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Privacy Policy

The Santa Marinha Port Wine Flats respects your privacy and complies with all applicable legal rules, both those of the European Union and Portuguese, regarding data protection, privacy and information security.

Port Wine Flats has implemented a Personal Data Protection System to ensure regulatory compliance and the demonstration or disclosure of institutional responsibility for data protection and information security. Port Wine Flats implements all technical and organizational measures necessary to comply with the legal regime of the General Data Protection Regulation (GDPR), applicable in Portugal since May 25, 2018.

For any clarification or additional information or to exercise rights in this regard, please contact the Port Wine Flats Data Protection Office at gdpr@portwineflats.pt.

Definitions

Personal data
“Personal data” means information relating to an identified or identifiable natural person (‘data subject’); A natural person who can be identified, directly or indirectly, in particular by reference to an identifier, is considered identifiable. Personal identifiers are considered, for example, a name, identification number, location data, electronic identifiers or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

Processing of Personal Data
“Processing” means an operation or set of operations carried out on personal data or personal data sets by automated or non-automated means such as collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, transmission, dissemination or any other form of provision, comparison or interconnection, limitation, deletion or destruction.

Cookies
Cookies are small text files with information deemed relevant that devices (computers, mobile phones or portable mobile devices) use for access and load via a web browser when a web site is visited by the Client or User.

Entity Responsible for Data Treatment

Port Wine Flats is the entity responsible for the www.portwineflats.pt online site, and for other channels, such as applications, through which Users or Clients may have access to Port Wine Flats services that are presented or provided at any time through those channels.
The use of the site or applications by any User or Client may imply the processing of personal data, whose protection, privacy and security by Port Wine Flats, as the entity responsible for the processing, is assured, in accordance with the terms of this Data Protection Policy.

For contact with the Port Wine Flats Data Protection Office, please email gdpr@portwineflats.pt, describing the subject of the request and indicating an email address, telephone contact, or correspondence address.

Collection and Processing of Personal Data

Port Wine Flats processes the personal data strictly necessary to make information available, and operation of its channels in accordance with the uses made by Users or Clients, such as access, consultations, reservations, transactions and for Port Wine Flats’ own advertising campaigns.

In particular, the use of certain channel features may involve the handling of various direct or indirect personal identifiers, such as name, credit card, email, home address, contacts, device addresses or geographical location, whenever there is express consent of the User or Client.

Notice that Port Wine Flats only asks for credit card information at payment time, but does not store it in any case; we just pass that information to payment platforms (such as STRIPE).

In all cases, Users or Clients will always be informed about the need to access such data in order to use the features of the channels concerned.

Legal Principles

All data processing operations comply with the fundamental legal principles of data protection and privacy, including data movement, lawfulness, fairness, transparency, purpose, minimization, retention, accuracy, integrity and confidentiality.

Legitimacy Basis

All data processing operations carried out by Port Wine Flats have a legitimacy basis, notably because the data owner has consented to the processing of his or her personal data, either because the treatment is necessary for the acquisition of a service, the processing of a reservation, or for the fulfillment of a legal obligation or for the public interest, or because the treatment is deemed necessary for the purpose of pursuing the legitimate interests of Port Wine Flats or third parties, for example the Portuguese Foreign and Borders Service (SEF).

Prior information and the collection of express authorization for these purposes is always ensured. However, Users or Clients may at any time exercise their right to withdraw consent or their right to oppose to the use of their personal data. To do so, they must send a written request to the Port Wine Flats Data Protection Office (gdpr@portwineflats.pt).

Cookie Usage

Port Wine Flats may use cookies, being, at any time, guaranteed the respective deactivation by the Users or the Clients (by using the adequate functionalities of their web browsers).

Reporting Data to Other Entities

The provision of information or the provision of services by Port Wine Flats to its Users or Clients through channels may eventually imply the use of third party services, for example payment platforms, and may imply access by these entities to such personal data.

In these circumstances, Port Wine Flats will only use entities that provide sufficient guarantees and implement appropriate technical and organizational measures in a way that the treatment meets the requirements of the applicable laws and standards.

Except in compliance with legal obligations, provision of services, execution of contracts or pursuit of legitimate interests, under no circumstances will personal data of Users or Clients be communicated to third parties other than subcontractors or legitimate recipients, and no other communication will be done for purposes other than those referred to above.

In our web site we may have links or may include embedded content from other web sites, for whom we are not responsible. Beware that these websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that linked or embedded content, including tracking your interaction with the content. The User or Client must read the Privacy Policy of that web sites.

International Data Transfers

Any transfer of personal data to a third country or an international organization will only be carried out within the framework of compliance with legal obligations or with the guarantee of conformity with applicable European Community and national legal rules.

Exercise of the Rights of Personal Data Holders

Port Wine Flats Users or Clients, as holders of personal data may, at any time, exercise their data protection and privacy rights, including rights of access, rectification, deletion, portability, limitation or opposition to processing, under the terms and limitations of applicable laws.

Any request for the exercise of data protection and privacy rights shall be directed by the data holder to the Data Protection Office (gdpr@portwineflats.pt).

Data Protection Policy Change

In order to ensure its update, development and continuous improvement, Port Wine Flats may at any time make any changes, as deemed appropriate or necessary, to this Data Protection Policy. Its publication on the various channels is ensured in order to provide transparency and information to Users and Clients.

Express Consent and Acceptance

The free, specific and informed provision of personal data by the respective holder implies the knowledge and acceptance of the conditions contained in this Policy, considering that, by using the channels or by making their personal data available, the Users and Clients are expressly authorizing their treatment in accordance with the rules set out on this Privacy Policy.

Data Protection Officer

For the exercise of any data protection and privacy rights or for any matter relating to data protection, privacy and information security issues, Users and Clients interacting with Port Wine Flats may contact the Data Protection Office by e-mail gdpr@portwineflats.pt, describing the subject of the request and providing an email address, telephone contact or correspondence address for reply.

Policy Version 1.1
Date: 2022/09/01