Privacy Policy

1. Who we are and how to contact us

The website www.club65.pt is owned by SENIOR CLUB, INDEPENDENT LIVING S.A. (“Club65”, “we”, “us”), the controller responsible for the processing of personal data collected through this website.

SENIOR CLUB, INDEPENDENT LIVING S.A.
Address: Campo Grande 28, 3.º A, 1700-053 Lisboa, Portugal
E-mail: info@club65.pt

For any question relating to privacy and data protection, including the exercise of your rights, you can contact us using the details above.

 

2. Scope of this policy

This Privacy Policy describes how Club65 collects, uses, shares and protects the personal data of the users of this website, in accordance with Regulation (EU) 2016/679 — the General Data Protection Regulation (“GDPR”) — and with the applicable national legislation, namely Portuguese Law no. 58/2019 of 8 August. It applies to data processed in the context of the use of the website and of the forms made available on it.

 

3. What personal data we collect

Data provided directly by the user: name, e-mail address, telephone number and any other information you submit through our contact forms, information requests, visit bookings or newsletter subscription. Mandatory fields are marked on each form; all other fields are optional.

Data collected automatically: IP address, device and browser type, language, pages visited and other browsing data, collected through cookies and similar technologies. The IP address is personal data and is used for security purposes, technical server diagnostics and the production of aggregated usage statistics (for example, to understand how the website is used across different geographical locations). For more information about the cookies we use, please see our Cookie Policy.

 

4. Purposes and legal bases of processing

We process your personal data only for specified purposes and on a valid legal basis:

• Responding to information requests, contacts and visit bookings — pre-contractual steps taken at the data subject’s request (Art. 6(1)(b) GDPR) or consent (Art. 6(1)(a));
• Sending the Club65 newsletter and informational communications — consent (Art. 6(1)(a));
• Personalised advertising and audiences on third-party platforms — specific consent (Art. 6(1)(a)) — see section 5;
• Statistics, audience measurement and website improvement — consent, in the case of non-essential cookies, and/or our legitimate interest in the continuous improvement of our services (Art. 6(1)(f));
• Website security and the prevention of fraud and misuse — legitimate interest (Art. 6(1)(f));
• Compliance with legal obligations to which Club65 is subject (Art. 6(1)(c)).

 

5. Personalised advertising and audiences on third-party platforms

With your consent, Club65 (Senior Club, Independent Living, S.A.) shares your contact details — your e-mail address and/or telephone number, transmitted in encrypted (hashed) form — with advertising platforms and social networks, namely Google (Google Ads), Meta (Facebook and Instagram) and LinkedIn. This data is used to show you more relevant Club65 communications on those platforms and to identify new audiences with characteristics similar to yours (“similar audiences” or lookalikes).

Legal basis: your consent (Art. 6(1)(a) GDPR), collected in a specific and separate manner. Subscribing to the newsletter and accepting this policy do not imply this consent.

International transfers: these platforms may process your data outside the European Economic Area, including in the United States, under the EU-U.S. Data Privacy Framework and/or standard contractual clauses approved by the European Commission.

Retention: your data remains in these audiences for as long as you maintain your consent or until the end of the campaign, after which it is removed.

Your rights: you may withdraw your consent at any time, without affecting the lawfulness of the processing carried out beforehand, by writing to info@club65.pt; withdrawal entails the removal of your data from these audiences. No automated decisions with legal effects concerning you are taken.

 

6. Who we share your data with

Your personal data is treated confidentially. It may be shared with:

• Service providers acting on behalf of Club65 (for example, website hosting, e-mail delivery and analytics tools), in their capacity as processors, bound by contract and required to guarantee the security and confidentiality of the data (Art. 28 GDPR);
• Advertising platforms identified in section 5, exclusively with your consent;
• Public authorities, where required by law or by a court decision.

Club65 does not sell personal data to third parties.

 

7. International data transfers

Some of our service providers and the platforms referred to in section 5 may process data outside the European Economic Area. In such cases, we ensure that the transfer takes place under appropriate safeguards, in accordance with Articles 44 et seq. of the GDPR — namely adequacy decisions of the European Commission (including the EU-U.S. Data Privacy Framework) and/or standard contractual clauses.

 

8. Retention periods

We keep your personal data only for as long as necessary for the purposes for which it was collected:

• Information requests and contacts: for the period necessary to respond and follow up;
• Newsletter and communications: until you withdraw your consent;
• Advertising audiences: for as long as you maintain your consent or until the end of the campaign (see section 5);
• Data subject to legal obligations: for the periods required by law.

Once these periods have elapsed, the data is securely deleted or anonymised.

 

9. Your rights

Under the GDPR, you have the right to request, at any time:

• Access to your personal data;
• The rectification of inaccurate or incomplete data;
• The erasure of your data (the “right to be forgotten”);
• The restriction of processing;
• The portability of your data;
• The right to object to processing, including for direct marketing purposes;
• The withdrawal of your consent, at any time, without affecting the lawfulness of the processing carried out until then.

These rights may be exercised in person, by letter or by e-mail, using the contact details indicated in section 1. We will respond without undue delay and, in any event, within a maximum of one month, extendable under the terms of the law.

If you consider that the processing of your personal data infringes the GDPR, you also have the right to lodge a complaint with the national supervisory authority: CNPD — Comissão Nacional de Proteção de Dados (the Portuguese Data Protection Authority — www.cnpd.pt).

 

10. Automated decision-making

Club65 does not take decisions based solely on automated processing, including profiling, which produce legal effects concerning the data subject or similarly significantly affect them.

 

11. Security

Club65 applies appropriate technical and organisational security measures, continuously optimised and updated in line with technological developments, to protect personal data against unauthorised access, destruction, loss, alteration and unlawful disclosure (Art. 32 GDPR).

 

12. Cookies

This website uses cookies and similar technologies. Detailed information about the cookies used, their purposes and durations is available in our Cookie Policy, and you can manage or withdraw your consent at any time using the ‘Consent Preferences’ button available on the website.

 

13. Links to external websites

The Club65 website may contain links to external websites, provided for the user’s convenience and information. By accessing these links, the user leaves the Club65 website. SENIOR CLUB, INDEPENDENT LIVING S.A. does not control those websites or their privacy policies, which may differ from this policy, and we therefore recommend that you read them before submitting any personal data.

 

14. Changes to this policy

SENIOR CLUB, INDEPENDENT LIVING S.A. may update this Privacy Policy from time to time, in particular to reflect changes in legislation or in its data processing practices. The date of the last update is always indicated at the top of this document. We recommend that you review this page regularly.

 

15. Governing law and jurisdiction

This website was created and operates in accordance with Portuguese law. Any dispute arising from its use will be governed by the legislation in force, with the Portuguese courts having jurisdiction, without prejudice to any applicable mandatory rules.