PRIVACY AND PERSONAL DATA PROTECTION POLICY

 

 

INTRODUCTION

 

 

Olhar Positivo Investimentos, Lda, hereinafter only known as Olhar Positivo, respects the privacy of its clients and undertakes to protect the personal data relating to them, from the outset in the actions subordinated to the management of their internal processes, as well as in the communication and information sharing actions that they decide to authorize, with a view to valuing their own interests.

As a company that operates in the activity of local housing,Olhar Positivo necessarily collects, stores and processes data relating to its customers in order to be able to fulfill its obligations to regulators, and also because this data is fundamental for the realization of their activity by organizing them into databases and / or physical files. It informs and requests its customers prior consent to collect such data, which is provided entirely by the customers.

The purpose of the data collection, storage and processing actions includes the creation of mechanisms for the dissemination of the services developed by Olhar Positivo.

On the other hand, it should be stressed that the collection, storage and processing of personal data relating to customers (Data Holders) is carried out in strict compliance with applicable personal data protection legislation - Law 67/98 of 26 October (Protection Act). Data) and Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 - to ensure the confidentiality and security of the data provided.

This document explains what personal data is collected through customer interactions, how this data is used and the means of customer protection. About the activity of Olhar Positivo detailed information can be found at www.PENSEPOSITIVO.pt.

 

ABOUT DATA COLLECTED

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The data collected by Look Positive refer essentially to customer information, including identifying information. Personal data and documents typically requested in the hotel industry for the purpose of guest accommodation.

Type of data collected

In the context of the action related to the administrative management of its clients, the data collected relates to the need to record information about them, namely in terms of their name, address, passport number, as well as other information regarding the validity of the data. documents. This data is freely provided by all customers at the time of booking by filling in their Fast Check-In, which can be done entirely online through the Avaibook website at the time of booking or through the website. Olhar Positivo.

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Personal and contact nature

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Within the scope of Olhar Positivo's administrative action, in terms of processes related to customer management, as well as actions related to the defense and representation of their interests / needs, the personal data collected relates to the need to obtain information. essential for the provision of services, including housing. This includes information relating to the personal identity of guests, as well as about their telephone, email or other contacts.

In addition to the information that characterizes each of the clients, data is also collected on the contact and interaction moments with Olhar Positivo, in order to provide the best service in the pursuit of ensuring customer satisfaction, meeting their needs and interests. of the same. These moments of contact are properly recorded in a digital platform (CRM - Customer Relationship Management), enabling the follow-up of all the processes that result from it. In this sense, the data collected necessarily include the name and informational elements of the persons with whom the contact was made.

About browsing digital platforms

The data collected, in addition to improving the user experience of each user, is also intended to enhance the best offer of services.

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How data are collected

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The information collected is provided by themselves and on their own initiative during their service registration and / or service subscription processes, as well as at the request of Olhar Positivo's services, namely for the purpose of obtaining necessary complementary data. The data are obtained by completing online forms by customers on different platforms, when interested parties express their willingness to receive information and / or make the reservation.

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The following are the digital platforms that correspond to contacts with the outside:

Institutional website - Pensepositivo.pt

Avaibook.com, chanel manager

Social Networking - https://www.facebook.com/Pense.Positivo.Investimentos

 

What is the purpose of the data collected

The data collected by Olhar Positivo is intended to ensure the existence of useful information about each of its customers, with a view to providing its services, which is also the reason behind the registration of each one of them. In this sense, Olhar Positivo believes that it is within their interests to carry out contact with them in order to inform them about the services provided by Olhar Positivo. It is therefore understood that the contact and disclosure of services provided by possible entities with whom Olhar Positivo has protocols, falls within the same context, which may be made directly by these entities.

 

DATA PROTECTION MECHANISMS COLLECTED

 

Olhar Positivo ensures the necessary privacy of the data of its customers, preventing its misuse for other purposes than those intended and by persons other than those authorized, namely internally.

