The confidentiality of the personal information of our clients is fundamental and a commitment of “Morgado da Lameira – Empreendimento Turístico e Golfe, S.A.” (hereinafter “Morgado da Lameira”).
1. User Data (Data Holder)
1.1. Collection and Handling of User Data
There are many circumstances in which we request “Personal Data” of a user (“User”) from the website www.amendoeiraresort.com ("Site"). This may happen within the scope of availability of the website; while entering into any contracts (namely hotel services, booking of accommodation and golf), supply of information, content, including newsletters, login areas, or any other telephone contact, (hereinafter collectively referred to as “Services”), to its users and other entities related to it.
As a rule, Personal Data is collected and handled when the User registers with the Site, requests to be contacted and/or to receive our newsletter, subscribes a specific Service, supplies or requests information, purchases a product or establishes a contractual relationship with Morgado da Lameira.
Personal Data is the information which allows for the identification or contact of the User when making a reservation, registers with our Site or subscribes our newsletter. The collected and handled Personal Data consists of information relating to name, nationality, date of birth, address, e-mail address, telephone, mobile phone, tax identification number, credit card details (only collected for invoicing purposes), however, other Personal Data may be collected which may prove necessary or useful for supply or charge of Services by “Morgado da Lameira – Empreendimento Turístico e Golfe, S.A.” – Responsible Entity for the collection and handling of Personal Data – better identified below. After the collection of the Personal Data, more detailed information is given to the User in relation to the nature of the data collected, the purpose of the collection and the handling of the data, as well as the information referred to in paragraph 7 below.
It is also collected and handled, information relating to the characteristics of your hardware and browser/software characteristics, as well as information on the pages visited by the User within the Site. This information may include your IP (Internet Protocol) address, the operating system and the type of browser (“Usability Information”). We use this information only to improve the quality of your visit to our Site.
1.2. Handling Responsible Entity
The Responsible Entity for collection of the Personal Data is “Morgado da Lameira – Empreendimento Turístico & Golfe, S.A.”, a company with its registered office at Amendoeira Golf Resort, Morgado da Lameira, 8365-302 Alcantarilha, Algarve, Portugal, registered in the Commercial Registry of Silves, under registration and taxpayer number 500952302, with a share capital of EUR 164,640.00.
1.3. Subcontracted Entities
These Subcontracted Entities will not be allowed to supply the User Data to other entities without “Morgado da Lameira” giving prior written authorization to this effect, being always prevented from contracting other entities without “Morgado da Lameira”’s prior authorization.
“Morgado da Lameira” commits to subcontract only entities who offer maximum security in the performance of technical and adequate organizational measures, for the purpose of ensuring the User rights protection. All Entities subcontracted by “Morgado da Lameira” are bound to the latter by a written contract regulating, specifically, the subject and duration of the handling, the nature and purpose of the handling, the type of personal data, the categories of the data holders and the rights and obligations of the parties.
Following the collection of the Personal Data, and if applicable, “Morgado da Lameira” provides the User, information about the Subcontracted Entities that in this specific instance might handle the data on behalf of “Morgado da Lameira”.
1.4. Data Collection Channels
“Morgado da Lameira” may collect data in a direct way (i.e. directly from the user) or in an indirect way (i.e. through partner entities or third parties). The collection may be done through the following channels:
Direct collection: in person, by telephone, by e-mail or through the Site.
Indirect collection: through partners or group companies and official entities.
2. General Principles Applicable to the User Data Handling
2.1. Principles Relating to Personal Data Handling
“Morgado da Lameira” ensures the User Data collected is handled in accordance with the following general principles:
2.2 Lawfulness of Handling
The data handling performed by “Morgado da Lameira” are permitted and legal when at least one of the following situations applies:
“Morgado da Lameira” undertakes to ensure the handling of the User data is only performed in the conditions set out above and respecting the principles above mentioned.
2.3. Applicable Conditions to Consent
When the processing of the User Data is performed by “Morgado da Lameira” based on the consent of the User, it has the right to withdraw its consent at any time. However, the withdrawal of consent does not compromise the lawfulness of the processing done by “Morgado da Lameira” based on the consent previously granted by the User.
