The companies (i) Açores 2000 Soc. Desenvolvimento Turístico Açores, S.A.; (ii) HTA, Hotéis, Turismo e Animação dos Açores, S.A.; (iii) Proturotel, Promoção Turística e Hoteleira, S.A.; e, (iv) Bensitur, Sociedade Açoriana de Investimentos Turísticos LDA., (hereinafter referred to as “BENSAUDE Hotels”), in the execution of its activities, processes personal data, meaning any information relating to an identified or identifiable natural person (henceforth “Data subject(s)”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
In the cases where BENSAUDE Hotels determines the purposes and means of the processing of personal data within the performance of its activities it shall be considered as joint controllers, ensuring full compliance with Data Protection Legislation.
According with the aforementioned Legislation, BENSAUDE Hotels stands for the processing of personal data pursuant to all applicable principles: i) Principle of Lawfulness, Fairness and Transparency; ii) Principle of Purpose Limitation; iii) Principle of Data Minimisation; iv) Principle of Accuracy; v) Principle of Storage Limitation; vi) Principle of Integrity and Confidentiality.
In full accordance with the principles outlined above, BENSAUDE Hotels fully respects the data protection rights of Data Subjects. Hence, Data Subjects may contact BENSAUDE Hotels to obtain any information related to the processing of personal data, using the contacts provided in paragraph 7.
- Legal Basis and Purposes for the Processing of Personal Data
The personal data of Data Subjects will be processed by BENSAUDE Hotels with the following legal basis:
|Lawful Basis||What does it consist of?|
|BENSAUDE Hotels will only process your Personal Data if you consent to its processing through a free, specific, informed and unambiguous act, by which you accept, by means of a statement (in writing or orally) or an unequivocal positive act (by completing an option), that your Personal Data is subject to processing.
|Pre-contractual information’s or performance of a contract||BENSAUDE Hotels may process your Personal Data if it is necessary, without limitation, for the execution of a service and / or product supply contract in which you are a part of the Company as a Collaborator, Customer and / or Supplier, or to perform pre-contractual agreements at your request.
|Compliance with a legal obligation||BENSAUDE Hotels may process your Personal Data to ensure and guarantee compliance with legal obligations to which you are subject under the legislation of a Member State and / or the European Union.
|Defence of vital interests of the Data Owner||BENSAUDE Hotels may process your Personal Data to ensure the defence of your vital interests, especially when the same processing is essential to your life.
|Legitimate Interests||BENSAUDE Hotels, other Controllers or Third Parties, may process your Personal Data provided that such processing legitimately prevails over your interests or fundamental rights and freedoms.
Taking into account the abovementioned, the collection of personal data on the basis of the grounds of lawfulness set forth will be primarily for purposes related to the development of BENSAUDE Hotels corporate purpose, for the execution of contracts and to comply with legal obligations. Hence, the non-collection of personal data will imply the impossibility of processing data for the aforesaid purposes.
- Processing of personal data on the Website
In the scope of the Website personal data will be processed for the management of the same in the legitimate interest of BENSAUDE Hotels and, for the purposes of using the Online Store, the personal data collected are processed for the purposes of (i) authentication; (ii) booking; (iii) clarifications.
BENSAUDE Hotels as the controller will process the following personal data of the Data Subject for the purposes of the Website for the abovementioned purpose are the following: name, surname, email address.
In terms of the terms of retention of the personal data processed by BENSAUDE Hotels as controller for the processing activities in the Website, these will be kept for the applicable fiscal, contractual and guarantee periods, as well as applicable legal retention periods that require a more extensive conservation of said data.
- Processing Methods
The processing of personal data will be executed automated and manually by computer tools, which are strictly related to the mentioned purposes and, in any case, guaranteeing the security and confidentiality of personal data.
- Disclosure and Transmission of Personal Data
Regarding the disclosure and transmission of personal data, BENSAUDE’s Hotels employees will process personal data and, as a result, they can access to the personal data of Data Subjects. The referred employees will solely process personal data of Data Subjects for the purposes specified in this Policy and in strict compliance with current or future Data Protection Legislation.
Third parties who may process personal data on behalf of BENSAUDE Hotels may also access to personal data of Data Subjects as subcontractors, including without limitation the providers of IT services required for the operation of information systems, outsourcing service providers or cloud computing services, professionals and consultants.
Data Subjects have the right to obtain a complete and up-to-date list of the subcontractors (if any) elected by BENSAUDE Hotels and for this purpose they shall submit a specific request to BENSAUDE Hotels under the terms specified in paragraph 7 of this Policy.
- Data Subjects Rights
|Rights||What do they consist in?|
BENSAUDE Hotels may refuse to provide the requested information whenever, in order to do so, BENSAUDE Hotels has to disclose Personal Data of another person or the information negatively impacts the rights of another person.
|Right to rectification||If your Data is incorrect or incomplete (for example, if your name or address is wrong), you may ask BENSAUDE Hotels to take reasonable measures to correct it.
|Right to erasure||This right is also known as the “right to be forgotten” and, in a simple way, allows you to request to permanently erase your data, as long as there are no valid grounds for BENSAUDE Hotels to continue using them or their use is illicit. This is not a general right to erasure, since exceptions are allowed (for example, where such data are necessary for the defence of a right in a judicial proceeding).
|Right to restriction of the processing activities||You have the right to “block” or prevent future use of your Data while BENSAUDE Hotels evaluates a request for rectification or as an alternative to deletion. Whenever the processing is limited, BENSAUDE Hotels continues to be able to store its data, but cannot use it later. BENSAUDE Hotels maintains a list of the holders who have requested the “blocking” of the future use of their data to ensure that this limitation is respected.
|Right to data portability||You have the right to object to certain types of processing, for reasons related to your particular situation, at any time during which this processing is carried out, for the legitimate interest of BENSAUDE Hotels or of Third Parties. BENSAUDE Hotels may continue to process such Data if it can prove “legitimate reasons for the processing that overlap its interests, rights and freedoms” or if such Data is necessary for the establishment, exercise or defence of a right in a judicial process.
|Right to lodge a complaint||You have the right to complain to the competent control authority, the Comissão Nacional de Proteção de Dados (CNPD), if you believe that the processing carried out on Personal Data violates your rights and / or applicable data protection laws.
You may at any time, in writing, exercise the rights enshrined in the Data Protection Legislation and other applicable legislation through the methods described in paragraph 7 of this Policy.
- Confidentiality and Security
- How to Contact BENSAUDE Hotels for Data Protection and Privacy Matters
Data Subjects may exercise their rights by contacting BENSAUDE Hotels through the following methods: i) Rua de Lisboa, Edifício Varela S/N, 9500-216 Ponta Delgada; ii ) sending e-mail to the following e-mail email@example.com.