Data Privacy Policy

The confidentiality of the personal information of our clients is fundamental and Dom Pedro Golf is committed to protecting their privacy.

Dom Pedro Golf complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 .

1. Data Privacy Policy

To Dom Pedro Hotels & Golf Collection users and customers privacy and security regarding personal data, is a priority.

In exception to the circumstances described in this privacy policy, Dom Pedro Hotels & Golf Collection does not share personal information with third parties.

The Group adopts principles, policies and procedures consistent with the values advocated; according to the standards and strategies that it has been taking, and that meet the requirements of the General Data Protection Regulation 2016/679.

Some information provided by users and customers who visit our website are saved, so that we can provide our services and market products in an appropriate way, always according to the regulation.

All data processing is made with the previous consent of the data holder.

These principles are scrupulously followed by all Group employees, in accordance with the Group's internal Code of Conduct, which can be accessed here.

All employees of the Group who process data in the scope of their activities are individually responsible for compliance with applicable legal and regulatory provisions.

2. Data Controller

The entity responsible for collecting and processing personal data is Dom Pedro Golf, S.A., Headquarters at Edifício Old Course, Apartado 970, 8126-912 Vilamoura, Portugal, and Tax Payer Number 502 268 808.

3. What type of personal information do we request

We may ask you to provide some personal information, through our website www.dompedrogolf.com.

If you wish to make a reservation, we request information such as name, address, telephone number, and e-mail.

Credit card information are exclusively used to ensure the payment of the reservation and it is protected by our systems.

All data collected and processed are used for the purposes that led to their collection, and of which the data holder has been duly informed.

4. For what purposes do we use your personal information?

The personal information that we process is requested for legal purposes, particularly in the context of reservations.

For any other activity, personal data are processed considering the previous consent of the data holder, especially when we use them for information of promotions and information of Dom Pedro Golf, through newsletters; and for statistical analysis of marketing of exclusive use of Dom Pedro Golf.

We also identify technical information about your computer when you visit the pages on our website, such as Internet Protocol (IP), operating system and browser type. We use this information to improve the quality of your visit to our website, and we will not disclose it to entities outside of Dom Pedro Golf without your consent.

There are no automated decisions in the Group, nor the definition of profiles and information.

5. With whom and when do we share personal information

In certain circumstances, and with your consent, we may share personal information with third parties.

Personal data may also be made available to external entities when specifically provided by law.

In the context of external authorities, when personal data information is requested based on a legal requirement, the information transmitted is limited to what is strictly necessary to achieve the purposes.

We do not give information regarding personal data by telephone, to avoid the leakage of personal and confidential information.

Dom Pedro Golf reserves the right to transmit any personal data in the event of sale or transmission of part or all its company or its assets, without prejudice to the confidentiality of the personal data in question, and interests of the holders.

6. How do we protect your personal information?

We have created security measures inside the organization, through the creation of files and databases with restricted access, so that personal data do not suffer any violation, disclosure or misuse.

To guarantee the security of personal data and the maximum confidentiality, we treat the information that you provided to us in a confidential way, in accordance with our internal policies and procedures of security and confidentiality.

Dom Pedro also adopts other security measures regarding the security of personal data:

- Antivirus software that provides protection against malware;

- Antivirus software that provides protection for the browser and for e-mail;

- The corporate network is protected by a firewall;

- Personal data backups are automatically enhanced;

- Our corporate Wi-Fi network is password protected;

- Remote access to our corporate network is only possible through a VPN (Virtual Private Network);

- Privileged accounts are not used for daily tasks and access to them is possible only by privileged users, and from devices dedicated and limited only to authorized persons;

- Access to sensitive personal data is controlled and limited;

- Data loss prevention software is used to protect sensitive and personal data;

- The procedures for verifying, detecting, analyzing and reporting security incidents are developed and communicated within the organization, mainly through frequent contact with the DPO;

- Personal and sensitive data are all encrypted;

- E-mail communications are encrypted;

- Folders in the Cloud / Network are encrypted.

