A. General Part
A.1. Collection and Processing of User Data
In the context of the availability of the website hosted at https://www.enatur.pt (“Site”) and the information and means of contact integrated therein, ENATUR-EMPRESA NACIONAL DE TURISMO S.A., with registered office at Av. Stª Joana Princesa, 12 D 2º, 1700 - 357 Lisboa, with the corporate taxpayer number 500792933, as the personal data controller (hereinafter “ENATUR”), may request and process certain personal data from user.
Personal data is any information of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person (“Data Subject” or “User”). A person who can be identified directly or indirectly is considered identifiable, namely by reference to an identification number or to more specific elements of their physical, physiological, psychological, economic, cultural or social identity.
The present Privacy Policy relates only to the Site, and ENATUR is not responsible for the content or processing of personal data carried out on the websites of third parties whose access links are available on the Site. You should therefore consult the Privacy Policies of those websites to learn more about how your personal data are processed.
A.2. Personal Data Collected
Through this Privacy Policy, ENATUR provides the User with detailed information about the nature of the data collected and about the purpose and treatment that will be carried out in relation to their data.
The personal data collected and processed include information regarding the name, e-mail address and telephone number (this data is optional), and there is also an open field in which the User is allowed to enter the information he wishes.
ENATUR may collect your personal data through cookies and other tracking technologies. The use of cookies by ENATUR is regulated in the chapter D.
A.3. Data Processors and Data Sharing with Third Parties
As part of the processing of the User’s personal data, ENATUR uses or may use third parties, subcontracted by it, so that, on behalf of ENATUR, and in accordance with the instructions given by it, they process the User’s data. User, in strict compliance with the provisions of the General Regulation on Data Protection (hereinafter, “RGPD”) and the GDPR Enforcement Law (Law No. 58/2019 8th of August), as well as this Privacy Policy.
Any subcontracted entity in this scope may not transmit the Data Subject’s data to other entities without ENATUR having previously given written authorization to do so, being also prevented from contracting other entities without prior authorization from ENATUR.
ENATUR undertakes to subcontract only entities that present sufficient guarantees for the execution of the appropriate technical and organizational measures, in order to ensure the defense of the User’s rights. All entities subcontracted by ENATUR are bound by the latter through a written contract which regulates, in particular, the object and duration of the treatment, the nature and purpose of the treatment, the type of personal data, the categories of data subjects. and the rights and obligations of the Parties.
A.4. Data Collection Channels
ENATUR may collect data directly, that is, directly from the Data Subject.
B. General Principles Applicable To The Processing Of Data Holder’s Data
In terms of general principles regarding the processing of your personal data, ENATUR undertakes to ensure that the User’s data processed by it is:
- Object of a lawful, fair and transparent treatment in relation to the User;
- Collected for specific, explicit and legitimate purposes, not being further processed in a way that is incompatible with those purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and updated whenever necessary, with all appropriate measures being taken so that inaccurate data, taking into account the purposes for which they are processed, are erased or rectified without delay;
- Kept in a way that allows the identification of the User only for the period necessary for the purposes for which the data are processed;
- Processed in a way that guarantees their safety, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, with appropriate technical or organizational measures being adopted.
The data processing carried out by ENATUR is carried out in this case based on your consent to contact and legitimate interest to collect cookies.
ENATUR undertakes to ensure that the processing of the User’s data is only carried out under the conditions listed above and with respect for the aforementioned principles.
Your personal data will be stored for one year after its collection.
B.1. Use And Purposes Of User Data Processing
In general terms, ENATUR uses your data for the following purposes:
- Provide information to the User, as requested in Site;
- Management of contacts with the User;
- Ensuring that the Site meets the User’s needs.
B.2. Technical, Organizational and Safety Measures Implemented
To ensure the security of the User’s data and maximum confidentiality, ENATUR processes the information provided to us in an absolutely confidential manner, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated according to needs, as well as, in accordance with the legally prescribed terms and conditions.
Depending on the nature, scope, context and purposes of data processing, as well as the risks arising from the processing to the User’s rights and freedoms, ENATUR undertakes to apply, both when defining the means of processing and at the time of processing itself, the necessary and appropriate technical and organizational measures for the protection of the User’s data and compliance with legal requirements.
