The company O ABRIGO DA PASSARELA, LDA, with the NIF 508379016, headquartered at Rua de Santo Amaro 3, 6290-093 Lagarinhos, Gouveia understands that the use of your personal data requires your trust. We are subject to the highest privacy standards and will only use your personal data for clearly identified purposes and in accordance with your data protection rights.
The confidentiality and integrity of your personal data is one of our main concerns.
1. General Part
1.1. COLLECTION AND PROCESSING OF USER DATA
The Personal Data collected and processed consists of information related to the name, email, address, although other Personal Data that may be necessary or convenient for the provision of Services by O ABRIGO DA PASSARELA, LDA may be collected.
After the collection of Personal Data, ABRIGO DA PASSARELA, LDA provides the User with detailed information about the nature of the data collected and about the purpose and treatment that will be carried out in relation to Personal Data.
O ABRIGO DA PASSARELA, LDA also collects and treats information about the characteristics of the device of its hardware and the characteristics of the 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 links through which the User accessed the Site (“Usability Information”). We use this information only to improve the quality of your visit to our Site.
1.2. SUBCONTRACTED ENTITIES
These subcontracted entities will not be able to transmit User Data to other entities without O ABRIGO DA PASSARELA, LDA having previously and in writing authorization to do so, being also prevented from hiring other entities without prior authorization from O ABRIGO DA PASSARELA, LDA.
O ABRIGO DA PASSARELA, LDA is committed to subcontracting only entities that offer maximum security in the execution of the appropriate technical and organizational measures, in order to guarantee the defense of the rights of the User. All entities subcontracted by O ABRIGO DA PASSARELA, LDA are bound by the latter through a written contract which regulates, namely, the object and duration of the treatment, the nature and purpose of the treatment, the type of personal data, the categories of data subjects and the rights and obligations of the parties.
After the collection of personal data, O ABRIGO DA PASSARELA, LDA provides the User with information about the categories of subcontracted entities that, in the specific case, can carry out data processing on behalf of O ABRIGO DA PASSARELA, LDA.
DATA COLLECTION CHANNELS
O ABRIGO DA PASSARELA, LDA may collect data directly (i.e., directly from the User) or indirectly (i.e., through partner entities or third parties). Collection can be done through the following channels:
Direct collection: in person, by phone, e-mail and through the Site;
Indirect collection: through partners or group companies and official entities.
2. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA
In terms of general principles related to the processing of personal data, O ABRIGO DA PASSARELA, LDA undertakes to ensure that the User Data processed by you are:
- Object of treatment according to the law, loyal and transparent in relation to the User;
- Collected for specific, objective and legitimate purposes, not subsequently being treated in a manner contrary to those purposes;
- Adequate, justified and limited to what is necessary in relation to the purposes for which it is treated;
- Accurate and updated whenever necessary, with all necessary measures being taken so that the inaccurate data, taking into account the purposes for which it is processed, is erased or corrected without delay;
- Kept in a way that allows the identification of the User only for the period necessary for the purposes for which the data is processed;
- Treated in a way that guarantees its safety, including protection against its unauthorized or illegal treatment and against its unforeseen loss, destruction or damage, with appropriate technical or organizational measures being adopted;
Data processing carried out by O ABRIGO DA PASSARELA, LDA is permitted and legal when at least one of the following situations occurs:
- The User has given, without any doubt, his consent for the processing of User Data for one or more specific purposes;
- Treatment is necessary for the execution of a contract to which the User is a party, or for pre-contractual procedures at the request of the User;
- Treatment is necessary to comply with a legal obligation to which O ABRIGO DA PASSARELA, LDA is subject;
- Treatment is necessary to defend the fundamental interests of the User or another individual;
- The treatment that is necessary for the purpose of the legal interests pursued by O ABRIGO DA PASSARELA, LDA or by third parties (except if the fundamental interests or rights and freedoms of the User that require the protection of personal data prevail).
ABRIGO DA PASSARELA, LDA undertakes to ensure that the processing of User Data is only carried out under the conditions listed above and with respect for the principles mentioned above.
When the processing of User Data is carried out by O ABRIGO DA PASSARELA, LDA based on the User’s consent, the User has the right to withdraw his consent at any time. The withdrawal of consent, however, does not compromise the legality of the treatment carried out by O ABRIGO DA PASSARELA, LDA based on the consent previously given by the User.
The period of time during which the data is stored and preserved varies according to the purpose for which the information is processed. Effectively, there are legal requirements that require data to be kept for a minimum period of time. Thus, and whenever there is no specific legal obligation, data will be stored and preserved only for the minimum period necessary for the purposes that motivated its collection or further processing and, at the end, they will be deleted.
