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PRIVACY POLICY

 

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Privacy Policy

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Machado & Mendanha Lda. (hereinafter “Smartrack Tours”) with registered office at Praceta Maria Clementina Borges de Sá, Nº1, 2º esquerdo, 8005-547, Faro, holder of the RNAVT nº 7064 is committed to protecting the privacy of your personal data (hereinafter “data”) and, therefore, undertake to process and guarantee the security of such data in accordance with the personal data protection legislation in force, and, in particular, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation - “GDPR”. This Privacy Policy aims to make known how Smartrack Tours treats your data and your rights as the data owner.
Any data made available to Smartrack Tours will be understood as obtained, processed and transmitted in strict observation and in full compliance with the requirements established in the GDPR and legislation in force.
 
Data Protection Office and Data Protection Officer:
In accordance with the provisions of the GDPR, Smartrack Tours acts as the entity responsible for processing your data. To obtain any clarification related to this Privacy Policy or the treatment of your data, you can contact the Smartrack Tours through:
 
Machado & Mendanha Lda 
Praceta Maria Clementina Borges de Sá, Nº1, 2º esquerdo, 8005-547, Faro

 

Type of personal data, Purposes and Grounds for Processing:
This policy covers the online and offline data collection activities of Smartrack Tours, including data it collects through various channels, such as brand websites, agencies and events / fairs in which Smartrack Tours participates.

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 Smartrack Tours collects and processes your data for a number of purposes:

• Reservation or purchase of services: There is a set of data that must necessarily be collected, so that Smartrack Tours can organize and provide the requested service (including sending the booking confirmation and travel documents), as well as for manage any complaints related to the reservation or purchase of services, such as name, date of birth, identification document details, address, mobile or telephone number, e-mail address -mail, data on travel preferences, data on interests, reason and complaint details, special occasions and special requests. The basis for collecting this data is the management of the contractual relationship and the legitimate interest of Smartrack Tours.

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In order to obtain a visa, Smartrack Tours may have the need to collect certain types of data requested by the issuing entities, those strictly necessary for the issue, such as: passport data, vaccination bulletin and data relating to the criminal record for compliance with legal obligation of certain countries of destination. The basis for the collection of this data is the fulfillment of a legal obligation.
 
• Conducting satisfaction surveys: in order to assess your level of satisfaction with the services provided, Smartrack Tours will be able to send you quality surveys. Customers are not obliged to respond to these quality surveys, which aim to collect opinions about the services provided, in order to improve / develop them. The foundation of the processing of these data is the legitimate interest of Smartrack Tours in continuously improving the quality of its services.
 
• Management and administration: the data collected so that Smartrack Tours can fulfill their accounting / tax obligations and of a legal and administrative nature, typically include their name, address and Tax Identification Number. The basis for the processing of these data is the fulfillment of a legal obligation and the legitimate interest of Smartrack Tours in managing the relationship with the client.
 
• Commercial and promotional communications: Smartrack Tours collects data such as name, telephone or mobile phone number and e-mail address, in order to provide you with information on services that may be of interest to you (for example, marketing communications or campaigns and promotions), collecting your consent when necessary. At any time, you may object to the processing of your data for these purposes, as stipulated in the paragraph below “Exercise of your Rights”. The basis for the processing of these data is the legitimate interest of Smartrack Tours or, when requested, its consent.
 
• Management of hobbies or promotional events: the data collected so that the Smartrack Tours can consider and manage your participation in a given hobby or promotional event, are in general the name, address, mobile or telephone number and e-mail address . For more information on the hobbies and other promotions, you can consult the regulations or terms and conditions included in each hobby / promotion. The basis for the processing of your data is your consent.
 

• Management of activities program, in golf, running, snow, motorcycles and other sports, the Smartrack Tours proposes complete travel programs, so that people can participate in sports events and experiences, which include, namely services transport, accommodation and access to the events, with your personal data being treated in particular for sending budgets, managing the registration of participants  and sports events held or promoted by third parties or by the Smartrack Tours itself, including the organization of travel and provision of the requested services, based on the execution of the contractual relationship with us and in our legitimate interest. Your data will also be processed to inform you of news, promotions, campaigns and other opportunities that, as a participant, you can benefit from, based on our legitimate interest or your consent, if you are not yet our customer. When participating in a tournament or golf event, your data can be used to participate in a draw for that event. The personal data processed for the purposes of the “Active Tourism” program are namely the following:

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- Name, address, nationality, gender, date of birth, FPG license number (Portuguese Golf Federation), handicap, certified by the Club, mobile phone, Tax Identification Number, e-mail address and polo size.

- In order to request a quote, the name, e-mail address, telephone or mobile phone, travel dates and age of minors, if any.
 
