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Privacy Policy

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Privacy Policy

1. INTRODUCTION

Hotel da Oliveira, operated by the company “Roteiro Util, Lda.”, has adopted the best practices in terms of privacy and will only use the Personal Data (physical and online) of its customers (effective or potential) for clearly identified purposes and with the your consent to the effect.

 

2. PERSONAL DATA

Personal Data is all information, of any nature and regardless of its support, relating to a natural person, directly or indirectly identified or identifiable.

 

3. DATA COLLECTION

As part of its activity, Hotel da Oliveira may ask its customers, actual or potential, in person, by phone, by email or through its website with its own domain, the following Personal Data:

  • Name
  • Number, issuing entity and validity of the Citizen Card / Passport •
  • Genre
  • Birth date
  • Telephone
  • Mobile phone
  • Household
  • Email
  • Tax Identification Number
  • Credit Card Details (for billing purposes)

Said Personal Data may also be obtained from partners, associated companies or official entities, and it is necessary for this purpose that the respective holders have authorized their transmission.

 

5. PURPOSE OF DATA PROCESSING

The processing of Personal Data requested from customers is intended to:

  • Comply with the legal obligations to which Hotel da Oliveira is obliged as an economic agent providing hotel services, including the provision of information to the competent authorities (Foreigners and Borders Service, Tax Authority and National Institute of Statistics, among other areas);
  • Carry out pre-contractual and contractual procedures requested by customers;
  • Provide all types of hotel services, including accommodation, catering, laundry, car parking and tourist programs, among others that are usually provided in hotel establishments;
  • Billing and charging customers for the services provided;
  • Contact customers by telephone, postal mail, email or by means of communication;
  • Inform customers about new products and services, offers, campaigns, promotions, updated information or other content, including newsletters and opinion surveys, as well as for Hotel da Oliveira's general marketing actions;

 

6. DATA RETENTION TERM

The period of time for which Personal Data are stored and preserved varies according to the purpose for which the information is processed, and there are legal requirements that oblige you to keep the data for a period of time.

Whenever there is no specific legal obligation, Personal Data will be stored and kept only for the period necessary for the purposes that motivated its collection or subsequent processing.

 

7. DATA TRANSFER

Personal Data collected by Hotel da Oliveira are not shared with third parties without the consent of the respective holders, unless:

  • This is necessary for the fulfillment of a legal obligation to which Hotel da Oliveira is subject;
  • The holders contract, through Hotel da Oliveira, services provided by other entities responsible for the processing of Personal Data, in which these may be consulted or accessed by these entities, insofar as this is necessary for the provision of said services;

In the event of a transmission of Personal Data to third parties, reasonable efforts will be made for the transferee to use them properly with this Privacy Policy.

 

8. SUBCONTRACTED ENTITIES

Within the scope of the processing of Personal Data, Hotel da Oliveira uses or may resort to third parties, which it subcontracts, to, on behalf of Hotel da Oliveira and in accordance with the instructions provided by it, process Personal Data, in compliance with current legislation and this Privacy Policy.

These subcontracted entities may not transmit Personal Data to other entities without Hotel da Oliveira having previously given written authorization to do so, and are also prevented from contracting other entities without prior authorization from Hotel da Oliveira.

Hotel da Oliveira undertakes to subcontract only entities that offer maximum security in carrying out the appropriate technical and organizational measures, in order to guarantee the defense of the rights of the holders of Personal Data

 

9. DATA HOLDERS' RIGHTS

Owners of Personal Data have the following rights:

Right to information

The holders of Personal Data have the right to be informed about:

  • Contacts of the Data Protection Officer or the lack thereof,
  • The purposes of the processing for which the Personal Data are intended, as well as, if applicable, the legal reasons for the processing;
  • In the event that the processing of Personal Data is based on the legitimate interests of Hotel da Oliveira or a third party, which interests it refers to;
  • The period of retention of Personal Data;
  • The right to request from Hotel da Oliveira permission to Personal Data, as well as its correction, elimination or limitation, the right to object to the processing and the right to data accessibility;
  • If the processing of Personal Data is based on the consent of the holder, the right to withdraw it at any time, without compromising the legality of the processing carried out based on the consent previously given;
  • The right to file a complaint with the National Data Protection Commission or other supervisory authority;
  • If Hotel da Oliveira intends to proceed with the further processing of Personal Data for a purpose other than that for which the data were collected, prior to such processing, Hotel da Oliveira will provide the holder with information about this purpose and any other information of interest, in the terms referred to above.

Right of Access

Hotel da Oliveira guarantees the means that allow the owner to consult his/her Personal Data.

