Manager and Owner responsible for Personal Data Processing

Paulo Fonseca
Sitio da Jardina, 8005-494 Faro
+351 917 771 247
info[at]conciergepaulofonseca.com

Concierge Paulo Fonseca is committed to protecting and guaranteeing the security of its clients’ information and privacy.

This Privacy Policy aims to inform you of the general privacy rules and the terms of processing the data we collect, in strict respect and compliance with applicable legislation in this context, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 “General Data Protection Regulation” or in its abbreviated acronym “GDPR”.

Data Collection and Processing
This Privacy Policy applies to all personal information collected and stored by conciergepaulofonseca.com in paper and/or digital formats.

Personal data voluntarily provided by its owner, and whose processing is a contractual and/or legal obligation of Concierge Paulo Fonseca, is treated confidentially by duly authorized employees or subcontractors, who must follow the specific instructions of Concierge Paulo Fonseca.

Your data may be collected directly when you fill out the contact forms available on our website for information and/or service requests.

The personal data we collect are: name, email, telephone or mobile phone number, and other supplementary information not classified as personal.

When browsing the website, whenever identification and collection of personal data is necessary, the user will have to authorize its collection through authorization mechanisms that may vary depending on the case, but which will be clear in their purpose and intuitive in their use. For example, in a contact form, there is a checkbox that the user must click to indicate that they authorize the collection and processing of the personal data entered in the form and subsequent contact by Concierge Paulo Fonseca. However, it should be made clear that without authorization for the processing of your data, you will not be able to send your message or contact Concierge Paulo Fonseca through the website.

Once authorized, the processing of personal data will be carried out in accordance with this Privacy Policy, and your authorization implies that you have read and understood it.

Purposes of Data Collection and Categories
Based on the GDPR (Article 6, paragraph 1, points b), c), d) and f):

Processing is necessary for the performance of a service to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract; for compliance with legal obligations to which Concierge Paulo Fonseca is subject; for the protection of the vital interests of the data subject; For the purposes of the legitimate interests pursued by Concierge Paulo Fonseca.

Regarding the data processing carried out by Concierge Paulo Fonseca in the context of fulfilling legal obligations, the legal basis for carrying out such processing – mostly data communications to external entities – will be the necessity of the processing for the purpose of fulfilling these legal obligations by the controller.

Therefore, we collect your data for:

• Billing
• Service provision
• Compliance with legal obligations
• Responding to information requests, among others

Personal Data Communication
Concierge Paulo Fonseca will implement the necessary and appropriate measures in light of applicable law to ensure the protection of personal data subject to communication, strictly complying with legal provisions regarding the requirements applicable to such communications, especially informing clients.

In cases where Concierge Paulo Fonseca communicates personal data to third parties, it will define clear rules for contracting the processing of personal data with its subcontractors, and will require them to adopt appropriate technical and organizational measures to protect your personal data.

Data may be provided to judicial or administrative authorities, provided that it is in compliance with legal obligations, as well as communicated to public and private bodies related to the activity of Concierge Paulo Fonseca.

The data, depending on the purpose for which it was collected, may be provided to the following categories of recipients:

• Public entities
• Subcontracted service providers
• Other entities subcontracted by Concierge Paulo Fonseca whose corporate purpose is essential for achieving the purpose for which the data was collected

Retention of Personal Data
Your personal data is kept by Concierge Paulo Fonseca for as long as the existing relationships between this entity and the respective data subjects remain in effect, or for the legal retention period, or for as long as the purpose for which it was collected remains, in order to allow the identification of the data subjects until these relationships or obligations have definitively ceased. The collected data will be destroyed at the end of its legal retention period.

