Privacy Policy
LEGAL INFORMATION REGARDING DATA PROTECTION
At the EMBRACE Group, we understand that the use of your personal data requires your trust. We are subject to the highest privacy standards and will only use your personal data for clearly identified purposes and in accordance with your data protection rights.
The confidentiality and integrity of your personal data are among our main concerns.
This Privacy Policy establishes how the EMBRACE Group uses the personal data of its clients and potential clients within the scope of this Homepage and is composed of the following sections:
WHICH COMPANIES MAKE UP THE EMBRACE GROUP
The EMBRACE Group in Portugal carries out its activity through the entity, Travel Store - Prestação de serviços de viagens, SA., headquartered at Campo Grande, 35 – 1A, registered at the Commercial Registry Office of Lisbon under the unique registration and legal entity number 503 903 310 (hereinafter solely "TRAVELSTORE"), manages the website www.travelstore.pt, and promotes the brands Allways, Travelstore American Express GBT, Emotionstore and Lab owned by TRAVELSTORE in Portugal.
WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA
The EMBRACE Group is responsible for the processing of the personal data of its clients and/or potential clients.
HOW WE COLLECT YOUR PERSONAL DATA
Your personal data will be collected and processed in the following situations:
• Following a commercial agreement, your company provides us with your personal data, essential for managing your trips.
FOR WHAT PURPOSES AND ON WHAT GROUNDS YOUR PERSONAL DATA MAY BE USED
Your personal data will be collected and used for Customer Assistance and Marketing purposes. Under the data protection legislation in force in the European Union (the General Data Protection Regulation), the use of personal data must be justified under at least one legal basis for processing personal data. You can consult the explanation regarding the scope of each of these grounds.*
The legal basis applicable to the collection and use of your personal data for customer assistance and marketing purposes is your consent.
*Legal grounds for processing personal data
• When you have given consent to the processing of your personal data;
• When processing is necessary to enter into a contract with you or proceed with its execution;
• When processing is necessary for compliance with legal obligations to which the EMBRACE Group is subject;
• When processing is necessary for achieving a legitimate interest and our reasons for its use outweigh your data protection rights;
• When processing is necessary for us to declare, exercise, or defend a right in court proceedings against you, us, or a third party.
WHAT PERSONAL DATA MAY BE COLLECTED
The following categories of personal data may be collected through the channels and services described in this Privacy Policy:
Data collected by the EMBRACE Group:
Contact information
Name; address; email; telephone; mobile phone
Personal information
Date of birth; citizen card number; citizen card expiry date; passport number; passport expiry date; preferred seat on airplane journeys
Identification data
Name of the company you belong to, function you perform in the company; department; area; employee number and cost center
Client history
Client satisfaction ratio; services acquired, date of purchase and price;
HOW WE KEEP YOUR PERSONAL DATA SECURE
We use a variety of security measures, including encryption and authentication tools, to help protect and maintain the security, integrity, and availability of your personal data.
Although data transmission over the internet or website cannot guarantee complete security against intrusions, we and our service providers and commercial partners make best efforts to implement and maintain physical, electronic, and procedural security measures designed to protect your personal data in accordance with applicable data protection requirements. Among others, we have implemented the following:
• Restricted personal access to your personal data based on the "need to know" criterion and only within the scope of the communicated purposes;
• Transfer of collected data only in encrypted form;
• Storage of highly confidential data (such as credit card information) only in encrypted form;
• Protection of information technology systems through firewalls, aiming to prevent unauthorized access to your personal data; and
• Permanent monitoring of access to information technology systems with a view to preventing, detecting, and preventing the misuse of your personal data.
FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA
We retain your data only for the period necessary within the scope of the purpose for which it was collected.
Once the maximum retention period is reached, your personal data will be irreversibly anonymized (anonymized data may be retained) or will be securely destroyed.
For the purposes described in this Privacy Policy (customer assistance and "marketing"), your personal data will be retained until explicit information of withdrawal of your consent.
WITH WHOM WE MAY SHARE YOUR PERSONAL DATA AND HOW WE KEEP IT SECURE
The EMBRACE Group is a group with offices in Portugal, Angola, and Mozambique. Therefore, your personal data may be accessed by our suppliers or service providers located in countries outside the EEA (European Economic Area), for the purposes described in this Privacy Policy, where data protection legislation may be less stringent than that in force in the EEA.
We guarantee that your personal data exported outside the EEA will be treated in accordance with appropriate security measures.
Your personal data may be transferred to service providers located in the USA who have adhered, with the United States Department of Commerce, to the EU-US Privacy Shield.
Please contact us* if you wish to request information on the specific safeguards that have been applied to the export of your data to suppliers/service providers located outside the EEA.
Your personal data is stored on the protected servers of our suppliers/service providers, and is accessed and used exclusively under our policies and standards (or equivalent policies and standards of our suppliers/service providers).
* EMBRACE Group and Data Protection Officer Contact Details
EMBRACE Group
Data Protection Officer
rgpd@travelstore.pt
Travelstore Customer Support Service
Telephone line: +351 213565300, available from 8:00 am to 8:00 pm from Monday to Friday
Email: operacoes@travelstore.pt
EMBRACE Group Portal: https://www.embraceambition.com
HOW YOU CAN CHANGE OR WITHDRAW YOUR CONSENT
You can, at any time, change or withdraw your consent, with effects for the future.
After total withdrawal of your consent declarations, you will no longer be contacted and will stop receiving communications for the purposes described in this Privacy Policy.
To withdraw your consent declarations submitted to the EMBRACE Group, simply send your request to the email address: rgpd@travelstore.pt
CONTACT US, YOUR DATA PROTECTION RIGHTS AND THE RIGHT TO LODGE A COMPLAINT WITH YOUR SUPERVISORY AUTHORITY
If you have any questions related to our use of your personal data, you should contact the Data Protection Officer via the email address: rgpd@travelstore.pt
Subject to certain conditions, you may have the right to ask us to:
• provide you with additional information about how we use your personal data;
• provide you with a copy of the personal data you have provided to us;
• provide the personal data you have provided to us to another data controller at your request;
• update any inaccuracies in the personal data we hold;
• delete personal data whose use is no longer legitimate;
• limit the way we use your personal data until the complaint filed is investigated.
Your exercise of these rights is subject to certain exceptions aimed at safeguarding the public interest (prevention or detection of crimes) or our interest (maintenance of professional secrecy).
If you exercise any of these rights, we will proceed with their analysis and will respond, expectably, within 1 (one) month.
If you are dissatisfied with our use of your personal data or with our response after exercising any of these rights, you have the right to lodge a complaint with your supervisory authority in Portugal (Comissão Nacional de Proteção de Dados – CNPD | Rua de São Bento, Nº 148, 3º, 1200-821 Lisboa | Tel: +351 213928400 | e-mail: geral@cnpd.pt).
