A. GENERAL PART
1.1. COLLECTION AND TREATMENT OF USER DATAIn connection with the provision of the website hosted on www.luzcasas.com ("Site"), the conclusion of any contracts (namely hotel services and vouchers), the provision of information, contents, including newslettl be informeer, or any telephone contacts customer cards and loyalty as well as membership (collectively, "Services") to its users ("User") and to other entities related to it, the Luzcasas entity, based at Estrada da Luz - Espiche 8600-147 Lagos may require the User to make personal data available, that is, information provided by the User that allows Light to identify and / or contact you (& ldquo; Personal Data & rdquo;).
As a rule, Personal Data is requested when the User registers on the Site, requests a contact and / or sending newsletters, subscribes to a certain service, provides or requests information, acquires a product or establishes a contractual relationship with Luzcasas. br
The Personal Data collected and processed consists essentially of information regarding the name, gender, date of birth, telephone, mobile phone, email, address, tax identification number, credit card data (collected for billing purposes only), although they may come to collect other Personal Data that may be necessary or convenient for the provision or collection of Services by Luzcasas.
After the collection of Personal Data, Luzcasas 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 the Personal Data, as well as the information mentioned in clause 8. < >
Luzcasas also collects and handles information about the features of your hardware device and the browser / software features 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 (& ldquo; Usability Information & rdquo;). We use this information only to improve the quality of your visit to our Site.
These subcontracted entities may not transmit the User Data to other entities without Luzcasas giving prior authorization and in writing, and are also prevented from contracting other entities without Luzcasas' prior authorization.
Luzcasas undertakes to subcontract only entities that offer the 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 contracted entities pale luzcasas are linked to the latter by means of a written agreement which governs, in particular, the purpose and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties.
After collecting personal data, Luzcasas provides the User with information about the categories of subcontracted entities that, in this case, can process data on behalf of Luzcasas.
1.3. DATA COLLECTION CHANNELSLuzcasas may collect data directly (i.e., directly from the User) or indirectly (i.e., through partner entities or third parties). The collection can be done through the following channels:
Direct collection: in person, by phone, by e-mail and through the Site;
Indirect collection: through partners or companies of the group and official entities.
2. GENERAL PRINCIPLES APPLICABLE TO THE TREATMENT OF USER DATAIn terms of general principles regarding the processing of personal data, Luzcasas undertakes to ensure that the User Data processed by you are:
- Object of a treatment in accordance with the law, fair and transparent in relation to the User;
- Collected for specific, objective and legitimate purposes and not subsequently treated in a way contrary to these purposes;
- adequate, justified and limited to what is necessary in relation to the purposes for which they are processed;
-Exact and updated whenever necessary, and all necessary measures are taken to ensure that inaccurate data, taking into account the purposes for which they are processed, are erased or corrected without delay; - Preserved in a way that allows the identification of the User only for the period necessary for the purposes for which the data is processed;
Treaties in a manner that ensures their safety, including protection against their unauthorized or illegal treatment and against their loss, destruction or unforeseen damage, and appropriate technical or organizational measures are taken.
Data processing performed by Luzcasas is permitted and legal when at least one of the following situations occurs:
- The User has, without any doubt, given their consent to the processing of the User Data for one or more specific purposes;
- Treatment is necessary for the execution of a contract in which the User is a party, or for pre-contractual procedures at the request of the User; - The processing is necessary for the fulfillment of a legal obligation to which Luzcasas is subject; - Treatment is necessary for the defense of the fundamental interests of the User or another individual;
The processing is necessary for the legal interests pursued by Luzcasas or by third parties (except if the interests or fundamental rights and freedoms of the User that require the protection of the personal data prevail).
Luzcasas undertakes to ensure that the processing of User Data is only done under the conditions listed above and with respect to the principles mentioned above.
When the processing of the User Data is performed by Luzcasas based on the User's agreement, the User has the right to withdraw its consent at any time. The withdrawal of the consent, however, does not compromise the legality of the treatment made by Luzcasas based on the consent previously given by the User.
