Privacy Policy
Effective date: April 1, 2020
SCOPE OF THIS PRIVACY POLICY
We ask that you read this Privacy Policy (“Policy”) carefully to understand Casa 12’s policies and practices regarding your Personal Data and how it is processed.
This Policy explains how Consumer Personal Data is collected, used and disclosed by the entity Casa 12, as presented in the section responsible for data processing and contacts (Section 12) (“Casa 12”). It also includes information on how the Consumer can access and update their Personal Data and how to make certain choices about the way their Personal Data is processed.
This policy covers Casa 12's online and offline data collection activities, including Personal Data that it collects through various channels, such as websites, third-party social networks, Consumer support services, points of sale and events. Please note that Casa 12 combines the Personal Data it collects through one method (e.g. website) with the Personal Data it collects through another (e.g. Facebook and Instagram platforms).
If the Consumer does not provide the necessary Personal Data (Casa 12 will indicate when this is the case, for example, by making this information clear on registration forms), Casa 12 may not be able to provide its goods and/or services. This Policy may be changed from time to time (see Section 11).
This Policy provides important information in the following areas:
1. SOURCES OF PERSONAL DATA
2. PERSONAL DATA THAT CASA 12 COLLECTS ABOUT THE CONSUMER AND THE WAY IT DOES IT
3. CHILDREN’S PERSONAL DATA
4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
5. USE OF CONSUMER PERSONAL DATA
6. DISCLOSURE OF CONSUMER PERSONAL DATA
7. RETENTION OF CONSUMER PERSONAL DATA
8. STORAGE AND/OR TRANSFER OF CONSUMER PERSONAL DATA
9. ACCESS TO CONSUMER PERSONAL DATA
10. CONSUMER CHOICES ABOUT HOW CASA 12 USES AND DISCLOSES YOUR PERSONAL DATA
11. CHANGES TO HOUSE 12 POLICY
12. RESPONSIBLE FOR DATA PROCESSING AND CONTACT
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1. SOURCES OF PERSONAL DATA
This Policy applies to all Personal Data that Casa 12 collects from and about the Consumer, through the methods described below (see Section 2), from the following sources: Casa 12 Website. Consumer-directed website operated by or for Casa 12, including mini-sites used on third-party social networks, such as Facebook (“Websites”). Email, text messages (SMS) and other electronic messages. Electronic communications between the Consumer and Casa 12. Data created by Casa 12. During the Consumer's interactions with Casa 12, we may create Personal Data about the Consumer (for example, records of purchases made on our website). Data from other sources. Third-party social networks (e.g. Facebook, Google) or market research (if feedback is not provided anonymously).
2. PERSONAL DATA THAT CASA 12 COLLECTS ABOUT THE CONSUMER AND THE WAY IT DOES IT
Depending on how the Consumer interacts with Casa 12 (online, offline, on the phone, etc.), Casa 12 collects various types of information, as described below. Personal contact details. This includes any information provided by the Consumer, which allows Casa 12 to contact you, such as name, postal address, email address, social media details or telephone number. Account access information. Any information necessary to access the Consumer's account profile. This may include the Consumer's login ID/email address, username, password in non-recoverable form and/or security question and answer. Demographic information and interests. Any information that describes the demographic or behavioral characteristics of the Consumer. This may include the Consumer's date of birth, age or age group, gender, geographic location (e.g. zip code), favorite products, hobbies, interests and household and lifestyle information. Technical information about the computer/mobile device. Any information about the computer system or other technological devices that the Consumer uses to access the Website, such as the Internet Protocol (IP) address used to connect the Consumer's computer or device to the Internet, type of operating system and type and version browser. If the Consumer accesses the website via a mobile device, such as a smartphone, the information collected will also include, where permitted, the unique device ID, advertising ID, geographic location and other similar data from the mobile device. Information about the use of Websites/communications. When the Consumer navigates through the Casa 12 Website or newsletters, interacting with them, Casa 12 uses automatic data collection technologies to collect certain information about the Consumer's actions. This includes information such as the links you click on, the pages or content you view and for how long, and other similar information and statistics about your interactions, such as page response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies (browser cookies, flash cookies) and web beacons; information also collected through the use of third-party tracking. The Consumer has the right to object to the use of such technologies. For more details, see Section 4. Market research and Consumer