Privacy Policy

HOLMES PLACE undertakes to maintain the privacy and confidentiality of all information provided by the user. Accordingly, this Privacy Policy sets out the measures adopted by HOLMES PLACE with regard to Personal Data collected directly from the user and/or through the website, in accordance with the General Data Protection Regulation and other applicable legislation, both at national and EU level.


The constant endeavour to improve resources, the addition of new functionalities to our website, as well as to existing services, which result in constant changes and improvements, our practices, changes to the applicable legal regime and the evolution of technology itself may dictate changes with regard to the processing of personal data. Therefore, when there are any changes to this Privacy Policy, HOLMES PLACE will notify the user of their rights, as well as the responsible supervisory authority, in the cases required by law.

DATA CONTROLLER AND CONTACT DETAILS

The data controller is Holmes Place Brands B.V., NIPC NL851189647B01, with registered office at Julianaweg 192 A-01 | 1131 DL VOLENDAM, owner of the trade mark HOLMES PLACE.


If you have any questions regarding our use of your personal data, you can contact the Data Protection Officer at the following e-mail address EPD@holmesplace.pt, or at the postal address Avenida da República, n.º 50.º, 7.º-A, 1050-196 Lisboa, bringing the matter to the attention of the Data Protection Officer. You can also contact our head office by telephone: +351 214 131 800. 

WHAT PERSONAL DATA IS AND WHEN WE COLLECT IT

The term "Personal Data" refers to all information relating to an identified or identifiable natural person, an identifiable person being one who can be identified, directly or indirectly, in particular by reference to an identifier - such as a name, an identification number, location data, electronic identifiers - or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


We collect your personal data when you fill in the membership form, when you register in the members-only area, when you subscribe to our newsletter, when you consent to market research, when you contact us through the different channels available on our website, when you provide us with your data in the context of a contractual/pre-contractual relationship or in the context of an application, as well as through browsing cookies (please consult our cookie policy in this regard). 

WHAT ARE THE PURPOSES AND LEGAL BASIS FOR EACH OF THE DATA PROCESSES?

TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED?

HOLMES PLACE may disclose your personal data to the following recipients:


- To other Group companies, in order to guarantee centralised and secure information management;


- To commercial partners to publicise products and/or services that may be of interest to you, if you have given your consent;


- To entities responsible for providing legal services, information storage, website management, accounting and the dissemination of commercial and promotional information, among others. In any case, HOLMES PLACE undertakes to ensure that service providers are bound to fulfil their obligations under the GDPR and, specifically, to process personal data only for the agreed purposes; 


- Public Authorities and Organisations, including courts, if required; 


- Other third parties, if the data subject gives their consent, or if the processing requires their intervention.


Your personal data may also be shared in the event of the sale, merger, reorganisation, dissolution or otherwise of HOLMES PLACE.

HOW LONG WILL PERSONAL DATA BE KEPT?

Your personal data will be kept:


- For as long as is appropriate to fulfil the purposes described above;


- Until your consent to their processing is revoked, unless there is another legal basis for their processing;


- For the legally prescribed period, if there is a legal obligation to fulfil in this regard.

WHAT ARE YOUR RIGHTS?

The data subject may exercise the following rights: 


- Access to personal data - The information will be sent by HOLMES PLACE to the e-mail address, telephone contact or address of the data subject, as indicated by the data subject;


- Rectification and updating of personal data - In the event of a change to any personal data, we ask that data subjects promptly notify us;


- Deletion - The data subject may request the deletion of their personal data if it is no longer necessary for the purposes for which it was collected;


- Limitation of processing;


- Objection - The data subject may object to the processing of personal data based on our legitimate interest;


- Portability;


- Reject automated individual decisions;


- Revoke consent/cancellation - You may revoke your consent at any time, however, this revocation does not affect the lawfulness of the processing carried out prior to the withdrawal of your consent.


You can exercise the rights described above through the following channels:


- In writing, with a request addressed to: 


Data Protection Officer 


Avenida da República, no. 50, 7º-A, 1050-196 Lisbon


- By e-mail to the following address EPD@holmesplace.pt 


- With regard to the right to withdraw consent/cancellation, the data subject may also, at any time:


  • Exercise it at any HOLMES PLACE establishment;
  • Contact our head office on +351 214 131 800; 
  • Or, in the case of newsletter subscriptions, the right can be exercised via the link at the end of each newsletter.


If you are dissatisfied with our use of your personal data, or with our response after exercising any of the rights provided for in this Policy and in the General Data Protection Regulation, you also have the right to lodge a complaint with the National Data Protection Commission on the website www.cnpd.pt. 

INTERNATIONAL TRANSFERS OF PERSONAL DATA

HOLMES PLACE will only transfer your personal data to third countries - which do not belong to the European Economic Area - for which the European Commission has not issued an adequacy decision regarding the level of protection of personal data, if the necessary and appropriate measures are in place under applicable law to ensure the protection of the personal data subject to such a transfer, such as standard contractual clauses approved by the European Commission or another mechanism.


If the user is in a country other than the one where the website's servers are located, communications may result in an international transfer of information. By visiting the HOLMES PLACE website and communicating with us electronically, you consent to the processing and transfer of your Personal Data as set out in this Privacy Policy.

INFORMATION SECURITY MEASURES APPLIED

HOLMES PLACE applies the appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These measures are periodically reviewed and are designed to guarantee the security and protection of your personal data in terms of its availability, authenticity, integrity and confidentiality, as well as to prevent its loss, misuse, alteration, unauthorised processing or access, or any other form of illicit or abusive processing.

APPLICABLE LAW

This Privacy Policy is an integral part of the Terms and Uses of our website. In the event of any dispute or claim of any nature relating to this website, Portuguese law shall apply, regardless of any conflict of laws provisions. All legal actions or proceedings arising out of or in connection with this Privacy Policy, its validity, application, fulfilment or non-compliance, or the subject matter of this Privacy Policy, shall fall within the jurisdiction of the Portuguese courts, and the user irrevocably consents and submits to the jurisdiction of these courts in the cases indicated. Notwithstanding the foregoing, HOLMES PLACE reserves the right to take legal action in any jurisdiction where there is a breach of this Privacy Policy.