The length of time during which the data is stored and stored varies according to the purpose for which the information is processed.
Effectively, there are legal requirements that require you to retain the data for a minimum period of time. Thus, and where there is no specific legal obligation, the data will be stored and kept only for the minimum period necessary for the purposes that led to their collection or subsequent processing, which in the end will be eliminated.
3. USING AND USING THE DATA PROCESSING PURPOSES
In general terms, Luzcasas uses the User Data with the following purposes:
- Provision of reservation and maintenance services and associated services;
- Management of contacts with the User;
- Billing and collection to the User;
- Registration of the User on the Site;
- Inform the User, who has requested it, of new products and services made available on the Site and / or in the hotel units, special offers and campaigns, updated information on Luzcasas activity and, in general, for Luzcasas marketing purposes , through any means of communication, including electronic media;
- Allow access to restricted areas of the Site, according to previously established terms;
- Ensure that the Site meets User's needs by developing and publishing content that is as adapted as possible to the requests and type of User, improving the search capabilities and functionalities of the Site and obtaining associated or statistical information in relation to the User's profile (analysis of consumption profiles);
- Provision of Services, and other services, such as newsletters, opinion surveys, or other information or products requested or purchased by the User; p>
Luzcasas 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, Luzcasas may combine Personal Data with Usability Information to provide the User with more personalized content.
The User Data collected by Luzcasas is not shared with third parties without the consent of the User, except for the situations mentioned in the following paragraph. However, in the event that the User contracts with Luzcasas that are provided by other entities responsible for the processing of personal data, the User Data may be consulted or accessed by such entities, to the extent that it is necessary to provide such services .
Under applicable legal terms, Luzcasas may transmit or communicate User Data to other entities in the event that such transmission or communication is necessary for the execution of the contract established between the User and Luzcasas, or for pre-contractual procedures at the request of the User , in case it is necessary for the fulfillment of a legal obligation to which Luzcasas is subject or in case it is necessary to obtain the legitimate interests of Luzcasas or third party.
4. TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES IMPLEMENTEDIn order to guarantee the security of the User Data and the maximum confidentiality, Luzcasas treats the information that it has provided to you in an absolutely confidential way, in accordance with its internal policies and procedures of security and confidentiality, which are updated periodically according to the needs, as well as with the terms and conditions legally established.
Due to the nature, scope, context and purpose of data processing, as well as the risks arising from the treatment of the rights and freedoms of the User, Luzcasas undertakes to apply, both when defining the means of treatment as at the time of the treatment itself, technical and organizational measures necessary and adequate for the protection of User Data and compliance with legal requirements.
It also undertakes to ensure that, by default, only data that is necessary for each specific purpose of treatment is processed and that such data are not made available without human intervention to an indeterminate number of persons.
Communication between the user's device and the Luzcasas Site is done through secure channels and communications that use the HTTPS protocol and the SSL security standard.
5. TRANSFER OF DATA OUT OF THE EUROPEAN UNIONPersonal data collected and used by Luzcasas are not made available to third parties established outside the European Union. If in the future this transfer takes place for the reasons mentioned above, Luzcasas undertakes to ensure that the transfer complies with applicable legal provisions, in particular as regards the determination of the country's suitability for data protection and the requirements applicable to such transfers.