How is data protection ensured?
Customer data protection is ensured at different levels:

 

At work process level
Olhar Positivo safeguards the exclusive access to certain data, according to the nature and purpose of the collected data, according to the purposes inherent to its use. Thus, for the purpose of contact with customers, only those employees who have to contact them access this information, using the existing means and information systems.

 

At the level of existing technologies and information systems
Olhar Positivo safeguards that the technologies and information systems at its disposal guarantee the protection of its customers' data, in particular by obliging its suppliers to comply with the RGPD specifications, including the possibility of pseudonymization and encryption. confidentiality, integrity, resilience and proper functioning of such systems, as well as the timely restoration and accessibility of data in the light of physical or technical incidents and the adoption of regular monitoring procedures to ensure security in their operation. treatment.

 

Olhar Positivo also guarantees that there are no replicas of Databases in other technologies and / or storage media, safeguarding the existence, with reserved access, to parts of the original Databases, limiting them to enable internal access to partial information. for purposes of analysis and / or support for specific activities.

 

Access Limitations
Access, through user profiles specifically created for this purpose, with password-conditioned access, is limited to the various employees who are dedicated to the specific activities under each of the technologies. In this sense, there are type profiles, such as:
Platform Administration - configures a complete usage level, allowing you to query and modify all existing information. At the level of access, this profile has the responsibility to configure other profiles for users with more restricted access, which should be done in conjunction with the Information Systems and Technology manager at Olhar Positivo, and also the Database Manager before the Data Protection Officer (DPO), in terms of the Privacy and Security of the underlying information;
User with create and delete permissions - this profile is the user who can access all database information, including the creation and deletion of records, and cannot create users and / or intervene at the configuration level of the database. application. Uses the application in all its functionalities, being responsible to the Platform Administrator in terms of the reliability / accuracy of existing data, as well as under the reservation and protection thereof, being prohibited from sharing with other unauthorized collaborators;
User with query permissions - corresponds to the user profile that only accesses for database query and use of various application features. It is responsible to the Platform Administrator under the reservation and protection of existing data, being prohibited from sharing it with other unauthorized collaborators;
How long are data retained
All personal data are retained for the time deemed necessary for the purpose of maintaining the existing relationship with Olhar Positivo, within the legal time limits imposed or until the member exercises his right to delete, which will be granted within the applicable legal limits.

 

DATA ACCESS AND RIGHTS
The Data Subject has the right to be able to access your data and to request changes, among other rights which follow.

 

Access, rectification, cancellation and opposition
Olhar Positivo guarantees free access to the existing information about each Data Holder, regardless of the underlying digital platform, and may request that it be rectified and / or canceled, under the terms referred to above, if it considers it to be inappropriate for the intended purposes. It may also oppose existing data management practices, in particular through the courts, as mentioned above.

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Data Portability
The Data Subject may request, under the terms referred to in 6., to be delivered to them in a structured format, of ordinary use and automatic reading, as well as request its portability, and may require that it be performed by computer, provided which are available for that purpose.

 

Right to forgetfulness
The Data Subject may request that their data be deleted. Exceptions to this possibility are situations on grounds of the exercise of freedom of expression and information, the fulfillment of legal obligations, the exercise of public interest or public authority functions, for the purposes of public interest archiving, scientific or historical research or for statistical purposes in certain situations, or for the purpose of declaring, exercising or defending a right in court proceedings.

 

Data Protection Officer
He is appointed as the data protection officer of Olhar Positivo, João Miguel Dias Valadas Ribeiro, whose mission is to ensure compliance with the requirements of the RGPD and to ensure all information to any data subject who so requests, as well as to respond. the various requests that it may make.
Update and contacts about Privacy and Data Protection Policy
Olhar Positivo reserves the right to update its Privacy and Personal Data Protection Policy at any time it deems it necessary to do so without informing its customers.
Any customer may request information about Olhar Positivo´s Privacy and Data Protection Policy from the Data Protection Officer, through the following contacts: geral@pensepositivo.pt; 219 241 007.

 

Law and Forum
These general conditions are governed by Portuguese law.

All disputes arising from the interpretation or execution of this Agreement shall be settled by the Lisbon District Court, with express waiver of any other.