Privacy and Data Policy

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1.-

Data controller:

MGP PROJETO 2, UNIPESSOAL LDA (RESERVA ALECRIM)

 

1- WHO IS THE DATA CONTROLLER OF YOUR PERSONAL DATA?

 

The controller of your personal data and owner of the website https://www.campingsaomiguel.pt/ is MGP PROJETO 2, UNIPESSOAL LDA Commercial Company with registered office at Avda. Duque d'Ávila, 46 3ª C 1050-083 Lisbon with NIPC (CIF) 517617595 registered in Conservatória do Registo Comercial de Lisboa (hereinafter referred to as RESERVA ALECRIM). RNET8415. 

The contact details of RESERVA ALECRIM in relation to data protection are:

 

 

+351 911111137
 
 
 
privacy@wecamp.net

2.-

Type of personal data we process and for what purposes:

Contact data, identification data for reservations and other data necessary for the required purposes such as replying to the information requested through our website https://www.reservaalecrim.com and other channels, managing reservations and the provision of our services, as well as the commercial and administrative management of our Camping.

2- TYPE OF PERSONAL DATA DO WE PROCESS AND PURPOSES?

The data we collect, the way in which we obtain it and the purpose of the processing is as follows:

1.     Contact forms and/or request for information:

o   Data required: name, email, telephone.

o   Purpose: to respond to queries and/or provide information requested by the User. We may contact you via WhatsApp.

o   Legitimisation: consent of the user.

2.     If you make a reservation through our website:

o   Required data: name and surname, address, email address, telephone number, date of birth, and credit or debit card information.

o   Purpose: to manage the booking.

o   Legitimisation: consent of the user.

3.     To carry out the contractual relationship and similar administrative, fiscal and accounting formalities that are necessary under current legislation.

o   Data required: name and surname, telephone, address, ID card number, email, signature.

o   Purpose: to carry out internal commercial, fiscal and administrative management.  

o   Legitimisation: Consent of the interested party and contractual relationship.

4.     To carry out the entry register:

o   Data required: name and surname, telephone number, address, ID card/passport number.

o   Purpose: compliance with the legal obligations of the entry register that this entity carries out.

o   Legitimisation: in accordance with the provisions of the legislation on the protection of public safety.

1-Types of personal data that we process

For reasons of confidentiality, we collect as little data as possible from the people we deal with, especially from our customers, beyond that which they voluntarily provide to us or that which we are required by law to collect and retain in the case of bookings made through booking engines.

We may collect and process the following categories of personal data:

a. In relation to our customers, name, title, gender, ID or passport number, payment details.

b. Your contact details, telephone number if you make a booking by telephone and leave them with us, your email address if you make a booking with us by email address or such other information as is required by the booking engine to make a booking.

c. In the case of our employees, identification data, social security data, bank details and all data necessary for the performance of the employment relationship.

d. Identification data of our suppliers (of their contact persons in the case of companies).

e. Images captured by our video surveillance cameras installed in our Camping.

f. Images captured in the events we hold in our facilities.

g. Information collected when you use our website and other digital media, if applicable.

When you use our website we may log your IP address, browser type, operating system, originating website and web browsing behaviour.

 

2-Your personal data will only be used for the following purposes:

a. Register you in our database if you make a booking, if you provide us with them in person or make a booking online.

b. To carry out the necessary commercial and administrative procedures with the users of our website and our customers or potential customers.

c. At RESERVA ALECRIM we process the information you provide us with in order to respond to the request for information you send us, provide you with information about our services, internally and externally manage your reservations or the provision of our services, as well as the purchases we make from our suppliers, and comply with the legal obligations arising from these activities.

d. To communicate with you to answer your queries and deal with your complaints or obtain your opinion on the quality of our Camping, our services or the treatment received.

e. To record the images captured by our video surveillance cameras for security reasons. These images may be given to the police or judicial authorities at their request.

f. To record the images captured at events in which it participates and their use for advertising purposes or dissemination among our customers.

g. Likewise, the data that may be collected during your browsing will be processed in order to provide access to the online content of the website, as well as to attend to the requests of the users of the website, keep a record of the statistics of visits (IP addresses, browser data, country, page accessed, etc.) for the purpose of helping us to develop better services and products, optimise our offer and provide a more efficient customer service and improve the design and content of our websites.

h. The data of our customers and suppliers will be processed, within the contractual relationship that binds them to us, in compliance with administrative, fiscal and accounting obligations and, where appropriate, in compliance with the law on public safety.