feedback. This includes information that the Consumer voluntarily shares with Casa 12 about their experience using the products and services it offers. Consumer Generated Content. Refers to any content that the Consumer creates and then shares with Casa 12 on third-party social networks or sends to the Casa 12 website, including the use of third-party social media applications, such as Facebook. Examples may include photographs, videos, personal stories, or other similar media and content. When permitted, Casa 12 may collect and publish Consumer-generated content relating to a variety of activities, including contests and other promotions, website attributes, Consumer engagement and third-party social networks. Third-party social media information. Refers to any information that the Consumer shares publicly on a third-party social network or information that is part of their profile on a third-party social network (such as Facebook) and that the Consumer allows the third-party social network to share with Casa 12 Examples include basic Consumer account information (e.g. name, email address, gender, date of birth, current city, profile picture, user ID, friends list, etc.) and any other information additional information or activities that the Consumer allows the third-party social network to share. Casa 12 receives the Consumer's profile information from the third-party social network (or parts thereof) whenever he downloads or interacts with a Casa 12 application on a third-party social network, such as Facebook, whenever he uses a social network integrated into the Casa 12 website (such as Facebook) or whenever you interact with Casa 12 through a third-party social network. For more information about how Consumer information on a third-party social network is obtained by Casa 12 or to opt out of sharing such social network information, visit the relevant third-party social network website. Payment and financial information. Any information necessary to complete an order or that the Consumer uses to make a purchase, such as details of their debit or credit card (holder name, card number, expiration date, etc.) or other forms of payment ( if available). In any case, Casa 12 or its payment processing service providers handle payment and financial information in accordance with applicable laws, regulations and security standards, such as PCI DSS.
Sensitive Personal Data. Casa 12 does not seek to collect or process sensitive personal data in the normal course of activity. When it proves necessary to process the Consumer's sensitive personal data for any reason, Casa 12 only does so in cases where the Consumer has voluntarily given their prior express consent (for example, for marketing purposes). If Casa 12 processes the Consumer's sensitive personal data for other purposes, it will only do so based on the following grounds: (i) detection and prevention of illicit activities (including fraud prevention); and (ii) in compliance with applicable law (for example, to comply with House 12 diversity reporting).
3. CHILDREN’S PERSONAL DATA
We do not knowingly request or collect personal data from children under the age of 13. If we discover that we have inadvertently collected personal data from a child under the age of 13, we will immediately delete that child's personal data from our records. However, Casa 12 may collect personal data about children under the age of 13 from parents or a legal guardian who expressly consents to such collection.
4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
Cookies/similar technologies. Consult our Cookies Policy to find out how you can manage your cookie settings and for detailed information about the cookies that Casa 12 uses, as well as the purposes for which they are used. Registry Files. Casa 12 may collect information in the format of log files that record activity on the website and collect statistics on Consumer browsing habits. These entries are automatically generated and help Casa 12 resolve errors, improve performance and maintain the security of your website. Web Beacons. Web beacons (also known as “web bugs”) are small sequences of code that provide a graphic image on a web page or in an email with the aim of transferring information back to Casa 12. Information collected through web beacons will include information such as the IP address and information about how the Consumer responds to an email campaign (for example, what time the email was opened, what links the Consumer clicked on in the email, etc.). Casa 12 will use web beacons on its websites or will include them in the emails it sends to the Consumer. Casa 12 uses information from web beacons for various purposes, including, but not limited to, reporting on website traffic, counting unique visitors, auditing and reporting on emails, advertising and personalization.
5. USE OF CONSUMER PERSONAL DATA
The following paragraphs describe the different purposes for which Casa 12 collects and uses Consumer Personal Data, as well as the different types of Personal Data that are collected for each purpose. Please note that not all uses below will be relevant to everyone.
