the following general contacts of Vilamoura Properties may be used:
– Postal Address: Buganvilia Plaza 1, Quinta do Lago, 8135-024 Almancil
– Email: info@vilamouraproperties.pt
– Phone: +351 912 235 548
Collection and Processing of Personal Data
Vilamoura Properties processes the personal data strictly necessary for the provision of information and the operation of its channels, in accordance with the uses made by Users, Service Recipients or Customers, whether those provided by Users, Recipients of the Service or Customers for the purpose of registering requests or obtaining information, either those provided by them for the purpose of joining those channels, or those resulting from the use of the services provided by Vilamoura Properties, such as accesses, queries, instructions, transactions and other records relating to its use.
In particular, the use or activation of certain features of the channels may involve the processing of various direct or indirect personal identifiers, such as name, home address, contacts, device addresses or geographical location; provided that there is the express consent of the User, Service Recipient or Customer.
In all cases, Users, Service Recipients or Customers will always be informed of the need to access such data for the use of the functionalities of the channels in question.
The personal data collected by Vilamoura Properties is processed electronically, in certain cases in an automated way, including the processing of files or the definition of profiles and within the scope of the management of the pre-contractual, contractual or post-contractual relationship with Users, Service Recipients or Customers, in accordance with the national and Community rules in force.
Categories of Personal Data Processed
The categories or types of personal data of Users, Service Recipients and Customers that are processed are as follows:
- Name;
- Home and/or work telephone number;
- Mobile phone;
- Address of residence and/or place of work;
- Email address
Legal Principles
All data processing operations comply with the fundamental legal principles in the field of data protection and privacy, namely regarding their circulation, lawfulness, loyalty, transparency, purpose, minimization, conservation, accuracy, integrity and confidentiality, and Vilamoura Properties is available to demonstrate its responsibility to the data subject or any other third party entity that has a legitimate interest in this matter.
Grounds of Legitimacy
All data processing operations carried out by Vilamoura Properties have a basis of legitimacy, namely, either because the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes, or because the processing is considered necessary for the performance of a contract in which the data subject has given his or her consent. data is a party, either for pre-contractual steps at the request of the data subject, either because the processing is necessary for compliance with a legal obligation to which the controller is subject, or because the processing is necessary for the purposes of the legitimate interests pursued by Vilamoura Properties or by third parties.
Purpose of Processing
All personal data processed within the scope of Vilamoura Properties' channels are intended exclusively for the provision of information to Users, the management of the personal information of the Service Recipients considered necessary for the purposes of managing the relationship or communication, as well as the provision of the services contracted by the Clients and, in general, the management of the pre-contractual, contractual or post-contractual relationship with the Users, Service Recipients or the Clients.
The personal data collected may also and eventually be processed for statistical purposes, for information dissemination or promotional actions and for commercial or marketing actions, namely to promote actions to disseminate new features or new products and services, through direct communication, whether by correspondence, email, messages or telephone calls or any other electronic communications service, and this data may be transmitted to other companies of the Vilamoura Properties Group for the same purposes.
Provided that prior information and express authorisation for the latter purposes are always ensured, Users, Service Recipients or Customers may, at any time, exercise their right to oppose the use of their personal data for purposes other than the management of the contractual relationship. namely for marketing purposes, for the sending of informative communications or for inclusion in lists or information services, and for this purpose, you must send a written request addressed to the Data Protection Office of Vilamoura Properties, in accordance with the procedures indicated below.
Data Retention Periods
Personal data will be kept only for the period necessary for the purposes for which it was collected or subsequently processed, and compliance with all applicable legal rules on archiving is guaranteed.
Use of Cookies
Vilamoura Properties may eventually use two broad categories of cookies: cookies within the scope of websites and cookies within the scope of direct electronic communication channels, and in any of the categories, the respective deactivation by Users is always guaranteed. Service Recipients or Customers.
Vilamoura Properties uses cookies on its websites in order to improve the performance and browsing experience of Users, Service Recipients and Customers, increasing, on the one hand, the speed and efficiency of response and, on the one hand, on the other hand, eliminating the need to repeatedly enter the same information.
The use of cookies helps websites to recognise Users' and Customers' devices the next time they visit them, and in some cases it is also essential for them to function.
The cookies used by Vilamoura Properties, in all its channels, do not collect personal information that allows the identification of Users, Service Recipients or Customers, but only store generic information, namely the form or geographical location of access and the way they use the channels. among others. Cookies only retain information related to the preferences of Users and Customers, and no personal identifiers are recorded.
Users, Service Recipients and Customers may, at any time, through the computer application they use to browse the internet (browser), make the decision to be notified of the receipt of cookies, as well as to block their entry into their system.
Regarding the type of intended purposes, Vilamoura Properties may, where appropriate, use three different types of cookies, according to the following specifications:
(i) essential cookies – some cookies are essential for accessing specific areas of the online channels, enabling browsing and use of their applications, as well as access to secure areas of the websites, through user registration – without these cookies, services that require it cannot be provided;
(ii) Functionality cookies – Functionality cookies allow the user's preferences regarding browsing on websites to be remembered, thus not requiring reconfiguration and personalisation
(iii) analytical cookies – these cookies are used to analyse how users use the websites, allowing to highlight articles or services that may be of interest to users, monitoring the performance of the websites, as well as knowing which pages are the most popular, which method of linking between pages is most effective or to determine why some pages are receiving error messages – these cookies are only used for the purpose of statistical creation and analysis, without ever collecting personal information.
For these purposes, Vilamoura Properties can provide a high quality experience to Users, Service Recipients or Customers, personalising information and offers and identifying or correcting any possible problems that may arise in the scope of their use.
