PRIVACY POLICY

OF THE WEBSITE www.clubedolagohotel.pt

Identification of the Data Controller

Name: SABOIA RESIDENCE LDA.
Registered Office: Rua da Moeda, 4, 1200-275 Lisbon
Company Registration Number: 516 172 948
Telephone: +351 214 666 000 (call to the national fixed-line network)
Email: financeiro@clubedolagohotel.pt

INFORMATION OBLIGATION

The protection of personal data relating to natural persons in Portugal is governed by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and Law No. 58/2019 of 8 August, which ensure the protection of natural persons with regard to the processing of personal data and the free movement of such data.

“Personal data” means any information of any nature and regardless of the medium, including sound and image, relating to an identified or identifiable natural person. The protection therefore does not cover data relating to legal entities.

A person is considered identifiable if they can be identified directly or indirectly, in particular by reference to an identification number or to one or more specific elements of their physical, physiological, psychological, economic, cultural or social identity (for example, their name associated with their telephone number or email address).

By reading this Privacy Policy, the User is informed about the processing of their personal data carried out by SABOIA RESIDENCE LDA. through the website www.clubedolagohotel.pt.

PURPOSES OF PERSONAL DATA PROCESSING

The personal data we collect and process through the aforementioned Website will only be used for the following purposes:

  • Managing the provision of services requested through the Website, such as contact requests or booking management;
  • Sending periodic communications with news relating to the activities of SABOIA RESIDENCE LDA. and the sector in which it operates;
  • Anonymous and aggregated analysis of the use of the services to identify Users’ habits and trends, with a view to improving the services offered and meeting Users’ specific needs;
  • In the event of a contractual relationship, the data collected through this Website, together with any other data obtained within the scope of the contractual relationship, will be used for human resources management, to ensure compliance with legal obligations and to provide employees with the means necessary to carry out their professional activities;
  • Complying with national and international legal provisions or executing orders issued by the competent judicial authorities;
  • Complying with legal obligations arising from applicable data protection legislation, as well as exercising data subjects’ rights, in particular the defence of a right in legal proceedings.

SABOIA RESIDENCE LDA. guarantees the confidentiality of all data provided. Although SABOIA RESIDENCE LDA. collects and processes data securely, using the most appropriate techniques to prevent its loss or manipulation, it should be noted that the transmission of data over open networks does not allow personal data to circulate under conditions of absolute security, and there is a risk that it may be accessed and used by unauthorised third parties.

Failure to provide data marked as mandatory may make it impossible to respond to the data subject’s request.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

SABOIA RESIDENCE LDA. processes Users’ data:

  • when they provide their free, specific, informed and unequivocal consent to the processing of their personal data for specific purposes; and/or
  • when it is necessary for the performance of a contract to which the User is a party, or for taking steps at the User’s request prior to entering into a contract; and/or
  • to comply with legal obligations to which SABOIA RESIDENCE LDA. is subject; and/or
  • for the purposes of the legitimate interests pursued by SABOIA RESIDENCE LDA. or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

The User guarantees that the information provided is true, accurate, complete and up to date, and is responsible for any direct or indirect damage or loss that may be caused as a result of breaching this obligation.

Where the data provided belongs to a third party, the User guarantees that they have informed the third party of the matters set out in this document and obtained their authorisation to provide their data to SABOIA RESIDENCE LDA. for the purposes indicated.

RETENTION PERIOD

SABOIA RESIDENCE LDA. only retains and processes your personal data for as long as is necessary or required to fulfil the purposes described above, applying appropriate data retention criteria to each processing activity and in accordance with applicable legal and regulatory obligations.

SABOIA RESIDENCE LDA. retains personal data in its systems in such a way that data subjects can be identified according to the following criteria:

  • for no longer than is necessary to fulfil the purposes for which the data was collected, unless otherwise required by legal or contractual obligations;
  • to comply with specific legal or contractual obligations;
  • where applicable and lawful, until the Data Subject exercises their right to object or request erasure.