• Organization of congresses and events, namely to manage the registration / registration of participants, accreditation, management of the respective accommodation and management of spaces, your identification data will be collected, namely the name, telephone and email address, name of the institution where you work / study, user name and password created for online registration, personal data required for billing, namely the Tax Identification Number and address, data on other services requested, namely hotels, transfers and meals. The basis for collecting this data is the management of the contractual relationship and the legitimate interest of Smartrack Tours.

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Video surveillance: With regard to the video surveillance system through closed-circuit television, implemented in some installations and properly marked, its image may be captured by the cameras mentioned above. The purpose of the aforementioned video surveillance cameras is to guarantee the safety of people and property, and this image capture is carried out based on a legitimate interest of Smartrack Tours, in the exercise of public interest functions or for the fulfillment of a legal obligation.

Provision of personal data:
Within the scope of your reservation and / or purchase, Smartrack Tours may assign your data:

 
I. Service providers (such as airlines, hotels, rent-a-car companies, operators, insurance companies), so that they use them for the purpose of correctly providing each requested service (in this case) case, the data will only be used for that specific purpose) and to comply with the legislation of the destination countries;
 
II. Government authorities (eg, immigration, border control, public security and security and anti-terrorism entities).

In the scope of merger, acquisition and / or incorporation processes in which it finds itself, when such a transfer is necessary within the scope of legitimate interests of Smartrack Tours or third parties to whom the data are communicated. The processing of your personal data may also be carried out by service providers, acting on behalf of Smartrack Tours, namely marketing and digital and social media agencies, accounting management services, auditors and lawyers, external entities that provide technological services, such as suppliers of computer platforms, hosting services, maintenance and assistance of our databases.

 

International Data Transfers:
Depending on the destination to which you are traveling, Smartrack Tours may need to transfer

your data to service providers, inside or outside the European Union (provided that such

transfer is essential for the execution / provision of the service).
Any transfer of personal data to a third country will only be carried out as part of the fulfillment

of legal obligations or provided that compliance with the applicable Community and national legal

rules in this matter is guaranteed.
 
 
Minor data:
Minority data is collected and processed with the consent of the parent or legal guardian.

Regarding this data, parents or legal guardians can exercise the rights that the GDPR grants to

data subjects.

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Retention period of personal data:
Your data is kept by Smartrack Tours for the period strictly necessary to fulfill the

aforementioned purposes, except when there are conservation obligations imposed by

applicable law, or legitimate interest, which require the maintenance of your personal data for a

longer period.
 
 
Personal Data Security Measures:
Smartrack Tours uses appropriate security measures to protect your data, including appropriate technical and organizational measures to protect them against abusive or illegal treatment and against accidental loss, damage or destruction.
The data are processed by employees of Smartrack Tours or by the authorized service providers, accessing only the data strictly necessary, depending on the specific purposes for which the data were collected.
 
Exercise of your Rights:
As the data owner, you can exercise the following rights, within the legally established limits:

i. Access to personal data [When submitting an access request, you will be provided with access and details about the personal data processed by Smartrack Tours.]
 
ii. Correction of personal data [If your personal data is incomplete or incorrect, you can request the correction of it.]
 
iii. Right to be forgotten [When exercising its right to be forgotten, Smartrack Tours will, if applicable, erase your personal data.]
 
iv. Personal data portability [When requesting the portability of your personal data, you will receive, in an automatic reading format, the personal data you have provided and which are processed based on your consent or the performance of a contract.]
 
v. Opposition to the processing of personal data [For reasons related to your particular situation, you have the right to object to the processing of your personal data by Smartrack Tours based on legitimate interest or in relation to direct marketing.
 
vi. Revocation of consent to treatment [If you revoke your consent, Smartrack Tours will remove your consent from the activity you specify].

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The exercise of these rights depends on a written request (including a copy of a document proving the client's identity and mention of the right or rights you wish to exercise), to be sent in one of the following ways:

 
Mail: Machado & Mendanha Lda. - Praceta Maria Clementina Borges de Sá, Nº1, 2º esquerdo, 8005-547, Faro
Email: info@smartrack.pt

 

After sending the request with the necessary information, Smartrack Tours will respond within one to two months, taking into account the complexity and the number of requests.
 
Supervisory Authority:
If you believe that there is a problem with the way the Smartrack Tours is processing your data, you have the right to file a complaint with the national supervisory authority (Comissão Nacional de Proteção de Dados – CNPD) em www.cnpd.pt ).

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Information on the use of Cookies:
See our Cookie Policy, on our websites, to find out how you can manage your cookie settings and for detailed information about the cookies that Smartrack Tours uses, as well as the purposes of their use. For more information on the Cookie Policy, please click here.
 
 
Changes to the Privacy Policy:
Smartrack Tours reserves the right, at any time, to make changes or updates to this Privacy Policy, these changes being duly updated on our platforms and websites. Check regularly to check for any updates or changes to this policy.
 
 
 
Last updated: June 12, 2019

 

 

 

 

 

 

Email: dpo@viagensabreu.pt