CUSTOMER PRIVACY POLICY

 

  1. Commitment of Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa)

The protection of privacy and personal data constitutes a fundamental commitment of Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) to its customers ("Customers") of its services and products.

The information provided to us, as well as that sent to us through our website, electronic mail or any other means, will be treated with the utmost confidentiality and in accordance with the applicable European or national legislation.

All personal data collected will be only those necessary for the purposes for which they are intended, namely for the processing of reservations and technical and commercial contacts related to them, as well as other legitimate objectives to the relationship established between both parties. In addition, the client may actively indicate whether he / she authorizes the use of the personal data previously provided or others that he may add or modify for other properly identified purposes, such as the sending of newsletters or other types of business contacts.

Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) advises reading this Privacy Policy and its updates.

 

  1. Responsible for data processing

The responsible for the collection and processing of your personal data will be who provides you the service or product and decides what data is collected, means of treatment and purposes for which the data is used.

 

  1. Personal data, holders of personal data and categories of personal data

What is personal data?

Personal Data is any information of any nature and in any support, relating to an identified or identifiable person. Any person who can be identified directly or indirectly, for example by name, identification number, location data, electronic identifier or other elements that allow identification of that individual is identified as identifiable.

Who are the holders of personal data?

The Client, an individual person, to whom the data relate and who has used the services or products of Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa). For example, a Client of Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) is someone who has made a contract in order to get a good or service provided. It will be a potential Client who is the target of publicity campaigns or promotional offers of Mar da Califórnia - Atividades Hoteleiras, SA (Sesimbra Hotel & Spa), as well as those who request information about products and services marketed by Mar da Califórnia - Atividades Hoteleiras, SA (Sesimbra Hotel & Spa).

In this regard, Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) informs that it also protects personal data and respects the rights of Customers.

What categories of personal data do we treat?

Categories of personal data

Examples of personal data

Identification

Name
ID number
Tax Identification Number
Nationality
Date of birth
Customer Number
Room number

Contacts

Address
Phone contact
E-mail address

Profile

Nationality
Country of residence
Date of birth
Gender
Marital status
Number of children

Electronic interactions

IP adress
Device identifiers
Cookies

 

  1. Basis, Purposes and Duration of the Treatment of Personal Data

Upon what grounds may Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) treat your personal data?

Consent:When we have your express consent - in writing, orally or through the validation of an option - and prior and if such consent is free, informed, specific and unambiguous. Examples are your consent to send direct marketing messages, profile definition, sharing of data with other entities; or

Contract execution and pre-contractual procedures:when the processing of personal data is necessary for the conclusion, execution and management of the contract signed with Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa), as for example requests for information, service proposal preparation, service provision, contact / complaint / billing / collection / payments management; or

Compliance with legal obligation:when the processing of personal data is necessary to comply with a legal obligation to which Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) is subject, such as the communication of data to police, judicial, fiscal or regulatory entities; or

Legitimate interest:when the processing of personal data corresponds to a legitimate interest of Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) or third party, such as improvement of quality of service, detection of fraud or when the reasons for their use should prevail over their rights of data holders).

(The communication of data as a legal or contractual obligation, or requirement necessary to conclude a contract, must be mentioned here, including the obligation of the Customer to provide the personal data and any consequences that may arise from not supplying).

For what purposes and for how long does Mar da Califórnia – Atividades Hoteleiras, S.A.  (Sesimbra Hotel & Spa) treat your personal data?

Your personal data are processed by Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) only for the period of time necessary to achieve the defined purpose or, depending on what is applicable, until you exercise your right of objection, right to be forgotten or withdraw consent. After the respective period of conservation has expired, Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) will eliminate or anonymize the data whenever they are not to be kept for a different purpose that may subsist.

Categories of purposes

Examples of purposes

Marketing

Marketing or selling of new services or products

Customer Management and Service Delivery

Management of contacts, information or requests
Complaint management
Billing, collection and payment management

Accounting, Tax and Administrative Management

Accounting, billing
Management of commissions
Tax information, including sending information to the tax authority

Litigation Management

Judicial and extrajudicial collection
Management of other conflicts

Physical security control

Video surveillance of premises

 

What are the deadlines for processing and keeping personal data?

Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) treats and keeps your personal data according to the purposes for which they are treated. There are cases in which the law requires the processing and storage of data for a minimum period of time, namely for 10 years, the data necessary for informing the Tax Authorities for accounting or tax purposes or the data relating to commercial bookkeeping, as well as for 7 years for the purpose of combating money laundering and terrorist financing.