Regarding the type of validity, there are two types of cookies:
(i) permanent cookies – these are cookies that are stored on the devices used to access the channels (computers, mobile phones, etc.), at the level of the computer application used to browse the internet (browser), and are used whenever Users or Customers visit any channel again – in general, they are used to direct navigation according to the interests of the User or the Client, allowing Vilamoura Properties to provide a more personalized service;
(ii) session cookies – these are temporary cookies, which are generated and are only available until the session ends, since the next time the Client/User accesses their internet browser the cookies will no longer be stored – informs theThe action obtained allows you to manage sessions, identify problems and provide a better browsing experience.
Users, Service Recipients and Customers may disable part or all of the cookies at any time – they must follow the instructions available in each of the computer applications used to browse the internet (browser), however, with deactivation, you may lose access to some features of the sites.
Vilamoura Properties, within the scope of direct electronic communication channels, may also use cookies in the opening of the different electronic communications sent, such as newsletters and e-mail, for statistical purposes – allowing us to know if these communications are opened and to verify clicks through a link to the or advertisements within these communications.
Also in this category of cookies, Users, Service Recipients and Customers always have the possibility to disable the sending of electronic communications through the specific option at the bottom of the same.
Communication of Data to Other Entities
The provision of information or the provision of services by Vilamoura Properties to its Users, Service Recipients or Customers through the channels may eventually involve the use of the services of third party subcontractors, including entities based outside the European Union, for the provision of certain services, which may imply access, by these entities, to the personal data of Users, Service Recipients or Customers.
In these circumstances and whenever necessary, Vilamoura Properties will only use subcontracted entities that present sufficient guarantees of the execution of appropriate technical and organisational measures in a way that the processing meets the requirements of the applicable standards, and such guarantees will be formalised in a contract signed between Vilamoura Properties and each of these third parties.
Data Recipients
Except in the context of compliance with legal obligations, under no circumstances will there be communication of personal data of Users, Service Recipients or Customers to third parties other than subcontractors, companies of the Quintela and Penalva Group or legitimate recipients, nor is any other communication made for purposes other than those referred to above.
International Data Transfers
Any transfer of personal data to a third country or an international organisation will only be carried out within the framework of compliance with legal obligations or ensuring compliance with the applicable Community and national legal rules in this matter.
Security Measures
Taking into account the most advanced techniques, the costs of application and the nature, scope, context and purposes of the processing, as well as the risks, of varying probability and severity, for Users, Service Recipients or Customers, Vilamoura Properties and all its subcontractors apply the appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
To this end, several security measures are adopted in order to protect personal data against its dissemination, loss, misuse, alteration, unauthorized processing or access, as well as against any other form of unlawful processing.
It is the sole responsibility of the Users, Service Recipients or Customers to keep the access codes secret, not sharing them with third parties, and also, in the particular case of the computer applications used to access the channels, maintain and maintain the access devices in safe conditions and follow the security practices advised by manufacturers and/or operators, namely regarding the installation and updating of the necessary security applications, namely, among others, antivirus applications.
If there is a need to subcontract services to third parties that may have access to the personal data of Users or Customers, Vilamoura Properties' subcontractors will be obliged to adopt the security measures and protocols at the organisational level and the technical measures necessary to protect confidentiality and security.personal data, as well as to prevent unauthorized access, loss or destruction of personal data.
Exercise of the Rights of the Holders of Personal Data
Users, Service Recipients and Customers of Vilamoura Properties may, as holders of personal data, at any time, exercise their data protection and privacy rights, namely the rights of access, rectification, erasure, portability, limitation or opposition to processing, under the terms and with the limitations provided for in the applicable regulations.
Any request to exercise data protection and privacy rights must be addressed in writing by the respective holder to the Vilamoura Properties Data Protection Office, in accordance with the procedure and contact details described below.
Complaints or Suggestions and Incident Communication
Users, Service Recipients and Clients of Vilamoura Properties have the right to file a complaint, either by registering the complaint in the Complaints Book or by submitting a complaint to the regulatory authorities.
Users, Service Recipients and Customers of Vilamoura Properties may also make suggestions by e-mail sent to the Vilamoura Properties Data Protection Office.
Incident Reporting
Vilamoura Properties has implemented an incident management system in the field of data protection, privacy and information security.
If any User, Service Recipient or Customer wishes to report the occurrence of any personal data breach that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or access, personal data transmitted, stored or subject to any other type of processing, you can contact the Vilamoura Properties Data Protection Office or use the general Vilamoura Properties contacts described above.
Changes to the Privacy Policy
In order to ensure its updating, development and continuous improvement, Vilamoura Properties may, at any time, make any changes that are deemed appropriate or necessary to this Data Protection and Privacy Policy, and its publication in the different channels is ensured to ensure the respective transparency and information to Users, Service Recipients and Customers.
Express Consent and Acceptance
The terms of the Data Protection and Privacy Policy are complementary to the terms and provisions, regarding personal data, provided for in specific communication campaigns and/or dissemination of Vilamoura Properties products or services that may be carried out.
The free, specific and informed provision of personal data by the respective holder implies knowledge and acceptance of the conditions contained in this Policy, considering that, by using the channels or by making their personal data available, Users, Service Recipients and Customers are expressly authorizing their processing. in accordance with the rules defined in each of the applicable collection channels or instruments.
Data Protection Office
For the exercise of any type of data protection and privacy rights or for any matter related to data protection, privacy and information security, Users, Service Recipients and Clients of Vilamoura Properties may contact the Data Protection Office through of the info@vilamouraproperties.pt email, describing the subject of the request and indicating an email address, a telephone contact address or a reply-to mailing address.
Accessory Clause
The content of the websites is translated into English and French, with the same meaning and content, prevailing, for due legal purposes, in case of discrepancy, the Portuguese version over any other.