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Personal Data Protection Policy

Data Controller 

The entity promoting the voyage, Santa Maria Manuela Turismo, S.A., with headquarters at Rua Actor António Silva, nº 7, in Lisbon, registered at the C.R.C. Lisbon under tax number 515 755 028, hereinafter referred to as SMM, is the Data Controller. 

Personal Data under Processing 

While attending this voyage, your voice and/or image may be recorded, including testimonials  related to the trip, either on video or in photographs.  

Lawfulness and Purposes for Data Processing and Storage Period 

The personal data we collect will be used for the purpose of communication and institutional  promotion of the SMM: the image and/or voice of those who attended the voyage (on video and/or  in photographs), based on your consent. 

The aforementioned purpose will be pursued by the Data Controller and, for situations provided for  in the “Communication of Personal Data” paragraph below, by the Jerónimo Martins Group  companies, of which the Data Controller is a part, through the promotion of the activity, individually  or together with other similar or related activities.  

Personal data collected may be freely reproduced in photographs, videos or other internal or  external communication material produced by the Data Controller or by the companies to which the  respective personal information is provided, pursuant to the terms stipulated below, individually or  together with other images and/or voice recordings. Such images and/or voice recordings may be  used and adapted in any way and disclosed in any territory, using the internal and external means  of dissemination available to the aforementioned entities, or which such entities use, namely the  intranet, in-house magazines and newsletters, corporate websites, social media and external media  produced and edited by third parties. 

Personal data recorded during the voyage will be stored by the Data Controller and the other Jerónimo Martins Group companies with whom they have been shared for as long as the internal communication network (intranet), website or social media pages exist. Such personal data may be used for institutional promotion during the same period of time. 

Personal data will also be stored for the purpose of maintaining the Data Controller's historical and  rolling records, for which there is a corresponding legitimate interest, ensuring the adequate security  measures, in accordance with the law. 

Data Subject’s Rights and How to Exercise such Rights 

Pursuant to prevailing legislation, data subjects have the right of access and rectification, portability and erasure of their personal data as well as the right of restriction of and to object to the processing of their data. When processing is solely on the grounds of user consent, you may also, at any time, withdraw your consent, without affecting the lawfulness of processing to date. 

You may exercise any of the aforementioned rights, within the limits stipulated by applicable law, through an e-mail

If you did not give your consent or if you object to this type of processing, you should ask the SMM crew, prior to attendance, for an identifier, such that the Data Controller can ensure that your voice and image are not recorded during the voyage.  

You also have the right to lodge a complaint with the Supervisory Authority in Portugal (CNPD).Security Measures 

To ensure the security of the personal data processed, SMM has implemented the technical and organisational security measures it deems necessary for such processing. 

Communication of Personal Data 

When personal data is to be reproduced using external media, such data may be shared with publications that are printed and edited by third-party entities, as well as social media and platforms, all of which have their own Privacy Policies. 

Personal data collected may be shared with Jerónimo Martins Group companies and reproduced, adapted or reused by said companies for the aforementioned processing purposes. The Jerónimo Martins Group, of which the Data Controller is a part, is made up of companies that, as the case may be, are involved in the management of equity holdings in associated companies and providing management services to such companies, as well as food distribution, food and specialised retail, catering, animal husbandry, dairy and aquaculture, located in Portugal, Poland and Colombia.  

Within the scope of the previously stated processing purposes, the Data Controller may also use other companies that are part of the Jerónimo Martins Group or partners and external service providers, namely agencies related to content production, management and communication, development, maintenance, hosting and information systems. In either case, the appropriate security measures shall be ensured to safeguard your personal data. The personal data we process may be transferred to entities located in countries outside of the European Economic Area. However, the appropriate and legally stipulated security measures will be ensured when such occurs.