CONFIDENTIALITY POLICY

At ATLANTIDA - VIAGENS E TURISMO, S.A. we respect your privacy and thank you for your trust in us. In this Privacy Policy we explain who we are, for what purposes we may use your data, how we treat it, with whom we share it, for how long we keep it, as well as the ways to contact us and exercise your rights.

Your data will be processed by "ATLÂNTIDA - VIAGENS E TURISMO, S.A.", legal entity number 502 607 971, with head office at Avenida João Crisóstomo, n.º 16, 1000-179, district of Lisbon, with the share capital of EUR 10,000,000.00 (ten million euros), henceforth "ATLÂNTIDA" or "we". ATLANTIDA is dedicated to the exercise of activities specific to travel and tourism agencies and complementary activities

This company is the controller of personal data within the meaning of the General Regulation on Data Protection ("RGPD").

The processing of your data is necessary for the performance of the services to be concluded with ATLANTIDE, or for carrying out pre-contractual procedures at your request.

For questions concerning the processing of your personal data you should contact us by the following means:

Telephone: +351 217228210

Address: Av. João Crisóstomo, N 16. 5º andar, 1000-179 - Lisbon

Email: lisboa@atlantidawta.com

Why do we need your information?

1. Access to Personal Data

The confirmation of the reservation implies the introduction in the system, by the CLIENTS, or by ACCOUNT, by automated or non-automated means, of personal identification data, and data referring to credit and debit cards, which will be used to facilitate and allow the hiring and reservation of the specific services that comprise the CLIENT's request, as well as to provide information regarding ATLANTIDE products and services.

Under no circumstances shall information be requested concerning philosophical or political beliefs, party or trade union membership, religious faith, private life and racial or ethnic origin as well as data concerning health and sex life, including genetic data.

The processing of personal data shall be carried out in strict compliance with personal data protection legislation, in accordance with the provisions of Regulation (EU) 2016/679 of the Parliament and of the Council, and/or any legislation regulating, supplementing or replacing that legislation.

Any personal data that CLIENTS may disclose to ATLANTIDE shall be understood as obtained, processed and transmitted in strict compliance with the RGDP.

By providing their personal data the CLIENTS declare that they authorize and consent to the processing of their data by ATLÂNTIDA for the purposes of facilitating and allowing the hiring and reservation of the specific services that make up their request, as well as to receive information regarding products and services made available by ATLÂNTIDA.

If the CLIENT wishes to exercise the rights of access, rectification, cancellation or opposition that the RGDP grants them, he/she must send an e-mail to  lisboa@atlantidawta.com or to be cancelled by the means available at the reception of the Newsletter.

2. Processing of Personal Data

Under the law, "personal data" means any information of any kind and regardless of its medium, including sound and images, relating to an identified or identifiable natural person, and therefore the protection does not extend to the data of legal persons.

Upon acceptance of this Privacy Policy the CLIENT gives informed, express, free and unequivocal consent for the personal data provided, namely, through the site www.atlantidawtaviagens.com are included in a file under the responsibility of ATLANTID, the processing of which under the RGPD complies with the appropriate technical and organisational security measures.

ATLANTIDA declares that it has implemented and will continue to implement the security measures of a technical and organizational nature necessary to ensure the security of personal data provided to it in order to prevent its alteration, loss, processing and/or unauthorized access, taking into account the current state of technology, the nature of the data stored and the risks to which they are exposed.

Personal Data obtained through registration, by automated or non-automated means, are incorporated into a computer application owned by ATLÂNTIDA.

ATLANTIDA employees access the information in an archive with the insertion of access passwords, whose registration is documented.

The alteration to the existing data in the archives is possible leaving a record of the date of the person responsible for the alteration.

The CLIENT is aware and accepts that Internet security measures are not impregnable.

ATLANTIDE is equipped with technical infrastructure for peripheral control that meets security requirements.

Credit card details are used only for payment and after the transaction is made, they are deleted from our records, unless the CLIENT has authorized us to keep them.

For security reasons applicable to certain countries, it is obligatory to place information concerning data such as name, passport number, gender, age, nationality in flight reservations. Such information contained in the reservation may, in accordance with applicable law, in particular on the basis of Directive (EU) 2016/680 of the European Parliament and of the Council, be consulted by the competent authorities of the countries of origin or destination for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, and the free movement of such data and Directive (EU) 2016/681 of the European Parliament and of the Council.