B. USER RIGHTS (DATA HOLDERS)
7. RIGHT TO INFORMATION7.1. Information provided to the User by Luzcasas (when data is collected directly from the User):
- The identity and contacts of Luzcasas, responsible for the treatment and, if applicable, of its representative;
- The contacts of the Data Protection Officer;
- the purposes of the treatment to which the personal data are intended, as well as, if applicable, the legal reasons for the treatment;
- If the processing of the data is based on the legitimate interests of Luzcasas or a third party, an indication of such interests;
- where applicable, the recipients or categories of recipients of personal data;
- where applicable, indication that personal data will be transferred to a third country or an international organization, and whether or not a decision on adequacy has been adopted by the Commission or reference to appropriate or appropriate transfer guarantees;
- Deadline for the preservation of personal data;
- The right to request from Luzcasas 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 consent of the User, the right to withdraw it at any time, without compromising the legality of the processing done on the basis of the previously given consent;
- The right to complain to the CNPD or other supervisory authority; - Indication whether the disclosure of personal data constitutes a legal or contractual obligation, or a requirement to conclude a contract, as well as whether the holder is required to provide the personal data and the possible consequences of not providing such data; /> - where applicable, the existence of automatic decisions, including profile definition, and information on the basic concept, as well as the importance and expected consequences of such processing for the data subject. - In the event that the User Data is not collected directly by Luzcasas from the User, in addition to the information referred to above, the User is also informed about the categories of personal data being processed, as well as the origin of the data and, if they are from sources accessible to the public.
- In the event that Luzcasas intends to proceed with the further processing of the User Data for a purpose other than that for which the data were collected, prior to such processing, Luzcasas will provide the User with information about that purpose and any other information of interest, in the terms above referred to.
7.2. Procedures and measures implemented to fulfill the right to information.
The information referred to in 7.1. is provided in writing (including by electronic means) by Light to the User prior to the processing of personal data in question. In accordance with applicable law, Luzcasas is under no obligation to provide the User with the information mentioned in 7.1 when and to the extent that the User is already aware of them.
Information is provided by Luzcasas at no cost.
8. RIGHT TO ACCESS PERSONAL DATALuzcasas guarantees the means by which the User may consult his Personal Data.
The User has the right to obtain from Luzcasas the confirmation that the personal data concerning him are treated or not 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 addressees or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients established in third countries or belonging to international organizations;
- The term of retention of personal data;
- Right to request from Luzcasas the correction, elimination or limitation of the processing of personal data, or the right to prevent such processing;
- Right to complain to the CNPD or other supervisory authority;
- If the data has not been collected from the User, the available information on the origin of the data;
- the existence of automated decisions, including the definition of profiles, and information on the underlying logic, as well as the importance and expected consequences of such processing for the data subject;
Right to be informed about the appropriate safeguards associated with the transfer of data to third countries or international organizations.
Upon request, Luzcasas 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 entail administrative costs.
9. RIGHT TO RETIFICATION OF PERSONAL DATAThe User has the right to request, at any time, the rectification of his Personal Data and also the right to have incomplete personal data completed, including by means of an additional declaration.
In case of rectification of the data, Luzcasas will inform each addressee to whom the data have been forwarded for rectification, unless such communication is considered impossible or involves a disproportionate effort for Luzcasas.
10. RIGHT TO ENFORCE PERSONAL DATA ("RIGHT TO BE FORGOTTENED")The User has the right to obtain, by Luzcasas, the deletion of his data when one of the following reasons applies:
- The User Data is no longer necessary for the purpose for which it was collected or processed;
- The User withdraws the consent on which the data treatment is based and there is no other legal basis for such treatment;
- The User opposes the treatment under the right of opposition and there are no prevailing legitimate interests justifying the treatment;
- In case the User Data is treated illegally;
- If User Data must be deleted in order to comply with a legal obligation to which Luzcasas is subject;
Under applicable legal terms, Luzcasas is under no obligation to delete the User Data to the extent that the processing proves necessary to fulfill a legal obligation to which Luzcasas is subject or for the purposes of declaration, exercise or defense of a Luzcasas's right in a judicial proceeding.
In the event of the deletion of data, Luzcasas notifies each recipient / entity to whom the data has been transmitted of its erasure, unless such communication proves impossible or involves a disproportionate effort for Luzcasas.
When Luzcasas has made public the User Data and is obliged to delete it under the right of such disposal, Luzcasas undertakes to ensure that measures are reasonable, including of a technical nature, taking into account available technology and costs of its application to inform those responsible for the effective treatment of personal data that the User has requested the deletion of links to such personal data, as well as copies or reproductions thereof.