3. USE AND PURPOSES OF USER DATA PROCESSING
In general terms, ABRIGO DA PASSARELA, LDA uses User Data for the following purposes:
- Management of contacts with the User;
- Inform the User, who has requested it, of new products and services available on the Site, special offers and campaigns, updated information on the activity of O ABRIGO DA PASSARELA, LDA, and, in general, for the purposes of marketing O ABRIGO DA PASSARELA, LDA and through any means of communication, including electronic support or social networks;
- Allow access to restricted areas of the Site, as is the case with the online store;
- Ensuring that the Site meets the needs of the User, through the development and publication of content as adapted as possible to the requests and type of User;
- Provision of Services, and other services, such as newsletters, opinion polls, or other information or products requested or purchased by the User;
O ABRIGO DA PASSARELA, LDA may combine Usability Information with anonymous demographic information for research purposes, and may use the result of that combination to provide more relevant content on the Site. In certain restricted areas of the Site, O ABRIGO DA PASSARELA, LDA may combine Personal Data with Usability Information to provide the User with more personalized content.
The User Data collected by O ABRIGO DA PASSARELA, LDA are not shared with third parties without the User’s consent, except for the situations referred to in the following paragraph. However, in case the User contracts with O ABRIGO DA PASSARELA, LDA services that are provided by other entities responsible for the processing of personal data, the User Data may be consulted or accessed by those entities, insofar as such necessary for the provision of said services and the User will be informed thereof.
4. IMPLEMENTED TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES
In order to guarantee the security of User Data and maximum confidentiality, O ABRIGO DA PASSARELA, LDA treats the information you have provided to us in an absolutely confidential manner, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated from time to time. according to needs, as well as legally provided terms and conditions.
Depending on the nature, scope, context and purposes of data processing, as well as the risks arising from the treatment for the rights and freedoms of the User, O ABRIGO DA PASSARELA, LDA undertakes to apply, both at the moment of definition of the means of treatment as at the time of the treatment itself, the necessary technical and organizational measures that are adequate and appropriate for the protection of User Data and for the fulfillment of legal requirements.
It also undertakes to ensure that, by default, only the data that is necessary for each specific purpose of treatment are processed and that these data are not made available without human intervention to an undetermined number of people.
Still, in terms of general measures, O ABRIGO DA PASSARELA, LDA adopts the following:
- Regular audits to identify the competence of the technical and organizational measures implemented;
- Awareness and training of personnel involved in data processing operations;
- Pseudonymization and encoding of personal data;
- Capable mechanisms of confidentiality, availability and permanent resilience of information systems;
When you visit our website, a small text file (Cookie) is created and saved on your computer’s disk, therefore, when browsing the Site you are accepting the installation of this text file on your device. This file will allow you to access the Site more easily and quickly, as well as to personalize it according to your preferences.
By browsing our Site you are allowing the collection and storage of small text files called cookies, which contain information and which are downloaded to the Users’ computer or other devices through a server. These text files will allow for a more personalized and efficient browsing experience. On each visit to the Site, your internet browser sends these cookies back to the Site, allowing the recognition and memorization of the Users’ identity, as well as their usage preferences.
6. USER RIGHTS (DATA HOLDERS)
6.1. RIGHT TO INFORMATION
6.1.1. Information provided to the User by O ABRIGO DA PASSARELA, LDA (when data is collected directly from the User):
- The identity and contacts of O ABRIGO DA PASSARELA, LDA. and the controller;
- 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 O ABRIGO DA PASSARELA, LDA 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;
- Period of retention of personal data;
- The right to request O ABRIGO DA PASSARELA, LDA the permission to personal data, as well as its correction, elimination or limitation, the right to oppose the treatment and the right to access the data;
- If the processing of the data is based on the User’s consent, the right to withdraw it at any time, without compromising the legality of the treatment carried out based on the consent previously given;
- The right to file a complaint with CNPD or another supervisory authority;
- Indication whether or not the provision of personal data constitutes a legal or contractual obligation, or a necessary requirement to conclude a contract, as well as whether the holder is obliged to provide personal data and the possible consequences of not providing such data;
- If applicable, the existence of automatic decisions, including the definition of profiles, and information related to the basic concept, as well as the importance and expected consequences of such treatment for the data subject.
In the event that User Data is not collected directly by the User from O ABRIGO DA PASSARELA, LDA, in addition to the information referred to above, the User is also informed about the categories of personal data being processed and, as well, about the origin of the data and, eventually, if they are from publicly accessible sources.
If O ABRIGO DA PASSARELA, LDA intends to proceed with the further processing of User Data for a purpose other than that for which the data was collected, before such treatment, O ABRIGO DA PASSARELA, LDA will provide the User with information about that purpose and any other information of interest, under the terms referred to above.
