At Herdade do Pinheiro (hereinafter also referred to as “the Company”), we care deeply about personal data privacy and safety of our guests and other partners.
This policy applies to the company's information system including all related systems, people and processes. The company management is fully committed to ensure that your privacy is protected. This commitment extends to all our staff, customers and partners. Herdade do Pinheiro promotes personal data protection and information security for all data collected.
We respect your privacy in the processing of your personal data. We further reiterate our commitment by implementing complying measures with legislation, particularly to ensure:
a) The lawful processing of personal data, supported by a legal framework and the legitimate interest or consent of the data subject;
b) That processing is limited to the purpose for which the data was made available;
c) That mechanisms are put in place in order to ensure the accuracy and completeness of the data available;
d) That the data required is minimised, requesting only data that is necessary for the intended purpose;
e) That the time limit on data storage in accordance with the retention periods;
f) That information integrity and confidentiality measures are in place.
The company is continuously improving its compliance procedures, for the existing information systems, grounded on the principals outlined above on the General Data Protection Regulation (GDPR).
The constant improvement includes prior Data Protection Impact Assessment (DPIA) procedures and implementation of measures for privacy in future data processing.
To learn more about how we collect, use, share and protect your personal information, please see the following sections of this Privacy Policy.
Herdade do Pinheiro S.A., is a legal entity whose focus is the managemed of the property located in Herdade do Pinheiro, Parish of Santa Maria do Castelo, 7580-313 Alcácer do Sal, Portugal.
Herdade do Pinheiro is responsible for its guests personal data treatment. In order to have a client centered approach the following data categories are collected:
a) Identification data (for example name, tax identification number);
b) Contact details (e.g. address, mobile phone, email)
c) Financial data (e.g. IBAN)
d) Insurance data (e.g. personal insurance data);
e) Image data (e.g. cctv image)
f) Curricular data (for job candidates)
Personal data is processed for the purposes presented in the table below, where we can also find the related treatment fundamentals.
The data storage period is limited to the strictly necessary period of pursuing the purposes, according to the storage period (or criteria adopted to define them) as indicated in the table below.
It may occur that Herdade do Pinheiro will keep personal data for larger periods than the contractual relationship. This will occur ground whether in the client's consent, or in order to ensure rights or duties related to the contract, or even if there are legitimate interests that justifies.
In any of these cases, the period strictly necessary to carry out the respective purposes will always be applied, considering the guidelines and decisions of the National Data Protection Commission (CNPD).
| Processing Purpose | Data Category | Lawfulness of Processing | Storage Period |
|---|---|---|---|
| Financial management (Contracts, Orders, Billing, Collections, Receipts, Payments and Accounting Records) | Personal Identification data; Personal Contact details data; Demographic data; Personal Financial data |
Pre-contractual arrangements, execution of a contract and post-contractual arrangements within the service provision | As long the contractual relationship lasts. The period might be longer in order to ensure legal obligation fulfillment of related rights or duties or in case of pending legal proceedings. |
| Legal obligations compliance namely with the supervision, tax, social security or administrative authorities among other | Personal Identification data; Personal Contact details data; Demographic data; Personal Financial data; Tax or financial foreclosure data |
Legal obligation. Declaration, exercise or defense of rights in judicial proceedings. |
Legal term applicable to each legal obligation fulfillment. Until the prescription period or the exercise of rights are expired. |
| Commercial and operational management (for example production and commercialization of cattle, horses, forest products, agriculture, activities in the nature protected area and in the bird’s sanctuary) | Personal Identification data; Personal Contact details data; Personal Financial data |
Pre-contractual arrangements, execution of a contract and post-contractual arrangements within the service provision | As long the contractual relationship lasts. The period might be longer to in order to ensure legal obligation fulfillment of related rights or duties or in case of pending legal proceedings. |
| Safety of people and assets (video collection through CCTV circuit) | Image data | Legitimate interest | 30 days |
| Recruitment process (Curriculum Vitae collection and spontaneous applications) | Personal Identification data; Personal Contact details data; Demographic data; Curricular data; |
Pre-contractual arrangements, execution and/or data subject consent to assess the profile and skills of the candidate for the job and to keep the data for future job offers. | Up to 1 year from the date of data collection. Except for the necessary data to comply with Article 32 of the Portuguese Labor Code, which will be stored for 5 years. |
The company may have to communicate your personal data, or give access to it, to third parties, in order to comply with its obligation and to provide you a quality service.