11. RIGHT TO LIMITATION OF THE TREATMENT OF PERSONAL DATAThe User has the right to obtain, by Luzcasas, the limitation of the processing of the User Data, if one of the following situations applies (the limitation is to insert a mark in the personal data conserved with the purpose of limiting its treatment in the future):
- If you dispute the accuracy of personal data, for a period that allows Luzcasas to verify its accuracy;
- If the treatment is unlawful and the User opposes the deletion of the data, requesting, on the other hand, the limitation of its use;
- If Luzcasas no longer requires User Data for treatment purposes, but such data is requested by the User for the purposes of declaration, exercise or defense of a right in a judicial process;
If the User has objected to the processing, until it is verified that the legitimate reasons of Luzcasas prevail over those of the User.
When User Data is subject to limitation, they may only, with the exception of conservation, be treated with the consent of the User or for the purpose of declaring, exercising or defending a right in a judicial process, defending the rights of another natural or legal person. or for reasons of public interest legally
The user who has obtained the limitation of the treatment of his data in the above cases will be informed by Luzcasas before the limitation to the treatment is annulled.
In case of limitation of the processing of the data, Luzcasas will inform each addressee to whom the data have been transmitted to its limitation, unless this communication proves impossible or involves a disproportionate effort for Luzcasas.
12. RIGHT OF PORTABILITY OF PERSONAL DATAThe User has the right to receive the personal data concerning him and which he has provided to Luzcasas, in a structured, current and automatic reading format, and the right to transmit this data to another person responsible for the treatment, if: />
- The treatment is based on the consent or a contract of which the User is a party;
The treatment is performed by automated means.
The portability right does not include inferred data or derivative data, i.e. personal data that is generated by Luzcasas as a consequence or result of the analysis of the data being processed.
The User is entitled to have his or her personal data transmitted directly between those responsible for the treatment, whenever this is technically possible.
13. RIGHT OF OPPOSITION TO TREATMENT The User has the right to oppose at any time, on grounds relating to his particular situation, the processing of personal data concerning him that is based on the exercise of legitimate interests pursued by Luzcasas or when the processing is carried out for purposes that do not are those for which personal data have been collected, including the definition of profiles, or when personal data are processed for statistical purposes.
Luzcasas will terminate the processing of 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 Luzcasas right in a judicial proceeding .
When User Data is processed for the purpose of direct marketing (marketing), the User has the right to oppose at any time the processing of the data that concern him for the purposes of said commercialization, which includes the definition of profiles in the insofar as it relates to direct marketing. If you oppose the processing of your data for the purposes of direct marketing, Luzcasas ceases processing of the data for that purpose.
You also have the right not to be subject to any decision made solely on the basis of automated processing, including profiling, that has legal effects or significantly affects it in a similar way, unless the decision:
- It is necessary for the execution or execution of a contract between the User and Luzcasas;
- is authorized by legislation to which Luzcasas is subject; or
- It is based on the explicit consent of the User.
Luzcasas will respond in writing (including by electronic means) to the request of the User within a maximum of one month from the 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 manifestly unjustified or excessive, in particular because of their repetitive nature, Luzcasas reserves the right to charge administrative costs or refuse to comply with the request.
15. VIOLATIONS OF PERSONAL DATA
In the event of a breach of data and to the extent that such breach is likely to pose a high risk to the rights and freedoms of the User, Lightcasas undertakes to report the violation of personal data to the User in question within 72 hours to knowledge of the incident.
Under legal terms, communication to the User is not required in the following cases:
- If Luzcasas has applied adequate protection measures, both technical and organizational, and these measures have been applied to personal data affected by the violation of personal data, especially measures that make the personal data incomprehensible to any unauthorized person to access such data , such as encryption;
- If Luzcasas 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 communication to the User implies a disproportionate effort for Lightcases. In this case, Luzcasas will make a public communication or take a similar action through which the User will be informed.
C. FINAL PART