Legal
Privacy
This notice names a retention period for every category of data rather than saying “as long as necessary”, because a period you can hold us to is the only kind worth publishing.
Dunara holds very little about you. The website offers six forms and one email address, and it stores two items on your own device, both of which exist so that the site behaves properly. This notice covers every one of those, and the records that a stay, a membership or a residence enquiry creates behind them.
Where a period below reads 180 days, that is the expiry written onto the record at the moment it is created. The storage removes it on the day it falls due, without anyone having to remember.
Who is responsible
The controller is CLICK-MART LIMITED, a company incorporated in England and Wales on 17 May 2022, company number 14111937, D-U-N-S 228941507, registered office 124 Islwyn Road, Cross Keys, Newport, Wales, NP11 7QJ, United Kingdom. The director is Maryam Nadeem.
The same company conceived, developed and built Dunara and operates it. That is why this notice is signed by a developer rather than by a management brand: the party that decides what happens to your data is the party that poured the walls.
Because the company is established in the United Kingdom and supplies accommodation in Portugal, two regimes apply to the same processing — the UK GDPR and the EU GDPR. Where the two differ we apply the stricter reading. The representative appointed under Article 27 of the EU GDPR is named in writing on request to the registered office or to the address below.
All data-protection correspondence reaches a person at [email protected]. That address and the forms on this site are the only contact channels Dunara publishes.
What we hold, why, and for how long
Eight categories, which is all of them. Each row names the lawful basis under Article 6 or Article 9 of the GDPR and the period after which the record is gone.
| What we hold | Why we hold it | Lawful basis | How long |
|---|---|---|---|
| Enquiry — your name, email address, subject and message | To read the enquiry and answer it, in the language you wrote in. | Article 6(1)(b), steps taken at your request before a contract. Where no stay is in view, Article 6(1)(f). | 180 days in the website's store, then it expires on its own. |
| Reservation enquiry — name, email, arrival and departure dates, the number of adults and children, the suite and rate plan you chose, and your requests | To check availability, hold the suite and confirm the stay. | Article 6(1)(b). | 180 days in the website's store. A confirmed booking moves into the reservation record and is kept for the stay and then ten years, the longer of the two accounting periods this company is subject to. |
| Dietary and accessibility requirements — written in the requests field, or sent to us by email afterwards | So that the kitchen, the spa and housekeeping can prepare before you arrive rather than improvise once you have. | Article 6(1)(b) for the arrangement itself, and Article 9(2)(a), your explicit consent, for the part that reveals a health condition or a belief. | Removed from the reservation record within 30 days of departure, unless you ask us to hold a standing note for future stays. |
| Spa health questionnaire — the answers you give before a first treatment, covering medication, pregnancy, allergies, recent surgery and skin conditions | So a therapist can judge which of the 18 treatments is safe for you, and at which of the four durations. | Article 9(2)(a), your explicit consent, given on the form itself. | 24 months from your last treatment, so a returning guest is not asked the same questions twice; then destroyed. |
| Membership application — name, email, the tier applied for, the intended start date and your country of residence | To place the application against the cap of 900 memberships, and of 60 at SOURCE, and to bill the right fee. | Article 6(1)(b). | 180 days in the website's store. A live membership for its term and then ten years. A place on the waiting list until you ask to leave it, reviewed every twelve months. |
| Event and residence enquiries — name, email, organisation, event type, date, guest numbers, the spaces or unit type you asked about, and an indicative budget | To answer with a capacity plan, a proposal or a price list. | Article 6(1)(b), and Article 6(1)(f) where the enquiry is exploratory. | 180 days in the website's store, then the sales record for six years from our last contact. |
| Newsletter — your email address and the language you read in | To send the estate's letter, which goes out when there is something to report. | Article 6(1)(a), consent. | Until you unsubscribe. Your address then stays on a suppression list so that a later import cannot add you back, and nothing else is kept beside it. |
| Submission context — the language of the page, the page you submitted from, the two-letter country code of your connection, and your browser's user-agent string | To answer in the right language, and to recognise automated abuse of the forms. | Article 6(1)(f), our interest in an enquiry channel that works and is not flooded. | With the submission it belongs to: 180 days. |
Ten years is the longer of the Portuguese and United Kingdom retention periods for accounting records; we apply the longer one to the whole financial record rather than split it.
The three things that are special-category data
Three of the categories above carry a higher bar under Article 9 of the GDPR, and they are handled differently from the rest.
A dietary note is ordinary information when it is a preference and special-category information when it reveals an allergy or a religious observance. From the outside the two look identical, so every dietary note is treated as the stricter case.
An accessibility requirement reveals something about health by its nature. It is held for the stay it relates to and shared only with the departments that have to act on it — reception, housekeeping, and the kitchen or the spa, depending on what you have asked for.
The spa health questionnaire is the only health form Dunara asks you to complete. It is filled in at the spa desk before a first treatment, not on this website, and it is read by the therapist treating you and by the spa manager. Nothing from it is copied into the reservation record.
In each case the lawful basis is Article 9(2)(a) — your explicit consent, given at the moment you choose to tell us. You can withdraw it by email and the answer is removed within five working days. The one consequence of declining the questionnaire is that a treatment whose safety depends on it cannot be booked; everything else on the estate is unaffected.
How a form submission is actually handled
Each of the six forms is a plain HTML form that posts to this domain. It works with JavaScript switched off; the script on the page only adds inline validation and the success message.
A submission is validated, given a reference you can quote — a three-letter prefix and six characters in two groups of three, such as RES-K4D-9PQ — and written to the store with a 180-day expiry. The reference is derived from the form kind, your email address and the timestamp, and nothing can be read back out of it.
