For the Madeira Promotion Bureau (APM) the privacy and security of your personal data are of crucial importance.

This privacy policy applies to the ‚‘ website. Its use implies agreement with the conditions present in this policy.

  1. The Madeira Promotion Bureau

The Madeira Promotion Bureau (APM) is a non-profit association, founded in August 2004 by a public and a private entity – the Regional Tourist Board and the Funchal Trade and Industrial Association. Its purpose is to carry out actions to promote Madeira as a destination, always seeking to develop a set of initiatives which encourage the diversification of the offer that the destination presents,

The data controller is the Madeira Promotion Bureau (APM), with registered office at Rua dos Aranhas, 24-26. 9000-044 Funchal, legal person no. 511236077. The commitment to the safety of the information and protection in the treatment of personal data treated to the website ‚‘, is undertaken by the Board of Directors of the Madeira Promotion Bureau (APM).

  1. The website ‘ is a website that promotes Golf in Madeira and Porto Santo. Its main objective is to provide users with a golf passport covering Madeira and Porto Santo golf courses, allowing players to book and choose which courses they want to play on and when.

To find out more details about how we collect, use, share and protect the personal data we obtain, please read the following sections of this Privacy Policy.

  1. Categories of Personal Data processed by the website
  • Filling in the booking form, personal data from the following categories can be collected:
  • Identification data (e.g. name, passport);
  • Contact details (e.g. address, mobile, email);
  1. Purposes, grounds for processing and time limits for storing personal data

In the performance of its duties, by virtue of a contractual relationship, legal obligation and/or legitimate interest, the APM, may process your personal data for the purposes described in the table below. 

Purpose of processing Data category Basis of lawfulness Retention period

Offer of reservation services – Golf Passport


Identification data; Contact details;


Submission of the booking form made voluntarily by the user.


Permanent retention, unless objected to by the data subject

The APM keeps the data indicated in point 3 until the data subject requests their elimination, through the channels provided for that purpose.

  1. Links to third party websites

On our website ‘’, there are links to our partners‘ websites. The APM is not responsible for the processing of personal data by our partners, so we recommend that you refer to the privacy policy of the respective partners.

  1. Transfer of personal data with other entities

Personal data, collected on our booking form, is shared with the following partners:

  • Santo da Serra Golf Club
  • Palheiro Golf
  • Porto Santo Golf

In order for the APM to fulfil its duties and to provide you with a quality service, it may need to give access to the same data mentioned in point 3 to other entities. In this case, the APM, as data controller, will take the necessary contractual measures to ensure that the subcontractors respect and protect the personal data of the data subject.

We resort to specialised service providers for the development, maintenance and hosting of the website. The APM is committed to ensuring that all data processing, even if provided by a subcontractor, is carried out transparently, securely and in compliance with the General Data Protection Regulations.

Association for the Promotion of the Autonomous Region of Madeira

In the event the APM is acquired by or merged with a third party entity, we reserve the right, in any such circumstance, to transfer or assign the information collected from our users as part of such merger, acquisition, sale, or other change of control. In the event of our bankruptcy, insolvency, reorganisation, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors‘ rights generally, we may not be able to control how your personal information is treated, transferred or used.

We may disclose your data to respond to subpoenas, court orders, or legal process, or to establish or exercise our rights to defend against legal claims; and if we deem it necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law.

  1. Data Subjects‘ Rights

Users of the website as data subjects enjoy the following rights:

  • Access rights

Whenever you request it, you can obtain information about which of your personal data is processed by the APM. You can also access your personal data and obtain the following information:

  • The purposes for which your personal data is processed;
  • The type of personal data that is processed;
  • The entities to whom your personal data may be disclosed, including entities in the European Union or international organisations;
  • The period for which your data will be stored, or, where that is not possible, the criteria for fixing that period;
  • The rights you enjoy in relation to the processing of your personal data;
  • If you were not the source of your personal data, information on its origin and the type of data concerned;


  • Right of rectification

Whenever you consider that your personal data (provided by you) is incomplete, you may ask for it to be completed, or you may request its rectification if it is found to be incorrect.

