Privacy and Data Policy
PRIVACY POLICY - Four Seasons Country Club
Last update: February 2025
1. General information
Four Seasons Country Club respects your privacy and is committed to protecting your personal data.
With this privacy policy (“Privacy Policy”), Four Seasons Country Club intends to provide clear and transparent information to users of its website (“User” or “Users”) https://www.fourseasonscountryclub.com/ (“Website”), as well as:
(a) To its clients (“Client” or “Clients”); and
(b) To the Members of Four Seasons Country Club Limited (“Member” or “Members”).
The information provided in this Privacy Policy will apply to Clients and Members, even if their contact with Four Seasons Country Club occurred in person, at its facilities, or by telephone.
Within this framework, Four Seasons Country Club intends to inform Users, Clients and Members, in respect of the collection and processing of their personal data, of the following:
(a) Controller of personal data;
(b) Personal data processed by Four Seasons Country Club;
(c) Purposes and legal basis of the processing of personal data;
(d) Storage of personal data;
(e) Contracts between Four Seasons Country Club and Clients or Members;
(f) Consent of personal data subjects;
(g) Processing of personal data through automated means;
(h) Recipients of personal data;
(i) Rights of the personal data subject;
(j) Security in the processing of personal data; and
(k) Amendments to the Privacy Policy.
The Privacy Policy was prepared in accordance with the General Data Protection Regulation of the European Union, Regulation (EU) No. 679/2016, of 27 April (“GDPR”).
If you have any questions regarding the content of this Privacy Policy, please do not hesitate to contact us through the channels identified in Section 1 below.
1. Responsible for the processing of personal data
The entity responsible for processing the personal data is the company Four Seasons Country Club (Properties), Sociedade Unipessoal Lda., a single shareholder limited liability company with registered office at Avenida André Jordan, Quinta do Lago, 8135-998 Almancil, in the parish of Almancil, municipality of Loulé, district of Faro, with the single commercial registry number 507160533.
You can contact Four Seasons Country Club by writing to its head-office at “Avenida André Jordan, Quinta do Lago, 8135-998 Almancil” or by email to the address: dataprotection@fsccqdl.com.
2. Personal data
For the purposes of this Privacy Policy, personal data is considered to be any information that, directly or in combination with other data, can identify an individual.
By entrusting your personal data to Four Seasons Country Club, we guarantee that we will process it in accordance with the provisions of this Privacy Policy.
The table below includes a list of personal data collected by Four Seasons Country Club, from the different categories of personal data subjects mentioned herewith.
Additionally, Four Seasons Country Club collects the image of its Clients and Members through CCTV video surveillance cameras that are installed in the main entrance area, in the service entrance area, at the reception, in the library and in the garbage collection area.
All people with access to recordings obtained through CCTV video surveillance cameras on the premises of Four Seasons Country Club are obliged to keep them confidential, under penalty of criminal prosecution.
Four Seasons Country Club is not responsible for the veracity, omissions or inaccuracies of the personal data it collects from the subjects or receives from group companies.
3. Purposes and legal basis for processing personal data
Four Seasons Country Club, within the scope of its activity, processes personal data for the purposes and on the grounds set out in the table below.
4. Storage of personal data
The personal data collected and processed by Four Seasons Country Club will be stored only for the period necessary for the purposes for which it is processed.
In general terms, personal data will be stored at least for as long as Four Seasons Country Club maintains a contractual relationship with the data subject.
Furthermore, personal data will be kept by Four Seasons Country Club when the law establishes a minimum retention period – for example, the period of 10 years during which it is necessary to maintain accounting data to inform the Tax Authority and commercial bookkeeping data – or when there is a statute of limitations to the rights associated with such personal data.
Personal data will only be stored for periods longer than those mentioned above when the data subject so consents, and always in compliance with applicable legislation and in accordance with the guidelines and decisions of the CNPD – Comissão Nacional de Proteção de Dados.
Images collected through video surveillance systems will be kept for a period of 30 days and deleted up to 48 hours after this period ends, without prejudice to the possibility of storing them for a longer period, in the event of ongoing criminal proceedings.
When the established storage period ends, Four Seasons Country Club will delete or anonymize the personal data.
5. Execution of contract between Four Seasons Country Club and Clients or Members
Where personal data is processed by Four Seasons Country Club, pursuant to Section 3 above, for the performance of a contract to which the data subject is a party, or for pre-contractual steps, pursuant to Article 6, paragraph 1, subparagraph b) of the GDPR, Four Seasons Country Club reserves the right not to conclude the contract or not to provide the services in question, if the respective data subject does not provide the necessary personal data.
6. Consent
When personal data is processed by Four Seasons Country Club based on the consent of its subject, based on Article 6, paragraph 1, subparagraph a) of the GDPR, the subject has the right to, at any time, withdraw his/her consent to the processing of the data, without compromising the lawfulness of the processing carried out based on the consent previously given.