2.4. Term of Data Storage
The period of time during which the data is stored and maintained varies in accordance with the purpose for which the information is processed.
“Morgado da Lameira” will comply with the legal requirements that oblige us to keep Personal Data for a minimum period of time. Where there is no specific legal obligation, the data will be stored only for the minimum period necessary for the purposes for which it was collected or subsequently processed, being deleted on its expiry.
3. Usage and Purpose of User Data Processing
The collected Personal Data will be used solely for the following purposes:
4. Implemented Technical, Organizational and Security Measures
User Data Security
To guarantee the security of the User Data and maximum confidentiality, “Morgado da Lameira” processes the information supplied in a completely confidential manner, in accordance with its internal security and confidentiality procedures, which are periodically reviewed and updated in accordance with the needs and in accordance with the terms and conditions legally envisaged.
Considering the nature, scope, context and the purposes of the data processing, as well as the inherent risks for the rights and liberties of the User, arising from the processing of data, “Morgado da Lameira” commits itself to applying, not only at the time of defining the processing means, but also at the time of the actual processing, the necessary and adequate technical and organizational measures to the protection of User Data and to the compliance with the legal obligations.
Commits itself further to ensure that, by default, only the necessary data for each specific purpose is processed and that that data is not made available without human intervention and to an undetermined number of people.
The communication between the User device and the Site of “Morgado da Lameira” is made through secure communications channels which use the HTTPS protocol and the security standard SSL. Nevertheless, in terms of general measures, “Morgado da Lameira” adopts the following:
5. Data transfer to outside the European Union
The Personal Data collected and used by “Morgado da Lameira” are not made available to third parties outside the European Union. If, in the future, this transfer comes to happen, “Morgado da Lameira” commits itself to ensure the transfer complies with the applicable legal terms, namely in terms of the determination of the suitability of such country for the protection of data and the requirements applicable to such transfers.
When visiting the Site of “Morgado da Lameira”, consent will be requested from the User for the creation and saving on your computer of a text file (Cookie). This file, when recognizing you, will allow the User an easier and faster access to the Site, as well as a personalized use in accordance with your preferences.
7. Right to Information
7.1. Information provided by “Morgado da Lameira” to the User (when the Data is collected directly from the User):
7.2. Information provided by “Morgado da Lameira” to the User (when the Data is not collected directly from the User):
7.3. Procedures and Implemented Measures for the Compliance with the Right to Information
The information set out in points 7.1 and 7.2 above shall be provided in writing (including by electronic means) by "Morgado da Lameira" prior to the processing of the Personal Data concerned. Under the applicable legislation, "Morgado da Lameira" has no obligation to provide the user the information mentioned in 7.1. and 7.2. above, when, and to the extent that the User is already aware of them.
The information is provided to the User by “Morgado da Lameira” at no cost.
8. Right of Access to Personal Data
"Morgado da Lameira" guarantees the means to enable the User to consult its personal data.
The User has the right to obtain confirmation from "Morgado da Lameira" whether its Personal Data is processed or not, and, as the case may be, the right to access its Personal Data and the following information:
Upon request, "Morgado da Lameira" will provide the User, free of charge, a copy of the User Data that is being processed. The supply of other copies requested by the User may entail administrative costs.
9. Right of Correction of Personal Data
The User has the right to request at any given moment, the correction of inaccurate Personal Data that concerns him or her, as well as the right to have his or her incomplete Personal Data completed, including by means of an additional declaration.
In case of data correction, "Morgado da Lameira" shall notify each recipient to whom the data has been forwarded of the correction, unless such communication is considered impossible or involves a disproportionate effort by "Morgado da Lameira".
