The protection of the privacy of personal data constitutes a fundamental commitment of AlvorInfante, Gestão Hoteleira Lda, under the trading name AlvorMar-Apartmentos Turísticos (hereinafter referred to as AlvorInfante), to its customers.

In the course of its activity, AlvorInfante, collects and processes personal data of several holders, including individuals who contract (or are interested in contracting) accommodation services, airport transfers, excursions, car rental, golf course rental, boat trips and events (collectively referred to, for the purposes of this policy, as "data subjects").

By reading this privacy policy you are informed of how AlvorInfante collects, processes and protects the personal data provided to us through the website www.alvormar.com, by email, by phone, by booking engines , agencies or presentially by the customer. To ensure the protection of data subjects, AlvorInfante establishes guidelines regarding the rights of the holders and the processing of personal data in accordance with the legislation in force.

The user must carefully read this privacy policy, drafted in a clear and simple way to facilitate its understanding, and freely and voluntarily determine whether to provide their personal data, or those of third parties, to AlvorInfante.

Last update: 3rd of July 2019

• + DATA CONTROLLER (responsible for treatment)

  It is considered "data controller", the natural or legal person who determines the purposes and means of processing the personal data of the data subjects.

  DATA CONTROLLER:

  Name: AlvorInfante, Gestão Hoteleira Lda, under the trading name AlvorMar, Apartamentos Turísticos (hereinafter AlvorInfante)

  Tax Id No.: 502103930

  Registered office: Rua D. Sancho I, n º 9/11, 8500-013 Alvor, Algarve, Portugal

  Phone: + 351 282 450 550

  Email: protecaodedados@alvormar.com.

  Data Protection: The user can contact data protection through the email protecaodedados@alvormar.com or by letter to the postal address of AlvorInafante's headquarters, addressed to data protection.

   

  All personal data collected by AlvorInfante shall be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, which entered into force on 25 May 2018.

• + PERSONAL DATA COLLECTED

  Personal data is collected through:

  • Bookings made on our website, subscription to our newsletter, via email and telephone in contact with our reservations department and in the act of checking in through the guest registration form.

  AlvorInfante collects and processes the following categories of personal data:

  • Identification Data: Gender, name, date of birth, nationality, ID number, tax id no.;
  • Contact Details: Postal address, e-mail address, telephone number;
  • Bank Details: Credit card number (required for payment of the reservation or to guarantee it, as well as to pay for the stay), account number;
  • Booking Details: Additional guests, date and time of check-in/check-out;
  • Event Data: Name of participants in events and preferences;
  • Site Data: Through tracking tools such as cookies, IP address, username, language, browsing preferences, service preferences, number of visits to the site;
  • Minor(s) Data: (Under 14 years of age) Name, nationality, date of birth, ID number.

  Personal data of children under 14 years of age are only collected after parental consent. It is important for parents/legal guardians to ensure that their children do not send us personal data without their consent (in particular through electronic means). If this happens, you can request its deletion by contacting us for this purpose via email protecaodedados@alvormar.com.

  In case the user provides the data of third parties, he is expressing their consent and undertakes to communicate to the data subject concerned, the information in this privacy policy, exempting AlvorInfante from any responsibility in this regard. However, AlvorInfante may carry out the necessary verifications to substantiate this fact by adopting due diligence measures that comply with the data protection regulation.

• + PURPOSES OF TREATMENT AND LEGAL BASIS

  Some categories of data requested by AlvorInfante in the course of its activity to comply with accommodation services and others that users contract or are interested in contracting are mandatory to fulfill the purposes established. Thus, if they are not provided or are not provided correctly, these purposes cannot be met.

  In order to make your reservation and manage your stay in our hotel unit we collect the following personal data that are mandatory:

  • Name and e-mail – mandatory at the time of booking whether this is done by email, telephone, via booking engine, agency or by the client in person (walk-in).
  • Billing name, tax identification number and billing address – mandatory for invoice issuance in the case of portuguese taxpayers and whose amount payable exceeds €100.
  • Credit card details – mandatory in the case of booking via reservation engine, website and email when you opt for the credit card payment method.
  • ID number and data contained therein – mandatory presentation at the time of check-in for all domestic and foreign guests. In the case of the latter for compulsory communication by law to the Immigration and Borders Services (SEF).

  According to customer requests, the identification data, contact details and bank details obtained will be processed by AlvorInfante for the following purposes:

  • Compliance with contracts concluded between AlvorInfante and customers, in particular the accommodation contract; which translates into the management of requests for contacts with AlvorInfante through the available means of communication, management of reservations made, including the management of payments, requests and preferences of customers, management of the provision of contracted accommodation services, as well as additional services provided during the stay.

