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This document establishes the Privacy and Cookies Policy (hereinafter "the Policy") of Automóvel Club de Portugal, a private company, deemed of public utility, founded in 1903 (nineteen hundred and three), with its headquarters in Lisbon, at Rua Rosa Aráujo, No. 24 (hereinafter "ACP") and the group of entities that comprise the ACP Universe. This Privacy Policy applies to processing the personal data of the Members and/or Customers (hereinafter referred to as “User" or “Users"), or of Website users who upload their personal data on any forms available on the site https://www.acp.pt.

If the user of the Website has any reservations, doubts or objections to this Privacy Policy, you should immediately cease to access and use the Website. You should leave the Website and refrain from using it and/or transmitting any personal data to ACP, including through submitting contact forms.

ACP reserves the right to change this Privacy Policy at any time. ACP will send alerts about changes to the Privacy Policy to Users who have subscribed to the ACP's news alert service.

Any change to this Privacy Policy will automatically be included in this version with date and effects as of the date of its publication on the Website.

Customers may visit the Website anonymously at any time. The Website still uses Cookies in this situation. To learn more about our Cookies Policy, click here.

Revised, updated version effective as of 24 May 2018.

Definitions

Unless the context states otherwise, the terms and expressions used in this Privacy Policy have the following meanings:

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?

ACP only processes data that is voluntarily submitted by Users which can legitimately be processed under the terms and for the purposes of the legislation in force, and in accordance with this Privacy Policy.

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

• Identification information
• Vehicle data
• Contact details
• Geolocation data (communicated by phone or via GPS system)
• History of assistance services’ use
• In cases where it is necessary to meet requests from Members/Clients, medical data and payment data 

ACP Autos

• Identification information
• Contact details
• Customer History

Camping and Caravanning

• Identification information for the Member and companions
• Contact details
• Payment details
• Customer history

Commercial and Marketing

• Identification information (including TIN) for the Member/Customer and family
• Contact/activities details, information/service requests, complaints
• Payment details
• Behavioural data/history
• Vehicle data
• Health Data
• Business opportunity and order data
• Communications subscription data
  
  

Call Centre

• Identification information
• Contact details
• Registration of telephone calls under the ACP Customer Support service, including call recording, the date and time of those communications
• Payment details
• Vehicle data (CRM registration or Cartrack sale)
• Data on financial standing, bank responsibilities, employer
• Membership interaction history (CRM registration of Member’s calls and emails)

Branches/Documentation

• Identification information for the Member/Customer and his/her family, in the case of subscription of services intended for the subscriber and relatives
• Contact details
• Payment details
• Member relationship and transaction history
• Health data (for subscription to health services through partners or issuing documents that require verification of health conditions)
• Property data
• Collecting Members’ pictures for driver´s licence renewal
  
  

Driving Test Centre and Driving Schools

• Member or Customer Identification Information
  
• Contact details
• Health Data
• Customer history and attendance control

Golf

• Member identification information (including picture)
• Contact details
• Sports data
• Payment details
• Sports history
• Publication of photos, videos and news with identification of Members

ACP Classics

• Member identification information, including picture
• Contact details
• Vehicle data
• Customer history and attendance control
• Sports history
• Payment details
• Lists of participants without contact details
• Publication of photos, videos and news with identification of Members

ACP Kids Events

• Identification information (including TIN) for the Member/Customer and family
• Contact details
• Professional data
• Payment details
• Transaction history

Travel & Tourism

• Member/Customer and companions identification information
• Contact details
• Payment details
• Customer History
• Food preferences/special needs

Insurance Brokerage

• Identification information (including TIN) for the Member/Customer and family
• Contact details
• Property data
• Payment details
• Health Data
• Data on professional activity
• Claims and Customer history
• Complaint resolution history
• Transaction history 

Motorsport

• Identification information (including TIN) for the Member/Customer and competitor in sporting events
• Contact details
• Property data
• Payment details
• Health Data
• Sports data
• Customer history
• Images of participants in event, staff and public

ACP also collects data from Users regarding their use of goods and services that it makes available, such as:

• Details on the use of services provided by entities of the ACP Universe, or products made available by the partners of the ACP Universe, when the User gives his/her consent or there is another legal basis or legitimate interest for such.
• Information on the preferred services of Members, the degree of satisfaction with these and satisfaction or dissatisfaction feedback on the partners of the ACP Universe, the services and products offered by the ACP Universe, so that we can continue to provide our services to Members and Customers and to continually improve them, whenever such monitoring is authorized, or whenever the Member or Customer sends us their feedback directly by way of complaints or compliments.
• Data on service subscriptions or service purchases made, or other information related to your account or included in myACP.
• Data to verify, retrieve and/or allow your credentials on the website or in your reserved area in myACP, using passwords, password recovery questions and other security information.
• Data on your preferences for products, services and activities in your ACP Universe, whenever you provide such information or we may infer such preferences according to how you interact with the Website, your area reserved in myACP and how you use the products and services in the ACP Universe, especially those of our partners.
• Data collected using Cookies, web beacons and other technologies, including for marketing and advertising purposes. To learn more, check out our Cookie Policy here

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.

