SPECIALSURF 78 is committed to protecting the security and privacy of personal data. In this context, SPECIALSURF 78 prepared this Privacy Policy, in order to make known the terms under which SPECIALSURF 78 collects and processes personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council , of April 27, 2016 (General Regulation on Data Protection – “RGPD”) and other personal data protection legislation.


Who is responsible for processing your personal data?
SPECIALSURF 78 is the entity responsible for the processing of personal data, under the terms of the RGPD, which sells Products and/or provides Services, as it defines which data is collected, the means of processing and the purposes for which these data are used . Personal data is considered to be any and all information relating to a natural person, identified or likely to be identified.


What personal data do we collect?
SPECIALSURF 78 directly collects and processes the personal data necessary for the marketing of its products and provision of its Services, to guarantee access to the Platforms and to comply with legal and regulatory obligations.
Personal Data Categories - Examples
a) Identification and Contact Data – such as name, email and telephone number.
b) Image registration data – Video and photo recordings.


What are the purposes for collecting your personal data and what is the basis for their processing?
The personal data of SPECIALSURF 78 Customers are used within the scope of the provision of services, the management and execution of the contractual/commercial relationship, the handling of complaints and suggestions, pre-contractual measures, compliance with legal obligations, as well as for the improvement and adaptation of services to the Client's needs and interests. The Customer may, however, provide, with consent, their personal data for other purposes, such as receiving information from the school, participating in competitions and market studies, receiving marketing communications (including campaigns and promotions about the Services and Products).

Thus, we treat personal data for the following purposes:
– Provision of Services and sale of Products – Execution of the contract and pre-contractual steps and compliance with legal obligations;
– Marketing or promotion of new Products or Services and Events – Use of statistical techniques and definition of profiles to personalize the offer and communications to be carried out within this scope;
– Customer relationship management – Contract execution and pre-contractual steps and Compliance with legal obligations;
– Compliance with legal obligations – Response and reporting to judicial authorities and tax administration;
– Information security (Access management, logs, backup management and security incident management) – Compliance with legal obligations.


How long do we keep your personal data?
SPECIALSURF 78 keeps the personal data of the holders only for the period strictly necessary to pursue the purpose for which they were collected.

We will also retain your data for as long as you have a contractual relationship with SPECIALSURF 78. However, we may retain your personal data for periods longer than the duration of the contract, based on your consent, to ensure rights and duties related to the contract or in situations where there is a legitimate interest of SPECIALSURF 78, always respecting the period necessary to pursue the purpose for which they were collected.

In the absence of a specific legal obligation, your data will be processed only for the period necessary to fulfill the purposes that motivated its collection, and as long as there are legitimate grounds that allow its conservation by SPECIALSURF 78, unless exercised, within the legal limits, the right to object, right to erasure or withdraw consent.

As a rule, your personal data, when processed for the purposes of marketing campaigns, will be kept for a maximum period of 5 years from the date of collection of your consent and if, within this period, you have not withdrawn your consent.

Once the maximum retention period is reached, the personal data will be irreversibly anonymized (and the anonymized data may be preserved) or will be securely destroyed.


What are the rights of data subjects?

Under applicable law, you may exercise the following rights:

(I) Right of Access: obtain confirmation of which personal data are being processed as well as obtain a copy of the personal data being processed.

(II) Right of Rectification: request the rectification of your personal data that are inaccurate or request that incomplete personal data be completed.

(III) Right to Erasure: obtain the erasure of your personal data, provided that there are no valid grounds for its conservation.

(IV) Right to Limit the Processing: requesting the restriction of the processing of your personal data, requesting the suspension of the processing or the limitation of the scope of processing to certain categories of data or processing purposes.

(V) Portability Right: to receive the data you have provided us in digital format for current use and to be read automatically or to request the direct transmission of your data to another entity that becomes the new person responsible for your personal data.

(VI) Right of Opposition: to object, at any time, to data processing, such as in the case of data processing for marketing purposes;

(VII) Right of Opposition to decision-making based on exclusively automated processing: not to be subject to any decision taken solely on the basis of automated processing, including the definition of profiles, that produce effects in its legal sphere or that significantly affect it from similar way.

Under the law, you are also guaranteed the right to withdraw your consent to the processing of data legitimized by consent, through the aforementioned means, or, if you have given your consent through an online channel, you may withdraw it by that same route. The withdrawal of consent does not invalidate, however, the treatment carried out up to that date based on the consent previously given.


Exercícios de Direitos – Direito de Reclamar

In fact, you can exercise your rights through the following address:
Email: specialsurf78@gmail.com

Even so, and if you are not satisfied with our response after exercising any of these rights, you have the right to file a complaint with the CNPD (National Data Protection Commission, (Rua de São Bento, no. 148, 3rd, 1200-821 Lisbon, Tel: 351 213928400, Fax: +351 213976832, e-mail: geral@cnpd.pt).



This website adheres to the electronic complaints book. If you wish to file your complaint, do so at  https://www.livroreclamacoes.pt


When do we communicate data to third parties?

In the scope of the provision of services, SPECIALSURF 78 may resort to third parties that have access to the personal data of its Customers.

These entities – subcontracting entities – may have access to personal data, following, for this purpose, the instructions of SPECIALSURF 78. These entities are essentially partners or suppliers of goods and service providers.

SPECIALSURF 78's service providers are contractually subject to the same terms and conditions for the processing of personal data that this privacy policy establishes, and are prohibited from using, transferring, disclosing or recording the holder's personal data for any other purpose that not the one for which they were specifically contracted.

SPECIALSURF 78 may also transmit personal data of its Clients to third parties, when such data communications are necessary or appropriate in light of the applicable law, in compliance with legal obligations/judicial orders, to respond to requests from public or governmental authorities, or when you have given us your consent.


Procedural and Technical Safety Measures

SPECIALSURF 78 makes use of physical, technological, organizational and security measures appropriate to the protection of your personal data in order to protect the personal data that are made available to us, against its dissemination, loss, misuse, alteration, processing or non-access authorized.


Atualização da Política de Privacidade

SPECIALSURF 78, reserves the right, at any time, to update this Privacy Policy. Therefore, it is recommended that you periodically consult this policy on our website to stay informed about the processing of your personal data.


Privacy Policy Update

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Peniche, September 30, 2021