PRIVACY AND COOKIES POLICY
PRIVACY AND COOKIES POLICY
LEGAL INFORMATION AND ACCEPTANCE OF THE PRIVACY AND COOKIES POLICY
It is our intention to inform you through our Privacy and Cookies Policy of the processing we will carry out on the data you provide us in the registration process, those that may be generated in the use of the website www.saba.pt (hereinafter "website") and the SABA application (hereinafter "App"), as well as the data processed in the process of purchasing and providing services and products.
Use of the website/App implies acceptance of this Privacy and Cookies Policy. SABA reserves the right to modify or update this Privacy and Cookies Policy at any time, notifying registered Users of any modification and being applicable from the date indicated therein.
1. BASIC INFORMATION ON THE PROTECTION OF PERSONAL DATA
RESPONSIBLE FOR THE TREATMENT
SabaPortugal - Parques de Estacionamento, S.A.
In addition, if you purchase a service or product: the company that owns the car park will be informed during the purchase process.
• Manage user registration on the website/App;
• Show you the car parks closest to your location;
• Manage the purchase of services or products through the website/App;
• Manage and execute the provision of the contracted services or products;
• Comply with applicable legal obligations;
• If you have given your consent, send you communications about services or products from other companies with which we collaborate and which may be of interest to you, related to the automotive mobility sector.
• To manage user registration on the website/App: user consent;
• To show you the nearest car parks: user consent;
• For the purchase of services or products, as well as for the performance thereof: execution of the contract;
• For processing necessary to fulfil SABA's legal obligations: compliance with legal obligations;
• To inform you about other services or products of SABA or third parties and send you personalised communications: consent of the person concerned.
Your data will not be transferred to third parties, except under legal obligation or unless such transfer is necessary
for the execution of the contract.
SABA's service providers who are contracted by SABA and who act as data processors may have access to personal data, acting in accordance with SABA's instructions.
You may exercise your rights of access, rectification, opposition, erasure, limitation of processing and data portability in the cases and under the conditions provided for by applicable law through the following address: firstname.lastname@example.org If you have given your consent for the purposes described above, you may withdraw it at any time.
In the following points of the Privacy and Cookies Policy.
2. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?
SABAPORTUGAL - PARQUES DE ESTACIONAMENTO, S.A., with registered office at Rua de Ceuta, n.º 43, 2.º, 4050-...
191 Porto, legal person number 501 737 855, is responsible for the processing of the personal data that you provide us in the registration process, those that may be generated on the website / App, as well as the data processed in the process of purchasing and providing services and products.
SABA has appointed a Data Protection Officer (DPO) who can be contacted for queries regarding the processing of your data at the following email address: email@example.com or by post to the address above.
3. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
Registration as a User of the website/App
When you register as a user on the website/App, your data will be processed for the purpose of managing your registration as a User on the website/App and the services available to you as a User of the website/App, which you can access through your private area of the website/App.
Registration as a User means that we can send you transactional, operational and informational communications.
The legal basis for these data processing operations is your consent, granted in the registration process.
Show you the car parks closest to your location
If you authorise it, through the website and the App, we may use your location data to suggest a nearby car park. You will always be asked for authorisation to access your location.
For the correct use of the App, we recommend that you activate geolocation, so that the App can suggest a nearby car park. The data used will be the coordinates.
The legal basis for these data processing operations is your consent, granted by allowing the website and the App to access your location. You can change the settings and withdraw your consent to the use of your location at any time.
Purchase and provision of services or products
If you purchase services or products through the website/App, your data will be processed to manage the purchase, provide the services or products, process the payment and, where applicable, issue the invoice and/or receipt.
The purchase and provision of services or products presupposes that we can send you transactional, operative and informative communications, as well as manage your enquiries and requests through other channels.
To process the payment, you will be required to enter your credit card number, however the payment is made via a secure third party payment platform and SABA does not process this information.
Failure to provide the requested data, or the provision of inaccurate or incomplete data, may result in the inability to provide the contracted services or products in an appropriate manner. We therefore recommend that you take responsibility for the accuracy of the data provided, as well as for informing SABA of any changes to it.
When you have purchased a service or product, your data will be processed in order to provide you with the contracted service:
• If the service requires the signature of a contract, the contract will include information about the processing of your personal data for the purpose of providing the service to you;
• If the product or service does not require the formalisation of a contract, you can find information about the processing of your personal data in the rules of use and operation of the car park, available in each car park.
In general, the data processing necessary for the provision of the services are:
• Management of the contractual relationship: your data will be processed for the formalisation of the contract, administrative, economic and fiscal management associated with it, including collection management;
• Video surveillance system: the car parks are equipped with a video surveillance system according to the signs on the respective car parks, in order to carry out operational management of the car park and ensure the safety of people and facilities;
• Via Verde device reading system: you can access the car parks by using your Via Verde device as a means of payment. If you are a member, you can use your device as a means of access. If you do not wish to use your Via Verde device, you can: i) remove the issuing device, ii) select the option available in the access machine to withdraw a ticket if you are a rotating customer or iii) request SABA or Via Verde to include you in a list that will cause your Via Verde device not to be recognised again when entering the respective car park if you are a paying customer;
• Any other data processing that may result from the provision of the service or product, such as complaints management, claims management, among others.
