CONFIDENTIALITY POLICY AND PERSONAL DATA PROCESSING OF 4GTS, LDA.
I- We and our commitment:
4Gts, Lda. is a company incorporated under the form of a limited liability company, which will henceforth be called 4GTS, which is dedicated to the activities of travel agencies.
Taking into account the proportionality and adequacy imposed by the ability to allocate resources and technical means within its reach, 4GTS is deeply and genuinely committed and committed to providing protection to its clients and regular or occasional employees, as well as to the users of our various media and platforms, physical or digital, including paper files, digital files and websites in use or to be implemented, with regard to their privacy and the processing and circulation of their personal data.
II- Our personal data collection devices and media in use:
We dispose, edit and manage the following personal data carriers
– Computer system composed of a set of software solutions supported on a set of hardware devices and other similar solutions, including email services and other external digital repositories and communication solutions.
– Paper files stored in cabinets and shelves in restricted access rooms;
– 4GTS website – www.4-gts.com
III- Personal and material coverage of this Privacy Policy:
This privacy policy is binding on the company and, exclusively with regard to the personal data it collects, processes and circulates.
The same or similar policy will also be assumed, through a contractual agreement entered into with 4GTS, by the entities that process such personal data on its behalf.
The availability through the referred website www.4-gts.com of other access links to other websites not belonging to 4GTS is made in good faith and in the interest of the user, and the user may not be held responsible, in any way whatsoever, for the collection, processing and destination of the data in those websites, nor for the reliability, exactness, lawfulness and functionalities available therein, and therefore this privacy policy shall not apply to them.
4GTS considers it obligatory and will assume for all purposes, without the possibility of proof to the contrary, that it will read the privacy policies of all the websites to which it has access.
IV- The reason for and the publicity of this Privacy Policy:
In addition to implementing it in its organizational processes, 4GTS has drafted this Privacy Policy with the purpose of making available, making known and advertising an instrument explaining the general rules of privacy and treatment of personal data that it collects, always in strict compliance with the relevant legislation.
For this purpose, the text of this Privacy Policy will be available in paper format at our facilities and in digital format at the website www.4-gts.com.
The provisions of this Privacy Policy complement those stipulated in the same matter in the contracts, formal or informal, that those concerned enter into with 4GTS.
Please read this Privacy Policy carefully as the provision of your personal data, either personally or when accessing the website, implies that you are aware of and accept the conditions contained herein and their treatment for the lawful and legitimate purposes established by law.
4GTS expressly reserves the right to change this privacy policy at any time, and the results will be duly advertised by the same means.
V- Concept of personal data:
Personal data shall mean any information or record, of any nature and regardless of the respective medium or format, namely sound, image, written, chiropractor or characteristic, related to an identified or identifiable individual.
An identifiable person is one who can be directly or indirectly identified by reference to one or more specific personal data, considered separately or in combination with each other, including his physical, physiological, mental, economic, ethnic, cultural, geographical, social or local identity.
VI- The entity responsible for processing the personal data:
The entity responsible for the collection and processing of personal data is the 4GTS, which, in the context of its relations with the holder of the personal data, establishes, always on a lawful and legitimate basis, the data collected, the means of processing and the purposes of such collection and processing.
VII- Types of personal data collected and processed:
Within the scope of its activity, 4GTS collects and processes, namely:
- Personal data necessary to provide and/or receive services and/or supply products to its clients and/or their suppliers, processing in this scope data such as name, tax identification number, address, telephone number and e-mail address among others strictly necessary, proportional and lawful.
- Personal data necessary for the performance of the contract of employment or services concluded with its employees, processing in this context data such as name, identification number and other data from it, tax identification number, composition of the household, social security number, address telephone numbers and e-mail address, health data, access, location among others strictly necessary, proportional and lawful.
- Personal data necessary to comply with legal obligations, whether to public entities or to private entities, processing in this context data such as name, identification number and other data, tax identification number, composition of the household, social security number, address(es) telephone numbers and e-mail address, health data among others strictly necessary, proportional and lawful.
- Data required for customer and supplier management,
the contracting and management of the contractual relationship with customers and suppliers,
the adequacy of the provision of services appropriate to the needs and interests of the Customer, including the sending of suggestions, information and marketing actions, making known campaigns, promotions, advertising and news about the services and/or products, the performance of market studies and/or satisfaction surveys, the management of complaints, dealing in this area with telephone number(s) and e-mail address, among others strictly necessary, proportional and lawful.
- All personal data necessary to exercise the rights of 4GTS within the scope of the relations referred to in the preceding items, and in the pursuit of its activity and legitimate interest, including accounting, tax and administrative management, litigation management, judicial evidence, fraud detection, revenue protection and auditing, network and systems management, information security and physical security control, and facility security.
Notwithstanding the compliance with legal rules, or legitimate orders coming from a competent authority, regarding the conservation and transmission of data, 4GTS will only process personal data necessary for its activity, to the fair and strict extent required by the nature of the contractual or other relationship established with the holder of such data, or the latter’s prior, legitimate, lawful and informed consent, if any.
VIII- Time and mode of collection of personal data:
4GTS collects personal data in person, in writing, by telephone, by e-mail or through its website.
As a rule, personal data is collected when the relationship, or collaboration, contractual or of any other nature necessary for the 4GTS to continue its activity, between it and the data subject is initiated.
Our websites may collect contact forms. These will be sent directly to our email server via an encrypted link and will only be available to our contact person. Whenever necessary, the information will be made available to a person in charge of a specific department for resolution of the request.