But, where there is no specific legal obligation, then the data will be processed only for the   necessary period to fulfill the purposes that led to their collection and preservation and always in accordance with the law, guidelines and decisions of the CNPD. Therefore:

Mar da Califórnia – Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) will treat and maintain your personal data for the period in which we have a contractual relationship with you.

Regarding the video surveillance of its facilities, Mar da Califórnia – Atividades Hoteleiras, S.A. will only keep the recordings of images and their personal data for a maximum period of 30 days.

Mar da Califórnia - Atividades Hoteleiras, SA (Sesimbra Hotel & Spa) may keep other personal data for periods longer than the duration of the contractual relationship, whether based on your consent, or to ensure rights or duties related to the contract, or even because we have legitimate interests that justify it, but always for the period strictly necessary for the fulfillment of the respective purposes and in accordance with the guidelines and decisions of the CNPD.

Examples are contact for marketing and sales purposes, preservation of data in the context of invoice claims procedures, exercise of guarantee rights or pending of legal litigation.

 

  1. Form and timing of the collection of personal data

When and how do we collect your personal data?

We collect personal data with your consent or when you purchase services or products of Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa).

The collection can be done orally, in writing or through the website of Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa).

But your personal information may also be collected from publicly available sources or other sources, such as travel agents, whose responsibility for ensuring data protection and information security applies equally.

 

  1. Rights of the holder of personal data

What are your rights?

Right of Access- right to obtain confirmation of what are your personal data that are treated and information about them, for example, what are the purposes of the treatment, what are the conservation periods, among others.

Right to see or obtain copy, for example of invoices or written agreements.

Right of Rectification- right to request rectification of your personal data that is inaccurate or request to complete incomplete personal data, such as the address, Tax Identification Number, email, telephone contacts, or others.

Right to erase data or "right to be forgotten"- right to erase your personal data, provided that there are no valid grounds for its conservation, such as the cases in which Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) must keep the data to fulfill a legal obligation or because a legal process is in progress. 

Right to Portability- right to receive the data you have provided us in a digital format of current use and automatic reading or to request the direct transmission of your data to another entity that becomes the new responsible for your personal data, but in this case only if technically possible.

Right to Withdraw Consent or Right of Opposition- right to object or withdraw consent at any time to data processing, for example in the case of data processing for marketing purposes, provided that no legitimate interests exist which prevail over your interests, rights and freedoms, such as defending a right in a judicial process.

Right of Limitation- right to request the limitation of the treatment of your personal data, in the form of: (i) suspension of treatment or (ii) limitation of the scope of treatment to certain categories of data or purposes of treatment.

Right to complain- right to complain to the supervisory authority, CNPD, in addition to the company or the DPO.

How can you exercise your rights?

The exercise of rights is free of charge, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged taking into account the existing costs.

In order to exercise your rights, you should approach our unit. The exception is the right to withdraw your consent / opposition, which, if the consent in question may have been provided via digital format, may be exercised through the following address: comercial@sesimbrahotelspa.com

The response to requests should be provided within a maximum of 30 days, unless it is a particularly complex request.

 

  1. Transmission of Personal Data

Under what circumstances is your personal data communicated to other entities, subcontractors or third parties?

Your data can be transmitted to subcontractors for them to handle in the name and on behalf of Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa). In this case, Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) will take the necessary contractual measures to ensure that the subcontractors respect and protect the personal data of the Client.

Data may also be transmitted to third parties - entities other than Mar da Califórnia - Atividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) or subcontractors - in case the holder has consented or to entities to whom the data must be communicated by virtue of law.

 

  1. SECURITY AND CONFIDENTIALITY

We commit to keep your data secure, and we apply appropriate security measures to ensure the protection of your personal data and prevent access to unauthorized persons. We submit our security systems and policies to periodic analyzes to ensure that data is secure and protected. However, the transmission of information over the Internet is not completely secure, and we cannot absolutely guarantee the security of the information transmitted through our site.

We also respect the confidentiality of your information. Therefore, we do not sell, distribute, or otherwise make your information commercially available to any third party. Mar da Califórnia -   Actividades Hoteleiras, S.A. (Sesimbra Hotel & Spa) is committed to keeping your information confidential in accordance with this Privacy Policy and applicable law.

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