The legal basis for data processing is the contractual relationship, which requires the processing of your data for its fulfilment.
Sending commercial communications about products and services of interest to you
If you expressly consent, your personal data may be processed to send you selected information, by any means, about offers and promotions of services or products of SABA group companies or third-party companies that provide services related to the automotive mobility sector or that provide services related to parking. For this purpose we will not communicate your data to third parties as the information will be communicated to you from SABA.
If you consent to this in the process of contracting a contract, your personal data may be used to create individualised profiles and send you personalised information, by any means, about offers and promotions for services or products of SABA group companies or third-party companies that provide services related to the automotive mobility sector or that provide services related to parking. If available, the following data may be incorporated into the profile that is created, as well as data that you have provided directly or that is created during your use of the services or products of SABA, other companies of the SABA group or third parties: contact data (such as name, address, email); additional information (such as preferences); customer history (such as purchase data); vehicle data (such as registration data or use of the SABA App); data collected through the website/App.
The legal basis for the commercial purposes is your consent, formalised in the registration process or, if applicable, in the contracting documentation of an agreement when you have selected the corresponding option.
Sending satisfaction surveys
Your data may be processed in order to contact you to find out what you think about the products or services you have contracted. The legal basis for processing the data is SABA's legitimate interest.
You can object to this data processing at any time by exercising your right to object by sending an e- mail to firstname.lastname@example.org
4. TO WHOM WILL WE COMMUNICATE YOUR PERSONAL DATA?
If you do not purchase any service or product, your data will not be communicated to third parties. Otherwise, your data may be communicated to the following entities:
• The entity that manages the payment platform, for the purpose of processing the payment, being the legal basis for the development of the contractual relationship;
• To administrations, authorities and other public bodies, law enforcement agencies, courts and alternative dispute resolution organisations, where legally required;
• Insurance organisations when claims occur on SABA premises or those of third parties and this is necessary;
• The SABA group company responsible for providing the contracted service or product, depending on the location of the car park, which will be identified at the time of purchase, for the purpose of providing the service or product;
• If the service or product contracted so requires, your data may be communicated to other SABA group companies for the purpose of applying loyalty policies specific to the service (this will be described in the specific contract that must be formalised);
• In any other case under the terms required by law or if necessary for the proper development of the contractual relationship.
In any case, service providers hired by SABA or acting as subcontractors may have access to your personal data. These suppliers will process personal data in accordance with SABA's instructions, and in any case, they are expressly required to comply with the legislation in force and to implement appropriate technical and organisational measures to guarantee the confidentiality of the information. These third parties collaborate with SABA to provide services related to information systems, collection management, marketing and professional services.
5. HOW LONG WILL WE KEEP YOUR DATA?
The data provided for the purpose of registration on the website/App will be kept until you decide to cancel your account. You can cancel your account through the website by accessing your private area or by sending an email to email@example.com
Even if you decide to cancel your account, if you have purchased a service or product or if another legitimate reason prevails, we will keep your blocked data for the periods provided for by applicable law. After such retention periods have elapsed, we will delete it.
6. HOW DO WE PROTECT YOUR DATA?
SABA is committed to information security and has adopted technical and organisational security measures to prevent the alteration, loss, misuse, unauthorised processing and access or theft of information, depending on the state of technology.
7. WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA?
You may exercise your rights at any time, as well as revoke the consents given when applicable and in accordance with the law in force.
• Right of access: allows you to confirm whether we process your personal data, and if so, which ones;
• Right of rectification: allows you to help us correct errors and modify data that may be inaccurate or incomplete;
• Right to erasure: allows you to request the erasure of your data, resulting in SABA ceasing to process the data, unless there is a legal obligation to retain it, in which case it will be blocked, or if legitimate reasons prevail for its processing;
• Limitation of processing: allows the processing of data to be limited, in accordance with the conditions established by law, although data may be kept blocked in order to respond to claims or exercise defence in administrative and/or judicial proceedings and/or procedures;
• Right to object: this allows you to ask us to stop processing personal data which we consider to have a legitimate interest in processing, for example, to make offers of products or services. We will cease processing your data, unless there are compelling legitimate grounds for doing so, or unless it is necessary to respond to claims or exercise a defence in administrative and/or judicial proceedings and/or procedures, in which case it will be blocked;
• Portability: allows you to receive your personal data in a structured, commonly used and machine-readable format so that you can transmit it to another controller;
• Withdraw consent: allows your data to cease to be processed for a purpose for whichyou have previously given your consent, for example for the receipt of commercial communications from third party companies with which we collaborate.
To do so, you can contact SABA at the address above or by e-mailing the Data Protection Officer at firstname.lastname@example.org
In addition, if you consider that a breach of applicable data protection legislation has occurred in relation to the processing of your personal data, you may lodge a complaint with the National Data Protection Commission (Comissão Nacional de Proteção de Dados).