Our Privacy Policy does not extend to all areas where we are present. On social media, such as Facebook, Instagram, Twitter or others, ACP may be present via an institutional page. However, all of the Customer's interaction with the ACP Universe in this space that may involve personal data is governed by the Privacy Policy of the operator and manager of the social network in question, to which ACP is totally unrelated.

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:

• You become an ACP Member.
• You register on the Website or, without registering, browse our website with the cookies feature turned on. Learn about our cookies policy here
• Contact us through other channels, i.e. our Call Centre or Branches, or request information about a product or service from the ACP Universe.
• Buy or use products or services from the ACP Universe, especially in the ACP Discounts area, from myACP or in the Rally Store.
• Use our network of partners that make up the ACP Universe
• Register for a specific activity, product or service in the ACP Universe.
• Subscribe to newsletters, alerts or other services from the ACP Universe.
• Participate in a contest, sweepstake or questionnaire promoted by us.
• Have authorized other companies, such as our partners in the ACP Universe for joint initiatives, our suppliers or third parties, to share information about you.
• Your information is publicly available.

What are the grounds for processing your data?

The ACP will treat your personal data based on the following grounds:

• In order to conclude and fulfil the contract as an ACP Partner, including the performance of pre-contractual procedures, and in the context of contractual relations established for the acquisition of goods or subscription to services provided by the ACP Universe, including for issuing corresponding invoices, and managing the use of the goods and services from the ACP Universe. Partners of the ACP Universe may need to carry out credit checks to enter into contracts that involve credit facilities, such as for example applying for the ACP Master Card.
• In pursuit of the ACP Universe’s legitimate interests, for example, to prevent fraud or to ensure the security of our network and services. Whenever there is legal basis under which data are collected from Users by the ACP Universe, we will assess our commercial interests to ensure that they do not clash with your rights. In addition, in certain cases, you will be entitled to oppose such processing. For more information about the exercise of Users’ rights, see the “What are your rights” section in this Privacy Policy.
• To fulfil a legal obligation to which the ACP Universe is bound, which includes, for example, compliance with accounting and tax obligations.
• On the basis of your consent, in cases where the ACP Universe does not use another legal basis. This consent can be withdrawn at any time. To better manage your consents, register at myACP and set up your profile. If you prefer, please go to an ACP Universe branch or contact our Customer Services at 219 429 133, 24hr/365 days a year (calls will be charged at national landline calling rate).

For what purposes do we process your data?

1. To manage our relationship with the Member

• To process your membership card application, issue and manage
• To manage our relationship with the Member, on complying with the provisions of the ACP Statutes
• For sending the ACP magazine and other institutional communications related to ACP to Users

2. Order processing, product supply and service provision

• In order to process your orders to purchase products and subscribe to services, whether these are provided by the entities of the ACP Universe or through the partner network of the ACP Universe, and to keep you informed about the processing of your orders or requests.
• To provide you with the requested products or services. Also included here are other related services, such as payment services (for example PayPal), or services that use information about your location (such as travel assistance or cartrack services).
• For the organization of events by ACP Universe departments, and the news and photos release of those events.

3. Billing and Customer Support

• To issue the invoice for your membership fees, or regarding the use of our products and services, or to collect a debt that you owe to us.
• To respond to any questions, complaints, doubts and/or concerns you may have about the ACP Universe or our products or services.

4. Service Information

We will contact you through messages to keep you up-to-date with the latest information about products and services that you have purchased or subscribed to. For example, we will contact you to inform you of any changes to our terms and conditions, the life cycle of your Membership Card, new services available and the best advantages available to you as Members, as well as any changes to this Privacy Policy.