The holder has the right to obtain from Hotel da Oliveira confirmation that the Personal Data concerning him or her are or are not the object of treatment and, if applicable, the right to access his Personal Data and the following information:

  • The purposes of data processing;
  • The categories of Personal Data in question;
  • The recipients or categories of recipients to whom Personal Data has been or will be disclosed
  • The period of retention of Personal Data;
  • If the data has not been collected from the holder, the information available on the origin of the data;

Upon request, Hotel da Oliveira will provide the holder, free of charge, with a copy of their Personal Data, which are in the process of being processed.

Providing other copies requested by the holder may incur administrative costs.

Right of Rectification

The holder has the right to request, at any time, the rectification of their Personal Data, as well as the right to have their Personal Data incomplete, including by means of an additional declaration.

In case of data rectification, Hotel da Oliveira communicates to each recipient to whom the data has been transmitted the respective rectification, unless such communication is considered impossible or implies a disproportionate effort for Hotel da Oliveira.

Right to be forgotten

The holder has the right to request the deletion of their Personal Data when one of the following reasons applies:

  • Personal Data are no longer necessary for the purpose for which they were collected or processed;
  • The holder withdraws the consent on which the processing of Personal Data is based and there is no other legal basis for such processing;
  • The holder opposes the processing under the right of opposition and there are no prevailing legitimate interests that justify the processing;
  • If Personal Data is processed illegally;

Under the applicable legal terms, Hotel da Oliveira has no obligation to delete Personal Data to the extent that the processing proves necessary to comply with a legal obligation to which Hotel da Oliveira is subject or for the purposes of declaration, exercise or defense of a right of Hotel da Oliveira in a legal proceeding.

In case of deletion of Personal Data, Hotel da Oliveira informs each recipient/entity to whom the data has been transmitted the respective deletion.

Right to Limitation

The limitation consists in inserting a mark in the Personal Data stored in order to limit its treatment in the future. The holder has the right to obtain a limitation on the processing of Personal Data if one of the following situations applies:

  • If you dispute the accuracy of the Personal Data, during a period that allows Hotel da Oliveira to verify its accuracy;
  • If the processing is illegal and the data subject opposes the deletion of the data, requesting, in return, the limitation of its use;
  • If Hotel da Oliveira no longer needs Personal Data for processing purposes, but these data are required by the holder for the purposes of declaration, exercise or defense of a right in a legal proceeding;
  • If the holder has opposed the treatment, until it is verified that the legitimate reasons for the Hotel da Oliveira prevail over those of the holder;
  • When the Personal Data of the holder is subject to limitation, they may only, with the exception of conservation, be processed with the consent of the holder or for the purposes of declaration, exercise or defense of a right in a legal proceeding, to defend the rights of another natural person or collective, or for reasons of public interest provided for by law.

The holder who has obtained the limitation on the processing of his/her Personal Data in the above mentioned cases will be informed by Hotel da Oliveira before the limitation on the processing is cancelled.

In case of limitation in the processing of Personal Data, Hotel da Oliveira will communicate to each recipient to whom the data has been transmitted the respective limitation, unless this communication proves to be impossible or implies a disproportionate effort for Hotel da Oliveira.

Right of Opposition

The holder has the right to oppose, at any time, for reasons related to his particular situation, the processing of his Personal Data based on the exercise of legitimate interests pursued by Hotel da Oliveira or when the processing is carried out for purposes other than those for which Personal Data has been collected.

In this circumstance, Hotel da Oliveira will cease the processing of Personal Data, unless it presents urgent and legitimate reasons for such treatment that prevail over the interests, rights and freedoms of the holder, or for the purposes of declaration, exercise or defense of a Hotel's right da Oliveira in a court case.

When Personal Data are processed for the purposes of direct marketing (Marketing or Telemarketing), the holder has the right to object at any time to the processing of data concerning him for the purposes of said marketing.

If the holder opposes the processing of their Personal Data for the purposes of direct marketing, Hotel da Oliveira will cease processing the data for this purpose.

The holder also has the right not to be subject to any decision taken solely on the basis of automated processing, including the definition of profiles, that produces effects in its legal sphere or that significantly affects it in a similar way, unless the decision:

  • It is necessary for the execution or execution of a contract between the owner and Hotel da Oliveira;
  • Is authorized by legislation to which Hotel da Oliveira is subject;
  • It is based on the explicit consent of the holder.

Right to Portability

The holder has the right to receive the Personal Data concerning him/her and which he/she has provided to Hotel da Oliveira in a structured format, for current use and for automatic reading.

The portability right does not include inferred data or derived data, that is, Personal Data that is generated by Hotel da Oliveira as a consequence or result of the analysis of the data being processed.

