Published: 3 April, 2023
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1. The Commitment of Kaveo
Protecting privacy and personal data is a fundamental commitment of Kaveo towards all customers (“Customers”) of its services and products.
The information provided to us, as well as that sent to us through our website, by email or by any other means, will be processed with the utmost confidentiality, and in accordance with applicable European or national legislation.
The personal data collected will only be those required for the purposes for which they are intended, namely for the processing of bookings, and for technical and commercial contacts related thereto, as well as regarding other legitimate purposes for the relationship established between both parties. Additionally, the Customer may actively mention whether he/she authorizes the use of his/her personal data previously provided or others that he/she may add or modify for other duly identified purposes, such as for sending newsletters or other types of commercial contacts.
Kaveo advises you to please read this Privacy Policy and its updates.
2. Data Controller
The Data Controller is the person that provides you the service or supplies you the product, and who, in this context, decides which data is collected, the processing means thereof, and the purposes for which such data are used. In this case, Kaveo is the Data Controller.
3. Personal Data, Data Subjects, and Categories of Personal Data
What is Personal Data?
Personal Data is any information, of any nature and in any medium, relating to an identified or identifiable natural person. An identifiable person is considered to be a person who can be identified directly or indirectly, for example through his/her name, ID number, location data, an electronic identifier or any other details that allow the identification of such natural person.
Who are the Data Subjects?
The Customer, a natural person, to whom the data relates and who has enjoyed the services or products of Kaveo. For example, a Customer of Kaveo is someone who has entered an agreement for the supply of a given good or for the provision of a given service by the latter. A potential Customer will be someone who is the target of advertising campaigns or promotional offers by Kaveo, as well as anyone who may request any information on the products and services marketed by Kaveo.
In this regard, Kaveo further informs that it also protects Customers' personal data and respects their rights.
What Categories of Personal Data do we Process?
| Categories of Personal Data | Examples of Personal Data |
| Identification |
Name |
| Contacts | Address Phone number Email address |
| Profile | Nationality Country of residence Date of birth Gender Marital status Number of children |
| Electronic interactions | IP Address Device Identifiers Cookies |
4. Grounds, Purposes and Duration of the Processing of Personal Data
On what basis can Kaveo process your personal data?
Consent: when it has your prior express consent — in writing, orally or by validating an option —, and if such consent is free, informed, specific, and unambiguous. Examples are your consent for mailing direct marketing messages, profiling, sharing data with other entities; or
Execution of contract and pre-contractual measures: when the processing of personal data is required for the conclusion, execution and management of the agreement entered into with Kaveo, such as for information requests, preparation of service proposals, provision of services, management of contacts/complaints, invoicing/collections/payments; or
Compliance with legal obligations: when the processing of personal data is required to comply with a legal obligation to which Kaveo is subject, such as communicating any data to police, judicial, tax or regulatory entities; or
Legitimate interest: when the processing of personal data corresponds to a legitimate interest of Kaveo or of third parties, such as improvement of service quality, fraud detection, or when the reasons for its use should prevail over the Data Subject's rights.
For what purposes and for how long does Kaveo process your personal data?
Your personal data are processed by Kaveo only for the period of time required to achieve the defined purpose or, as applicable, until you exercise your right of opposition, right to be forgotten or you withdraw your consent. After the respective conservation period has elapsed, Kaveo will delete or anonymize the data whenever they should not be kept for a different purpose that may subsist.
| Categories of Purposes | Examples of Purposes |
| Marketing | Marketing or sale of new services or products |
| Customer Management and Service Delivery |
Management of contacts, information or requests |
| Accounting, Tax and Administrative Management | Accounting, invoicing Management of fees Tax information, including sending information to the tax authority |
| Litigation Management |
Judicial and extrajudicial collection |
| Physical security control |
Video surveillance of facilities |
What are the Deadlines for Processing and Retaining Personal Data?