ATLANTIDE, by accessing any personal data, undertakes to:

- Protect the personal data of CLIENTS through security measures, legally required, of a technical and organizational nature in order to prevent alteration, loss, processing or unauthorized access, in accordance with the state of technology at any time, the nature of the data and the possible risks to which they are exposed;
- To use or apply the data solely for the purposes intended;
- Ensure that the data are used solely for the provision of the service and are bound by the duty of secrecy and confidentiality. If the information can be disclosed to third parties, they should be obliged to keep it duly confidential in accordance with the provisions of this document.

- Security

Please ensure that you have provided us with your credit card details correctly, otherwise your booking may be delayed and the total costs may change due to late booking.

ATLANTIDA reserves the right to cancel the reserved services after confirmation of the reservation if payment is refused by the credit card issuer or if you have provided us with incorrect data.

ATLANTIDIA also reserves the right to carry out random checks in order to minimise credit card fraud, in particular to request, before confirmation of the reservation, the most recent proof of address or statement of account. The documents provided shall be used exclusively to confirm the data provided and shall be destroyed as soon as they are no longer required.

- Data Purpose

Personal Data are obtained for the purpose of:

(i) Owned the activity linked to a travel agency, wholesale and retail;
(ii) Supply to those involved in the services requested by the CLIENT in order to make the reservation / service contracted by the CLIENT;
(iii) Management, administration, provision, expansion and improvement of services in which the CLIENT decides to subscribe and register or use the adequacy of these services to the preferences and tastes of the CLIENTS;
(iv) Check credit cards and other types of cards used in payment and indicated by the CLIENT himself;
(v) the study of the use of services by CUSTOMERS;
(vi) verify, maintain and develop statistical systems and analyses;
(vii) Advertising, promotion and commercial prospecting activities if duly accepted by the CLIENT, Newsletters;
(viii) Send out survey forms to which the CLIENT is not obliged to respond;
(ix) Send SMS messages for the purpose of direct sale, advertising or related to the contracted service, if duly authorized and consented by the CLIENT.

The CLIENT may consent to ATLANTIDA's processing of their Personal Data in order to determine their profile and offer them suitable products and services. These services may be owned or provided by third parties.

In addition, the CLIENT will expressly consent to the Personal Data being transferred to:

(i) national and international authorities responsible for tourism, terrorism or offences against human rights;

(ii) any legal entity which is subsidiary or participated by ATLANTIDE or the company which has provided the contracted service (hotels, water, land, rail, air, rent, etc...), so that they may use them for the purpose of the correct provision of each service requested by the CLIENT.

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

On the other hand, the CLIENT consents to have access to the information related to the service contracted with ATLANTIDA in order to be able to offer additional services to the contractor.

Failure to respond to the data, which are considered obligatory, will make it impossible to access the service for which the data was requested.

ATLANTID may disclose the CUSTOMERS' information to third parties solely for the purpose of completing the reservation requested and for administrative reasons in accordance with the legislation in force for the implementation of travel/service to certain countries.

Any data collected by automated or non-automated means will be transmitted, in accordance with the RGDP, to the entities involved to contract the required services to the extent absolutely necessary for the completion of the reservation / service desired and to comply with the legislation of the countries of destination.

If you do not agree with the above conditions, ATLANTID can not contract with you and therefore cannot accept your reservation.

- Marketing

ATLANTIDA may process your data to send you electronic communications with information regarding commercial and promotional communications.

This data processing will be carried out only with your consent. If you consent, you will receive marketing communications via e-mail and SMS.

Consent to the processing of personal data for direct marketing purposes may be withdrawn at any time by sending an e-mail to the following address lisboa@atlantidawta.com or through the link enabled for that purpose in the communications themselves.

Your data will be kept for this purpose for 2 years of inactivity.

3. Will my information be shared with others?

Your personal information may be disclosed:

- Within the ATLANTIDE Business Group.
- Third-party service providers of ATLANTIDE.

Your personal data may be processed by ATLANTIDA's subcontractors, in particular for hosting, e-mail, answering users' questions about services, sending information about new services and products, special offers. These companies shall be provided only with the personal data necessary for the provision of the service in question.

4. What are my rights?

At any time, you can ask us:

- Access to the information we have about you;
- The rectification of information if incorrect or incomplete;
- To delete or limit the processing of your personal data;
- If the processing is subject to your consent or agreement and is carried out by automated means, you have the right to have the personal data previously supplied sent in a structured, commonly used and computer-readable form.

Your requests will be handled with special care so that we can ensure the effectiveness of your rights. You may be asked to provide proof of your identity in order to ensure that the personal data is only shared with the owner.

You should be aware that in certain cases (e.g. due to legal requirements) your request may not be met immediately.

In any event, it shall be informed of the measures taken to that end, at the latest one month after the request is made.