  • Right to erasure

Under certain circumstances, the data subject may request the erasure of their personal data. The APM will inform you whether or not it is possible to satisfy this right in view of existing retention obligations imposed by law or legitimate interest.

  • Right to restriction of processing

The right to limit the processing of your personal data allows you to request the data controller to restrict the scope of access and processing of your personal data or to suspend processing activities. You may request the limitation of the processing of your personal data in the following cases:

  • if you contest the accuracy of your personal data, for a period of time that allows Madeira Golf to verify its accuracy;
  • if the APM no longer needs the personal data for processing purposes, but the data is necessary for the establishment, exercise or defence of legal claims.


  • Right to portability

You may request the APM to deliver, in a structured, commonly accepted and machine readable format, the personal data you have provided. You also have the right to request that the APM transmit such data to another controller, provided that this is technically possible.

The right to portability only applies in the following cases:

  • where the processing is based on explicit consent or on the performance of a contract;
  • where the processing in question is carried out by automated means.


  • Right of opposition

You have the right to object to the processing of your personal data at any time, for reasons relating to your particular situation, and where the processing is carried out for purposes other than, but compatible with, those for which the data was collected.

The APM will, in such cases, no longer process your personal data unless it has legitimate reasons for doing so and these override your interests.

The exercise of your right to object may result in the suspension or termination, in whole or in part, of the benefits associated with the purpose of the processing of the data in question.

  • Right to withdraw consent

In cases where data processing is done on the basis of your consent, you may withdraw consent at any time.

If you withdraw your consent, your personal data will no longer be processed, unless there are other grounds, such as legal and regulatory obligations or the legitimate interest of the APM, which justify such processing.

  • Right to lodge complaints with the APM or a supervisory authority

The data subject may exercise the rights granted by the General Data Protection Regulations (GDPR) in relation to each of the controllers. Contact for matters relating to the protection of personal data can be made to the following addresses:

Postal address: Rua dos Aranhas, 24-26, 9000-044 Funchal

Email address: [email protected]

Exercising your rights is free of charge, unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged considering the associated costs.

Your requests should be answered within a maximum of 30 days, unless the request is particularly complex, in which case the deadline may be longer.

Should you wish to lodge a complaint regarding matters relating to the processing of your personal data, you may do so with the Portuguese Data Protection Commission, the competent supervisory authority in Portugal (

You can find out more about your rights on the EU website here. (

  1. Responsibilities

The Board of Directors of the APM, is responsible for defining and implementing this policy, ensuring compliance of data processing with the legislation in force and verifying compliance with this data protection policy.

It is also the responsibility of the APM to collaborate with the National Data Protection Commission ‚(…) at its request, in the pursuit of its attributions.‘, in matters related to the processing of personal data and which are in the possession of the APM .

All APM employees, collaborators and service providers are responsible for complying with the defined rules, as well as for reporting any incident or violation of the privacy policy to the Board of Directors.

  1. Security Measures

The APM undertakes to implement security measures, against the destruction, modification, loss, improper or accidental access or disclosure, of the personal data in their possession, through:

  • Minimisation of personal data processed on the website, restricting the use of personal data to what is strictly necessary for the purpose of the processing.
  • Rigorous selection of subcontractors/partners, who ensure strict compliance with the GDPR.
  1. Cookies system

Cookies are small information files sent from the website or server to your computer’s hard drive through your Web Browser (if you allow it to do so) that enable websites or service providers to recognise your browser and capture and remember certain data.

For further information you should refer to the cookies policy at

  1. Changes to this policy

The APM reserves the right to change this Privacy Policy at any time to reflect current privacy practices while maintaining compliance with applicable law. When we make changes to the Privacy Policy, we review the ‚update date‘ at the bottom of the document.

We encourage you to read this Privacy Policy periodically so that you are aware of how the APM protects your information.