Политика конфиденциальности

Last Update: 25 March 2024

The privacy policy applies to the collection and processing of data by the travel agency ASL Partners, hereby known as business or agency. This document portrays relevant information about how your personal data is collected, processed and disclosed and the legislation appliable on this subject, including those referring to the Portuguese National Data Protection Authority, as the business is settled in Portugal.

We are committed to protecting and preserving safely the privacy and confidentiality of personal information; improving our business relationship through the information gathered; facilitating your access to the information as diligently as possible.

We reserve the right to update our policies at any time, due to business strategies, legislation and procedures changes required in the country of our settlement. In case of doubt or require further detailing on our Privacy Policy or your rights, please contact us through the means explained below.

By continuing on the asl.partners webpage (here forward referred as website) you agree the information you are using, now and in the future, are true, reliable and you are committed to notify us with regards to any changes on them. If you insert information related to a third party you are bound to obtain their previous consent and inform them on this Privacy Notice, being responsible for obeying on their behalf with the disposition in this document and in the Terms and Conditions of this business.

Regarding the safety of our clients while navigating our website, we inform it is SSL – Secure Socket Layer protected. This technology ensures the safeguarding of data transfer through the internet by encrypting and protecting the information using an HTTPS protocol. SSL guarantees the user’s data is not wrongfully intercepted. According to some country’s entry, flying and accommodation protocols it is mandatory for booking purposes to include information such as full name, personal identification registry, sex, age, nationality, country of origin and others. The information gathered for booking processing will be disclosed to border safety agencies in the country of arrival and/or departure.

> Who’s responsible for the processing of my information?

Unless specifically notified otherwise, while navigating the website the business ASL — AVIA SERVICES & LOGISTICS, SOCIEDADE UNIPESSOAL LDA, business registration identification 515798258, recorded address at Rua Eng. Moniz da Maia 12 RC/C, 2615-044 Vila Franca de Xira, Portugal, available at the email address asl@asl.partners

> Which information can be gathered?

While navigating any forms or requests you fill, for example, when registering for our newsletters, requesting a quotation or purchasing a service. We will also gather information in the requests and communication arriving by e-mail, digital platforms, voice and text messages as well as phone calls. Profile and analysis derived from users navigating on the website. Your participation in sales campaigns, as per example, contests, satisfaction surveys and promotions.

The data obtained is directly filled out by yourself, or third parties who insert it on your behalf, for instance, the client who made the booking, the business you work for who booked on your behalf, or other travel agencies.

Usually, the type of data managed includes: full name, personal identification and means of contact; personal characteristics such as language, sex, date of birth, nationality; economical and financial information on transactions and bank statements when required; information relating to your navigation experience, as your equipment IP address, actions performed while navigating the website, and in order to reach such means online monitoring technologies are used; booking history data and means of contact with business; data related to business requests; identifiable information and contacts obtained through social media used to contact us; data generated by the use of social media you shared with us (such as likes, shares and comments).

> Why do we handle your data?

Our users and clients data is handled for relationship management; processing of requests and services provided; services and website quality evaluation; legal obligation fulfilment, such as billing and financial duties; sales purposes, including but not limited to – forwarding sales information to our clients, commercial profile set-up from booking and information filled in (no automated or artificial intelligence decision are used in profiling), a budget you submitted or a form you started filling without completing, or the data used for sales to fulfill your requests.

When joining a sales campaign, your information will be processed for management and safe keeping. The participation in said campaigns implies consent to the processing and transfer of your information, to the purpose, and under the terms of each campaign you are taking, being a conscious commitment of this data use and your full agreement. Participants or winners information may be published on the website, social media, generic media or internet, as specified in each campaign. The winners personal information, as required for the full enjoyment of the prize, will be disclosed to suppliers of said prize services, being inferred the winners consent for international disclosure of personal information, when those suppliers rely outside of the European Economic Area.

> Who can we disclose your information to?