6.2. PROCEDURES AND MEASURES IMPLEMENTED TO COMPLY WITH THE RIGHT TO INFORMATION
The information referred to in point 6.1. is provided in writing (including by electronic means) by ‘O ABRIGO DA PASSARELA, LDA to the User prior to the processing of the personal data in question. Under the terms of the applicable law, O ABRIGO DA PASSARELA, LDA has no obligation to provide the User with the information mentioned in 6.1 when and to the extent that the User is already aware of it.
Information is provided by O ABRIGO DA PASSARELA, LDA at no cost.
7. RIGHT OF ACCESS TO PERSONAL DATA
O ABRIGO DA PASSARELA, LDA guarantees the means that allow the User to consult their Personal Data. The User has the right to obtain from O ABRIGO DA PASSARELA, LDA the confirmation that the personal data concerning him are or are not subject to treatment and, if applicable, the right to access his personal data and the following information :
- The purposes of data processing;
- The categories of personal data in question;
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, namely recipients established in third countries or belonging to international organizations;
- The period of retention of personal data;
- Right to request O ABRIGO DA PASSARELA, LDA to correct, eliminate or limit the processing of personal data, or the right to prevent such treatment;
- Right to file a complaint with CNPD or another supervisory authority;
- If the data has not been collected from the User, the information available on the source of that data;
- The existence of automated decisions, including the definition of profiles, and information related to the underlying logic, as well as the importance and expected consequences of such treatment for the data subject;
- Right to be informed about adequate guarantees associated with the transfer of data to third countries or international organizations.
Upon request, O ABRIGO DA PASSARELA, LDA will provide the User, free of charge, with a copy of the User Data that is being processed. The provision of other copies requested by the User may incur administrative costs.
8. RIGHT TO RECTIFY PERSONAL DATA
The User has the right to request, at any time, the rectification of his Personal Data and, as well, the right to have his incomplete personal data completed, including by means of an additional declaration.
In case of rectification of the data, O ABRIGO DA PASSARELA, LDA informs each recipient to whom the data have been transmitted the respective rectification, unless such communication is considered impossible or implies a disproportionate effort for O ABRIGO DA PASSARELA, LDA.
9. RIGHT TO DELETE PERSONAL DATA (“RIGHT TO BE FORGOTTEN”)
The User has the right to obtain, from O ABRIGO DA PASSARELA, LDA, the elimination of his data when one of the following reasons applies:
- User Data is no longer necessary for the purpose that motivated its collection or treatment;
- The User withdraws the consent on which the data processing is based and there is no other legal basis for such processing;
- The User opposes the treatment under the right of opposition and there are no prevailing legitimate interests that justify the treatment;
- If the User Data is treated illegally;
- If the User Data has to be erased in order to comply with a legal obligation to which O ABRIGO DA PASSARELA, LDA is subject;
Under applicable legal terms, ABRIGO DA PASSARELA, LDA has no obligation to delete User Data to the extent that the treatment proves necessary to fulfill a legal obligation to which ABRIGO DA PASSARELA, LDA is subject or for the purposes of declaration, exercise or defense of a right of O ABRIGO DA PASSARELA, LDA. in a judicial process.
In case of data deletion, O ABRIGO DA PASSARELA, LDA informs each recipient / entity to whom the data has been transmitted the respective elimination, unless such communication proves impossible or implies a disproportionate effort for O ABRIGO DA PASSARELA, LDA.
When O ABRIGO DA PASSARELA, LDA has made the User Data public and is obliged to delete it under the right of such elimination, O ABRIGO DA PASSARELA, LDA undertakes to ensure the measures that are reasonable, including of a technical nature, 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 that they remove the links to such personal data, as well as copies or reproductions thereof.
10. RIGHT TO LIMIT THE PROCESSING OF PERSONAL DATA
The User has the right to obtain, from O ABRIGO DA PASSARELA, LDA, the limitation of the treatment of the User Data, if one of the following situations applies (the limitation consists of inserting a mark in the personal data kept for the purpose of limiting your treatment in the future):
- If you challenge the accuracy of personal data, during a period that allows O ABRIGO DA PASSARELA, LDA to verify its accuracy;
- If the treatment is illegal and the User opposes the elimination of the data, requesting, on the other hand, the limitation of its use;
- If O ABRIGO DA PASSARELA, LDA no longer needs User Data for processing purposes, but such data is required by the User for the purposes of declaring, exercising or defending a right in a judicial process;
- If the User has opposed the treatment, until it is verified that the legitimate reasons of O ‘ABRIGO DA PASSARELA, LDA prevail over those of the User.