We inform you that RESERVA ALECRIM does not carry out SPAM practices, therefore, it does not send commercial mail by e-mail if it does not have the necessary legitimacy. In any case, you will always have the possibility of withdrawing your consent to receive our communications.

We will not process your personal data for any purpose other than those described in this Policy, except by legal obligation or court order.

Your personal data will not be subject to decisions based on automated processing that produce effects on you.

3.-

Legal Basis:

User consent, compliance with legal obligations, the execution of contracts generated between RSERVA ALECRIM and its customers, employees, suppliers or third parties and, where appropriate, the legitimate interests of RESERVA ALECRIM.

3- WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA?

 

The legal basis that legitimizes the processing of your personal data is your express consent given to carry out the purposes described above, which will be requested at the time you request information from us.

In the event of a business relationship between you, whether as a customer, supplier or employee and RESERVA ALECRIM, the legal basis that legitimates the processing of your personal data will be the execution of the contractual relationship that will have been generated, as well as, where appropriate, compliance with the corresponding legal obligations.

The legal basis that legitimises the processing of the images recorded by our video surveillance cameras is our legitimate interest in maintaining the security of our facilities.

The legal basis that legitimizes the processing of images captured during our events and in which you participate will be our legitimate interest and your express consent to publish it.

The legal basis that legitimizes the transfer of your personal data to the authorities or public bodies is compliance with current regulations.

4.-

Data retention:

For the duration of the legitimisation by consent, contractual relationship, legal obligation or legitimate interest.

4- DATA RETENTION. For how much time will we keep your personal data?

The personal data you provide to us will be kept for the time necessary to manage the information you request from us, as well as to manage the bookings made by our customers or for the fulfilment of any contract generated between RESERVA ALECRIM and third parties.

The images recorded by our video surveillance cameras will be kept for 30 days, unless required by the police or judicial authorities to be kept for a longer period of time. In these cases, they will be duly blocked.

Once the data has served the purpose for which it was collected, we will delete it permanently. We will, however, keep your data for a longer period if this is necessary for the fulfilment of legal obligations. We may also need to keep your data for as long as it is necessary for the statute of limitations for any legal liabilities that may arise.

The data you provide us with in order to initiate a personnel selection process at RESERVA ALECRIM will be kept for a maximum period of one year. Subsequently, if you have not joined RESERVA ALECRIM and are not part of a selection process, they will be deleted, and we will not keep a copy.

The personal data of our employees will be kept for the duration of their employment relationship with RESERVA ALECRIM and, subsequently, for the legally stipulated periods of time.

5.-

Recipients:

The data you provide will be incorporated into a database belonging to RESERVA ALECRIM and may be shared, for operational reasons, with WECAMP FUTURE, SL, the company that administratively manages the campsite, as well as with MERIDIA CAPITAL PARTNERS SGEIC, the management company of the company that owns the Camping. They will not be transferred to third parties except to those who, necessarily, must intervene for the management of the reservations and the stay or the provision of our services, as well as for the fulfilment of the legal obligations that correspond to us.

5- DATA RECIPIENTS

 

Within our organisation, your personal data will be processed by duly authorised personnel and, if necessary or practical to fulfil the purposes indicated above, may be processed by third parties.

The recipients or categories of recipients to whom your personal data may be communicated from RESERVA ALECRIM are the following:

 

Third parties appointed as processors, such as IT providers, consultants and advisors and other companies providing ancillary services.

 

WE CAMP FUTURE, SL, the company that administratively manages RESERVA ALECRIM, may process personal data for organisational, administrative and management purposes. 

 

MERIDIA CAPITAL PARTNERS SGEIC, S.A as the management company of the company that owns RESERVA ALECRIM, may process personal data for management and control purposes.

 

Public entities and organisations, exclusively for the purpose of complying with the corresponding legal obligations.

 

Other providers to whom, where appropriate, your personal data may be transferred to financial institutions, fraud detection service providers, where appropriate, etc.

 

Security company with access to security images captured by the video surveillance system.

