Quintinha de São João

PRIVACY POLICY AND PERSONAL DATA

For Quintinha de São João, the privacy and security of the personal data it processes are of crucial importance.

The hotel guarantees the security and confidentiality of this data, which it collects and retains directly with the holders or through its IT applications – the website www.quintinhasaojoao.com and the APP Quintinha de São João – from social networks or indirectly through tourist operators.

Quintinha de São João is defining processes and procedures for the company’s compliance with the principles and requirements of Regulation (EU) 2016/679 of the European Parliament and Council (General Data Protection Regulation, or GDPR) and other legislation in force related to the protection of personal data, in order to implement the appropriate technical and organisational measures to guarantee the security and confidentiality of the personal data that it handles or will handle in the future, in particular in relation to the unauthorised or unlawful processing of personal data and its respective accidental loss, destruction or damage.

To find out more details about how we process your personal data, please refer to the following sections of this Privacy Policy.

1. Quintinha de São João

Quintinha de São João is a 5-star hotel located on Funchal, the capital of the Portuguese archipelago Madeira, that provides guest accommodation and catering, drinks and Spa services.

Quintinha de São João is managed by QSJ – Unipessoal, Lda., whose headquarters are at Rua das Maravilhas, nº 76, 9000-177, Funchal. QSJ is the “Controller” of the personal data collected as part of Quintinha de São João’s activity.

2. Categories of Personal Date processed by Quintinha de São João

For the execution of its activities, Quintinha de São João processes the following categories of personal data:

Identification data (e.g., name, ID document number);

Demographic data (e.g., gender, birth date, nationality and country of residence);

Contact data (e.g., address, telephone number, email);

Preference data, insofar as it is related to the products and/or services to be made available by Quintinha de São João (e.g., sports, leisure and cultural preferences, dietary restrictions or preferences, special physical needs);

Payment details (e.g., Credit Card, Tax ID number)

Social networks data;

IT usage data (e.g., Data traffic, user ID, session start time, IP address)

3. Purposes of processing personal data and respective legal bases and retention periods

Main purpose of processing personal data: guest management, including but not limited to:

• Reservations management;

• Invoicing;

• Collection management and credit recovery;

• Promotion of a satisfactory stay for the interests and safety of guests;

• Bespoke service for SPA treatments, catering and drinks and care provision at the hotel.

Legal Basis: – pre-contractual process or execution of a contract between guests and Quintinha de São João.

Retention Period: – 5 (five) years after the termination of the contract, notwithstanding the retaining of personal data for a longer period for compliance with legal obligations.


Main purpose of processing the personal data of users of the Website, Quintinha de São João APP and social networks: – e-mail management.

Legal Basis: – pre-contractual process or execution of a contract between users and Quintinha de São João.

Retention Period: 1 (one) year from the last visit to the aforementioned IT applications.



Other purposes: – commercial and marketing activities.

Legal Basis: – legitimate interest (soft opt-in) of Quintinha de São João.

Retention Period: – unlimited.


Other purposes: – suitability of promotional offers or guest loyalty actions.

Legal Basis: – consent

Retention Period: – unlimited.


Other purposes: – definition and analysis of profiles.

Legal Basis: – legitimate interest of Quintinha de São João.

Retention Period: – 1 (one) year after last contact.


Other purposes: – carrying out surveys.

Legal Basis: – consent

Retention Period: – 1 (one) year after last contact.


Other purposes: – security of people and goods through video surveillance system.

Legal Basis: legitimate interest.

Retention Period: – 30 (thirty) days after image capture.


Main purpose of processing guests’ personal data: Maintenance of health data history for customer service in future appointments.

Legal Basis: – consent.

Retention Period: – 1 month after processing executed.


Main purpose of processing guests’ personal data: Data traffic management for promotion of a satisfactory stay for the interests and safety of guests.

Legal Basis: – pre-contractual process or execution of a contract between guests and Quintinha de São

Retention Period: – 5 (five) years after the termination of the contract, notwithstanding the retention of personal data for a longer period for compliance with legal obligations.


You can object to the processing of your personal data through opt-out mechanisms that will be provided both at the time of the collection of your data and in all subsequent communications for the same purpose, without any consequence arising from this and without requiring the right of opposition through reference to any specific ground or justification to be exercised.


If you do not wish to receive information about products and services from Quintinha de São João in the scope of its commercial and marketing activities, you should exercise your right of opposition by sending an e-mail to: [email protected] [email protected]

4. Cookies

When accessing our Website, various information is collected such as your IP address, version and type of browser, operating system, domains and the time of access. We use this data only for statistical purposes in order to improve the way we present content to our users.


We may collect additional information such as the e-mail, phone number, address and name provided by you when using our website. It is possible to use our service without disclosing your personal data by providing data that does not identify you, using a pseudonym or anonymising the data.


With your explicit consent, you can sign up to our Newsletter via the Website and select areas of interest to receive emails that are relevant to you. We use this data and your personal data in order to share information that is of interest to you.


Google Analytics

This Website uses Google Analytics as an analysis service supported by Google that helps us customise the Website in order to guarantee a better experience according to your preferences.


This service uses cookies to understand your visit, such as the time you browse our website and the pages you visit. Please be aware that no personal data is collected by our Google Analytics account which means that we cannot see who has accessed our Website. You can obtain more information about Google Analytics on the official Google Analytics website.