In addition to all measures taken, the Group closely monitors all procedures through audits to see if they are effective and match the needs of the GDPR.

7. Cookies

When you visit our website, you will receive a "cookie" (a small data package sent to your browser) to be stored on your computer's hard drive. The purpose of using cookies is to identify you when you visit our website, so we can enhance and customize the online experience.

Most browsers automatically accept these files (cookies), but you can either delete them or set their block automatically.

In your browser menu you will find how to make these settings. You may also accept cookies or not explicitly on the site. However, if you do not allow the use of cookies there may be some features that you will not be able to use.

We only use session cookies on this site, and they are always temporary. This means that they only remain in the cookie store until you leave the site, so they are deleted when you close your browser. The information obtained serves to analyze traffic patterns, which facilitates the identification of problems.

Regarding the purpose of use of these cookies is “strictly necessary”, it is solely for the purpose of permitting 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 unidentifiable. It does not contain your name, address, telephone number or email address, or any personal identifiable information.

Some of our business partners (advertisers, for example) use cookies on our site. Dom Pedro Hotels & Golf Collection has no access to or control over these cookies. This privacy policy refers only to the use of cookies on the Dom Pedro 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 cookies or close the bar. Non-acceptance will not affect access to the site.

8. E-mail communications

We have no intention of sending marketing communications by e-mail, without your prior consent.

If you choose to receive our periodic communications, we may occasionally send you emails with new promotions and special offers.

You may, at any time, choose to stop receiving these emails, through our website or in the “unsubscribe” option in every e-mail sent.

 9.  Subcontractors

In the processing of personal data, we may have to consult and hire third parties, or subcontractors, so that on behalf of Dom Pedro Golf, and in accordance with the instructions given by us, they may process personal data.

The processing of personal data by subcontracting companies is done in strict compliance with the provisions of the law and this Privacy Policy.

These subcontracted entities may not transmit personal data to other entities without Dom Pedro Golf having previously given written permission to and are also prevented from contracting other entities without prior authorization.

We are committed to hire only those entities that have sufficient guarantees to implement the appropriate technical and organizational measures to ensure that all personal data are protected.

All subcontractors are bound by a Data Processing Agreement, which regulates the terms in which the services will be provided, namely the obligation to comply with all standards related to data protection, security and confidentiality.

 10.  Your rights

Dom Pedro Golf establishes procedures to protect and enforce the rights of data holders.

Some of your rights:

  • The right to access your data processed by us, obtaining a copy of the data;
  • The right to rectification of any inaccurate personal data;
  • The right to have your personal data deleted, unless the law provides otherwise, and, in that case, to limit processing;
  • The right to oppose the processing of data, for purposes associated with personal circumstances, in accordance with the law;
  • The right to request the limitation of data processing;
  • Data portability right;
  • Right to change the consent already given, without compromising the treatment made with the consent previously given;
  • The right to be notified in the case of personal data breach;
  • Right to be notified when information is stored by another method other than the original;
  • Right not to be contacted for advertising, direct marketing or any other form of commercial prospecting, as well as its non-communication to third parties for the same purposes, except with the prior consent of the data holder; and
  • Right to complain to any supervisory authority, or through the website of the National Data Protection Commission.

11. Duration

We store personal data for the duration established by law, in case of legal obligations.

Regarding any other personal data, those are stored for the duration our guests agree to, according to the commercial relations established.

12. Data Protection Officer

Our Data Protection Officer is Margarida Araújo, and may be contacted through the e-mail address: dpo@dompedro.com 

If you wish to be informed about any issue related to our Privacy Policy, please contact us at dpo@dompedro.com 

13. Changes in this Privacy Policy

To ensure the updating of the Data Privacy Policy, Dom Pedro Golf may change this privacy policy. 

All changes will be published in the related channels, so that all guests and employees have access to it.