Mostly, your information will be disclosed with your previous agreement and when necessary to process your requests, service delivery, or legal obligations. Namely:

— adequate management of the booking requests, the disclosure of the collected data to suppliers, tour operator, travel agencies and/or global distribution systems is required; including international data disclosure to businesses outside of the European Economic Area;

— relevant information may also be checked at fraud software and databases, in order to detect and prevent fraudulent bookings and payments;

— technologies or service providers, from outside the European Economic Area, may be used for some of the website functions. In such cases, appropriate safety measures regarding personal data will take place. Including, but not limited to, Google service and affiliate programs (all protected by the Privacy Shield agreement between UE and USA);

— email communications using several online servers and services may be used for sales purposes such as mailing and management.

All information shared with us through blogs, forums or other public participation solutions, available in the website or internet, will be considered public information, hence the users should take special care with the content of what they are sharing as comments, pictures and personal data; this information is, however, subject to the following terms:

— an appropriate use of the comment functionality in publications on the website or internet related to the business is demanded, in particular but not solely, information and/or comments relating to unlawful or illegal activities, against good faith and public order;

— sharing content or propaganda of racist, xenophobic or pornographic nature, inciting terrorism, or against human rights;

— containing content that may infringe copyrights, trademarks, intellectual or industrial property rights;

— offend against someone’s image;

— install or share digital viruses, or any other physical or technological systems that may cause damage to the networks or equipment;

— use or share third party e-mail accounts or personal information, modify or manipulate messaging.

We reserve the right to withdraw or unpublish any comments or participations that infringe the terms above, in particular those who violate people’s dignity, are discriminatory, xenophobic, racist or pornographic in nature, threaten to the youth or child’s safety and upbringing, public safety and order, or that, in our opinion, may be considered impropriate. We take no responsibility for the information shared with our users, including the opinions, accuracy, quality, liability or rightfulness on said information. Notwithstanding all above, the information, comments or pictures shared in these conditions by the people may be revised or cancelled, providing a request by themselves, as explained in the “What are your rights?” section.

> Legal basis for processing data

A legal relationship is bound for the processing of your data as required for the delivery of the services requested or booked, legal obligations, tax and billing, tourism, safety and border regulations that may be applicable. The processing of the data is based on said lawful requirements:

— the websites safety measures, as well as preventive and detection fraud software, settle the lawful legal relationship as needed to ensure the safety of our systems and transactions;

— the ability to perform statistical and quality checkups settles the lawful legal relationship;

— tracking sales requests, the messages exchanged and data bases the agency may create, settles the lawful relationship as it enables the agency to promote the its services and products, and the consent for archiving said electronic data is obtained in this document;

— data conservation settles the lawful relationship as necessary for administrative procedures of the business.

> How long will your data be kept for?

In general terms, while the contractual relationship with our clients, users and participants exists, we are legally bound to keep your data, for instance, for tax and billing purposes, insurance and contractual obligations, as well as the origin of the data and any services provided. Your information will be deleted when deemed unnecessary or relevant for the original purposes it has been collected. However, the data processed for sales campaigns and sales profiles shall be deleted only when requested by the user. Meanwhile, the documentation related to your consent for said data processing and it’s purposes, such as electronic communications, forms, papers or other, will be kept for the duration of the data processing, contractual periods and legal limitation periods.

> What are your rights?

You have the right to confirm if and which of your personal data is being processed by us, as well as have access to it. You may also require any rectifying when the information is inaccurate, completion when the information is incomplete, as requiring the deletion of information that may no longer be required for the purposes it was collected for. Under specific circumstances you may require limited processing of your information, in which case, only the information or data required for the contractual and legal roles will be processed, or undue third party law infringements. Under specific circumstances and reasons may you also oppose to data processing, in which case we will not process your data unless legal and imperative laws override your personal rights, liberties, requests or complaint defense. You may revoke the consent prior given for data processing and collection, or limit the consent given, without allocation to legal requirements. To dropout of data processing and collection for sales purposes please forward your request to asl@asl.partners .

It is within your right to complain at a data protection authority. The National Data Protection Authorities are regulated by the European Commission, and it’s contacts are available at

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

To exercise your rights, please forward your request, attaching a copy of your national identification or including the national identification number, or another document that may identify you as a person in our data base, through postal or electronic mail, to the addresses available at the “Who’s responsible for the processing of my information?”

In compliance with the law number 144/2015 we inform that any conflicts regarding the services provided by this agency may be moderated by the arbitration commission of the Tourism of Portugal, available for contacts at www.turismodeportugal.pt .