7. Recipients of personal data
Four Seasons Country Club does not share your personal data with third parties, other than those entities listed in this Section. In particular, Four Seasons Country Club will not share your personal data with third parties for the purposes of using that information for direct marketing purposes.
When sharing personal data with third parties, Four Seasons Country Club undertakes, under the terms of the contracts to be entered into with such third parties, to adopt the necessary and appropriate measures to ensure that all entities that have access to such personal data offer security guarantees, limiting the communication of personal data to the minimum necessary.
The Sole Shareholder of Four Seasons Country Club is Four Seasons Country Club Limited, a company incorporated under United Kingdom law. With the exception of transfers of personal data to its Sole Shareholder, Four Seasons Country Club does not transfer personal data outside the European Economic Area.
Four Seasons Country Club may share your personal data, in the context of its activity, namely, with the categories of recipients described in the table below.
In addition to the categories of recipients of personal data mentioned above, Four Seasons Country Club may transfer your personal data whenever this is necessary to comply with legal obligations.
8. Rights of personal data subjects
Users, Clients and Members, as personal data subjects, have the right to, at any time, access their personal data, as well as to the rectification, elimination, portability, limitation and/or opposition to processing of their data.
As the data subject, you also have the right to withdraw your consent at any time. Withdrawal of consent does not compromise the lawfulness of the processing carried out based on the consent previously given.
The exercise of any of these rights must be made in writing, by means of communication addressed to Four Seasons Country Club, either to the address of its head-office located at Avenida André Jordan, Quinta do Lago, 8135-998 Almancil, or to the following email address: dataprotection@fsccqdl.com.
Additionally, personal data subjects may always submit any complaints they deem necessary to the CNPD – Comissão Nacional de Proteção de Dados.
9. Security in the processing of personal data
Four Seasons Country Club is committed to ensuring the security and integrity of the personal data it collects and processes. To this end, it has adopted the following measures:
- Antivirus and firewall software;
- Access to information systems using a username and personal, non-transferable access code; and
- Implementation of confidentiality obligations towards employees and service providers who have access to personal data.
If, for any reason, there is a breach of security that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorized access to personal data, Four Seasons Country Club undertakes, in accordance with applicable legislation, to communicate with the competent authorities without undue delay and, whenever possible, within 72 hours of becoming aware of such occurrence.
Additionally, and under the terms referred to in the previous paragraph, Four Seasons Country Club undertakes to communicate the breach of personal data to the respective data subject.
10. Amendments to the Privacy Policy
Four Seasons Country Club reserves the right to make changes to the Privacy Policy at any time and without prior notice.
Any changes will be published on our Website.
Privacy and Personal Data Policy - applicable to Users of this Hospitality Business when making a reservation
This website is owned and operated by Four Seasons Country Club (Propriedades), Sociedade unipessoal Lda. - Registered Office: Av. André Jordan, Apartado 2208, Quinta do Lago, 8135-024 Almancil, Portugal - (FSCC)
Data Controller (we): The Hospitality Business which will provide to you, the user, the requested service. Our identification and contact details are available on the website you used to make your reservation / to pose your questions to us. They will also appear on our invoice which we'll send to you.
Data Compliance Officer: Not applicable to Data Controllers' activities.
User: You, who filled-in the reservation form or any other documentation related to it.
Purpose: The purpose of processing the data provided through this form is to manage the reservations made by you, user and/or to answer to the questions / requests you pose.
Legal basis:
- Either the need to perform our contract with you, user / the need to take steps at your request prior to entering into a contract.
- Or the consent of you, the user, by ticking in the box of acceptance of the Terms and Conditions of which this Privacy and Personal Data Policy is an integral part.
Duration: We store your data only for as long as it is necessary for the purpose for which they were collected.
Processor: We engage our partner Guestcentric Group (www.guestcentric.com ) for carrying out the reservations engine of our business. Guestcentric acts under our authority and we have signed a contract with Guestcentric Group for the provision of their services. We have instructed Guestcentric Group in written as per how the processing should be done.
Data subjects different from the users: Where you, user, provide us with personal data pertaining to a different data subject from yourself, you are responsible for such acts as well as for obtaining the respective consent of such data subjects for the provisioning of their data.
Transfer of Data: We never disclose information about our customers to any other organisation without their consent unless there is an emergency situation that requires it or we are legally required to do so.
Data Subject Rights: Data Subjects can exercise their rights of access, rectification, cancellation and opposition by sending an email or through the postal service to the contact details on our reservation website and on our invoices.
Supervisory Authority: If a data subject considers their rights affected, they can also appeal to the competent supervisory authority of the Member State concerned. More info at: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en