1. Collection and processing of user data
There are various circumstances in which we request personal data from a user (“User”) of the website hosted on www.casinodamadeira.com (“Site”), that is, information that allows the user’s identification or contact (“Personal Data”) : When you subscribe to the newsletter, you send us a contact to request a conference or event for your company, or when you send us the spontaneous or requested application form. The Personal Data collected and processed consists of information regarding the name, email address, sex, date of birth, address and telephone number.
Accordingly, the entity responsible for the collection of Personal Data is the ITI – Sociedade de Investimentos Turísticos in Ilha de Madeira, SA (“Casino da Madeira”), a limited liability company with registered office at Avenida do Infante, 9004-513 FUNCHAL, number of legal person 511 008 740 and with the share capital of EUR 8,000,000.00, which in turn comprises Casino da Madeira, SGPS, SA (“Casino da Madeira”);
2. Usage and purpose of processing user data
The Personal Data will only be used for your information on the promotions and information of the Madeira Casino (if you subscribe to our newsletter), and for statistical analysis of marketing exclusively for Madeira Casino.
We also identify technical information about your computer when you visit the pages of our site, such as the IP (Internet Protocol), the operating system and the type of browser (“Usability Information”). We use this information to improve the quality of your visit to our Site, and we will not disclose it to entities outside the Madeira Casino without your consent.
3. Princípios gerais aplicáveis ao tratamento de dados do utilizador
In terms of general principles regarding the processing of Personal Data, Casino de Madeira undertakes to ensure that the User Data processed by you are:
♦ Object of a lawful, fair and transparent treatment in relation to the User;
♦ Collected for specific, explicit and legitimate purposes and not subsequently processed in a manner incompatible with those purposes;
♦ Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
♦ Accurate and up-to-date where necessary, all appropriate measures being taken to ensure that inaccurate data, taking into account the purposes for which they are processed, are erased or rectified without delay;
♦ Preserved in a manner that allows the identification of the User only for the period necessary for the purposes for which the data are processed;
♦ Treaties in a way that guarantees their safety, including protection against their unauthorized or unlawful treatment and against their accidental loss, destruction or damage, and appropriate technical or organizational measures are taken.
The processing of data made by the Madeira Casino is lawful when at least one of the following situations occurs:
♦ The User has given explicit consent to the processing of the User Data for one or more specific purposes;
♦ Treatment is necessary for the execution of a contract in which the User is a party, or for pre-contractual procedures at the request of the User;
♦ Treatment is necessary for the fulfillment of a legal obligation to which the Madeira Casino is subject;
♦ Treatment is necessary for the defense of vital interests of the User or another natural person;
♦ Treatment is necessary for the legitimate interests pursued by the Madeira Casino or by third parties (except if the interests or fundamental rights and freedoms of the User that require the protection of Personal Data prevail).
The Casino of Madeira undertakes to ensure that the processing of User Data is only done under the conditions listed above and with respect to the principles mentioned above.
When the User Data is processed by the Madeira Casino based on the consent of the User, the User has the right to withdraw his consent at any time. The withdrawal of the consent, however, does not compromise the lawfulness of the treatment made by the Madeira Casino based on the consent previously given by the User.
The length of time during which the data is stored and stored varies according to the purpose for which the information is processed.
Effectively, there are legal requirements that require you to retain the data for a minimum period of time. Thus, and where there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the purposes that led to their collection or subsequent processing, after which they will be eliminated.
4. Right to information
4.1. Information provided to the User by the Madeira Casino (when data is collected directly from the User):
♦ The identity and contacts of the Madeira Casino, responsible for the treatment and, if applicable, of its representative;
♦ The contacts of the Data Protection Officer;
♦ The purposes of the treatment to which Personal Data is intended, as well as, if applicable, the legal basis for treatment;
♦ If the processing of the data is based on the legitimate interests of the Madeira Casino or a third party, an indication of such interests;
♦ If applicable, the recipients or categories of recipients of the Personal Data;
♦ If applicable, indication that Personal Data will be transferred to a third country or an international organization, and whether there is a compliance decision adopted by the Commission or reference to appropriate or appropriate transfer guarantees;
♦ Deadline for the preservation of Personal Data;
♦ The right to request the Casino de Madeira access to Personal Data, as well as its rectification, erasure or limitation, the right to oppose the treatment and the right to portability of the data;
♦ If the processing of the data is based on the consent of the User, the right to withdraw consent at any time, without compromising the lawfulness of the treatment made on the basis of the consent previously given;
♦ The right to lodge a complaint with the CNPD or other supervisory authority;
♦ Indication if the communication of Personal Data constitutes a legal or contractual obligation, or a requirement to conclude a contract, as well as if the holder is obliged to provide Personal Data and the possible consequences of not providing such data;
♦ If applicable, the existence of automated decisions, including the definition of profiles, and information on the underlying logic, as well as the importance and expected consequences of such processing for the data subject.