Google AdWords Remarketing

We use Google AdWords Remarketing for Internet advertising purposes.


The AdWords remarketing programme allows you to view relevant ads based on the pages you visited on the Website. This cookie does not identify any personal information or permit access to your computer.


With the Google AdWords Remarketing programme, we can customise our marketing actions in accordance with your needs and only show ads that are relevant to you.


Facebook: Custom Audience Pixel

Part of JavaScript installed on each page of our Website that collects and transmits predefined data to the marketing programme of Facebook. We use this service to collect data on the behaviour of users on our website.


Some of the information collected by the pixel includes the browser that is sent to Facebook with the Facebook user ID and URL of the site visited by the user. Each Facebook user has a unique Facebook ID that is device independent and which helps to monitor website users when they access the site from different devices. We use this information for commercial purposes, specifically advertisements suitable for the user on Facebook platforms.

5. Transfer of personal data

In order for Quintinha de São João to be able to undertake its activity and in order to provide you with a quality service, you may have to communicate your personal data or give access to it to other entities – Subcontractors or Third Parties.

Subcontractors:
GuestCentric is the entity that in the name and on behalf of Quintinha de São João is responsible for managing the Website. Quintinha de São João signed with GuestCentric a written agreement whereby it is obliged to process the data for the aforementioned purposes, and is not authorised to process it, directly or indirectly, for any other purpose, for its own benefit or that of a third party.

Third Parties:
In compliance with legal and/or contractual obligations, Quintinha de São João may also transmit personal data to the following categories of recipients:

Entities and authorities to whom personal data must be communicated under a legal obligation (Foreigners and Borders Service and police authorities)

Reservations centre

Tourism observatory

SR Tourism

Tax Authority


Additionally, when it comes into contact with Quintinha de São João through Facebook, Twitter, Pinterest and/or Instagram, your personal data is processed in accordance with the respective Data Policy, available at https://www.facebook.com/about/privacy/; https://help.twitter.com/pt/rules-and-policies/update-privacy-policy ; https://policy.pinterest.com/pt-pt/privacy-policy ; https://www.facebook.com/help/instagram/155833707900388/ and/or for other information about their products, the Help Centre available on each of these platforms. We recommend reading it.

6. Rights of Data Subjects

Data subjects have the following rights that may be exercised through email at: [email protected]: [email protected]:

6.1. Right of access

Whenever you want, you can obtain information on how your personal data is processed by Quintinha de São João, namely:

• The purposes for which your personal data is processed;

• The type of personal data that is processed;

• The entities to whom your personal data may be sent;

• The period of retention of your data or, if this is not possible, the criteria for setting that period;

• If personal data has not been collected from the holder, information available on its source.

6.2. Right to rectification

Whenever you think that your personal data is incomplete, you may ask for it to be completed, or you can request its rectification if it is found to be incorrect.

6.3. Right to erasure

You can request the deletion of your personal data. Quintinha de São João will inform you of the possibility or not to exercise this right in view of existing retention obligations by contractual means and/or by legal requirement.

The right to limit the processing of your personal data enables you to request that Quintinha de São João restricts the processing of your personal data to the following cases:

if you dispute the accuracy of your personal data, for a period of time that allows Quintinha de São João to check its accuracy;

• if the processing is unlawful but you do not want your data to be deleted;

• if Quintinha de São João no longer requires the personal data for the aforementioned purposes of processing, but if that data is required for the purposes of declaring, exercising or defending a right in legal proceedings.

• 6.5. Right to portability

You may request from Quintinha de São João the delivery, in a structured, normal and automated reading format, of the personal data provided by you. You still have the right to request that Quintinha de São João transmits this data to another controller, as long as this is technically possible.

The right to portability only applies in the following cases:

when processing is based on explicit consent or the execution of a contract;

• when the processing in question is carried out by automated means.

• 6.6. Right of opposition

You have the right to object to the processing of your personal data at any time, for reasons related to your individual situation and when the processing is carried out for purposes other than those for which the data was collected, but which are compatible with them

In such cases, Quintinha de São João shall cease to process your personal data, unless you have legitimate reasons for such processing to be carried out and that these take precedence over your interests.

6.7. Right to withdraw your consent

In cases where data is processed based on your consent, you can withdraw your consent at any time.

The revocation of your consent shall imply the end of the processing performed for the purpose in question (e.g., the inability to receive exclusive offers from Quintinha de São João).

6.8. The right to lodge complaints with Quintinha de São João or a supervisory authority

The exercise of your rights is free, unless the request is manifestly unfounded or excessive; in such cases, a reasonable fee may be charged for associated costs.

The response to your requests must be provided within a maximum period of 30 days, unless it is a particularly complex request, in which case this period may be longer.

Quintinha de São João has appointed a Data Protection Officer, pursuant to articles 37, 38 and 39 of the General Regulation for the Protection of Personal Data. You may contact the DPO at Quintinha de São João or exercise your rights through the following channel:

— E-mail [email protected]

If you want to make a complaint regarding matters related to the processing of your personal data, you can do so through the National Data Protection Commission, the competent supervisory authority in Portugal – WWW.CNPD.PT

7. Changes to this policy

Quintinha de São João may change this Privacy Policy at any time in order to reflect current privacy practices. When we make changes to this statement, we review the “update date” at the bottom of the document. We advise you to periodically read this Privacy Policy so that you are aware of how Quintinha de São João processes your personal data.

Last update: 24-10-2018