It also undertakes to ensure that, by default, only the data necessary for each specific purpose of the processing are processed and that such data are not made available without human intervention to an indefinite number of people.
In terms of general measures, ENATUR adopts the following:
- Regular audits in order to assess the effectiveness of the technical and organizational measures implemented;
- Sensitization and training of personnel involved in data processing operations;
- Pseudonymization and encryption of Personal Data;
- Mechanisms capable of ensuring the permanent confidentiality, availability and resilience of information systems;
- Mechanisms that ensure the restoration of information systems and access to Personal Data in a timely manner in the event of a physical or technical incident.
B.3. Data Transfers To Third Countries
The processing operations associated with the Data Subject’s interaction with the Website will not imply the transfer of data or the processing of the same outside the European Economic Area.
C. Rights Of Users (Data Subjects)
C.1. Procedures For The Exercise Of Rights By The User
The right of access, the right of rectification, the right of erasure, the right of limitation, the right of portability and the right of opposition can be exercised by the User by contacting ENATUR, through the contact with the Data Protection Officer of ENATUR, through the e-mail dpo@enatur.pt
When the processing of the User’s personal data is carried out by ENATUR based on the User’s consent, the User has the right to withdraw his consent at any time. The withdrawal of consent, however, does not compromise the lawfulness of the processing carried out by ENATUR based on the consent previously given by the User.
The table below contains a brief summary of the rights of Holders, as referred to in the paragraphs above.
Right of access:
You will be able to obtain confirmation that the personal data concerning you are being processed, as well as access to them, being made available, if you require, and there are no legal restrictions, a copy of the personal data being processed.
Right of rectification:
You may request the rectification of your personal data that are inaccurate as well as that your incomplete personal data be completed.
Right to erasure:
Under the terms of the law, you can also, at any time, request the deletion of your personal data. ENATUR may refuse to grant your request in certain situations, namely when the data is still necessary for the purpose that motivated the collection or the processing is required to fulfill a legal obligation.
Right to limitation of treatment:
The Data Subject may obtain the limitation of treatment when: a) contest the accuracy of the personal data; b) the treatment is unlawful and the holder requests the limitation as an alternative to erasure; c) ENATUR no longer needs the data for the original purpose, these being required by the holder for the purposes of declaring, exercising or defending a right in a judicial process and; d) when the Data Subject has opposed the processing, until it is ascertained whether the legitimate interests of the person in charge prevail over those of the data subject.
Right to data portability:
When the basis for the treatment is the consent or the execution of the contract and there is treatment by automated means, the Data Subject has the right to request the portability of his data. This right cannot, however, prejudice the rights and freedoms of third parties.
Right of opposition:
When the data are processed on the basis of legitimate interests or public interest, or when the data are processed for the purpose of direct marketing, the data subject has the right to object to the treatment.
Right to withdraw consent:
When consent is the legal basis for the processing of data, you are guaranteed the right to withdraw your consent at any time. This does not, however, invalidate the lawfulness of the processing carried out until that date based on the consent previously given.
ENATUR will respond in writing (including by electronic means) to the User’s request without undue delay and, in any case, within a maximum period of one month from the receipt of the request, except in cases of special complexity or due to number of requests, where this period can be extended by up to two more months.
If the requests made by the User are manifestly unfounded or excessive, namely due to their repetitive nature, ENATUR reserves the right to charge administrative costs or refuse to comply with the request.
Without prejudice to any other administrative or judicial remedy, the Data Subject has the right to submit a complaint to the National Data Protection Commission or to another competent control authority under the law, if he considers that his data are not subject to lawful treatment by the ENATUR, under the terms of applicable legislation and this Policy.
C.2. Personal Data Violations
In the event of a data breach (data breach) and to the extent that such breach is likely to entail a high risk for the User’s rights and freedoms, ENATUR undertakes to report the breach of personal data to the Control Authority within 72 hours of becoming aware of the incident.
