Revised, updated version effective as of 24 May 2018.
Member: the active member(s) of ACP, i.e. with valid and current membership, under the terms of the ACP Statutes.
Customer: an individual whose personal data is processed by any entity of the ACP Universe as a result of the acquisition of goods and/or subscription services marketed by the entities of the ACP Universe.
ACP Universe: the legal entities constituted by ACP and its subsidiary companies, namely ACP Mediação de Seguros, Lda., ACP Mobilidade Sociedade de Seguros de Assistência, SA., ACP Motorsport Eventos Desportivos, Lda., ACP Serviços de Assistência, Lda., ACP Serviços Rápidos, Lda. and ACP Viagens e Turismo, Lda., as well as any other entity in whose share capital ACP comes to have a controlling stake.
Website: the ACP website, with the domain https://www.acp.pt
What data do we collect?
As a User, you are free to refuse consent for any act of processing your personal data that requires your or any other entity’s consent, and may withdraw consent that you have previously given, at your sole and exclusive discretion and at any time.
The information collected by the ACP Universe on the Users, and how their personal data are collected, may vary according to the products and services they use and subscribe to, how the products and services were used, and how Users have interacted with the ACP Universe.
The following is an indication of the personal data categories processed by the various departments of the ACP Universe:
Assistance and Quick Services
Camping and Caravanning
Commercial and Marketing
Driving Test Centre and Driving Schools
ACP Kids Events
Travel & Tourism
ACP also collects data from Users regarding their use of goods and services that it makes available, such as:
The ACP application (available on iOS and Android) allows the collection of personal data from Users, has specific privacy settings that can be managed in the application itself and can also process data that the ACP Universe receives from third parties that have the User’s permission to share them with the ACP Universe.
Who is responsible for processing your personal data?
ACP, as the entity that controls the ACP Universe business group, is responsible for processing Users’ personal data, to the extent that it is responsible for determining the purposes and means of processing their data.
When do we collect your data?
We will collect personal information about you if:
What are the grounds for processing your data?
The ACP will treat your personal data based on the following grounds:
For what purposes do we process your data?
1. To manage our relationship with the Member
2. Order processing, product supply and service provision
3. Billing and Customer Support
4. Service Information
5. For continuous technical improvement
6. For marketing and personalization of our services
7. Analytics and statistical data
The ACP Universe adopts mathematical analysis techniques that study large and varied data sets to find patterns and trends that help ACP entities to gather relevant management information on their evolution and the evolution of their Membership and Customer universe. Our professionals are obliged to respect and comply with a very strict Code of Ethics and Internal Security Policies. We apply stringent processes and adopt rigorous technical measures to ensure that the data can be anonymized or de-characterized at the appropriate stage before any processing operation.
8. For Fraud Prevention and Security
We process your data to prevent and detect fraud in the subscription and use of services and/or to detect any misuse. We also do this to avoid damage and security threats that may exist on our networks.
9. To comply with our legal and, in particular, accounting and tax obligations
10. In pursuit of the ACP Universe’s legitimate interests
Particularly for the preservation of its history and its collective memory, associated with sports events, prizes, distinctions or moments of particular relevance to ACP and/or its associates.
Who do we share your data with?
We will share your information with the following entities:
In cases where you acquire products and services from ACP Universe entities through a third party or partner organization, we will need to exchange information to manage that relationship and your account. If we make a contract with a service provider or an intermediary to provide us with services or to provide a service on our behalf and the latter has access to your personal information (for example, for data storage and retention in a cloud infrastructure), we will not authorize this third party to use or disclose your personal information beyond what is strictly necessary for the fulfillment of that subcontract.
Whenever you purchase a product or service from a third party through the ACP Universe, the contractual relationship will be established by you directly with the party that sells that product or provides that service. ACP or the other entities of the ACP Universe will only intervene if this is provided for in your agreement with the seller. The ACP Universe may transfer your personal information to the seller to complete that purchase, and this is understood as necessary for the fulfillment of the contract.
The seller's terms and conditions and their privacy and cookie policies will apply to the manner in which the seller uses your personal information and should be read carefully before you decide to complete any type of transaction with such third parties.
Partnerships established by the entities of the ACP Universe with the aim of providing them with the goods and services of interest to them, at the best market conditions, may involve joint responsibility by the ACP Universe and the partner regarding the processing of your personal data within the scope of the said partnership.
The following entities are part of the group of potential recipients of Users’ data processed by the ACP Universe:
Data transmission. How does it work?
