Privacy Policy

ASSOCIAÇÃO dos PROPRIETÁRIOS à BEIRA LAGO (A.P.B.L.)

PRIVACY STATEMENT – 25th May 2018

Introduction

This Privacy Statement sets out how A.P.B.L. manages and processes personal data it collects and holds in the course of its business, pursuant to the requirements of the General Data Protection Regulation, (‘GDPR’). Personal Data is any information which directly or indirectly identifies an identifiable natural person, (‘data subject’).

Data Controller

A.P.B.L. will be the Controller of personal data that you provide to us. The full contact details of A.P.B.L. are as follows:

ASSOCIAÇÃO dos PROPRIETÁRIOS à BEIRA LAGO (A.P.B.L.)

Avenida dos Pinheiros no. 10, Recepção, Lakeside Village, Quinta do Lago, 8135-024 Almancil, PORTUGAL

Fiscal Number: PT 503 864 382

Telephone: +351 289 398 606

Your Personal Data

A.P.B.L. collects personal data about you which may include your name, address and other contact information as well as your, IVA (VAT) and tax registration details where applicable. A more detailed overview is given in Appendix 1. In order to process personal data there must be a lawful basis. These are set out under Article 6 of the GDPR as follows and at least one must apply:

· Consent – This is where an individual gives clear consent for A.P.B.L. to process personal data for a specific purpose.

· Contract – The processing is necessary for a contract with the individual or because they have asked for specific steps to be taken before entering into a contract.

· Legal Obligation – Necessary for A.P.B.L. to comply with the law, (not including contractual obligations).

· Vital Interests – The processing is necessary to protect someone’s

· Public Task – The processing is necessary for A.P.B.L. to perform a task in the public interest or for official functions and the task has a clear basis in

· Legitimate Interests – The processing is necessary for P.B.L.’s legitimate interests or the interests of a third party unless there is good reason to protect the individual’s personal data which over-rides those legitimate interests.

Telephone Calls & e-mails

A.P.B.L. will generally take notes of phone calls so that an accurate record of what is said is kept. A.P.B.L. will also retain emails, text messages and other communications. It is in A.P.B.L.’s legitimate interests to do so and may be a contractual or legal obligation.

Purpose & Principle

A.P.B.L. needs personal data to satisfy contractual and legal obligations and for legitimate interests to facilitate its proper operation. A.P.B.L. will seek to ensure that it is processed lawfully, fairly and transparently and will not seek more data than needed.

How A.P.B.L. Deals With it

The information A.P.B.L. collects is processed under the supervision of the Board of Directors of A.P.B.L.  Only designated staff have involvement and access to the information. A.P.B.L. will treat information it holds as confidential, but it may be necessary or appropriate to provide other parties, including statutory undertakers, legal advisers, insurers, local authorities, contractors and service providers amongst others with information. This is to ensure that A.P.B.L. can satisfy its legal and contractual duties and is able to fulfil its business obligations. Further information on how data may be shared is provided in Appendix 2.

Accuracy of Data

A.P.B.L. will ensure that all personal data collected and processed is kept accurate and up to date.  Where any inaccuracy is found all reasonable steps will be taken to amend without delay.

How long will A.P.B.L. keep it

A.P.B.L. will not keep personal data for any longer than is necessary having regard to the context in which it is held.

Your Rights

Data Subjects have the following rights:

· To be informed. A.P.B.L. have sought to satisfy this within the context of this Privacy Statement.

· You have the right to make a request about data A.P.B.L. hold at any time. This is known as a ‘SAR’ (Subject Access Request) and A.P.B.L. would normally respond within one month of receipt.

· Correction/Rectification. If you believe that the information A.P.B.L. hold on you is incorrect you can ask A.P.B.L. to correct it and change any inaccuracies. Any third parties to whom the data has been disclosed will also be informed.

· You have the right in certain circumstances to ask that any data A.P.B.L. hold is erased, (subject to any statutory, contractual or legal obligations on A.P.B.L. to the contrary). You should be aware that the deletion of any data may impact on A.P.B.L.’s operational abilities.

· Restriction of processing. Data Subjects can request based on legitimate reasons, that A.P.B.L. ceases processing the personal data it holds about them. This includes where the accuracy or lawfulness of the data is being contested.

· Data Portability. This allows individuals to reuse their personal data for their own purposes across different services, allowing them to move copy or transfer personal data more easily.

· Withdrawal of Consent. Where consent is the legal gateway to process data you can withdraw this at any time by contacting A.P.B.L. at the address given above.

To exercise these rights, you should contact A.P.B.L. at the address given above.

Implementation

This policy shall be deemed to be effective as of 25 May 2018. No part shall have retroactive effect.

Complaints

If you wish to make a complaint about how A.P.B.L. have handled your personal data, you should contact A.P.B.L. who will investigate the matter.

Appendix 1. Personal Data

The following personal data may be held and processed by A.P.B.L.:

Identity and Contact details. A.P.B.L. require this in order to communicate with you, to operate effectively and to enable A.P.B.L. to satisfy legal and contractual requirements.

Apartment and Villa Owners. To satisfy statutory requirements, determine voting rights, etc.

Designated point of contact. To enable A.P.B.L. to communicate due to circumstances or in an emergency.

Professional advisers. A.P.B.L. may hold details about your solicitor, accountant or other professional adviser in order to ensure that A.P.B.L. can communicate with them where required to fulfil A.P.B.L.’s duties and responsibilities.

Payment records. A.P.B.L. are required to keep detailed records of receipts and payments including any associated records, reminders and final demands. This is to enable A.P.B.L. to fulfil its operational obligations.

Correspondence. A.P.B.L. receive and keep communications by email, letter, text, fax, phone and all other legitimate means. A.P.B.L. handle and maintain this within the context of required records to operate and undertake its duties.

A.P.B.L. considers that the above information is necessary in A.P.B.L.’s legitimate interests and to satisfy contractual and legal obligations.

Appendix 2. Sharing Information

This is a broad overview of whose data might typically be shared with and why:

A.P.B.L. Directors & Officers. For the effective operation of A.P.B.L. and to satisfy legal and statutory obligations.

Other Apartment & Villa Owners in the context of legitimate requirement, attendance, voting at meetings, etc.

A.P.B.L. Auditors to the extent required to satisfy Audit and accountancy requirements.

Professional advisers. Including solicitors and accountants. For assistance and advice in connection with legitimate management, professional and legal matters. To assist with financial issues.

Regulatory Bodies. To enable them to carry out their functions and legitimate interests. Satisfy legal obligation. Courts. For the administration of justice. Pursuit and defense of claims.

Receivers & Administrators. To assist with winding up of estates, deal with legitimate financial issues.

A.P.B.L. consider that this information needs to be shared to satisfy A.P.B.L.’s legitimate interests, contractual and legal obligations.

End.

ASSOCIAÇÃO dos PROPRIETÁRIOS à BEIRA LAGO (A.P.B.L.)