Privacy Policy

This Privacy Policy (”Privacy Policy”) describes how SURFGASM LDA  (RUA DA LAPA NO 14/6 NIF 513812725), process your Personal Data. “Personal Data” is any information with which one can, directly or indirectly, identify a physical person. Please read this Privacy Policy carefully to understand how and for what purposes we process your Personal Data.

We process your Personal Data when you use our services (“Services”) as described below. We care about your privacy and comply with applicable law aiming to protect you as an individual. This Privacy Policy describes the foundation of how we process Personal Data you share with us or that we collect when you use the Services. For some of our Services, specific terms and conditions may apply that you need to accept prior to using the Service.

Different companies partnering with SURFGASM LDA may be either controller or processor, or joint controllers, with regards to the processing we carry out, such as processing necessary for hotel bookings or recruitment.

We aim to maintain a high level of protection of your integrity. SURFGASM LDA processes Personal Data mainly to administer, provide, develop and maintain the Services, handle your bookings, optimise your experience of the Services and to communicate with you.

If we make changes to this Privacy Policy, we will notify you. The means of notification varies depending on what Services you use and when. The new terms will be published on SURFGASM LDA’s documentation.

If you provide us with Personal Data concerning other persons, you are responsible for ensuring that SURFGASM LDA is allowed to process that Personal Data in accordance with this Privacy Policy.

COLLECTION AND PROCESSING OF PERSONAL DATA

SURFGASM LDA only processes your Personal Data in accordance with applicable law.

SURFGASM LDA may collect Personal Data directly from you when you use the Service (for instance when you book a apartment or room). We may also receive and transfer your Personal Data from and to companies within the SURFGASM LDA or our partners (e.g. if you have used a booking platform to book). We use different means to collect your Personal Data, some of which include cookies, web beacons, customer surveys and customer service. Depending on what Service you use the means of collecting and the purpose of processing may vary.

SURFGASM LDA will process your Personal Data for the purposes outlined below, and the purposes described to you when you use a specific Service. When your consent is required by law in order for us to process your Personal Data, we will collect your consent prior to processing.

WHAT PERSONAL DATA DO WE PROCESS AND WHY?

Handle booking 

If you book a room or apartament with us, we will process your Personal Data in order to provide, handle, administer, follow up and obtain payment for your booking. This includes processing in order to remind you or inform you of your booking when you are to stay with us.

You are required to provide the details we request in order for you to handle your reservation. When you book on someone else’s behalf you are responsible in relation to us for having the person’s consent to SURFGASM LDA processing of their Personal Data in accordance with this Privacy Policy.

Your Personal Data and other information about your booking can be transferred to companies within and outside the EU/EEA that operate SURFGASM LDA bookings but that are not part of the SURFGASM LDA, or to our suppliers.

Retention period: 365 days after the end of your stay.

Newsletter and other direct marketing

If you use our Services we may process your Personal Data in order to send you newsletters containing relevant information and offers about our own services, or selected partners’ products and services, through different information channels, such as post, e-mail or our other digital channels, as long as you are our customer. We may also send you customer surveys that give you the opportunity to influence the range of products and services we provide. Our processing of sending you direct marketing and customer surveys are based on our legitimate interest.

If you wish to no longer receive newsletters or other direct marketing from us, you can object to further processing by contacting us (see contact details below) or deregister in the marketing message. If you object to our continued processing, your Personal Data will be deleted or anonymised (unless the Personal Data in question is also processed for other purposes) and you will no longer receive direct marketing from us.

Retention period: As long as you are our customer or before that if you object to further processing.

Processing based on your consent

If you have given us your consent and subscribes to our newsletter we will process your Personal Data in order to send you offers regarding our products and Services. If you wish to no longer receive newsletters or other direct marketing from us you can object to further processing for these purposes by contacting us (see contact details below) or deregister directly in the marketing message. If you object to further processing, your Personal Data will be deleted or anonymised (unless the Personal Data is processed for other purposes) and you will no longer receive direct marketing from us.

Retention period: Until you withdraw your consent to the processing.