♦ In the event that the User Data is not collected directly by the Madeira Casino from the User, in addition to the information referred to above, the User is further informed of the categories of Personal Data being processed, as well as the origin of the data and possibly from sources accessible to the public.
♦ In the event that the Casino de Madeira intends to proceed with the further processing of the User Data for a purpose other than that for which the data was collected, prior to such treatment the Madeira Casino will provide the User with information about that purpose and any other pertinent information, in the terms referred to above.
4.2. Procedures and measures implemented to fulfill the right to information.
The information referred to in 4.1. is provided in writing (including by electronic means) by the Madeira Casino to the User prior to the processing of Personal Data in question. In accordance with applicable law, the Madeira Casino is under no obligation to provide the User with the information mentioned in 4.1 when and to the extent that the User is already aware of them.
The information is provided by the Casino da Madeira free of charge.
5. Access to personal data
The Casino of Madeira guarantees the means that allow the access, by the User, to his Personal Data. If you wish to access your Personal Data, you must contact the Madeira Casino on the terms described here.
6. Rectification of personal data
7. Right to erase personal data (“right to be forgotten”)
The User has the right to obtain, on the part of the Casino of Madeira, the erasure of his data when one of the following reasons applies:
♦ User Data is no longer required for the purpose for which it was collected or processed;
♦ The User withdraws the consent on which the data treatment is based and there is no other legal basis for such treatment;
♦ The User opposes the treatment under the right of opposition and there are no prevailing legitimate interests justifying the treatment;
♦ In case the User Data is treated unlawfully;
♦ In case User Data has to be erased in order to comply with a legal obligation to which the Madeira Casino is subject;
Under the applicable legal terms, the Madeira Casino is under no obligation to delete the User Data to the extent that the processing proves necessary to fulfill a legal obligation to which the Madeira Casino is subject or for the purposes of declaration, exercise or defense of a right of the Madeira Casino in a judicial process.
In case of deletion of the data, the Madeira Casino communicates to each recipient / entity to whom the data has been transmitted the deletion, unless such communication proves impossible or involves a disproportionate effort for the Madeira Casino.
When the Madeira Casino has made public the User Data and is obliged to delete it under the right of erasure, the Casino de Madeira undertakes to ensure reasonable measures, including of a technical nature, taking into account the technology available and the costs of its application to inform those responsible for the effective treatment of Personal Data that the User has requested the deletion of the links to this Personal Data, as well as copies or reproductions thereof.
8. Right to limit the processing of personal data
The User has the right to obtain, on the part of the Madeira Casino, the limitation of the processing of the User Data, if one of the following situations applies (the limitation is to insert a mark in the Personal Data preserved in order to limit its treatment in the future):
♦ If you dispute the accuracy of the Personal Data, during a period that allows the Casino of Madeira to verify its accuracy;
♦ If the treatment is unlawful and the User opposes the erasure of the data, requesting, however, the limitation of its use;
♦ If Madeira Casino no longer requires User Data for processing purposes, but such data is required by the User for the purposes of declaration, exercise or defense of a right in a legal proceeding;
♦ If the User has objected to the processing, until it is verified that the legitimate reasons of the Madeira Casino prevail over those of the User.
When User Data is subject to limitation, they may only, with the exception of conservation, be treated with the consent of the User or for the purposes of declaration, exercise or defense of a right in a judicial process, to defend the rights of another natural or or for reasons of public interest legally envisaged.
The User who has obtained the limitation of the treatment of his data in the above cases will be informed by the Casino of Madeira before the treatment limitation is annulled.
In the event of limitation of the processing of the data, the Madeira Casino shall communicate to each recipient to whom the data has been transmitted to the respective limitation, unless such communication is impossible or involves a disproportionate effort for the Madeira Casino.
9. Right of portability of personal data
The User has the right to receive the Personal Data that concerns him and which he has provided to the Madeira Casino in a structured, current and automatic reading format and the right to transmit this data to another party responsible for the treatment if:
♦ The treatment is based on the consent or a contract to which the User is a party; and
♦ Treatment is performed by automated means.
The portability right does not include inferred data or derivative data, i.e. Personal Data that is generated by the Madeira Casino as a consequence or result of the analysis of the data being processed.
The User has the right to have Personal Data transmitted directly between those responsible for the treatment, whenever this is technically possible.
