PRIVACY POLICY

Caravel Devotion, S.A. firmly intends to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter "GDPR") and other applicable data protection legislation.

  1. CONTROLLER

Caravel Devotion, S.A., with Tax ID number 514552530 and registered office at Avenida Elias Garcia, n.º 91, 1.º andar, 1050-097 Lisboa, is the Controller and, as such, determines the purposes and means of the processing of personal data. To contact Caravel Devotion, S.A. you must use the following contact details:

E-mail address: [email protected]

Address: Avenida Elias Garcia 91, 1050-097 Lisboa, Portugal

  1. PERSONAL DATA

Caravel Devotion, S.A. may process the following personal data:

  • Identification Data (full name, nationality/country, date of birth, gender and number, validity and issuing authority of the identity document);
  • Contact Data (telephone contact, e-mail address and address);
  • Emergency Contact Data (telephone contact and e-mail address - you must inform the emergency contact that you have given us these personal details and give them a copy of this Policy);
  • Invoicing Data (IBAN and tax identification number);
  • Payment data (payment method, if the selected payment method is direct debit, name of the bank account holder and country code and, if the selected payment method is credit card, name of the credit card holder and credit card type, validity and last four digits of the credit card number);
  • Academic/Professional Life Data (Course and Faculty);
  • Data concerning the Accommodation (dates of arrival and departure, goods and services used, payment history and communications exchanged with Caravel Devotion, S.A. employees);
  • Data collected through the use of Closed-Circuit Television systems, internet systems (including wired or wireless networks that may collect data about the computer or the mobile device, for example IP address and other online location identifiers) and access cards;
  • Internet browsing data (IP address and cookies);
  • If people interested in living in the Residence already live alone in properties (for example, flats, houses and other university residences), the average cost and characteristics of the accommodation may also be processed.
  1. WHEN AND HOW PERSONAL DATA ARE COLLECTED?

Full name, gender, nationality/country, telephone number and e-mail address, invoicing data and payment data are collected when the website users fill in the form on this website to sign a Contract with Caravel Devotion, S.A. for the provision of Student Residence Services. The IP address and cookies are collected when users surf the website. The rest of the personal information will be collected later when the Reservation Form for the Provision of Services in the Student Residence (Special Conditions) is handed out or sent by e-mail to the Caravel Devotion, S.A. employees and during the execution of the aforementioned contract.

The mandatory nature of the collection of personal data through this website is indicated below each of the collection fields. This website automatically and mandatorily collects some personal data through the actions of the users. The personal data collected in the Reservation Form for the Provision of Services in the Student Residence (Special Conditions) are necessary for the conclusion of the Contract. Subsequently, during the execution of the Contract, the collection of some personal data will be mandatory for the provision of the services.

Most of the personal data that Caravel Devotion, S.A. process is information collected directly from the data subjects. However, in some cases, Caravel Devotion, S.A. may process personal data that is inferred from other personal data collected from the data subjects or in the interactions between the latter and the employees of Caravel Devotion, S.A..

  1. PURPOSE OF THE PROCESSING AND LEGAL BASIS FOR THE PROCESSING

Caravel Devotion, S.A. may process the personal data for the following purposes and with the respective legal basis:

  • For the purpose of answer the requests for clarification/more informationfrom the users of the website and/or residents about the Residence, Caravel Devotion, S.A. processes personal data having as legal basis its legitimate interest in keeping them satisfied and informed and, in some cases, the realization of pre-contractual procedures at the request of the data subjects or to enforce contracts to which they are party.
  • For the purposes of suitability of the type of accommodation to be proposed to the future resident, administrative management, calculating and processing the payment of the monthly amount, the amount of the booking, the security deposit amount and the additional services, processing possible cancellations and the corresponding refunds, providing services within the scope of its accommodation activity (including the provision of services, facilities and amenities) and executing court orders, Caravel Devotion, S.A. processes the personal data of the users of the website and/or residents having as legal basis the carrying out pre-contractual procedures at the request of the data subjects or to enforce contracts to which they are party.
  • For the purpose of maintaining aggregate information about the residents, Caravel Devotion, S.A. processes their personal data having as legal basis its legitimate interest in optimising administrative management.
  • For the purpose of monitoring financial results, Caravel Devotion, S.A. processes the residents' personal data having as legal basis its legitimate interest in monitoring their financial results in order to optimise revenues.
  • For the purpose of adapting its offer for commercial objectives (including for internal statistics and analysis of the occupancy levels of the Residence), Caravel Devotion, S.A. processes the residents' personal data having as legal basis its legitimate interest in guaranteeing the suitability of the services provided to the residents.
  • For the purpose of facilitating the provision of services by third parties in the Residence and to book spaces in the Residence, Caravel Devotion, S.A. processes the personal data of residents and visitors having as legal basis its legitimate interest in guaranteeing the satisfaction of residents and visitors and the diversity of the services provided.
  • For the purposes of protecting people and property, Caravel Devotion, S.A. processes the personal data of residents and visitors having as legal basis its legitimate interest in ensuring the safety in the Residence.
  • For the purpose of make phone calls and send newsletters, commercial and advertising communications and promotional communications/event invitation notices (“marketing communications”), Caravel Devotion, S.A. processes residents' personal data having as legal basis, as applicable, its legitimate interest in keeping them informed about its services and events or their consent.
  • For the purpose of comply with legal obligations, Caravel Devotion, S.A. processes personal data having as legal basis the complying with the legal obligations to which it is bound.
  1. TIME LIMITS FOR STORING PERSONAL DATA