10. Right to Deletion of Personal Data (“Right to be Forgotten”)
The User has the right to obtain, from "Morgado da Lameira", the deletion of his/her Personal Data when one of the following reasons applies:
In accordance with the applicable legal provisions, "Morgado da Lameira" is under no obligation to delete the User Data to the extent that the treatment proves necessary to fulfill a legal obligation that "Morgado da Lameira" is subject to or for the purpose of declaring, exercising or defending a right of "Morgado da Lameira" in a legal proceeding. In the event of deletion of the Data, "Morgado da Lameira" communicates the deletion to each recipient/entity to whom the data has been transmitted, unless such communication proves impossible or involves a disproportionate effort by "Morgado da Lameira".
When "Morgado da Lameira" has made a User's Data publicly available and is obliged to delete it under the right to deletion, "Morgado da Lameira" undertakes to ensure that such measures as are reasonable, including taking into account the available technology and the costs of its application, to inform those responsible for the effective treatment of the Personal Data that the User has requested the deletion of the links to this Personal Data, as well as copies or reproductions thereof.
11. Right of Limitation of Personal Data Processing
The User has the right to obtain from "Morgado da Lameira" the limitation of the processing of its Personal Data if one of the following situations applies (the limitation consists of inserting a mark in the stored Personal Data with the objective of limiting processing in the future):
When User Data is subject to limitation, it may only, with the exception of storage, be processed with the consent of the User for the purpose of declaration, exercise or defense of a right in a legal proceeding, to defend the rights of another person or company, or for reasons of public interest legally established.
The User who has attained the limitation of processing of its Personal Data in the above mentioned cases will be informed by "Morgado da Lameira" before the limitation to the processing is annulled.
In case of data processing limitation, "Morgado da Lameira" will communicate to each recipient to whom the data has been transmitted of the respective limitation, unless such communication proves impossible or involves a disproportionate effort by "Morgado da Lameira".
12. Right of Portability of Personal Data
The User has the right to receive its Personal Data, which it provided to "Morgado da Lameira", in a structured format, in current use and automatic reading, and the right to transmit this Data to another Responsible for Processing, if:
The portability right does not include inferred data or derived data, i.e. personal data generated by "Morgado da Lameira" as a consequence or result of the analysis of the data being processed.
The User has the right to have its Personal Data transmitted directly between those responsible for the processing, whenever this is technically possible.
13. Right to Oppose Processing
The User has the right to oppose, at any time, for reasons relating to its particular situation, the processing of its personal data, for the purposes of the legitimate interests pursued by "Morgado da Lameira” or when the processing is carried out for purposes other than those for which the Personal Data has been collected, including the definition of profiles, or when Personal Data is processed for statistical purposes.
"Morgado da Lameira" will stop processing the User Data, unless it presents urgent and legitimate reasons for such processing that prevail over the interests, rights and freedoms of the User, or for the purposes of declaration, exercise or defense of a right in legal proceedings.
When the User Data is processed for the purpose of direct marketing, the User has the right to oppose at any time the processing of its Personal Data for the purposes of said marketing, which includes the definition of profiles, insofar as it is related to direct marketing.
If the User opposes the processing for the purposes of direct marketing, "Morgado da Lameira" will cease the processing of Personal Data for this purpose.
The User has also the right to not be subject to any decision solely based on automated processing, including profiling, which may affect its legal position or significantly affects it in a similar way, unless:
14. Procedure for the Exercise of Rights by the User
"Morgado da Lameira" will respond in writing (including electronic media) to the request of the User within a maximum of one month from receipt of the request, except in cases of special complexity, where this period may be extended up to two months.
If the requests presented by the User are clearly unjustified or excessive, in particular due to their repetitive nature, "Morgado da Lameira" reserves the right to charge administrative costs or refuse to comply with the request.
15. Personal Data Breaches
In the event of a breach of Personal Data and to the extent that such breach is likely to pose a high risk to the User's rights, freedoms and warranties, "Morgado da Lameira" undertakes to notify the User in question of any Personal Data breach within 72 hours of becoming aware of the incident.
In legal terms, communication to the User is not required in the following cases:
17. Applicable Law and Forum
18. Declaration of Consent
Published on [[*publishedon:strtotime:date=`%d-%m-%Y`]]. Updated on [[*editedon:strtotime:date=`%d-%m-%Y`]].