Kaveo processes and retains your personal data according to the purposes for which they are processed. There are cases in which the law requires the processing and retention of data for a minimum period of time, namely for 10 years in case of data required for informing the Tax Authority for accounting or tax purposes or data relating to commercial bookkeeping, and for 7 years for the purpose of combating money laundering and the financing of terrorism.
However, whenever there are no specific legal obligations, then the data will be processed only for the period required to fulfil the purposes that motivated its collection and preservation, and always in accordance with the law, and the guidelines and decisions of the National Data Protection Committee (CNPD).
Thus:
Kaveo will process and retain your personal data for as long as it has a contractual relationship with you.
With regard to video surveillance of its facilities, Kaveo will only keep the recordings of images and respective personal data for a maximum period of 30 days.
Kaveo may keep other personal data for periods longer than the duration of the contractual relationship, either based on your consent, or to ensure rights or duties related to the contract, or because it has legitimate interests which substantiate it, but always for the period strictly required to achieve the respective purposes, and in accordance with the guidelines and decisions of the CNPD.
Examples are contacts for marketing and sales purposes, data retention for the purpose of invoice claiming proceedings, exercise of warranty rights or pending legal disputes.
5. How and When Collect Personal Data
When and how do we collect your personal data?
We collect personal data with your consent or when you purchase services or products from Kaveo.
The collection can be done orally, in writing or through the website of Kaveo.
But your personal information may also be collected from publicly accessible sources or other sources, such as travel agencies, whose responsibility for ensuring data protection and information security also applies.
6. Rights of the Data Subject
What are your rights?
Right of Access - right to obtain confirmation of which personal data are being processed and information about that same data, such as the respective processing purposes and the retention periods thereof, among others.
Right to view or obtain a copy of, for example, invoices or written agreements.
Right of Rectification - right to request the correction of any of your personal data deemed as inaccurate or request that incomplete personal data be completed, such as your address, Tax Identification Number, email, phone contacts, or other details..
Right to Delete your data or "right to be forgotten" - right to have your personal data deleted, provided that there are no valid grounds for its retention, such as in cases where Kaveo must keep your data to comply with a legal obligation or because legal proceedings are in progress.
Right to Portability - right to receive the data you have provided us in digital format for current use and with automatic reading, or to request the direct transmission of your data to another entity that becomes the new Data Controller, but in this case only if technically possible.
Right to Withdraw Consent or Right to Oppose - right to oppose or withdraw your consent at any time regarding data processing. For instance, in case of data processing for marketing purposes, provided that there are no legitimate interests that prevail over your interests, rights and freedoms, such as defending a right under judicial proceedings.
Right of Limitation - right to request the that the processing of your personal data be limited, namely in terms of: (i) suspension of processing or (ii) limitation of the scope of processing to certain categories of data or processing purposes.
Right to Complain - right to file a complaint with the supervisory authority, the CNPD, in addition to the company or the DPO.
How can you exercise your rights?
The exercise of rights is free of charge, unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged taking into account the administrative costs involved.
If you wish to exercise any of your rights, please contact us in writing via email to: info@kaveoleadership.com.
Answers to requests received shall be provided within a maximum period of 30 days, unless it is a particularly complex request.
7. Transmission of Personal Data
Under what circumstances are your personal data communicated or provided to other entities, subcontractors or third parties?
Your data may be provided to subcontractors so that they can be processed in the name and on behalf of Kaveo In this case, Kaveo will take the necessary contractual measures to ensure that the subcontractors respect and protect the Customer's personal data.
The data may also be provided to third parties — entities other than Kaveo or subcontractors — subject to the Data Subject's agreement, or to entities unto whom the data must be provided by law.
8. Security and Confidentiality
We strive to keep your data secure, and we employ appropriate security measures to ensure the protection of your personal data and to prevent access by unauthorized persons. We periodically review our systems and security policies to ensure that all data is safe and secure. However, the transmission of information via the Internet is not completely secure, and we cannot absolutely guarantee the security of the information transmitted through our website.