In these cases, Herdade do Pinheiro will only transmit your personal data to the following recipients categories:
a) Entities and authorities to whom there is a legal obligation to communicate personal data (Tax Authority, Social Security, courts, police authorities, insurers companies, enforcement agents, and other);
b) Company subcontractors responsible for personal data processing (accounting, IT services, insurance, law firms, internet and communications services)
For the convenience of its users and to provide an efficient client centered service, it is necessary to memorize and store information on how this website should be used. When accessing our website, various information is collected such as your IP address, the browser type version, the operating system, domains and the time you access.
The collected data is used only for statistical purposes, in order to improve the way we present our content to the users. For more detailed information on cookies and their operation please consult our Cookies Policy available on the website.
Staff, customers and partners and other data subjects have the following rights:
6.1. Right of Access
You may request information, at any time, about how your personal data is processed by Herdade do Pinheiro. You may also access your personal data, as well as obtain the following information:
• The purposes for which your personal data is processed;
• The type of personal data that is processed;
• The third parties your personal data may have been shared with, including EU institutions or international organizations;
• The period of retention for your data or, if this is not possible, the criteria used to define this period;
• If personal data has not been collected from you, information about how it was collected, and the type of data stored;
6.2. Right of Rectification
If you believe that your personal information (provided by you) is incomplete or incorrect. (e.g. address, TIN, contacts), you may request that it be completed or corrected.
6.3. Right to Erasure
In certain circumstances, the data subject may request their personal data deletion. Herdade do Pinheiro will inform you whether, or not, this right can be applied, as retention obligations due to legal regulations or legitimate interest may prevent them from being able to do so.
6.4. Right to Restriction of Processing
The right to restriction of processing of your personal data allows you to ask Herdade do Pinheiro to restrict the scope of access and processing of your personal data or to block the processing altogether.
You can request the processing restriction of your personal data in the following cases:
• If you question the accuracy of your personal data, for a period that allows Herdade do Pinheiro to verify its accuracy;
• If Herdade do Pinheiro no longer needs the personal data for processing purposes, but if such data is necessary for the purposes of declaration, exercise or defense of a right in legal proceedings.
6.5. Right to Data Portability
You may request to Herdade do Pinheiro to send you the personal information you provide in a format that is structured, relevant and machine-readable. You also have the right to ask Herdade do Pinheiro to pass this information on to another party responsible for processing it, as long as they are technically able to do so.
The right to portability only applies in the following cases:
• Where processing is based on explicit consent or the signing of a contract;
• Where the processing in question is carried out automatically.
6.6. Right to Object to Processing
You have the right to object to the processing of your personal data at any time on grounds relating to your particular circumstances, and where the processing is performed for purposes other than those for which the data has been collected, but that the data is compatible with.
In such cases, Herdade do Pinheiro cease to process your personal data, unless the company has compelling legitimate grounds for the processing, which prevail over your interests.
The exercise of the right to object may entail in the suspension or termination, in whole or in part, of the related data-base benefits.
6.7. Right to Withdraw Consent
When your personal data is processed grounded in your consent, you have the right to withdraw your consent at any time.
If you withdraw your consent, your personal data will no longer be processed, unless on other
lawfulness foundation, such as compliance with legal and regulatory obligations, which justifies such processing.
The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
6.8. The Right to Complain to Herdade do Pinheiro or any Supervisory Authority
You may exercise your rights free of charge, unless the application is manifestly unfounded or excessive. In such cases a reasonable fee may be charged to cover any costs incurred. Replies to requests will be made within a maximum period of 30 days. For exceptionally complex requests this period may be longer.
To lodge a complaint, you may contact Herdade do Pinheiro at geral@herdadedopinheiro.com.
If you wish to file a complaint regarding matters related to the processing of your personal data, you may do so at the National Commission for Data Protection (CNPD), the Portuguese Data Protection Authority (www.cnpd.pt).
Herdade do Pinheiro may change this Privacy Policy over time to reflect its current privacy practices. Along with any changes to this statement, the "last updated" date in the footer of the document is also updated.
We encourage you to regularly read this Privacy Policy to stay updated and always aware of how is Herdade do Pinheiro protecting your information.