It also has the right to lodge a complaint with the National Data Protection Commission.

a) Right of Access

The data subject shall have the right to obtain confirmation from ATLANTIDA as to whether or not data concerning him is being processed and, if so, to have access to his personal data and to the information provided for by law.

b) Right of Rectification

The data subject shall have the right to have inaccurate or incomplete data concerning him corrected by ATLANTIDA without undue delay.

(c) Right to Erasure of Data ("Right to be Forgotten")

The data subject shall have the right to request ATLANTIDA to delete his or her data without undue delay, and ATLANTIDA shall be obliged to delete the personal data where one of the following grounds, inter alia, applies:

(a) the personal data are no longer necessary for the purpose for which they were collected or processed;

(b) the data subject has withdrawn his consent to the processing (where the processing is based on consent) and there is no other basis for the processing;

(c) the holder opposes the treatment and there are no overriding legitimate interests justifying the treatment;

d) Right to Limitation of Treatment

The data subject shall have the right to obtain from ATLANTIDE the limitation of the processing if, inter alia, one of the following situations applies:

(i) contest the accuracy of the personal data for a period of time that allows ATLANTIDA to verify their accuracy;

(ii) the processing of the data is lawful and the data subject opposes the erasure of his personal data and requests, in return, that their use be limited;

(iii) ATLANTIDE no longer needs the personal data for processing purposes, but such data are required by the data subject for the purpose of declaration, exercise or defence of a right in a legal proceeding;

(iv) if he opposed the processing, until it is established that the controller's legitimate grounds prevail over those of the data subject.

e) Data Portability Right

If the processing depends on the consent of the data subject and that consent has been given by automated means, the data subject shall have the right to receive the personal data concerning him/her which he has supplied to ATLANTIDA in a structured, commonly used and automatically readable format.

(f) Right of opposition

Where the data are processed for the purposes of ATLANTIDIA's legitimate interests; or the data are processed for the purposes of direct marketing; the data subject may at any time object to the processing of his personal data.

g) Can I revoke my consent later?

If consent is legally required for the processing of personal data, the data subject has the right to withdraw consent at any time, although this right shall not affect the lawfulness of the processing carried out on the basis of the consent previously given or the further processing of the same data on another legal basis, such as the fulfilment of the contract or legal obligations to which ATLANTIDA is subject.

If you wish to withdraw your consent, you can contact us by letter, phone or e-mail lisboa@atlantidawta.com

5. How does ATLANTID use cookies and similar technology?

Cookies are small files that are saved on the CUSTOMER's computer and serve only to identify the computer that is accessing the web site.

Those files do not contain any personal information. Cookies are generally limited in time. No cookie can extract information from the CLIENT's computer hard drive, steal personal information or read cookie files created by other vendors.

Thanks to cookies, it is possible for ATLANTIDA to recognize duly registered CUSTOMERS, as long as they use the same equipment and browser, without having to register at each visit to access the areas and services exclusively reserved for them. The CLIENT is free to reject our cookies if the browser allows it, but by doing so may be compromising the full functionality of the web sites used.

This technology is used by ATLANTIDE mainly for:

- Collect IP addresses from users. The cookie information identifies the user and if the user is subscribed to any service, promotion, contest or event promoted by us, it gives the system an order to access the information about the user that we have stored. Thus, we can customize the user's preferences and facilitate the use of their services.

- Carry out statistical studies to distinguish between regular users, so as to be able to calculate the quantity of users and their growth.

- Recognize whether users have viewed a certain part of the web page and thus avoid the repetitive appearance of the page itself.

You can also consult our Cookie Policy.
6. Video surveillance

ATLANTIDA facilities have a video surveillance system, duly signposted. The installation of this system is a legal obligation of ATLANTIDA, in accordance with the Private Security Law (Law no. 34/2013, of 16 May, art. 8 no. 2).

Image recordings obtained by video-surveillance systems are kept in encrypted form for a period of 30 days from their capture, after which they are destroyed (without prejudice to their conservation for a longer period in the event of legal proceedings).

7. Do you have any questions?

If you have any questions regarding the processing of your personal data, or wish to exercise any of your rights, please contact us:

- By phone:+351 217228210

- By e-mail: lisboa@atlantidawta.com

Conditions of use of the Site
1.Object
1.1 The atlantidawtaviagens.com website, including logos, trademarks, copyrights and services, is the property of ATLÂNTIDA VIAGENS E TURISMO S.A, Sociedade Anónima with head office in Lisbon, Av. Columbano Bordalo Pinheiro, Nº 61 B with licence no. 610/1991
1.2 These General Conditions of Use are intended to establish the terms and conditions under which access to the information and content available on the atlantidawtaviagens.com website will be governed.

