At Pickorashufflespot Media Portugal Lda. (“we,” “us,” or “our”), governing the digital domain pickorashufflespot.forum, we hold the privacy and personal integrity of our global readers, club patrons, and digital members with the utmost seriousness. This Privacy Policy details our operational protocols concerning the collection, storage, processing, transfer, and safeguarding of your personal data under the European Union General Data Protection Regulation (Regulation EU 2016/679 - GDPR), the Portuguese Data Protection Act (Lei n.º 58/2019), and relevant international data privacy laws.
1. Legal Entity & Data Controller
The designated Data Controller responsible for all processing activities on this platform is:
- Company Name: Pickorashufflespot Media Portugal Lda.
- Registration Number: PT-517894231
- Official Address: Avenida 24 de Julho 102B, 1200-868 Lisboa, Portugal
- Data Protection Officer (DPO): [email protected]
2. Categories of Information We Collect
Depending on your direct interaction with our website, our 3D architectural engines, and our VIP concierge reservation portals, we collect several categories of information:
- Voluntarily Provided Information: Full legal name, professional email address, telephone contact numbers, dietary preferences, special occasion notations, and billing verification details submitted when requesting sky table bookings or concierge assistance.
- Automated Device & Navigational Analytics: Internet Protocol (IP) addresses (anonymized prior to database indexing), operating system type, browser user-agent tokens, GPU hardware capabilities (for optimizing canvas performance), referring URLs, session duration, and clickstream trails across our regional rooftop directories.
- Preference & Consent Tokens: Encrypted local storage flags indicating your explicit acceptance or refusal of non-essential tracking cookies and interactive shader features.
3. Legal Bases for Data Processing
In strict alignment with Article 6 of the GDPR, Pickorashufflespot Media Portugal Lda. processes your information solely under the following verified legal grounds:
- Performance of Contract (Art. 6(1)(b)): Necessary to execute your VIP rooftop reservation requests, transmit booking confirmations, and interface directly with partnered hospitality directors.
- Legitimate Interests (Art. 6(1)(f)): Necessary to ensure site security, defend against distributed denial-of-service (DDoS) threats, monitor GPU frame rate delivery for seamless 3D rendering, and improve editorial coverage.
- Explicit Consent (Art. 6(1)(a)): Provided when subscribing to our weekly curated Atlantic Heights newsletter or approving analytical cookies via our persistent consent banner.
- Legal Compliance (Art. 6(1)(c)): Fulfilling tax, corporate reporting, and commercial invoice verification mandates under Portuguese commercial law (Código das Sociedades Comerciais).
4. Third-Party Processors & International Transfers
We do not sell, rent, or trade your personal information to marketing brokers. We share necessary data only with certified service providers under rigorous Data Processing Agreements (DPAs):
- Cloud Hosting & CDN: Servers hosted within the European Economic Area (Frankfurt and Lisbon nodes) with ISO/IEC 27001 certifications.
- Concierge Integration: Partner club booking directors in Lisbon, Porto, Cascais, and the Algarve strictly for confirmed guest list execution.
- Content Delivery: Static mathematical dependencies (such as Three.js libraries) distributed via Cloudflare CDN without collecting user-identifying telemetry.
5. Data Retention Periods
Personal information collected for concierge communications is retained for exactly 24 months following the conclusion of the reservation date to satisfy administrative follow-up and accounting requirements. Web server logs and technical telemetry are purged or anonymized on a 90-day rolling cycle.
6. Your Statutory Rights Under GDPR
Every user interacting from the European Union, European Economic Area, or international jurisdictions with reciprocal standards possesses the following enforceable statutory rights:
- Right of Access (Art. 15): Request a structured extract of all personal data held concerning you.
- Right to Rectification (Art. 16): Correct outdated or inaccurate address, phone, or identity records.
- Right to Erasure (Art. 17): Demand total deletion ("Right to Be Forgotten") when data is no longer necessary.
- Right to Restriction of Processing (Art. 18): Restrict processing during active disputes.
- Right to Data Portability (Art. 20): Receive your records in an interoperable, machine-readable format.
- Right to Object (Art. 21): Object at any time to legitimate interest processing or editorial newsletters.
To exercise any right, contact our Data Protection Officer at [email protected]. Under Portuguese law, you also retain the right to lodge an official complaint with the national supervisory authority: Comissão Nacional de Protecção de Dados (CNPD), Av. D. Carlos I, 134 - 1.º, 1200-651 Lisboa, Portugal.