1. Introduction
The purpose of this document is to provide a concise policy statement on the data protection obligations to be implemented at West Lake Eco Resort, located at Lote do Pinhal Óbidos, Portugal, duly represented by its headquarters and data protection team. This policy includes West Lake Eco Resort’s obligations regarding the processing of personal data to ensure compliance with the requirements of the relevant legislation, while adapting to a continuously evolving landscape and addressing the most significant risks.
2. Grounds
West Lake Eco Resort must comply with data protection principles established in current legislation. This Policy applies to all personal data processing operations, including data collection, processing, and storage by West Lake Eco Resort of personal data belonging to their employees, service providers, and clients during the course of their activities.
3. Scope
The Policy covers all personal data, including data regarding special personal data categories, which are processed in relation to the data subjects by West Lake Eco Resort, as the Data Controller or Subcontractor. This Policy also applies to personal data processed manually, provided this data is included in a structured file. All personal data, including special personal data categories, will be processed with extra care by West Lake Eco Resort. Both categories are equally referred to as “Personal Data” in this Policy, unless stated otherwise.
4. Who processes your data
In the course of daily activities, West Lake Eco Resort may acquire, process, and store personal data. According to European and Portuguese data protection legislation, this data must be lawfully, fairly, and transparently acquired and managed. West Lake Eco Resort is committed to ensuring that its team is sufficiently aware of data protection laws and practices to anticipate and identify any data protection issues that may arise. Under these circumstances, the team must ensure that the Controller is informed, so that appropriate and necessary corrective actions may be taken to protect the rights, freedoms, and guarantees of the Data Subjects. West Lake Eco Resort may share Personal Data of their Data Subjects with Processors provided it is necessary for the normal provision of services. Regarding the obligations of West Lake Eco Resort, Processors’ access to Personal Data shared by the Resort is regulated by contracts made with their Processors. West Lake Eco Resort contractually ensures and regularly verifies that Processors are reliable entities offering appropriate protection guarantees and that no more data is sent to them than is required to provide the contracted service. During the course of their duties as Data Controller, West Lake Eco Resort may also share the Personal Data of their Data Subjects with other Data Controllers to perform processing operations required for providing the contracted services. Within the scope of the aforementioned joint responsibility, West Lake Eco Resort makes an agreement with the other controller, in which the purposes and responsibilities are clearly identified in compliance with the applicable data protection legislation, ensuring compliance with the Rights and Freedoms of Data Subjects by establishing appropriate communication channels to respond to requests from Data Subjects. Regardless of the existing relationship between Personal Data Recipients, West Lake Eco Resort shall outline, by means of a formal written contract, the personal data obligations, the specific purpose(s) of their involvement, and their agreement to perform data processing operations according to the Portuguese Data Protection Law.
5. Your data may be shared with the following Recipients:
- Providers of digital, technical, and operational support services.
- Entities operating under or alongside West Lake Eco Resort management.
- Judicial bodies, and bodies of the Criminal Police and Administrative Authorities.
6. What we do with your data:
As Data Controller, West Lake Eco Resort ensures that all Personal Data:
- Is obtained for specific, lawful, and clearly defined purposes. The Data Subject may question the purpose(s) for which West Lake Eco Resort collects and maintains the data, and the Resort must clearly and precisely state what those purposes are.
- Will be compatible with the purposes for which the data was acquired.
- Will be stored with appropriate security measures – implemented or to be implemented – to protect the data against unauthorized access, or against modification, destruction, or disclosure.
- Will be stored complete, accurate, and updated as necessary.
- Will be collected minimally and stored only for the time strictly necessary.
West Lake Eco Resort has implemented a procedure to respond to Data Subjects’ requests efficiently and appropriately within the time limits set out in the legislation.
All employees of West Lake Eco Resort are also subject to confidentiality standards.
7. Purposes and lawfulness of the Processing operations:
- Clients: West Lake Eco Resort processes Personal Data of Clients to ensure compliance with service agreements, legal obligations, or marketing operations based on consent.
- Employees: Data is processed to enforce employment contracts, comply with legal obligations, and ensure occupational health and safety.
- Service Providers: Data is processed to fulfill service agreements, comply with legal obligations, and safeguard the public interest.
8. Criteria for Calculating Retention Periods:
West Lake Eco Resort will store Personal Data only for the necessary duration to fulfill the purpose behind its collection and processing, varying based on legal standards. Upon expiry, data will be deleted with appropriate technical and operational guarantees.
9. Right of Access and Exercise of Rights:
Data Subjects can exercise their rights under the applicable data protection law by writing to the following email address: westlake@dataprotection.pt. West Lake Eco Resort has appointed a Data Protection Officer who can be contacted at the same address: westlake@dataprotection.pt.