10. Right to object to treatment
The User has the right to oppose at any time, for reasons related to his particular situation, the processing of Personal Data concerning him that is based on the exercise of legitimate interests pursued by Casino de Madeira or when the treatment is carried out for purposes other than those for which Personal Data has been collected, including the definition of profiles, or when Personal Data is processed for statistical purposes.
The Casino of Madeira will cease processing User Data, unless it presents imperative and legitimate reasons for such treatment that prevail over the interests, rights and freedoms of the User, or for the purposes of declaration, exercise or defense of a right of the Madeira Casino proceedings.
When User Data is processed for the purpose of direct marketing (marketing), the User has the right to oppose at any time the processing of the data that concern him for the purposes of said commercialization, which includes the definition of profiles in the insofar as it relates to direct marketing. If the User objects to the processing of their data for the purpose of direct marketing, the Madeira Casino ceases processing of the data for that purpose.
You also have the right not to be subject to any decision made solely on the basis of automated processing, including profiling, that has effects in your legal sphere or significantly affects you in a similar way, unless the decision:
♦ It is necessary for the execution or execution of a contract between the User and the Madeira Casino;
♦ Is authorized by legislation to which the Madeira Casino is subject; or
♦ It is based on the explicit consent of the User.
11. Tools used by the site to read statistics and user behavior
The Site uses Google Analytics, a network analytics service provided by Google. Cookies that provide information on use and navigability on the Site will be stored. This data, including the User’s IP address, is transmitted to Google’s servers, but is not related to any other data owned by Google.
You can disable the tool by downloading and installing a browser add-on available from Google.
Facebook e Instagram
On the Site there is interactivity with Facebook and Instagram, through a connection to the servers of these social networks, this will allow to identify the website that the user is visiting and possibly store other data, such as the IP address.
If you have your Facebook and / or Instagram session started, the data will be associated with your accounts. For this to happen, the User must end their sessions on Facebook and Instagram before visiting the page.
The Site provides an interactivity with Twitter, through its button, establishing a link to the Twitter servers, which will identify the Site that the user is visiting and possibly store other data, such as the IP address.
More information on how Twitter processes data is available here.
12. User data security
♦ In order to ensure the security of the User Data and the maximum confidentiality, we treat the information you have provided us in an absolutely confidential manner, in accordance with our internal security and confidentiality policies and procedures.
♦ We will use SSL on all pages where you are asked for personal information, which means that your information will be sent over the internet in an encrypted form. You may find that you are in safe mode when you see a lock or key icon in the lower right corner or the lower left corner of your screen. In addition, you can see that the first characters of the site url will be “https”, indicating that you are accessing a secure server.
♦ However, User Data may circulate on the network without security conditions and may be viewed and / or used by unauthorized third parties. Should this occur, Madeira Casino is not responsible for the theft, destruction or dissemination of User Data.
When you visit our Site, a small text file (Cookie) is created and saved to your computer’s disk. This file, when recognizing it, will allow you greater ease and speed in access, as well as customization of the Site according to your preferences.
14. Transfer of data outside the European Union
The Personal Data collected and used by the Madeira Casino is not available to third parties established outside the European Union. If, in the future, this transfer occurs for the reasons mentioned above, Casino de Madeira undertakes to ensure that the transfer complies with applicable legal provisions, in particular as regards the determination of the country’s suitability as regards data protection and the requirements applicable to such transfers.
16. Procedures for the exercise of rights by the user
The right of access, right of rectification, right of erasure, right to limitation, right of portability and right to opposition can be exercised by the User through the platform available here.
The Casino of Madeira will respond in writing (including by electronic means) to the request of the User within a maximum of one month from the receipt of the request, except in cases of special complexity, where this period may be extended by up to two months.
If the requests presented by the User are manifestly unfounded or excessive, in particular because of their repetitive nature, Casino de Madeira reserves the right to charge administrative costs or refuse to comply with the request.
For more information on privacy and data protection, please contact email@example.com.
17. Violations of personal data
In the event of a breach of data and to the extent that such breach is likely to pose a high risk to the rights and freedoms of the User, Casino de Madeira undertakes to report the breach of Personal Data to the User in question within 72 hours of the incident.
Under legal terms, communication to the User is not required in the following cases:
♦ If the Casino of Madeira has applied adequate technical and organizational protection measures, and these measures have been applied to the Personal Data affected by the violation of Personal Data, especially measures that make Personal Data incomprehensible to anyone unauthorized to access such data, such as encryption;
♦ If the Casino of Madeira has taken subsequent measures to ensure that the high risk to the rights and freedoms of the User is no longer likely to materialize; or
♦ If communication to the User implies a disproportionate effort for the Madeira Casino. In that case, the Madeira Casino will make a public communication or take a similar action through which the User will be informed.
18. Applicable law and forum
CASINO DA MADEIRA
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