Alongside what you typed, the record keeps four pieces of context: the language of the page, the page you submitted from, the two-letter country code of your connection, and your browser's user-agent string. The address your connection came from is used in memory for exactly one purpose, a per-minute submission limit that blunts an accidental flood, and it is not written into the record.
Two automated checks run before a person reads your form: a hidden field that a person never fills in, and that per-minute limit. Neither one makes a decision about you. If either stops a submission that should have gone through, an email to [email protected] reaches a person directly.
Who else sees it
Inside the company, access follows the role. Reservations sees reservation records. The spa sees spa records. The membership office sees membership records. The finance function sees what the accounts require and no more.
Outside the company, three kinds of processor are involved: the edge-network and storage provider that serves this website and holds form submissions until they expire; the reservation and property-management system that a confirmed booking moves into; and the provider that carries our email. Each works under a written contract that binds it to our instructions. The current list, with the country each processor operates from, is sent by email on request.
A payment is taken by a payment provider, which receives the card details directly from you. Dunara's own records keep the last four digits, the card scheme and the authorisation reference, which is what a refund or a chargeback needs.
We give data to a public authority only where the law requires it — the guest registration that Portuguese law asks of accommodation, and a lawful request from a tax authority. Each such disclosure is logged with its date and its legal ground.
Where it goes
The website is served from the edge network's data centre nearest to you, which for a European reader is in Europe. Form submissions are written to a storage layer that the provider may replicate outside the United Kingdom and the European Economic Area.
Where that happens, the transfer rests on the UK International Data Transfer Addendum and, under the EU regime, the European Commission's standard contractual clauses, together with an assessment of the destination's law. A copy of the clauses relied on for a particular transfer is sent by email on request.
Your rights, and how to use them
Every one of these is exercised the same way: an email to [email protected]. There is no form to find and no portal to register for.
You can ask for a copy of everything we hold about you, with the purposes, the recipients and the retention periods. We answer within one month. A request that is genuinely complex can be extended by two further months, and we will tell you it has been extended before the first month is up.
Access is free. We ask one question to be sure we are speaking to the right person, usually a detail from the booking the request concerns.
A name, a date, a spelling or a dietary note is corrected by email and we confirm the change in writing. A correction that touches a confirmed booking produces a reissued confirmation, so the version you hold and the version we hold stay identical.
An enquiry, a newsletter subscription, a spa questionnaire or a place on the membership waiting list is deleted on request, normally within five working days.
Where the record supports a stay that has already happened, accounting law requires us to keep the financial part of it for ten years. In that case we delete everything the accounts do not need and tell you precisely what remains and when it goes.
If you contest the accuracy of something, or you have objected and we are still considering it, you can ask us to hold the record without using it until the point is settled. We confirm when the hold starts and when it lifts.
The data you gave us through a form, and the booking data that follows from it, can be sent to you or to another provider in a structured, machine-readable file. We send JSON or CSV, whichever you ask for.
Where we rely on a legitimate interest — the submission context, and an exploratory enquiry — you can object, and we stop unless we can show a ground that overrides yours, in writing. For marketing there is no balancing exercise at all: an objection ends it.
The newsletter carries an unsubscribe link in every message. A dietary note, an accessibility note or a spa questionnaire is withdrawn by email. Withdrawing is as easy as giving it was, and it leaves untouched whatever was lawfully done beforehand.
If our answer does not satisfy you, you can complain to a supervisory authority. For the United Kingdom that is the Information Commissioner's Office; for Portugal, the Comissão Nacional de Proteção de Dados; you may also go to the authority of the country you live in.
Going to a regulator does not stop you asking us again, and we would rather you did both.
Children
The forms on this site are written for an adult making an arrangement. A child's details reach us through the adult booking the stay: the number of children, their ages where a cot or the extra bed in an Atlantic Suite or the Lagoa Villa is involved, and a dietary note where there is one.
A child's dietary or health note is handled as special-category data on the explicit consent of the person with parental responsibility, and it leaves the reservation record within 30 days of departure on the same schedule as an adult's.
The newsletter is for adults. The treatments that require the health questionnaire, and the Long Circuit, are for guests of 16 and over.
Automated decisions and profiling
No decision about a booking, a rate, a membership, an event or a residence is taken by automated means. Every enquiry is read by a person, and that person's name is on the reply.
There is no profiling. We do not score you, group you into a segment, or assemble a picture of you across visits. The two automated checks on the forms are described above, and they decide nothing about you.
The response this server sends also tells your browser that the site will not ask for your location, your camera or your microphone, and will not take part in interest-based advertising cohorts. Your browser enforces that, which makes it a stronger promise than a sentence in a policy.
Keeping it safe
Traffic to this site is encrypted in transit and the connection is pinned to HTTPS for a year at a time. Every response carries a content security policy that allows scripts, styles, fonts, images and form posts from this domain only, a strict referrer policy, and the headers that stop a page being framed or its content type guessed.
Stored submissions sit in a key-value store that only this site's own service can read. Access inside the company is by named account, and an account is closed on the day a person leaves.
If a breach ever puts your rights at risk, we tell the relevant supervisory authority within 72 hours of becoming aware of it, and we tell you directly, in plain language, with what we know, what we do not yet know, and what we are doing about it.
Changes to this notice
This notice is reviewed every twelve months and whenever something material changes — a new processor, a new form, a new purpose.
A material change is dated at the foot of this page and, if you hold a live booking or a membership at the time, sent to you by email. A change of wording that does not change what we do is simply dated.
A question about your data
One address, read by a person: [email protected]. The cookie policy covers the two items this site stores on your own device.