Profiling

In order to communicate personalised and relevant information and offers to you about our Services, we analyse the information we collect about you, for instance by dividing customers into different customer categories based on purchase patterns, behavior and interactions with us. We do this in order to improve your experience when you use our Services. The analysis is anonymised and is carried out in an aggregated form. The information from the analysis can never be connected to a specific person.

Retention period: As long as you are our customer or before that if you object to further processing.

Recruitment

If you submit a job or internship application (general or for a specific role) via our website or our other communication channels, we process your Personal Data in order to evaluate your application and recruit staff. This includes, if applicable, references and background checks if part of the recruitment process.

We kindly ask you not to send us any sensitive Personal Data (e.g. information revealing health conditions, race or ethnicity).

If you are offered and accept employment with us, some of the Personal Data we have collected during the recruitment process will form part of your employment contract.

Retention period: Your application is saved throughout the entire recruitment process. If you are not offered a job with us we may save the information we have collected up to 24 months after the recruitment process has finished. General applications are saved up to 12 months from submission, unless a recruitment process has been initiated.

Legal obligations

We may also process your Personal Data if we are compelled to do so by law, court or public authority, e.g. to fulfil our obligations with regards to financial reporting, under tax law or due to a decision by the police department or other authority.

Retention period: In accordance with national law in respective country. 

Handling of customer service inquiries

We may process your Personal Data in order to respond to, assist, follow up and handle your customer service inquiry. This includes communication necessary in order for us to respond to questions you have submitted to us via telephone, e-mail, social media or other communication channel. We may also process your Personal Data in order to handle complaints or support inquiries, including technical support.

Retention period: Twelve months after the customer service inquiry has been closed in order to administer and to follow up on your inquiry.

Development and assessment of our Services, products and systems

We may process your Personal Data to adapt, develop and maintain our Services in order to improve user friendliness, product and Service range, quality and efficiency from an environmental and sustainability perspective. We may also process your Personal Data in order to diagnose errors, optimise technology and improve our IT systems.

We analyse the data we collect about you, e.g. by means of our analytics tools from booking platforms, social media and our website. The analysis is anonymised and is carried out in an aggregated form. The information from the analysis can never be connected to a specific person. The analysis helps us develop our IT systems, website and product and Service range.

Retention period: Maximum 38 months from collection.

FOR HOW LONG IS YOUR PERSONAL DATA RETAINED?

Your Personal Data is retained as long as it is necessary in order for us to fulfill the purposes of our processing. Thereafter we will in a secure way delete or anonymise your Personal Data to the extent that it is no longer possible to identify you or know that the data relates to you. You will find a pre-defined retention period below each of the processing activities in the tables above.

SURFGASM LDA deletes Personal Data in accordance with applicable law and the criteria outlined above. This means that SURFGASM LDA deletes or anonymises your Personal Data when the Personal Data is no longer required for the purpose of processing.

TRANSFER OF PERSONAL DATA AND RECIPIENTS WITH WHOM WE SHARE INFORMATION

We may share your Personal Data with third parties. As detailed above, your Personal data may be transferred to companies within and outside the EU/EEA that operate SURFGASM LDA  bookings but that are not part of SURFGASM LDA, or to our suppliers. We never sell your personal data and SURFGASM LDA will always enter into necessary data processing agreements with the companies that process your Personal Data on our behalf; all to ensure an adequate security level for the processing of your Personal Data.

• Suppliers
  We may, in order to fulfil the purposes with our processing of your Personal Data, use other companies to fulfil our obligations to you. To that end, we will share or transfer your Personal data with or to companies that provide services to SURFGASM LDA, including, but not limited to, our suppliers providing customer service, delivery services, analysing services, communication and marketing services. SURFGASM LDA may also share your Personal Data with our suppliers providing hosting, storage, technical support and maintenance of our IT solutions. Furthermore we may transfer your Personal Data to our payment service providers who provide us with payment solution services, in order to facilitate your payment to us. Our suppliers only process your Personal Data in accordance with our documented instructions and may not use your Personal Data for their own purposes. They are also required by law to protect your Personal Data from unauthorised access and similar.