Caravel Devotion, S.A. will store the personal data for different periods of time depending on the purposes of the processing. Thus, Caravel Devotion, S.A. will store the personal data during the following periods:

  • Answering requests for clarification/more information from the users of the website and/or residents about the Residence: for the time needed for Caravel Devotion, S.A. to answer the requests and during the contact exchange in order to celebrate the Student Residence Services Contract or to clarify any issue after its celebration (12 months maximum) (in the case that the legal basis of processing is not the realization of pre-contractual procedures at the request of the data subjects or the execution of contracts to which they are party).
  • Suitability of the type of accommodation to be proposed to the future resident, administrative management, calculating and processing the payment of the monthly amount, the amount of the booking, the security deposit amount and the additional services, processing possible cancellations and the corresponding refunds, providing services within the scope of its accommodation activity (including the provision of services, facilities and amenities) and executing court orders: throughout the duration of the contracts.
  • Maintaining aggregate information about the residents: throughout the duration of the contracts.
  • Monitoring financial results: 1 year.
  • Adapting its offer for commercial objectives: 1 year.
  • Facilitating the provision of services by third parties in the Residence and to book spaces in the Residence: 60 days.
  • Protecting people and property: 30 days.
  • Making phone calls and sending newsletters, commercial and advertising communications and promotional communications/event invitation notices (“marketing communications”): 1 year after the expiry of the Student Residence Services Contract or, in any event, as applicable, until the residents exercise their right to object or withdraw their consent.
  • Compliance with legal obligations: during the time required to comply with the legal obligation in question.

If the personal data are processed for different purposes for which there are different storage periods, Caravel Devotion, S.A. will keep them for the longest of these periods, in which case the processing of the personal data will be restricted to the purpose for which the storage period is the longest.

  1. TRANSMISSION OF PERSONAL DATA TO THIRD PARTIES

Caravel Devotion, S.A will only transmit the personal data to:

  • Caravel Devotion, S.A. service providers - these providers act as processors of Caravel Devotion, S.A. and, as such, provide services on behalf of and in accordance with the express instructions of Caravel Devotion, S.A. as a result of the agreements concluded between Caravel Devotion, S.A. and the service providers;
  • Companies that belong to the corporate group to which Caravel Devotion, S.A. belongs (the group consisting of Mithril, S.A. and all the companies owned by it) or related with it and Caravel Devotion, S.A. partner entities;
  • Third parties to whom Caravel Devotion, S.A is obliged to transmit personal data in order to comply with legal obligations or instructions from the competent judicial authorities and administrative bodies.

Caravel Devotion, S.A. does not intend to transfer personal data to a third country or an international organisation. Nevertheless, should this occur, Caravel Devotion, S.A. will carry out the transfer on the basis of an adequacy decision adopted by the European Commission or, in cases where there is no adequacy decision, will provide appropriate safeguards to ensure the protection of personal data and that data subjects enjoy enforceable rights and effective legal remedies.

  1. RIGHTS OF DATA SUBJECTS

Data subjects shall enjoy, as applicable, the following rights:

Right to withdraw the consent – the right to withdraw the consent at any time without the withdrawal compromising the lawfulness of the processing carried out on the basis of the consent previously given.

Right of access – the right to know whether or not their personal data is being processed by Caravel Devotion, S.A.. If so, data subjects may also request access to their personal data and to the information listed in article 15 of the GDPR.

Right of rectification - the right to obtain from Caravel Devotion, S.A. the rectification or completion of any personal data concerning them that is inaccurate or incomplete, under the terms of article 16 of the GDPR.

Right to erasure – the right to request Caravel Devotion, S.A. to erase their personal data on the grounds set out in article 17 of the GDPR.

Right to restriction of processing – the right to obtain from Caravel Devotion, S.A. the restriction of processing under the conditions set out in article 18 of the GDPR.

Right to data portability – in the cases provided for the article 20 of the GDPR, the right to receive from Caravel Devotion, S.A. the personal data concerning them in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from Caravel Devotion, S.A..

Right to object - the right to object to processing of personal data by Caravel Devotion, S.A. in the circumstances established in article 21 of the GDPR.

Right not to be subject to automated individual decisions - Caravel Devotion, S.A. does not adopt automated individual decisions, including profiling, which produce effects in the legal sphere of the data subjects or that significantly affect them in a similar way.

To exercise these rights an e-mail should be sent to [email protected].

Right to complain with the supervisory authority - the right to submit a complaint with the National Data Protection Commission (www.cnpd.pt) if they consider that Caravel Devotion, S.A. has not acted in accordance with the applicable legislation on the protection of personal data.

  1. UPDATES

Caravel Devotion, S.A. reserves the right to modify all or part of this Privacy Policy at any time. Any modifications will be published immediately on this page and we therefore advise you to consult it regularly. Last update: 22th of June 2021.