2. Intellectual Property Law
2.1. The atlantidawtaviagens.com website is for your personal, non-commercial use. All reproduction, transmission, exhibition, publication, distribution, making available to the public, creation of derivative works, modification, adaptation, translation, transfer or sale of any information, products or services obtained through this site and any other forms of exploitation, total or partial, of the content and materials of the atlantidawtaviagens.com site, namely, text, images, software, audio or video clips, is protected by Portuguese and international copyright law and is totally prohibited without prior written authorisation from ATLÂNTIDA VIAGENS E TURISMO S.A.
2.2 The use, obtaining or storage of the contents, materials, functions and information made available on the atlantidawtaviagens.com website may only be carried out by the means foreseen and provided on the same. In particular, the partial removal of text and/or images and their reproduction in another context, or the complete reproduction of the atlantidawtaviagens.com site on another site, are prohibited without the prior written consent of ATLÂNTIDA VIAGENS E TURISMO S.A.

3. Responsibility
3.1. ATLANTIDA VIAGENSES AND TOURISM makes no warranties of any kind, express or implied, including, but not limited to, warranties of title, non-infringement, implied warranties of merchantability or fitness for any particular purpose, regarding the availability, accuracy, reliability or content of these pages.
3.2 Under no circumstances shall ATLÂNTIDA VIAGENS E TURISMO S.A. be held liable for any losses, including lost profits and emerging damages, that are directly or indirectly related to the use, or the impossibility of use, of the contents, materials, functions and information made available through the atlantidaWTAviagens.com website, even if ATLÂNTIDA VIAGENS E TURISMO S.A. has been informed of the possibility of such damages.
3.3 The limitation of liability set out in the preceding paragraph includes all damage caused to the User's computers by direct or indirect, incidental or consequential use of the atlantidawtagens.com website, as well as any damage caused by the spread of viruses, "trojans" and "worms", whatever their origin and mode of transmission.
3.4 All contents, materials, functions and information made available on or through the atlantidawtaviagens.com website are provided as they appear on it and are disclosed, without any guarantee of any kind provided by ATLÂNTIDA VIAGENS E TURISMO S.A.
3.5.The atlantidawtaviagens.com site may contain information, addresses or materials from other sites not belonging to ATLÂNTIDA VIAGENS E TURISMO S.A, for which the authors of those sites are solely and exclusively responsible. ATLÂNTIDA VIAGENS E TURISMO S.A is not responsible for the information, addresses or materials included in these sites.
3.6. The atlantidawtaviagens.com website may contain "links" (electronic links) to third-party websites. Such links are merely informative and ATLÂNTIDA VIAGENS E TURISMO S.A does not assume any responsibility for the accuracy, completeness or legality of the content of these websites, or for any information, opinions, product or service offers contained therein. ATLÂNTIDA VIAGENS E TURISMO S.A declares that it does not have any control, with regard to the risk of confidentiality, security and others, over third party sites.
3.7. By sending materials to any of ATLÂNTIDA VIAGENS E TURISMO S.A's servers by e-mail or through the ATLÂNTIDA VIAGENS E TURISMO S.A. pages on its website, the User agrees to the following: (i) the materials shall not contain any element that is illegal or inappropriate for publication; (ii) it shall search for and eliminate any viruses or other destructive aspects before presenting any material; (iii) it owns the material it sends or has an unlimited right to provide it; (iv) ATLÂNTIDA VIAGENS E TURISMO S.A may publish these same materials free of charge and/or incorporate them or any of the concepts described therein in its products.

4. Information on prices and conditions
All information provided on the atlantidaWTAviagens.com website about prices and availability of services, is merely approximate and indicative, and does not bind ATLÂNTIDA VIAGENS E TURISMO S.A. To obtain more information about the general conditions for the provision of services by ATLÂNTIDA VIAGENS E TURISMO S.A.

5. Amendments
ATLÂNTIDA VIAGENS E TURISMO S.A reserves the right to insert, change and remove, without prior notice and at its sole discretion, any information in these Conditions of Use. The user is responsible for reviewing the content of these Conditions of Use whenever consulting trips through the website atlantidawtaviagens.com. The use of the atlantidawtaviagens.com website, after any changes introduced by ATLÂNTIDA VIAGENS E TURISMO S.A, will be considered as tacit acceptance of them.

6. Legislation and Jurisdiction
6.1 Portuguese law shall apply to all disputes arising from the interpretation or enforcement of these Terms of Use.
6.2 All disputes arising from the interpretation or execution of these General Conditions of Use shall be settled in the Court of the District of Lisbon, with express waiver of any other.

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