Privacy Policy

Privacy policy

 

The confidentiality of our customers’ personal information is fundamental and a commitment of San Lorenzo.
San Lorenzo complies with the General Data Protection Regulation (EU) 2016/679.

  1. Data Privacy Policy

For San Lorenzo, the privacy and security of its customers’ personal data are a priority.
With the exception of the circumstances described in this privacy policy, San Lorenzo does not share personal information with third parties.
The Group adopts principles, policies, and procedures consistent with its values; in accordance with the standards and strategies it has been implementing, which meet the requirements of the General Data Protection Regulation 2016/679.
Information provided by users and customers is stored and processed to allow us to provide our services and sell products appropriately, always according to legal requirements.
All processing of personal data is done with the consent of its owner.
These principles are scrupulously fulfilled by all Group employees, according to the internal Code of Conduct .
All Group employees who handle personal data as part of their activities are individually responsible for complying with applicable legal and regulatory provisions.

  1. Data Controller

    The entity responsible for collecting Personal Data is Força e Autenticidade, S.A., a public limited company with headquarters at Av. Alm. Gago Coutinho, Nr. 30 Piso 0 2000-017 – Lisboa, Portugal, register with the unique registration and corporate tax number 518 588 785.

  2. What type of personal information we request

There are various circumstances in which personal data is requested from the user of the website www.golfsanlorenzo.pt
The personal data collected and processed consists of information related to the name, email address, physical address, and phone number.
Credit card data is used solely and exclusively for payment processing and is protected by our system.
All collected personal data is used for specific and legitimate purposes, and the owner has been informed of those purposes.

  1. How we use your personal information

Personal data is used solely for reservation processing.
For any other activity, personal data is processed with the prior consent of its owner, notably when used for informing promotions and news from Vilamoura Golf through newsletters; and for statistical marketing analysis for the exclusive use of San Lorenzo.
We also identify technical information from your computer when visiting our site, such as IP (Internet Protocol), operating system, and browser type. We use this information to improve your visit’s quality to our Site and will not disclose it to external entities without your consent.
The Group has no automated decisions or profiling information.

  1. With whom and when we share personal information

Under certain circumstances, and with your consent, we may share personal information with third parties.
Personal data may also be provided to external entities when specifically required by law.
In the context of external authorities, and when information about personal data is requested based on a legal requirement, the transmitted information is limited to what is strictly necessary to achieve the purposes and goals in question.
We do not provide personal data information via telephone to avoid the leak of personal and confidential information.
San Lorenzo reserves the right to transmit any personal data in the event of the sale or transfer of part or all of its company or respective assets, without compromising the confidentiality of the concerned personal data and interests of the data subjects.

  1. How we protect your personal information

We have implemented security measures throughout the organization, namely through the creation of files and databases with restricted access, to ensure that data subjects’ personal data does not suffer any violation, disclosure, or misuse.
To guarantee the security of personal data and maximum confidentiality, we treat the information you provided with absolute confidentiality, according to our internal security and confidentiality policies and procedures.
San Lorenzo also adopts other security measures concerning your data’s security:
– Antivirus software providing malware protection;
– Antivirus software providing browser and email protection;
– The business network is protected by a firewall;
– Personal data backups are automatically reinforced;
– Our business Wi-Fi network is password-protected;
– Remote access to our business network is only possible through a VPN (Virtual Private Network);
– Privileged accounts are not used for daily tasks, and access is only possible for privileged users, from dedicated devices limited only to authorized individuals.
– Access to sensitive data is controlled and limited only to those who need to access it.
– Data loss prevention software is used to protect sensitive personal data.
– Procedures to verify, detect, analyze, and report security incidents are developed and communicated within the organization, primarily through frequent contact with the DPO.
– All personal and sensitive data is encrypted.
– Email communications are encrypted.
– Cloud/Network folders are encrypted.
Apart from all adopted measures, the Group closely and periodically monitors all procedures through audits to determine if they are effective and meet GDPR needs.

  1. Use of Cookies

When you visit our website, you will receive a “cookie” (a small package of data sent to the user’s browser) to be stored on your computer’s hard drive. The purpose of cookie use is to identify the user when visiting our website, so we can improve and personalize the online experience.
Most browsers automatically accept these files (Cookies), but you can delete them or set their automatic blocking.
In your browser’s menu, you will find how to configure these settings. You may also explicitly accept or refuse Cookies on the site. However, if you do not allow the use of cookies, you may not be able to use some features.
On this site, we only use session cookies, and these are always temporary. This means they remain in the cookie file only until the user leaves the site and are deleted when the browser is closed.
The information obtained is used to analyze traffic patterns, which helps identify problems.
Regarding the purpose of using these cookies, it is “strictly necessary,” meaning it serves only to allow navigation on the website using secure areas.
The cookie only identifies the user’s device and does not store any personal information.
The information we collect and share is anonymous and not identifiable. It does not contain your name, address, phone number, email address, or any personal data that could identify you.
Some of our business partners (advertisers, for example) use cookies on our site. San Lorenzo does not have access to or control over these cookies. This privacy policy refers only to the use of cookies on the San Lorenzo Golf website and does not cover the use of cookies by any other advertiser or partner.
When you open our site, a bar appears to accept the use of cookies or close the bar. Non-acceptance will not prejudice access to the site.

  1. Email Communications

We do not intend to send you promotions or any type of advertising by email unless you consent to it.
If you choose to receive our newsletters, we may send you information with new promotions and special offers.
You can unsubscribe from our emails at any time through our site or the “unsubscribe” options in the sent emails.

  1. Subcontractors

Regarding personal data processing, we may use third parties, or subcontractors to process personal data on behalf of San Lorenzo, following our instructions.
The processing of personal data by subcontracting companies is strictly in compliance with the law and this Privacy Policy.
These subcontracted entities may not transmit personal data to other entities without San Lorenzo’s prior written authorization, and they are also prohibited from contracting other entities without prior authorization.
We commit only to subcontract entities that provide sufficient guarantees of implementing appropriate technical and organizational measures to ensure the defense of data subject rights.
All subcontracted companies are bound by a Data Processing Agreement regulating the terms of service provision, particularly the obligation to comply with all data protection, security, and confidentiality norms.

  1. Your rights

San Lorenzo establishes procedures aiming to protect and enforce data subject rights.
Some of your rights:

  • Right to access your data, obtaining a copy;
  • Right to have inaccurate personal data rectified;
  • Right to the erasure of personal data, unless otherwise provided by law, and where applicable, to restrict processing;
  • Right to object to data processing based on a particular situation, per the law;
  • Right to request the restriction of personal data processing;
  • Right to data portability;
  • Right to change consent without affecting the lawfulness of processing previously conducted based on consent;
  • Right to be notified in the case of a personal data breach;
  • Right to be notified when information is initially stored using a method distinct from the original;
  • Right not to use personal data for advertising, direct marketing, or other commercial prospecting, nor to communicate it to third parties for these purposes, except with the data subject’s prior consent;
  • Right to complain to any supervisory authority or through the National Data Protection Commission’s website.

  1. Terms

    We retain collected data for the period established by law, concerning legal obligations.

    For storing data not resulting from legal obligations, it’s retained for the period consented by data subjects within commercial relationships.

  2. Data Protection Officer

    For any clarifications regarding our Data Privacy Policy, please contact us via email at dpo@details.net

  3. Changes to the Privacy Policy


To ensure the Data Privacy Policy’s update, San Lorenzo may make changes to this privacy policy.
All changes will be published through appropriate channels.