PRIVACY POLICY AND PERSONAL DATA PROTECTION

WHO ARE WE?
We are MANTAMARIA and we are located on the island of Santa Maria, Azores. Our main activity is the provision of training and certification services for diving and sea related activities.

WHY THIS PRIVACY AND PERSONAL DATA PROTECTION POLICY?
This Policy is intended to make known to Customers / Users of the "MANTAMARIA" the general rules of privacy and processing of personal data, which are collected and processed in strict compliance with the provisions of personal data protection legislation in force at all times, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("RGPD"). The "MANTAMARIA" respects best practices in the field of security and protection of personal data, and to this end has taken the necessary technical and organisational measures in order to comply with the GDPR and to ensure that the processing of personal data is lawful, fair, transparent and limited to the authorised purposes. The "MANTAMARIA" is committed to the protection and confidentiality of personal data, having adopted the measures it deems appropriate to ensure the accuracy, integrity and confidentiality of personal data, as well as all other rights to which the respective holders are entitled.

WHAT DOES THE PRESENT POLICY COVER?
This Policy applies exclusively to the collection and processing of personal data for which "MANTAMARIA" is responsible for the respective processing, within the scope of the services and products made available to its Customers/Users and in all situations in which personal data processing occurs.

WHAT IS PERSONAL DATA?
Personal data is any information, of whatever nature and whatever its medium, including sound and image, concerning an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, location data, electronic identifiers or one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

WHAT IS THE PROCESSING OF PERSONAL DATA?
The processing of personal data consists of an operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, restriction, erasure or destruction.

WHO IS THE DATA CONTROLLER?
The entity responsible for the treatment of personal data is "MANTAMARIA", which determines the purposes and means of their treatment. For this purpose, should the holder of the personal data need to contact the data controller, he/she may do so through the following means and contacts indicated: info@mantamaria.com

WHAT TYPES OF PERSONAL DATA ARE PROCESSED?
The "MANTAMARIA", in the scope of its activities, processes personal data necessary for the provision of services and/or supply of products, processing data such as name, telephone number, e-mail address, location, nationality, date of birth, Civil Identity Number, NIF, according to information provided by the holders of personal data. Personal data may also be processed for marketing purposes, dissemination of offers of goods or services or requests for quotes to the "MANTAMARIA", if the respective holder has consented. If there is prior consent of the holder, this may be withdrawn at any time, without the lawfulness of the processing carried out on the basis of the consent previously given being compromised.

WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?
The "MANTAMARIA" collects your personal data, including via telephone, in writing, through its website, ensuring, where necessary, the prior consent of the holder of the personal data. Some personal data is essential to the execution of the contract, without which "MANTARIA” will not be able to provide the product or service in question. If the holder of the personal data is not a customer/user of "MANTAMARIA", the respective personal data will only be processed when they are made available, in which case the rules of this Policy will apply. The personal data collected may be processed automatically or non-automatically, ensuring in all cases strict compliance with the legislation on the protection of personal data, being stored in specific databases created for this purpose and, under no circumstances, the data collected shall be used for any purpose other than that for which they were collected or consent was given by the data subject.

WHO ARE THE RECIPIENTS OF THE PERSONAL DATA?
Without prejudice to the recipients listed throughout this Policy, the "MANTAMARIA" may communicate the personal data of the Customer / User, for the purpose of compliance with legal obligations, including police, judicial, tax and regulatory authorities.

WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA AND THE RESPECTIVE LEGAL GROUNDS?
In general, the personal data collected is based on and intended for the management of the contractual and commercial relationship, the provision of the contracted services, the adequacy of the services to the needs and interests of the Customer/User, namely for the purposes of access to specific features of the services, information and marketing actions. Additionally, personal data may also be processed for the purpose of compliance with legal obligations.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?
The period of time for which personal data is stored and retained varies according to the purpose for which the information is processed. In fact, there are legal requirements that oblige us to retain data for a minimum period of time. Therefore, and whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the pursuit of the purposes that motivated their collection or their subsequent processing, under the terms defined by law.

WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
As holders of personal data, Customers/Users are guaranteed, at any time, the right to access, rectify, update, limit and delete their personal data (except for data which are indispensable to the provision of services by "MANTAMARIA" or to comply with legal obligations to which the controller is subject), the right to oppose the use of such data for commercial purposes by "MANTAMARIA" and to withdraw consent, without this compromising the lawfulness of the processing carried out under that consent, as well as the right to data portability.

HOW CAN YOU ACCESS, RECTIFY, UPDATE, LIMIT, DELETE, OPPOSE THE PROCESSING OF YOUR PERSONAL DATA, OR REMOVE CONSENT?
Without prejudice to the provisions of the RGPD, the holder of personal data may do so, directly or by written request, addressed to the respective Responsible for processing, through the contacts provided for this purpose in this document, as well as other contacts provided by "MANTAMARIA".

HOW CAN YOU OBJECT TO RECEIVING CONTACTS FOR MARKETING PURPOSES?
The "MANTAMARIA" can promote actions of dissemination to its Customers / Users, of new products or services, including by telephone, e-mail, SMS or any other electronic communications service, if the holder of personal data has given his consent. If the holder of the personal data does not wish to continue to receive these communications he/she may, at any time, withdraw his/her consent to the use of his/her data for marketing purposes.