The period of time during which the data is stored and maintained varies according to the purpose for which the information is used. There are, however, legal requirements that require data to be kept for a certain period of time. Security Measures

Concierge Paulo Fonseca is committed to ensuring the confidentiality, protection, and security of its clients’ personal data through the implementation of appropriate technical and organizational measures to protect their data against any form of improper or illegitimate processing and against any accidental loss or destruction of such data. To this end, we have created procedures to prevent unauthorized access, accidental loss, and/or destruction of personal data, committing ourselves to respecting the legislation relating to the protection of clients’ personal data and to processing this data only for the purposes for which it was collected, as well as ensuring that this data is processed with adequate levels of security and confidentiality.

Your personal data will be accessed only to those who need to know it in the performance of their duties, strictly to the extent necessary for the achievement of the processing purposes.

Among the cases in which administrative staff have access to your data and other special categories of data are the processing of data for the purpose of billing for services rendered to you or for managing your requests for information or complaints.

Concierge Paulo Fonseca is not responsible for the data that the user makes available on social networks. The use of Concierge Paulo Fonseca’s social networks may involve the transmission of data to social network service providers, which may be located outside the European Union or the European Economic Area.

Information Storage
Data will be stored electronically on a server maintained and controlled by Concierge Paulo Fonseca, located in Portugal, and on cloud service providers located in the European Union.

Security is always monitored in terms of infrastructure and data access. Access is restricted and protected by various access management and encryption tools, with the aim of preventing unauthorized third parties from accessing it. The risk of loss/destruction is thus minimized, but not eliminated, and there is always the possibility of illegal access to the data. In this case, measures to contain the leak will be implemented by the web service provider.

Data Subject Rights
Right to information – at the time of collection or processing, the data subject has the right to be informed about the purpose of the processing, the data controller, entities to which their data may be communicated, conditions of access and rectification, and which data is mandatory and optional.

Right of access – the holder of personal data has the right to access their personal data without restrictions or delays, as well as to know what information is available about the origin of the data, purposes of processing, and communication of the same to third-party entities.

Right to rectification – the holder has the right to demand that their data be accurate and up-to-date, and may at any time request its rectification from the data controller.

Right to erasure – the data subject has the right to have their data no longer processed, erased and deleted, under certain conditions, in the case of:

• They are no longer necessary for the purpose for which they were collected
• Data subjects withdraw their consent or object to the processing of the same
• If the data processing does not comply with legal provisions
• Right to restriction of processing – the data subject has the right to have their data limited only to what is essential for the purpose of the processing

Right to data portability (data transfer) – the data subject has the right to receive their data or to request its transmission to another entity that becomes the new controller of their personal data (only if technically possible).

Right to object – the data subject has the right to object, upon request and free of charge, to the processing of their personal data for direct marketing purposes or any other form of prospecting, and to the communication of their personal data to third parties, unless otherwise provided by law.

Right not to be subject to automated decisions or profiling – As a data subject, you have the right not to be subject to any decision taken solely on the basis of automated processing, including profiling.

Right to be informed of a data breach – the data subject has the right to be informed if there is any security breach that compromises their data.

Right to lodge a complaint with a supervisory authority – the data subject has the right to lodge a complaint not only with the company’s data controller, but also with the supervisory authority, the National Data Protection Commission (CNPD).

You also have the right to withdraw or change, at any time, the consent you have given us to use your personal data, when it has legitimized the use thereof.

Obligations of Entities Involved in Data Processing
Each entity involved in processing your data is obliged to comply with applicable data protection legislation, particularly regarding the security and confidentiality of its processing.

Those responsible for processing Personal Data, as well as those who, in the exercise of their functions, become aware of it, are bound by professional secrecy, as required by law.

Data Protection Officer Contact
Paulo Fonseca
Sitio da Jardina, 8005-494 Faro
+351 917 771 247
info[at]conciergepaulofonseca.com

If you have any questions or wish to unsubscribe from the Concierge Paulo Fonseca database at any time, you may exercise this right by contacting us using the means described above.

Paulo Fonseca Concierge reserves the right to modify or update this Privacy Policy at any time,
and such changes will be duly published on this page.