1. WHAT ARE COOKIES?
Cookies are small files that are installed on a device (computer, smartphone, tablet) from which a website is accessed and in which information is stored. There are two types of cookies:
- Depending on the entity that manages the equipment or domain from which cookies are sent and the data obtained are processed:
o Own cookies: those that are sent to the user's device from a device or domain managed by SABA and from which the service requested by the user is provided;
o Third-party cookies: these are cookies sent to your device from a device or domain that is not managed by SABA, but by another entity that processes the data obtained through cookies.
- Depending on the length of time they remain active in the terminal equipment:
o Session cookies: these are designed to collect and store data while the user accesses a website and remain on the user's device for the duration of the visit (e.g. until the user closes the browser and finalises the visit);
o Persistent cookies: these are cookies that are stored on the device and can be accessed and processed for a period defined by the cookie owner, which can range from a few minutes to several years.
- Depending on the purpose for which the data obtained through cookies are processed:
o Personalisation cookies: allow the user to access the service with some general characteristics predefined according to a series of criteria of the user's equipment, for example, language, type of browser from which the website is accessed, regional configuration, etc:
o Analysis cookies: are those that, when processed by the website owner or third parties, allow the tracking and analysis of the behaviour of website users, quantify user numbers and thus perform the measurement and statistical analysis of website use through aggregate or statistical information;
o Advertising cookies: these are those that allow the most effective management of advertising spaces that, where applicable, the holder has included on the website based on criteria such as the content edited or the frequency with which the adverts are shown;
o Social cookies: these are those that are required for external social networks (Facebook, Google, Twitter, Pinterest, Instagram, etc.) and their function is to control interaction with social widgets within the website.
2. WHAT COOKIES DOES THIS WEBSITE USE?
This website uses its own and third-party cookies in order to ensure the functioning of the website, as well as to collect information about the use of the website and analyse your browsing habits inorder to facilitate your browsing, ensure access to certain functions and improve browsing habits.
SABA uses the Google Analytics audience measurement system, which is a tool for obtaining and analysing browsing information that provides information on how website users interact. Google Analytics is a service provided by Google, Inc., a company based in the United States. Below is the link where you can consult the types of cookies used by Google Analytics and their validity period:
If you give your consent, the website uses advertising cookies. We detail below the cookies used on the website:
COOKIE TYPE OBJECTIV E DURATIO N
Technical This cookie is used to identify the open session between your browser and the portal. It also allows the portal to remember certain settings, for example if you are logged into the Private Area. It is automatically removed every time the browser is closed
Technical This cookie checks if cookies are enabled by your browser. Some of the website services need to work with cookies.
This cookie is used to identify language preferences.
This cookie is used by Google Analytics to understand user interaction with the website.
Google Analytics This cookie is installed by Google Analytics. It is used to calculate visitors, sessions, campaign data and track website usage for website analytics. Cookies store information anonymously and assign a randomly generated number to identify unique visitors.
Google Analytics This cookie is installed by Google Analytics. It is used to store information about how visitors use a website and helps in creating an analytical report about the performance of the website. The data collected includes the number of visitors, the source they come from and the pages visited anonymously.
Publicity Used by Microsoft as a unique identifier. The purpose of this cookie is to synchronise the ID across several different Microsoft domains to enable user tracking.
Publicity This cookie is set by doubleclick.net. It is used to determine whether the user's browser supports cookies.
Publicity The cookie is set by taboola.com. The cookie assigns a unique user ID to users and uses this ID to serve relevant advertising and content.
Publicity This cookie is set by Facebook to provide advertising when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.
Publicity The cookie is set by Facebook to show relevant adverts to users and to measure and improve adverts. The cookie also tracks user behaviour on the web on websites that have the Facebook pixel or the Facebook social plug-in.
3. HOW CAN YOU MANAGE COOKIES?
You can at any time allow, block or delete cookies installed on your device through your browser options. However, disabling cookies may affect the normal functioning of certain sections of the website.
Depending on the browser you use, the cookie setting options may be in different sections. You can consult your browser's instructions if you want to know how to block or allow the installation of cookies. For the different browsers, you will find information in the following links:
• Chrome: https://support.google.com/chrome/answer/95647?hl=pt
• Explorer: https://support.microsoft.com/pt-pt/help/17442/windows-internet-explorer-delete- manage-cookies
• Firefox :https://support.mozilla.org/pt-BR/kb/cookies-informacoes-sites-armazenam-no- computer
• Safari: https://support.apple.com/pt-pt/guide/safari/sfri11471/mac
If you do not want Google Analytics to collect information you can install the following Google plug-in by clicking on the link https://tools.google.com/dlpage/gaoptout?hl=pt-BR.
If you wish to have greater control over the installation of cookies, you can install add-ons to your browser, known as "Do Not Track" tools, which allow you to choose the cookies you wish to allow.
DATE: 26 June 2020