When User Data is subject to limitation, it may only, with the exception of retention, be treated with the User’s consent or for the purpose of declaring, exercising or defending a right in a judicial proceeding, defending the rights of another natural person or collective bargaining, or for reasons of public interest provided for by law.
The User who has obtained a limitation in the treatment of his data in the cases referred to above will be informed by O ABRIGO DA PASSARELA, LDA before the limitation to treatment is lifted. In case of limitation of data processing, O ABRIGO DA PASSARELA, LDA will notify each recipient to whom the data has been transmitted the respective limitation, unless this communication proves impossible or implies a disproportionate effort for O ABRIGO DA PASSARELA, LDA.
In case of limitation in the processing of data, O ABRIGO DA PASSARELA, LDA will notify each recipient to whom the data have been transmitted the respective limitation, unless this communication proves impossible or implies a disproportionate effort for O ABRIGO DA PASSARELA, LDA.
11. RIGHT TO PORTABILITY OF PERSONAL DATA
The User has the right to receive the personal data that concerns him and that he has provided to O ABRIGO DA PASSARELA, LDA, in a structured format, in common use and automatic reading, and the right to transmit this data to another responsible for the processing , if: the treatment is based on consent or a contract to which the User is a party; and if the treatment is carried out by automated means.
The portability right does not include inferred data or derived data, i.e., personal data that is generated by O ABRIGO DA PASSARELA, LDA as a consequence or result of the analysis of the data being processed.
The User has the right to have his personal data transmitted directly between those responsible for the processing, whenever this is technically possible.
12. RIGHT OF OPPOSITION TO TREATMENT
The User has the right to object 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 ‘O ABRIGO DA PASSARELA, LDA, or when the processing is carried out for purposes other than those for which personal data were collected, including the definition of profiles, or when personal data are processed for statistical purposes.
O ABRIGO DA PASSARELA, LDA will finalize the treatment of the User Data, unless it presents urgent and legitimate reasons for such treatment that prevail over the interests, rights and freedoms of the User, or for the purposes of declaration, exercise or defense of a right O ABRIGO DA PASSARELA, LDA in a lawsuit.
When the User Data is processed for the purposes 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 said marketing, which includes the definition of profiles in the insofar as it relates to direct marketing. If the User opposes the processing of his data for the purpose of direct marketing, O ABRIGO DA PASSARELA, LDA stops processing the data for this purpose.
The User also has the right not to be subject to any decision taken exclusively on the basis of automated treatment, including the definition of profiles, which has an effect on its legal sphere or which significantly affects it in a similar way, unless the decision:
- Is necessary for the conclusion or execution of a contract between the User and O ABRIGO DA PASSARELA, LDA;
- Is authorized by legislation to which O ABRIGO DA PASSARELA, LDA is subject or
- It is based on the User’s explicit consent.
13. PROCEDURES WITH A VIEW TO THE EXERCISE OF RIGHTS BY THE USER
O direito de acesso, o direito de retificação, o direito de eliminação, o direito à limitação, o direito de portabilidade e o direito à oposição podem ser exercidos pelo Utilizador mediante contacto com O ABRIGO DA PASSARELA, LDA através do email [email protected].
O ABRIGO DA PASSARELA, LDA dará resposta por escrito (incluindo por meios eletrónicos) ao pedido do Utilizador no prazo máximo de um mês a contar da receção do pedido, salvo em casos de especial complexidade, em que esse prazo pode ser prolongado até dois meses.
Se os pedidos apresentados pelo Utilizador forem manifestamente injustificados ou excessivos, nomeadamente devido ao seu carácter repetitivo, O ABRIGO DA PASSARELA, LDA reserva-se o direito de cobrar custos administrativos ou recusar-se a dar seguimento ao pedido.
14. Violações de dados pessoais
In the event of a data breach and, insofar as such breach is likely to imply a high risk to the User’s rights and freedoms, O ABRIGO DA PASSARELA, LDA undertakes to report the breach of personal data to the User concerned in the within 72 hours of becoming aware of the incident.
Under legal terms, communication to the User is not required in the following cases:
- If O ABRIGO DA PASSARELA, LDA has applied adequate protection measures, both technical and organizational, and these measures have been applied to personal data affected by the breach of personal data, especially measures that make personal data incomprehensible to any unauthorized person. access that data, such as encryption;
- If O ABRIGO DA PASSARELA, LDA 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 O ABRIGO DA PASSARELA, LDA. In this case, O ABRIGO DA PASSARELA, LDA will make a public communication or take a similar measure through which the User will be informed.
15. Final Part
16. APPLICABLE LAW AND JURISDICTION