 

In any case, all of the aforementioned third parties will have previously signed the corresponding confidentiality commitment following our instructions in accordance with the current personal data protection regulations, will be subject to the duty of professional secrecy or will be acting in compliance with a legal obligation.

 

The information that you provide to us through this website will be hosted on the servers of RESERVA ALECRIM.

6.-

Rights:

Access, rectify and delete your data, as well as the other rights provided for by current legislation.

6.- WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US YOUR PERSONAL DATA?

 

If you wish to exercise the rights that the data protection regulations grant you, please send us an e-mail to the following address privacy@wecamp.net putting the right you wish to exercise in the subject line and attaching a copy of your national ID card or passport.

The rights that the current legislation recognises and that, if applicable, you may exercise are:

Right of access to the data:

You have the right to be informed by RESERVA ALECRIM whether or not your personal data is being processed and, in the event that the processing is confirmed, will provide you with the following information:

-The purposes of the processing.

-The categories of data being processed.

-The period or criteria for the storage of the data.

The right to rectify the data:

You will have the right to have RESERVA ALECRIM rectify your data when it is inaccurate or incomplete by means of an additional rectifying statement.

Right to suppression of data:

The interested party will have the right for RESERVA ALECRIM to delete their data, when:

-The processing is unlawful.

-The data subject has withdrawn his/her consent.

-They are no longer necessary in relation to the purposes for which they were collected or processed.

-The data subject has exercised the right to object and no other legitimate grounds for the processing prevail.

-The data must be deleted in order to comply with a legal obligation of RESERVA ALECRIM.

The data subject shall not have the right to have his/her data deleted by RESERVA ALECRIM when the processing is necessary:

-To exercise the right to freedom of expression and information.

-To comply with a legal obligation of RESERVA ALECRIM.

-To formulate, exercise or defend claims.

-For public interest based on current legislation for reasons of public health or for historical, statistical or scientific research purposes.

Right to data portability:

You have the right for RESERVA ALECRIM to transmit your data to another data controller or to the data subject himself/herself, using a structured format that is commonly used and machine-readable, when the processing is carried out by automated means and is based on:

-The data subject's consent for specific purposes.

The performance of a contract or pre-contract with the data subject.

The right to data portability shall not apply where:

-It is technically impossible to transmit.

-It is likely to adversely affect the rights and freedoms of third parties.

-The processing has a public interest mission based on the legislation in force.

Right to restrict processing:

The data subject shall have the right to object to the processing of his/her data carried out by RESERVA ALECRIM for reasons related to his/her particular situation, when the processing is based on:

-Direct marketing.

-Profiling.

-Legitimate interest of the data controller or third parties, provided that the interests or the rights and freedoms of the data subject, especially if he/she is a child, do not prevail.

-Historical, statistical or scientific research, unless the processing is necessary for reasons of public interest.

Even if the data subject objects to the processing of his or her data, RESERVA ALECRIM may continue to process them provided that its legitimate interest prevails over the interests or the rights and freedoms of the data subject in a legal proceeding that justifies it.

RESERVA ALECRIM shall inform the data subject of the right to object to the processing of their data explicitly, clearly and separately from any other information, at the time of the first communication.

Right to object processing:

This is the right to not have their data processed or to cease processing when their consent to the processing is not required, due to the concurrence of a legitimate and well-founded reason, referring to their specific personal situation, which justifies it, and provided that a Law does not provide otherwise.

Right not to be subject to profiling:

The data subject shall have the right to not be subject to profiling whose purpose is to take individual decisions based on automated data processing and intended to evaluate, analyse or predict the following personal aspects:

-Professional performance.

-Financial situation.

-Health

-Personal preferences or interests

-Reliability.

-Behaviour.

-Location or movements of the person.

Where profiling is based solely on automated processing:

-The data subject shall have the right to be informed if the decision which may be taken is likely to produce legal effects which significantly affect him/her.

-The data subject shall have the right to obtain human intervention on the part of RESERVA ALECRIM, to express his or her point of view and to challenge the decision, if the processing has been authorised by means of:

-The explicit consent of the data subject.

-A contract between RESERVA ALECRIM and the data subject.

The right to refuse to be profiled shall not apply where the decision that may be taken as a result of profiling is authorised by:

-the data subject's explicit consent

-A contract between RESERVA ALECRIM and the data subject.

-A processing operation based on the legislation in force.