The holder has the right to have their Personal Data transmitted directly between the data controllers, whenever this is technically possible.

Right to File a Claim

The holders of Personal Data have the right to file a complaint with the Supervisory Authority (National Data Protection Commission), through the website www.cnpd.pt.

The right of access, the right of rectification, the right of elimination, the right of limitation, the right of portability and the right of opposition can be exercised by the holder by contacting the email reservas@hoteldaoliveira.pt.

Hotel da Oliveira will respond in writing (including by electronic means) to the holder's request within a maximum period of one month from receipt of the request, except in cases of special complexity, in which this period may be extended to two months.

If the requests submitted by the holder are manifestly unjustified or excessive, namely due to their repetitive nature, Hotel da Oliveira reserves the right to charge administrative costs or refuse to comply with the request.

 

10. TECHNICAL ORGANIZATIONAL AND SAFETY MEASURES IMPLEMENTED

In order to guarantee the security of Personal Data and its maximum confidentiality, Hotel da Oliveira treats information in an absolutely confidential and confidential manner and in accordance with the terms and conditions provided by law.

Depending on the nature, scope, context and purposes of the processing of Personal Data, as well as the risks arising from the processing for the rights and freedoms of the holders, Hotel da Oliveira undertakes to apply, both at the time of defining the means of processing such as at the time of the processing itself, the technical and organizational measures necessary and adequate for the protection of Personal Data and compliance with legal requirements.

It also undertakes to ensure that, by default, only data that are necessary for each specific purpose of the processing are processed and that such data are not made available without human intervention to an indeterminate number of people.

Communication between the devices of the holders of Personal Data and the Hotel da Oliveira websites is carried out through secure and communications channels that use the HTTPS protocol and the SSL security standard.

In order to guarantee the privacy and security of the Personal Data of its customers and employees, Hotel da Oliveira has implemented the following technical, organizational and security measures:

  • The Personal Data collected is adequate, justified and limited to what is strictly necessary for the purposes for which it is processed; Personal Data is accurate and up to date;
  • Personal Data are kept in a way that allows the identification of the holders only for the period necessary for the purposes for which the data are processed;
  • Personal Data are processed in order to guarantee its security, including protection against its unauthorized or illegal processing and against its loss, destruction or unforeseen damage;
  • It has adopted internal rules that ensure the quick and effective exercise of their rights by the holders of Personal Data and the implementation for this purpose of free procedures for them;
  • Ensured the confidentiality, integrity, availability and ongoing resilience of treatment systems and services;
  • Ensured the ability to re-establish availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
  • Carefully evaluates and implements appropriate technical and organizational measures and procedures from the outset to ensure that the processing complies with current legislation and protects the rights of data subjects;
  • It protects data by default, that is, it ensures that mechanisms are put in place to ensure that, by default, only the necessary amount of Personal Data will be collected, used and stored for each task, an obligation that applies to the extent of your treatment, shelf life and accessibility.

 

11. PERSONAL DATA BREACH

In case of data breach and to the extent that such breach is likely to imply a high risk to the rights and freedoms of the holder, Hotel da Oliveira undertakes to communicate the breach of Personal Data to the concerned holder within a period of seventy and two hours from the knowledge of the incident.

Hotel da Oliveira undertakes to notify the Control Authority as soon as possible, without undue delay and, whenever possible, within seventy-two hours after becoming aware of the data breach.

Under legal terms, communication to the holder is not required in the following cases:

  • If Hotel da Oliveira has applied adequate protection measures, both technical and organizational, and these measures have been applied to Personal Data affected by the violation of Personal Data, especially measures that make the Personal Data incomprehensible to any person not authorized to access them data such as encryption;
  • If Hotel da Oliveira has taken subsequent measures to ensure that the high risk to the rights and freedoms of the holder is no longer likely to materialise;
  • If the communication to the holder implies a disproportionate effort for Hotel da Oliveira, it will make a public communication or take a similar measure through which the holder will be informed.

 

12. RESPONSIBLE FOR DATA PROTECTION (DPO)

It was not designated as a DPO because Hotel da Oliveira is not a public authority or body, does not regularly and systematically monitor the holders of Personal Data on a large scale and does not process sensitive Personal Data on a large scale.

 

13. CHANGES TO THE PRIVACY POLICY

Hotel da Oliveira reserves the right to change this Privacy Policy at any time.

 

14. APPLICABLE LAW AND JURISDICTION

The Privacy Policy and the collection, processing or transmission of Personal Data are governed by Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016 and by the legislation and regulations applicable in Portugal.