  These purposes have as legal basis the following reasons: 1st the execution of a contract in which the data subject is a party, or for pre-contractual diligence at the request of the data subject (treatment is legitimized because it is necessary for the fulfillment of these purposes) and/or 2nd compliance with legal obligations to which AlvorInfante is subject.

  • For the purpose of managing the subscription of the newsletter and subsequent submission and management of the sending of commercial communications through electronic and/or conventional means. This purpose implies the explicit and unequivocal consent of the data subject.

  The subjects personal data shall be retained for a sufficient period of time for the fulfillment of each purpose or until the user requests its elimination to AlvorInfante, opposes this treatment or withdraws his consent. If the data subject revokes his/her consent for any of the treatments, this will not affect the lawfulness of the treatments previously carried out.

• + HOW WE PROTECT PERSONAL DATA

  AlvorInfante will treat data from data subjects always in an absolutely confidential way and maintain the obligation of secrecy required, in accordance with the provisions of the regulation, adopting, for this purpose, organizational and technical measures necessary to ensure the security of their data and preventing unauthorized alteration, loss, processing or unauthorized access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed.

• + DISCLOSURE OF PERSONAL DATA

  AlvorInfante may share the personal data of the data subjects (in the case of services customers may request) with entities providing services to AlvorInfante and that in the context of the provision of such services can proceed to the processing of personal data on account and by instructions of AlvorInfante, for the above mentioned purposes.

  In the sharing of personal data to its service providers, AlvorInfante guarantees that the subcontracted entity is bound by a subcontracting agreement that obliges it to process of personal data in compliance with the legislation on protection of personal data.

  Identification data, check-in and check-out dates will be shared with the Immigration and Borders Services (SEF) under Law 23/2007, of July 4, in the drafting in force. Identification data is also shared with the tax authority in accordance with the legislation in force.

  For the purposes of marketing communications, such as sending newsletters, AlvorInfante uses the MailChimp platform with whom it shares the data required to send them. You can learn more about Mailchimp's privacy policy at www.mailchimp.com.

  AlvorInfante may also share the personal data of the holders with third parties:

  • by virtue of requirement or judicial notification for that purpose, provided that duly substantiated and legally sustained;
  • in the case of a request by a public authority, provided that duly substantiated and legally sustained;
  • following the express request of the data subject, regarding their data, in the exercise of his rights, in particular, the portability right.

  If the data subject exercises his right to rectify, erase or restrict the processing of his personal data, AlvorInfante undertakes to communicate to the entities with whom it has shared the data of the holder in question that they were exercised and will act accordingly.

• + USE OF COOKIES

  When you visit AlvorInfante's website, consent will be required to create and save a text file (cookie) on your computer. This file will allow easier and faster access to the site, as well as its customization according to your preferences. Most browsers accept these files (cookies), but you may delete them or set their block automatically. In the "Help" menu of your browser you will find how to make these settings. However, if you do not allow the use of cookies there may be some features of the site that you will not be able to use.
  
  Cookies are files that websites or applications install on your browser or on your device (smartphone, tablet, etc.) during your journey through the website or application pages, and serve to store information about your visit.
  The use of cookies allows you to optimize your browsing, adapting the information and services offered to your interests, to provide you with a better experience every time you visit the website.
  
  TYPE OF COOKIES ACCORDING TO THE MANAGEMENT ENTITY:

  • First-party (own) cookies: a cookie managed by this domain / website
  • Third-party cookies: a cookie managed by another domain / website.
    

  AlvorInfante uses its own and third party cookies. AlvorInfante uses google analytics and session cookies.
  

  TYPE OF COOKIES CONSIDERING THEIR PERMANENCE:

  • Permanent (persistent) cookies: these are cookies that are permanently stored at the browser level on your access devices and are used whenever the user visits the site again. They are often used to direct navigation to the user's interests, allowing them to provide a more personalized service.
  • Session cookies: these are temporary cookies that remain in the browser cookie file until you leave the site. The information obtained by these cookies serves to analyze web traffic patterns, allowing you to identify problems and provide a better browsing experience.
    

  AlvorInfante uses permanent and session cookies. AlvorInfante uses google analytics and session cookies.
  