· Compliance with contractual obligations;
· Compliance with legal obligations;
· Legitimate interests of the 12th House;
· Improve and develop products and services;
· Make Casa 12 more efficient;
· Protect the assets and personnel of Casa 12;
6. DISCLOSURE OF CONSUMER PERSONAL DATA
In addition to the Casa 12 entity or ad-hoc partners in the country (responsible for Casa 12 operations) mentioned in the data controllers and contacts section (see Section 12), Casa 12 shares Consumer Personal Data with following organizations: Service providers. These are external companies that Casa 12 uses for assistance and support in its business (e.g. order processing, payment processing, fraud detection and identity verification, website operation, market research companies, support, promotions, website development, data analysis, SAC, etc.). Service providers and their selected team are only permitted to access and use the Consumer's Personal Data in the name and on behalf of Casa 12, for the specific tasks requested of them, based on the instructions given by Casa 12, and are obliged to keep Consumer Personal Data confidential and secure. When required by applicable legislation, the Consumer may obtain a list of suppliers that process their Personal Data (see Section 12 to contact Casa 12). Credit/collection reporting agencies. To the extent permitted by applicable law, credit information and collection agencies are external companies that Casa 12 uses to assist in verifying the Consumer's creditworthiness (in particular for invoiced orders) or to collect outstanding invoices. Third party companies using Personal Data for their own marketing purposes. Casa 12 does not license or sell the Consumer's Personal Data to third party companies for its own marketing purposes, except in situations where the Consumer has given consent. The identity of these third parties will be disclosed at the time the Consumer's authorization is requested. Third party recipients using Personal Data for legal reasons or due to merger/acquisition. Casa 12 will disclose Consumer Personal Data to third parties for legal reasons or in the context of an acquisition or merger (see Section 5 for further details).
7. RETENTION OF CONSUMER PERSONAL DATA
Casa 12 will take reasonable measures to ensure that Personal Data will only be processed for the time necessary to satisfy the purposes set out in this Privacy Policy. The criteria for determining the retention period for Consumer Personal Data are as follows: a) Casa 12 will keep copies of Personal Data in a form that allows identification during: i. The duration of the relationship with the Consumer (e.g. when the Consumer is included in a newsletter sending list and has not stopped subscribing to it); ii. The period in which the Personal Data is necessary in connection with the purposes set out in this Privacy Policy and Casa 12 has a legal basis for keeping it; Furthermore, b) The duration of: i) any applicable legal period (e.g.: period legally provided for the Consumer to take legal action) and ii) an additional period of 2 months after the period described above (so that the House 12 can identify any Personal Data of a consumer who may take legal action after the period set out in i), and c) Additionally, if any relevant legal actions are brought, Casa 12 may continue to process the Consumer's Personal Data for the necessary period of the respective legal action. During the situations described in paragraphs b) i) and b) ii), Casa 12 will restrict data processing to storage and apply the respective security measures, except if such Personal Data needs to be reviewed or accessed following a complaint. or any legally stipulated obligation. After the periods set out in paragraphs a), b) and c) are completed, Casa 12 will permanently delete or destroy the Consumer's Personal Data or, alternatively, may anonymize them.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF CONSUMER PERSONAL DATA
Casa 12 uses several reasonable measures (described below) to keep Consumer Personal Data confidential and secure. Please note, however, that such protections do not apply to information that the Consumer chooses to share in public areas, such as third-party social networks. People who can access Consumer Personal Data. The Consumer's Personal Data will be processed by Casa 12 employees or authorized service providers, accessing only the strictly necessary data, depending on the specific purposes for which the Consumer's Personal Data was collected (for example, the team responsible for matters of Consumer support will have access to the Consumer register). Measures applied in operational environments. Casa 12 stores Consumer Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. Casa 12 follows reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and, although Casa 12 makes every effort to protect Consumer Personal Data, it cannot guarantee the security of data during transmission via Casa 12 websites or applications. . Measures that the Consumer must adopt. It is important that the Consumer also plays an active role in keeping their Personal Data safe and protected. When signing up for an online account, the Consumer should choose a password that is difficult for others to guess and never reveal their password to anyone. The Consumer is responsible for any use of their account and for keeping this password confidential. If the Consumer uses a shared or public computer, they should never select the option to remember their access data, email or password and make sure to log out every time they leave the computer. The Consumer must also make use of any privacy settings or controls that Casa 12 provides on its website or applications.