5. For continuous technical improvement

• In order to improve your experience of using the Website, to detect and correct fraudulent use of our networks (and our partners' networks) and to resolve technical problems, should they occur.
• To better understand the performance of the ACP Universe in relation to the provision of services, to verify that the Services and products are in compliance or whether improvements should be made.
• For these purposes, the ACP Universe totally and partially uses its personal data or uses metadata that allow for their effective use. Based on this information, the ACP Universe creates aggregated and anonymized statistical reports. This processing can help the ACP Universe to improve the delivery of its services without Customers being identified individually.
  
  

6. For marketing and personalization of our services

• As a Customer or Member of the ACP Universe, we want to keep you informed about our products and services, and about the products and services that you can access through our partner network, by sending you newsletters or reports, invitations to participate in questionnaires or news about offers, promotions, sweepstakes or contests in your areas of interest. We will tailor these messages based on the types of products and services that you have purchased from us, or on the subjects you have indicated are of interest to you when subscribing to our newsletters.
• We will be able to better customize the offers and business recommendations that we will present to you based on how you use our services, your location information or browsing history, provided you have consented to data processing for this purpose.
• If you have authorized processing for this purpose, we can also contact you to inform you about products and services from the ACP Universe that we believe will interest you.
• We may also present information online and contact you through the various channels available: email, text message, telemarketing or by sending notifications through the ACP App.
• In order for us to be able to present to you with the most relevant advertising, you will be able to view ads online about ACP Universe products and services using cookies (online behavioural advertising). Advertising may be displayed on websites that belong to the ACP Universe, ACP Universe partners as well as other online communication channels such as social media.
• We may also combine data collected through cookies with other data that we have obtained, or interconnect your data with the data that our partners have about you. If you do not want your information to be processed through the use of cookies, you should consult our Cookie Policy here
• You should be aware that the behavior - and/or interest-based advertising refusal option does not prevent ads from being displayed to you; it simply means that they will not be tailored to your interests.
• You can control and manage the contact channels and their consents at any time. To manage your consents for processing your personal data, register with myACP and set up your profile. If you prefer, please go to an ACP Universe branch or contact our Customer Services at 219 429 133, 24hr/365 days a year (calls will be charged at national landline calling rate).
  
  

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

• To carry out ACP functions in the exercise of powers of public interest conferred by Law.
• In order to fulfil the legal obligations to which the entities of the ACP Universe are bound, in particular for accounting, tax and regulatory purposes, with respect to the activities carried out by the departments of the ACP Universe that are subject to specific regulation (e.g. Insurance, Camping and Caravanning, Motor Sports, etc.).

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:

• Among entities of the ACP Universe.
• Counterparts of ACP or of the entities that comprise the ACP Universe in the rest of the world, according to request and/or interest of Members/Customers.
• The commercial partners of the ACP Universe identified here
• Companies contracted to perform services for or on behalf of any entity in the ACP Universe.

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:

• Debt collection agencies or other organizations for debt recovery.
• Police authorities, government agencies, regulatory authorities, courts or other public authorities, when required or permitted under domestic law. Your personal data will only be made available when we are required to do so by law, and after an evaluation of all legal requirements.
• Third parties with whom we may develop promotions and joint actions. In these cases, the third parties will be responsible, within the scope of their activity, for compliance with the applicable laws.
• Other third parties, whenever you have specifically given us your consent.
  
  

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:

• for as long as the Membership relationship, if any, lasts.
• for the whole term of the contractual relationship established with ACP or the ACP Universe company concerned, plus the legal deadline for the custody and retention of accounting and financial information in question, and beyond (it being understood furthermore herein) until the end of the legal limitation period of the rights arising from the contractual relationship.

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:

• for as long as it lasts for the purpose of the processing and/or for another period required by law, whichever is longer.
• with respect to processing personal data for marketing purposes, which relates to data which are not owned by Members or Customers, for the period in which the processing has been authorized by the User’s consent, or, in the absence thereof, for a period of 3 years from the date of the last interaction initiated by the User with the ACP Universe.

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?

ACP and the whole group of partners and associates - the ACP Universe and partner network - provide a vast array of goods and services, some of which are the subject of a separate and complementary privacy policy. When you access a specific area for a given ACP Universe product or service (for example, ACP Discounts), you will be provided with the link to the specific ACP Partner Policy - VIP Collectives - which, in addition to this policy, adopts its own Privacy Policy.

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.

To do this you can contact an ACP Branch near you, or contact the entity responsible for the processing indicated in this Privacy Policy.

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 protected]

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 [email protected]. 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 protected]. 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 [email protected].

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

Privacy

Rua Rosa Araújo, no. 24

1250-195 Lisbon

Portugal

Or by email at [email protected]

You may also submit your request in writing to any ACP Branch.

Last update: 24 May 2018