We may use subcontractors for the total or partial processing of your personal data, under the terms permitted by law. These entities, including other companies in the ACP Universe, are bound by the contracts concluded to maintain confidentiality and to ensure the security of your data to which they have access, and may not use such data for any other purpose, nor relate them to other data they have.
In cases where partnerships established between entities of the ACP Universe and third parties involve the joint responsibility of the parties for processing personal data, the contract in question will determine, on the one hand, the responsibilities of the ACP Universe entity involved and those of the partner in relation to the processing operations, and, moreover, that Users should be informed about this co-responsibility relationship.
If we have to send your information to a country outside the European Economic Area (in particular for an ACP Universe counterpart), we will ensure that all necessary security measures are carried out and that these transfers are carried out under standard contractual clauses approved by the European Commission for this purpose, if the country to which the data may be transferred does not have legislation equivalent to the European Union standards on the protection of personal data.
How long do we keep your data?
We will store your information:
The accounting and billing data are kept throughout the duration of the Membership relationship and, after this ends, for the entire period of retention/maintenance of tax and accounting documents, i.e. 10 (ten) years.
The ACP, or one of our partners, may contact you during the retention/maintenance period of your ACP universe services data to the extent legally permissible:
Your data security while you browse the internet
Internet-based communications (such as emails) will only be considered secure if encrypted. We will not accept liability for any loss or unauthorized access to personal information beyond our control.
The Website may contain links to third-party websites. We cannot be held responsible for the security and content of such third-party websites. Users should ensure that they have read the Privacy and Cookie Policies of these companies before using or transferring personal information to them. The same applies to any third-party websites or content that you access by using our products and services.
You may choose to disclose your personal information, for example on social media or by using third-party services that allow you to post comments or other information, which means that such third parties may use this information. The information you disclose through social media, and social applications, is used by the social network itself and is subject to its own use, privacy and cookies policies. You must ensure that you are aware of these policies and that you accept or reject them freely and clearly.
Are there any other privacy policies?
What are your rights?
Right of access and rectification of personal data
You have the right to access your data and to require its rectification if it is not correct or has changed. In myACP, you may directly change some of your data that is incorrect, using the settings available in your profile.
You have the right to request a copy of the personal data that ACP holds about you.
You should formulate and submit these applications for the exercise of your rights (provided this is not done from a myACP profile) at an ACP branch, or send them to the address of the responsible entity indicated herein.
Right to data portability
You are entitled, in certain circumstances, to receive the data you have supplied to ACP, and to transmit it to another processor.
Right to object to the processing of personal data
You have the right to object to the processing of your personal data whenever the exercise of this right does not conflict with the need to comply with a legal or contractual obligation, nor with a legitimate interest of the ACP Universe.
In the event that you are aware of any situation related to the protection of your personal data, in particular with some practice with which you do not agree or that you object to, you must notify ACP by email email@example.com
Right to complain
If you wish to contact us for information on the exercise of your rights or to complain about how ACP handles your personal data, you should contact us by email at firstname.lastname@example.org. If, after contacting ACP, any questions remain, you may contact the CNPD – Portuguese Data Protection Authority, whose contact details can be found at www.cnpd.pt
Right to restriction of processing
If you consider that your data is incorrect or should not be processed by ACP, you must immediately notify ACP by email at email@example.com. In certain circumstances, you will have the right to request limitation of the use of your data by the ACP Universe.
Right to erasure your data
ACP will endeavour to only process and store the personal data for which it is responsible for the time strictly necessary to achieve its purposes. In certain circumstances, you have the right to request that we delete your personal data by e-mail at firstname.lastname@example.org.
If you consider that we are keeping your data longer than necessary, you should start by checking to see if your contract or Membership relationship with the ACP Universe is over, which can be done by contacting our Branches or by contacting the Member Support Line + 351 215 915 915, 24hr/365 days a year.
Please note that although you may no longer have a Membership relationship with the ACP Universe - or have never had one - we may have a specific legitimacy to handle your data.
Who is the entity responsible for processing?
Automóvel Club de Portugal, headquartered in Lisbon at Rua Rosa Araújo, no. 24, is responsible for Data Processing.
If you wish to contact ACP to exercise any of the above rights, please send us a written request to:
Automobile Club of Portugal
Rua Rosa Araújo, no. 24
Or by email at email@example.com
You may also submit your request in writing to any ACP Branch.
Last update: 24 May 2018
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