  TYPE OF COOKIES ACCORDING TO PURPOSE OF USE:

  • Strictly needed cookies (registration): these are the ones essential for the correct functioning of the page. They allow the user to browse the site and use their applications as well as access to secure areas of the site. Without these cookies, the services requested cannot be provided.
  • Analytical cookies: they collect information about the user's browsing experience on the website, usually anonymously, although sometimes also allow the user to be uniquely and unambiguously identified in order to obtain information about their interests in the services that the website provides.
  • Advertising cookies: customize advertising to the interests of each user to tailor advertising campaigns to users' tastes and limit the number of times they see the ad, helping to measure the effectiveness and success of advertisement.
  • Functional cookies: these are cookies that allow us to store information about users' options and allow us to adapt the site to users' needs.

  AlvorInfante uses strictly necessary, analytical and functional cookies. AlvorInfante does not use advertising cookies. AlvorInfante uses google analytics and session cookies.
  
  HOW TO MANAGE COOKIES
  If you so wish, you may not accept cookies from our browser, or you may not accept cookies from a particular service.
  All modern browsers allow you to change the cookies setting. These adjustments can usually be made in the "Options" or "Preferences" zone of the browser menu. However, disabling cookies may prevent some web services from working properly, affecting some or all of the site navigation.

• + RIGHTS OF THE DATA SUBJECT

  As an expression of its commitment to ensure the privacy of data subjects, AlvorInfante guarantees, in accordance with applicable national and community law, a broad set of rights that may be exercised under the following terms:

  Right of Access: Data subjects may, at any time, contact AlvorInfante and request confirmation that their personal data is being processed and, if so, be informed of the categories of personal data concerned, purposes of the processing of their data, the recipients to whom the data is disclosed, the retention period or the criteria used to establish it, the rights and means of exercising them, the origin of the data concerning them, the automated decisions, including profile definition.

  AlvorInfante may only provide the information of the data subjects and not personal data of third parties. In addition, if access may adversely affect someone else's rights, it may not be possible for AlvorInfante to provide them.

  If requested by the data subject, Alvorinfante will send a copy of the personal data being processed, in electronic form. If other copies are requested, AlvorInfante reserves the right to demand the payment of a fee equivalent to the administrative costs incurred to fulfill the request.

  Right to Erasure: Also known as “the right to be forgotten”, allows the data subject to request the deletion or removal of their personal data when there is no compelling reason for AlvorInfante to continue using them. The right to erasure is not absolute as AlvorInfante may have the right or the obligation to withhold information, such as, for example, when it is subject to a legal obligation or has another valid reason to retain it.

  Right to Rectification: Whenever the personal data processed is found to be outdated, incomplete or incorrect, the data subject may request AlvorInfante to rectify it as soon as possible.

  Right to Data Portability: Data subjects also have the right to receive from AlvorInfante personal data concerning them, in a commonly used and readable format, and to transmit this data to another data controller under their sole responsibility. The holder may also request AlvorInfante to transmit such data to third parties. The right to portability covers only data to which the holder has consented to be processed, data relating to a contract in which the holder is party or if the processing is performed by automated means.

  AlvorInfante reserves the right to refuse data portability requests whenever they impair the rights and freedoms of third parties or conflict with any legal requirement.

  Right to Restriction of Processing: In certain situations, the data subject has the right to obtain from the controller the limitation of the processing of his personal data. When processing is limited, AlvorInfante may still retain the personal data of data subjects but may not continue to use them.

  The data subject may request limitation of the processing of his data for an indefinite period, when he wishes to suspend processing but retain his data. This may occur when:

  • the data subject disputes the accuracy of the data. In this case processing is limited for a period of time that allows AlvorInfante to verify the accuracy of the data, or
  • the data subject is waiting for a response to a request to oppose the processing.

  When processing is limited, personal data will only be processed again if the data subject gives his consent, except for specific processing contemplated in the law. AlvorInfante guarantees that the data subject who requested the limitation of processing of his data is informed before the limitation is annulled. AlvorInfante reserves the right to limit the processing of data of holders when it does not need it, committing to retain the data for the pre-established retention period.

  Right to Object: AlvorInfante provides the necessary means for the data subject to object to certain processing of personal data for certain purposes, without prejudice to existing directives or laws.

  The data subject may object to the processing in the following circumstances:

  • for reasons relating to his/her particular situation, objecting to the processing of any personal data about them based on legitimate interests. However, AlvorInfante may continue to process the holder's data if it can demonstrate legitimate reasons for the processing of data that overlaps the subject's interests, rights and freedoms, or if it needs personal data to establish, exercise or defend itself in legal proceedings;
  • when pertaining to data processing for marketing purposes (including profiling related to that direct marketing).