7.-

Claim before the supervisory authority:

You can address complaints arising from the processing of your personal data to the Comissão Nacional de Proteção de Dados (www.cnpd.pt).

7-CLAIM TO THE SUPERVISORY AUTHORITY:

 

In case you consider that RESERVA ALECRIM has infringed any of your rights protected by the personal data protection regulations or that it has violated any obligation regarding the protection of Personal Data, you have the right to submit a complaint to the competent supervisory authority which in Portugal is the Comissão Nacional de Proteção de Dados (located at Av. D. Carlos I, 134, 1º1200-651 Lisboa)

Tel. 213 928 400 - 213 976 832

 

You can also file an electronic complaint through the electronic site available on its website https://www.cnpd.pt/.    

8.-

Legislation and jurisdiction

This privacy policy is governed in each and every one of its aspects by the General Data Protection Regulation of the European Union and other related Portuguese legislation.

8-LEGISLATON AND JURISDICTION

 

This privacy policy is governed in each and every one of its points by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

 

It is also governed by Lei nº58/2019, on the Protection of Personal Data.

 

Users of this website are subject to Portuguese and Spanish legislation and jurisdiction to which they expressly submit, and the Courts and Tribunals of BARCELONA shall be competent for the resolution of all conflicts arising from or related to its use.

9.-

Additional information

Additional information about security and other aspects.

9- ADDITIONAL INFORMATION

 

SAFETY PROVISIONS:

 

The data you provide will be treated confidentially. RESERVA ALECRIM has adopted all the technical and organisational measures and all the necessary levels of protection to guarantee security in the processing of data and to avoid its alteration, loss, theft, unauthorised processing or access, in accordance with the state of technology and the nature of the data stored. Likewise, it is also guaranteed that the processing and recording in files, programmes, systems or equipment, premises and centres comply with the requirements and conditions of integrity and security established in the regulations in force.

 

SSL CERTIFICATE (SECURE SOCKETS LAYER)

The SSL CERTIFICATE provides authentication, privacy and security of the information between RESERVA ALECRIM and the user. RESERVA ALECRIM has a security certificate that is used to make secure connections and is established using pre-established keys, encrypting and decrypting all data sent until the connection is closed.

SOCIAL NETWORKS

We inform you that RESERVA ALECRIM may have a presence on social networks. The processing of data that is carried out from the people who become followers on social networks (and / or perform any link or action of connection through social networks) of the official pages of RESERVA ALECRIM will be governed by this section, as well as for those conditions of use, privacy policies and access regulations that belong to the social network that applies in each case and previously accepted by the user.

RESERVA ALECRIM will process your data for the purposes of correctly administering its presence on the social network, informing of activities, products or services of the provider, as well as for any other purpose that the regulations of the Social Networks allow.

The publication of content is prohibited:

            - That are allegedly unlawful by national, community or international regulations or that carry out allegedly unlawful activities or contravene the principles of good faith.

            - That violate the fundamental rights of persons, lack of courtesy on the network, disturb or may generate negative opinions in our users or third parties and in general any content that RESERVA ALECRIM considers inappropriate.

            - And in general, that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

Likewise, RESERVA ALECRIM reserves the right to remove, without prior notice, from the website or the corporate social network those contents that are considered inappropriate.

In any case, if you send personal information through the social network, RESERVA ALECRIM shall be exempt from liability in relation to the security measures applicable to this platform and the user, if he/she wishes to know them, should consult the corresponding specific conditions of the network in question.

VIDEO SURVEILLANCE

In our camping, images are captured in order to preserve the safety of people and property, as well as of the facilities.   

The user is informed by means of a video surveillance sign located in a sufficiently visible place in front of the camera, which informs that the facilities are under video surveillance.

No transfers are foreseen, except to the security forces, nor will there be any international transfer of data.

The images will be kept for a maximum period of 30 days from their capture. Once this period has elapsed, the images must be deleted, in accordance with current legislation.

LANGUAGE

 

The language applicable to this Privacy Policy is Spanish. Therefore, in the event of any contradiction in any of the versions provided in other languages, the Spanish version shall prevail.

10.-

Update:

SEPTEMBER 2024

10-UPDATE

 

This Privacy policy was updated for the last time in September 24, but may be updated at any time. Therefore, we recommend that you check it each time you access our website in the event that it has been changed.