• Other recipients
  We may as the case may be transfer your Personal Data to other recipients than those outlined above if it is necessary in order for us to fulfil the purposes outlined in the table below.

HOW ARE YOUR PERSONAL DATA PROTECTED?

SURFGASM LDA has implemented appropriate technical and organisational measures to protect your Personal Data against for instance loss, manipulation and unauthorised access. We continuously adapt our security to new technology in order to maintain high security levels.

THIRD PARTY APPLICATIONS/WEBSITES

SURFGASM LDA’s Services may contain links to other applications and/or websites over which SURFGASM LDA has no control. This Privacy Policy is only applicable to your use of SURFGASM LDA’s own Services. SURFGASM LDA is not responsible for the content of any linked applications/websites and the processing of Personal Data that may be undertaken by the owner or operator of linked applications/websites.

COOKIES

SURFGASM LDA uses cookies as part of its digital Services. The cookies may in some cases, automatically collect Personal Data (such as IP address and online behavior). We use cookies to improve your user experience and the security of our digital Services. The Personal Data that is collected via cookies may be anonymised and used in aggregated form for the purpose of using for development, statistics and analysis. You can find information about SURFGASM LDA’s use of cookies, what Personal Data we collect by means of cookies, for what they are used and what you do if you want to avoid them, in  SURFGASM LDA Cookie Policy (as updated from time to time).

YOUR RIGHTS

Privacy law gives you several rights in relation to our processing of your Personal Data. If you would like to use your rights, please contact to SURFGASM LDA by sending an e-mail to management.surfgasm@gamil.com.

• Access to your Personal Data

You have the right to obtain from us a confirmation as to whether we process your Personal Data, and where is the case, access to the Personal Data along with information about the processing and your associated rights, a so-called subject access request. 

• Request for rectification

If you think that certain Personal Data that we process concerning you is incorrect or incomplete, you have the right to request rectification. In order for us to change the Personal Data, you need to contact us (see contact details below). SURFGASM LDA is not responsible for problems caused by your Personal Data being incorrect if you have omitted to inform us thereof. 

• Withdrawal of consent with effect from the withdrawal and onwards

To the extent that we process your Personal Data based on your consent, you may at any point in time withdraw your consent to the processing. The withdrawal of your consent does not affect the lawfulness of processing based on consent prior to the withdrawal.

• Objection to processing for the purpose of direct marketing

As mentioned above, you have the right to object to processing for the purpose of direct marketing. You deregister from continued processing by either clicking the deregistration link in the marketing message or by contacting us (see contact details below).

• Objection to certain processing activities

You have the right to object to processing that is based on our legitimate interest, if you have personal reasons therefore. We may however continue to process your Personal Data if, even if you object thereto, we have compelling legitimate grounds for the processing that override your integrity interest.

• Deletion

You have the right to request that your Personal Data is deleted. This is not the case when it comes to Personal Data that we process due to law or an agreement with you. 

• Restriction of processing

You have the right to request that the processing of your personal data is restricted. Please note that this may prevent us from providing you with all our Services.

• Data portability

You have the right to receive a digital copy of your Personal Data that we process in a commonly used, structured and machine readable format (dataportability) to move to and use with another supplier. The right to dataportability, in difference to subject access right, only applies to the Personal Data that you have provided us with and that we process based on your consent or our fulfilment of an agreement with you.

• Lodge a complaint with a supervisory authority

If you are not happy with the way we process your Personal Data or if you for another reason believe that we have processed your Personal Data in an unlawful manner, you have the right to lodge a complaint with the supervisory authority responsible for data protection.

WHO DO YOU CONTACT IF YOU HAVE QUESTIONS?

If you have any questions, comments or complains regarding our processing of your Personal Data our compliance with the Privacy Policy and applicable privacy law, please feel free to contact us (see contact details below).

Contact details 
SURFGASM LDA
Rua de Lapa 14/6Lisbon, Portugal

info@surfgasm.world

Adapted 08-11-2023, Version: 2.0