DATA DISCLOSURE

In addition to disclosures made in compliance with legal obligations, the Data Subject’s personal data may be accessed, in addition to SABOIA RESIDENCE LDA., by:

  • external service providers of SABOIA RESIDENCE LDA., acting as data processors;
  • national and international companies belonging to the same group as SABOIA RESIDENCE LDA.;
  • authorities in general, administrations, public entities and bodies, both national and international;
  • SABOIA RESIDENCE LDA.

INTERNATIONAL DATA TRANSFERS

The personal data collected will be processed within the European Economic Area, and there will be no international transfers of data to third countries or international organisations.

In the event that personal data is processed outside the European Economic Area, this will only take place where appropriate safeguards and the required level of protection have been implemented, in accordance with applicable personal data protection legislation.

INFORMATION SECURITY

SABOIA RESIDENCE LDA. has implemented appropriate technical and organisational security measures to ensure the security of the personal data provided by the User, with the aim of preventing its alteration, loss, processing and/or unauthorised access, taking into account the current state of technology, the nature of the data stored and the risks to which it is exposed.

Personal data is processed with the level of protection required by law to ensure its security and prevent its alteration, loss, processing or unauthorised access, taking into account the current state of technology. The User acknowledges and accepts that security measures on the Internet are not infallible.

Where SABOIA RESIDENCE LDA. engages other entities to provide services involving the disclosure of personal data, such entities will be required to adopt the necessary technical and organisational measures to protect personal data against destruction, loss, alteration, disclosure, unauthorised access or any other form of unlawful processing.

EXERCISE OF RIGHTS

In accordance with the provisions of the GDPR, the User may exercise their rights of access, rectification and, where applicable, restriction of processing, erasure, data portability, objection and withdrawal of consent, in accordance with the GDPR, by submitting a written request through any of the following means, specifying the right or rights they wish to exercise:

Email: financeiro@clubedolagohotel.pt
Postal address: Av. Sabóia 1017, 2765-420 Estoril-Cascais, Lisbon, Portugal

SUPERVISORY AUTHORITY

The User also has the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados) regarding matters relating to the exercise of their rights and the protection of their personal data, if they believe that their data protection rights have been infringed.

THIRD-PARTY WEBSITES

The Website may contain advertising, links or other content that link to or redirect to pages and services provided by suppliers, advertisers, affiliates, sponsors of SABOIA RESIDENCE LDA. and other third parties.

However, SABOIA RESIDENCE LDA. does not control the content or links that appear on these pages and is not responsible for the practices employed by such pages or websites. SABOIA RESIDENCE LDA. advises Users to review the privacy policy, as well as the terms and conditions, of such pages.

Browsing or interacting with any other website, including those that contain an external link to the Website, is subject to the terms and conditions of that website. Under no circumstances shall SABOIA RESIDENCE LDA. be responsible for such access or use.

DATA PROCESSING CARRIED OUT BY THE COMPANY THAT DEVELOPS AND MANAGES THE WEBSITE, ACTING AS AN INDEPENDENT DATA CONTROLLER

Without prejudice to the processing of data collected through the Website being the responsibility of SABOIA RESIDENCE LDA., as identified above in Section 1 of this Privacy Policy, we inform the User that MIRAIFUTURE PORTUGAL, LDA., with registered office at Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil, and Company Registration Number 515 139 092, may, in specific circumstances, act as an independent Data Controller, determining the purposes and means of processing autonomously.

This applies, in particular, to data processed to ensure the operation, maintenance and security of the booking engine.

In such cases, the User’s data will be processed in accordance with the information below:

  • Purpose: to ensure the operation, security and continuous improvement of the Website;
  • Legal basis: legitimate interest;
  • Retention period: for the period strictly necessary to fulfil these purposes.

Mirai ensures that, even in these circumstances, it only processes the data that is strictly necessary and adopts appropriate technical and organisational measures to ensure its security and confidentiality.

The User may exercise the rights referred to in Section 9 by submitting a written request through any of the following means, specifying the right or rights they wish to exercise:

Email: portugal@mirai.com
Postal address: Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil

The User may also exercise the rights set out in Section 10.

CHANGES TO THE PRIVACY POLICY

To ensure that this document remains up to date, SABOIA RESIDENCE LDA. reserves the right to review this Policy at any time it deems appropriate. Users are therefore advised to check this Privacy Policy regularly and/or each time they access the Website.

Updated on 23/04/2026.