Some personal data are mandatory and necessary for the commencement and normal and legal development of the said relationship or collaboration, so in the absence or insufficiency of such data, it will not be initiated or continued, in which case 4GTS will inform the holder of the data of such mandatory and necessary nature.
Apart from those of that nature, those included in any public list and those that may be used in the legitimate interest of 4GTS, your data will only be collected and processed if and for the purposes that you have previously freely, informally, specifically and unequivocally consented to, by means of a written or oral statement or by means of the validation of an option, namely for the subscription of newsletters or marketing communications, in which case the other rules of this privacy policy will apply.
If you wish to stop receiving these communications, you may express your opposition at any time.
The data collected will be processed on a documentary basis, either paper or digital, in strict compliance with the legislation governing the protection of personal data, and will be stored and contained in paper files and/or a specific database, created and managed for the purpose and with restricted and exclusive access to 4GTS employees who necessarily have to deal with them in the pursuit of its activity. Under no circumstances shall those collected be used for any purpose other than that for which consent has been given by the owner, if such consent is necessary, or for the lawful and legitimate purpose on which the collection was based.
IX- Purposes of collection and processing of personal data:
In general, the personal data collected aims at the management of clients, suppliers and collaborators, the hiring and management of the contractual relationship with clients, suppliers and collaborators, the receipt and/or the rendering of the contracted services/supplies, the adequacy of the rendering of services/supplies to the client’s needs and interests, the sending of suggestions, the information and marketing actions, the disclosure of campaigns, promotions, publicity and news about the services and/or products, conducting market research and/or satisfaction surveys, complaint management, accounting, tax and administrative management, litigation management, judicial evidence, fraud detection, revenue and audit protection, network and systems management, information security and physical security control, facility security, compliance with legal obligations and for other purposes for which the Law recognizes a legitimate interest to 4GTS.
At the time the data is collected, or when you request it, you will be informed in more detail about how we process your data.
X- Time limits for the storage of your personal data:
Where there is a specific legal requirement to retain data for a minimum period of time, this will be observed by 4GTS.
4GTS will keep your personal data stored for the minimum period of time strictly necessary for the purpose for which the information is collected and processed, after which it will be deleted.
XI- Right of Access, Rectification, Opposition, Deletion, Limitation and Portability of Your Personal Data:
4GTS guarantees to the holder of your personal data the right of access, rectification, opposition, erasure, limitation and portability of your personal data.
These rights may be exercised by calling 253 782 101 or by writing to Rua Óscar Dias Pereira nº40, 4710-081 Gualtar – Braga or electronically info@4-gts.com.
If you consider it pertinent, you may submit a complaint to the National Data Protection Commission – Av. D. Carlos I, 134 – 1.º 1200-651 Lisboa – Tel: +351 213928400 – Fax: +351 213976832 – e-mail: geral@cnpd.pt.
XII- Measures that we adopt with a view to the security of your personal data:
4GTS observes the best practices, for which it adopts the technical and organizational measures appropriate to the risk, in the field of security and protection of personal data, having approved and implemented a demanding plan of compliance with the objectives, the Law and the interest of the holders of personal data, capable of safeguarding the protection of the data made available to us by all those who in any way relate to us, in order to protect them against their dissemination, loss, misuse, alteration, unauthorized treatment or access, as well as any other form of unlawful treatment.
Thus, the form(s) for the collection of digital or paper personal data, whether filled in at the 4GTS physical facilities or at the website (which require encrypted sessions of the Browser) or with any of the 4GTS employees, are stored securely in our physical repositories and digital systems.
All personal data that you give us about you are in a data center of 4GTS itself, or of a subcontractor, under cover of all advanced physical and logistical security measures, which we consider indispensable for the protection of your personal data.
Whenever, in the legitimate and lawful pursuit of the objectives of 4GTS’s activity, it adopts measures to monitor its employees, particularly as regards access control, working hours, tasks and productivity, circulation and transportation, not only will those concerned be informed in advance of the respective implementation – whenever legally necessary and lawful, the respective consent being requested – but the tools used for that purpose will ensure the same level of security of the personal data collected and processed by them.
The aforementioned compliance and security plan includes the existence in office of a designated Personal Data Protection Officer, who is responsible, among other things, for verifying this Privacy Policy, keeping the rules for the treatment of personal data clear and communicating with the control authorities, guaranteeing to all those who entrust 4GTS with the treatment of their personal data, effective knowledge of the way in which it treats them and of their rights in that regard.
XIII- Communication of data to other entities, subcontractors or third parties:
4GTS may use subcontractors for the collection and processing of data, for the same purposes as it seeks, obtaining from such entities by contractual means, reputation guarantee and obligation to develop the appropriate technical and organizational measures for data protection and to ensure the defense of the rights of the holders. In certain circumstances determined by law, certain personal data may have to be communicated to public authorities, such as tax authorities, courts and security forces.
Accordingly, any such sub-contractor will treat our clients’ personal data on behalf of and for the account of 4GTS, under an obligation to take appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access and against any other form of unlawful processing.
XIV- Transfer of personal data:
The continuation of 4GTS activity may imply the transfer of your data outside Portugal.
In such case, 4GTS will strictly comply with the applicable legal provisions, namely as to the determination of the reliability and suitability of the destination country as regards the protection of personal data and the requirements applicable to such transfers.
XV- Cookies:
“Cookies” are small software tags that are stored on your computer through your browser, which as a rule retain only information related to your preferences, not including, as such, your personal data.
Where this is not the case, you will always be asked for your consent to provide them in accordance with the law.