HOW CAN YOU COMPLAIN?
Without prejudice to the possibility of filing complaints directly to "MANTAMARIA" through the contacts provided for that purpose, the Customer/User may complain directly to the Control Authority, which is the National Commission for Data Protection (CNPD), using the contacts provided by this entity for that purpose.

WHAT MEASURES HAVE BEEN ADOPTED BY "MANTAMARIA" TO ENSURE THE SECURITY OF YOUR PERSONAL DATA?
“MANTAMARIA" is committed to ensuring the protection of the security of personal data made available to it, having approved and implemented strict rules on this matter. Compliance with these rules is an obligation of all those who legally access them. Bearing in mind the concern and commitment that "MANTAMARIA" reveals in the defence of personal data, various security measures of a technical and organisational nature have been adopted in order to protect the personal data provided against diffusion, loss, improper use, alteration, unauthorised treatment or access, as well as against any other form of illicit treatment. Additionally, third parties who, as part of the provision of services, process the personal data of the Customer/User in the name and on behalf of "MANTAMARIA", are obliged in writing to implement appropriate technical and security measures that, at all times, meet the requirements set out in the legislation in force and ensure the protection of the rights of the data subject (namely, the protection of privacy and personal data).

UNDER WHAT CIRCUMSTANCES IS THERE COMMUNICATION OF DATA TO OTHER ENTITIES (THIRD PARTIES AND SUBCONTRACTORS)?
“MANTAMARIA”, as part of its activity, may use third parties to provide certain services. Sometimes, the provision of these services involves access, by these entities, to Customers/Users personal data. When this happens, "MANTAMARIA" takes the appropriate measures to ensure that the entities that have access to the data are reputable and offer the highest guarantees at this level, which is duly established and safeguarded contractually between "MANTAMARIA" and the third entity(ies). Thus, any entity subcontracted by "MANTAMARIA" will process the personal data of our customers/users in the name and on behalf of "MANTAMARIA" and adopting the necessary technical and organizational measures to protect the personal data against destruction, accidental or illicit, accidental loss, alteration, diffusion or unauthorized access and against any other form of illicit treatment. In any case, “MANTAMARIA” shall remain responsible for the personal data provided. In this case, the "MANTAMARIA" uses Mailchimp, as a marketing platform. By agreeing to our policies, you acknowledge that your information will be transferred to Mailchimp. Learn more about Mailchimp privacy policies here https://mailchimp.com/legal/. You can unsubscribe at any time by clicking the link in the footer of our emails. For more information on our privacy policies, please visit our website.

IN WHAT CIRCUMSTANCES DO WE TRANSFER YOUR PERSONAL DATA?
The provision of certain services by "MANTAMARIA" may involve the transfer of your data outside Portugal, including outside the European Union or to International Organizations. In such a case, "MANTAMARIA" will strictly comply with the applicable legal provisions, namely as regards the determination of the suitability of the destination country(ies) as regards the protection of personal data and the requirements applicable to such transfers, including, where applicable, the conclusion of appropriate contractual instruments that guarantee and respect the legal requirements in force.

HOW DO WE USE "COOKIES"?
"Cookies" are small software tags that are stored on your computer by your browser, retaining only preference-related information and as such do not include personal data. To learn more about cookies and how "MANTAMARIA" uses them on its website, please see the section below "ABOUT COOKIES".

HOW CAN YOU FIND OUT ABOUT ANY CHANGES TO THE PERSONAL DATA PROTECTION POLICY?
“MANTAMARIA” reserves the right to make adjustments or changes to this Personal Data Protection Policy at any time.

WHAT ARE COOKIES?
"Cookies" are small software tags that are stored in the access equipment through the browser, retaining only information related to preferences, not including, as such, personal data.

WHAT ARE COOKIES USED FOR?
Cookies are used to help determine the usefulness, interest and number of uses of websites, allowing faster and more efficient browsing by eliminating the need to repeatedly enter the same information.

WHAT KIND OF COOKIES ARE THERE?
There are two groups of cookies that can be used: Permanent cookies - these are cookies that are stored at browser level in the access equipment (PC, mobile and tablet) and are used whenever you make a new visit to one of the websites of "MANTAMARIA". They are generally used to direct navigation to the users interests, allowing a more personalized service. Session cookies - temporary cookies that remain in the cookie file of the browser until you leave the website. The information obtained by these cookies is used to analyse web traffic patterns, allowing problems to be identified and providing a better browsing experience.

WHAT DO WE USE COOKIES FOR?
• Strictly necessary cookies - These allow you to navigate the website and use applications, as well as access secure areas of the website. Without these cookies, necessary services cannot be provided. • Analytical cookies - These are used anonymously for the purpose of creating and analysing statistics in order to improve the functioning of the website.

HOW CAN YOU MANAGE COOKIES?
All browsers allow you to accept, refuse or delete cookies, and also to inform you when a cookie is received, namely by selecting the appropriate settings in your browser. You can configure cookies in the "options" or "preferences" menu of your browser. It should be noted, however, that by disabling cookies you may prevent some web services from working properly, partially or totally affecting navigation on the website.