  The rights foreseen and described in this policy, as well as other rights legally set forth in the relevant legislation in force, can be freely exercised by sending an email to AlvorInfante to protecaodedados@alvormar.com or by sending a letter to the postal address of AlvorInfante headquarters, to the care of data protection.

   

• + RIGHT OF COMPLAINT

  Notwithstanding AlvorInfante's best practices regarding personal data protection, data subjects are entitled to submit a complaint to the National Data Protection Authority (CNPD) (https://www.cnpd.pt) regarding data processing carried out by AlvorInfante, through any of the channels allowed by the supervisory authority.

  The rights foreseen and described in this policy, as well as other rights legally set forth in the relevant legislation in force, may be freely exercised by sending an email to AlvorInfante to protecaodedados@alvormar.com or by sending a letter to the address of AlvorInfante headquarters, to the care of data protection.

• + SUPERVISORY AUTHORITY

  In Portugal, under the Regulation (GDPR), the National Data Protection Commission (CNPD) is the supervisory authority to monitor compliance with this law, and has the task of correcting and sanctioning possible irregularities and non-compliance.

  CNPD

  Address: Rua de São Bento, n º 148-3 º 1200-821 LISBOA

  Phone Number: + 351 213 928 400

  Website: https://www.cnpd.pt/

  Email: geral@cnpd.pt

• + DATA BREACH

  In the event of a breach of data and to the extent that such a breach is likely to pose a high risk to the rights and freedoms of the data subject, AlvorInfante has to notify it to the data subject and the supervisory authority (the latter not later than 72 hours after having become aware of it in accordance with article 55 of the regulation).

  According to the law, communication to the data subject is not required in the following cases:

  • If AlvorInfante has applied appropriate protection measures, both technical and organizational, and those measures have been applied to personal data affected by the breach, especially measures that make personal data incomprehensible to any unauthorized person to access such data, such as encryption;
  • In the event that AlvorInfante has taken subsequent measures to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialize; or
  • If the communication to the data subject implies a disproportionate effort for AlvorInfante. In this case, AlvorInfante will make a public communication or take a similar measure through which the data subject will be informed.

• + DATA CONSERVATION PERIOD

  The subjects personal data shall be retained for a sufficient period of time to fulfill each purpose; and always in accordance with the deadlines established in the applicable legislation. In some situations the conservation period may be longer, in which case such extension will be legally justified and sustained.

  Data retention periods:

  • data collected for communication to the Immigration and Borders Services shall be retained for a period of 1 year from the day following the date of the departure notice, in accordance with the provisions of article 15, paragraph 5 of law 23/2007 of July 4, in the applicable wording;
  • personal data used for tax purposes shall be retained for up to 10 years from the end of the contractual relationship;
  • the data referring to each stay will be kept for 1 year from the day of check-out (unless the customer has given his express consent to keep his data in a database, in which case the data will be retained until the holder withdraws his consent);
  • credit card details are deleted from the system 7 days after check-out or 7 days after cancellation of the reservation;
  • data for marketing and commercial communication purposes will be retained until the subject requests its deletion to AlvorInfante, opposes this treatment or withdraws his consent. If the data subject revokes his consent for any of the treatments, this will not affect the lawfulness of the treatments previously carried out.

  After the respective conservation period has elapsed, AlvorInfante will destroy or anonymize the data.

  The processing of personal data for marketing purposes and commercial communication purposes, will be carried out only with the consent of the data subject, provided at the time of collection thereof. If the data subject consents, he may receive marketing communications through email, postal mail, telephone contact and SMS. For the purposes of marketing communications AlvorInfante uses the MailChimp platform. You can learn more about Mailchimp's privacy policy at www.mailchimp.com.

  Consent for the above-mentioned purposes may be withdrawn at any time, although this right does not compromise the lawfulness of the treatment carried out on the basis of the prior consent given or the subsequent processing of the same data, based on another legal basis, such as the execution of a contract in which the data subject is party, or for pre-contractual procedures at the request of the holder and in compliance with legal obligations to which AlvorInfante is subject.

  If you wish to withdraw your consent, you may do so through the contacts indicated in this policy.

• + UPDATES AND CHANGES TO THIS PRIVACY POLICY

  AlvorInfante may change or update this privacy policy in accordance with new legal or regulatory requirements, as well as following improvements in the quality of its services and development of our commitment to the protection of personal data.

  Please read this policy carefully before using the website or purchasing our services or products. By using our website or by contacting us for the use of any services or for the purchase of our products you consent to the collection and processing of your data as described in this privacy policy.

  Last update: 3rd of July 2019