Additionally, ENATUR will notify the User of this violation when required by law or when ENATUR deems it relevant. Under legal terms, communication to the User is not required in the following cases:
- If ENATUR has applied adequate protection measures, both technical and organizational, and these measures have been applied to the personal data affected by the personal data breach, especially measures that make the personal data incomprehensible to any person not authorized to access such data, such as encryption;
- If ENATUR has taken subsequent measures to ensure that the high risk to the User’s rights and freedoms is no longer likely to materialise; or
- If the communication to the User implies a disproportionate effort for ENATUR. In this case, ENATUR will make a public communication or take a similar measure through which the User will be informed.
D. Cookies
D.1. What Are Cookies?
The Cookies are small information files, usually in .html format, stored by a website on your device (computer, laptop, smartphone, tablet, etc)
You may automatically delete or set to block Cookies that are strictly necessary, as explained in the instructions under point D.4 (Security, Control and Blocking of Cookie).
D.2. What Are Cookies Used For?
Cookies may be used to ensure the functioning of certain essential features of websites, to increase their efficiency and to enable owners to collect information and preferences of users.
The Site's specific use of Cookies is described in section D.3 below.
D.3. For What Purposes Do We Use Cookies?
Regarding to the categories of Cookies used on the website, there are only cookies that are strictly necessary for the operation of the website. Without these cookies it will not possible to ensure the basic functionalities of the website and/or offer you access to functions that you expressly request from us. As such, these cookies cannot be disabled on our systems. These cookies may be used to give you access to functions such as ensuring your security while browsing the Website. You may set your browser to block or alert you about these cookies, but this may affect the operation/functioning of the website.
Specifically, we use the following cookie, with the following characteristics:
- Cookie Name: AceitacaoPoliticaPrivacidade
- Responsible Entity: ENATUR-EMPRESA NACIONAL DE TURISMO S.A.
- Category: Functional
- Description: Preferred language storage
- Duration: 6 months
- Access or sharing with third parties: No
D.4. Security, Management and Blocking of Cookies
Most internet browsers make it possible to control Cookies by managing their settings, allowing users to view the Cookies hosted, as well as to delete them immediately.You may also amend your browser settings to block the installation of new cookies or to be notified each time a Cookie is placed on your device.
- For further information on the “Private Browsing” function and Cookie management in the Google Chrome browser, click here;
- For further information on the “Private Browsing” function and Cookie management in the Microsoft Edge, click here;
- For further information on the “Private Browsing” function and Cookie management in the Mozilla Firefox, click here;
- For further information on the “Private Browsing” function and Cookie management in the Internet Explorer, cli here;
- For further information on the “Private Browsing” function and Cookie management in the Opera, click here;
- For further information on the “Private Browsing” function and Cookie management in the Safari, click aqui.
The User should be aware that disabling Cookies through their browsers settings may have an impact on the functioning of the website, as most browsers do not offer a settings panel with sufficient detail to allow you to move away only Cookies that are not strictly necessary to ensure the essential functions of the websites that you visit. On equipment offering this type of functionality, the user may be able to obtain greater control over the cookies that are installed through free extensions available online.
E. Final Part
E.1. Questions
In case of doubts or questions regarding the way in which ENATUR processes your personal data, please contact your Data Protection Officer at dpo@enatur.pt.
You can also contact ENATUR directly through the forms available on the website.
E.2. Applicable Law and Jurisdiction
1. The Privacy Policy, as well as the collection, processing or transmission of User data, are governed by the provisions of the RGPD and by the legislation and regulations applicable in Portugal, in particular the RGPD Enforcement Law.
2. Any disputes arising from the validity, interpretation or execution of the Privacy Policy, or that are related to the collection, processing or transmission of User data, must be submitted exclusively to the jurisdiction of the judicial courts of the jurisdiction of the district where the ENATUR’s headquarters are located. (Judicial Court of the District of Lisbon), without prejudice to the mandatory legal rules applicable.
E.3. Changes to the Privacy Policy
ENATUR reserves the right to change this Privacy Policy at any time. In case of modification of the Privacy Policy, the date of the last modification, available at the top of this page, is also updated. If the change is substantial, a notice will be posted on the Site.
January 1, 2022