9. DIREITOS DO CONSUMIDOR RELATIVAMENTE AOS SEUS DADOS PESSOAIS
Access to personal data. The Consumer has the right to access, review and request a physical or electronic copy of the information held about him. The Consumer also has the right to request information about the origin of their Personal Data. These rights can be exercised by sending us an email to info@casa12azores.com or to Casa 12, Rua da Conceição nr 12 9900-080 Horta, providing proof of identification. If the order is submitted by a person other than the Consumer, without providing evidence that the order was legitimately made in their name, it will be rejected. Please note that any identifying information provided to Casa 12 will only be treated in accordance with and to the extent permitted by applicable law. Additional rights (e.g. modification, deletion of Personal Data). When provided for by law, the Consumer may (i) request the deletion, portability, correction or review of their Personal Data; (ii) limit the use and disclosure of Personal Data; and (iv) revoke consent for any of Casa 12’s data processing activities. Under applicable legislation, the Consumer also has the following rights regarding their Personal Data: • The right to object, based on the Consumer's particular situations, to the use of Personal Data by Casa 12, or its representatives;
• The right to object to the processing of Personal Data by Casa 12 or its representatives for direct marketing purposes. Please note that, in certain circumstances, Casa 12 will not be able to delete the Consumer's Personal Data without also deleting their user account. Casa 12 may be obliged to retain some of the Consumer's Personal Data after the Consumer has requested its deletion, in order to satisfy its contractual or legal obligations. Casa 12 may also be authorized by applicable laws to retain some of the Consumer's Personal Data to meet its commercial needs. When available, the Casa 12 website has a dedicated tool through which the Consumer can review and edit the Personal Data they have provided. Please note that Casa 12 requires its registered Consumers to confirm their identity (e.g. login ID/email address, password) before they can access or make changes to their account information. This helps to prevent unauthorized access to the Consumer's account. Casa 12 hopes to be able to satisfy any questions the Consumer has about the way we treat their Personal Data. However, if the Consumer has unresolved doubts/issues, they also have the right to complain to the competent data protection authorities.
10. CONSUMER CHOICES ABOUT HOW CASA 12 USES AND DISCLOSES YOUR PERSONAL DATA
Casa 12 strives to give the Consumer options related to the Personal Data they provide. The following mechanisms provide the Consumer with the following control over their Personal Data: Cookies/similar technologies. The Consumer manages their consent through (i) the Casa 12 consent management solution or (ii) their browser, to refuse all or some cookies/similar technologies, or to receive alerts when they are being used. See Section 4 above. Advertising, marketing and promotions. The Consumer can consent to Casa 12 using their Personal Data to promote their products or services, they can indicate this through the relevant check box(es) located on the registration form or answering questions presented by commercial demonstrators, SAC Collaborators. If the Consumer decides that they no longer wish to receive such communications, they may unsubscribe from marketing-related communications at any time by following the instructions provided in each communication. In order not to receive marketing communications sent by any means, including third-party social networks, the Consumer can deactivate them at any time by accessing the website/application or third-party social networks and adjusting their user preferences in the account profile, unchecking the relevant boxes or by calling Casa 12's SAC. Please note that, even if the Consumer chooses not to receive marketing communications, they will still receive operational communications from Casa 12, such as confirmations of orders or other transactions, notifications about activities (e.g. account confirmations, password changes, etc.) and other important non-marketing announcements Personalization (offline and online): Whenever required by law, if the Consumer wishes for their Personal Data to be used by Casa 12 to provide them with a personalized experience/advertising and targeted content, they can indicate so through the box(es) relevant verification s) on the registration form or by answering the question(s) presented by the commercial demonstrators or SAC. If the Consumer decides that they no longer wish to benefit from this situation, they can cancel reception at any time by accessing the website/application and adjusting their user preferences in the account profile, unchecking the relevant boxes or calling Casa 12 SAC . Interest-based advertising. Casa 12 partners with ad networks and other ad serving providers ("Advertising Providers") that serve advertising on behalf of Casa 12 and on behalf of other unaffiliated companies on the Internet. Some of these advertisements are tailored to the Consumer's interests based on information collected on Casa 12 websites or non-affiliated websites over time. You may also stop the collection of precise location data from your mobile device through your mobile device's location services settings.
11. CHANGES TO CASA 12 POLICY
Casa 12 will update this privacy policy if it changes the way it treats Consumer Personal Data. Casa 12 reserves the right to make changes to its practices and this Policy at any time; Please check back regularly for any updates or changes to the Casa 12 policy.
12. RESPONSIBLE FOR DATA PROCESSING AND CONTACT
To ask questions or comments about this policy and Casa 12's privacy practices or file a complaint about Casa 12's compliance with applicable privacy laws, please contact Casa 12 at: info@casa12azores.com or postal letter to Casa 12, Rua da Conceição nr 12, 9900-080 Horta. Casa 12 will confirm receipt and investigate any complaint about the way it processes Personal Data (including complaints alleging that Casa 12 has violated the Consumer's rights under applicable privacy laws).