Privacy Policy

DATA PROTECTION AND PRIVACY POLICY

Açores 2000 Soc. Desenvolvimento Turístico Açores, S.A., a public limited company with registered offices at Avenida Infante D. Henrique-S. Pedro 9500-764 Ponta Delgada, and NIPC 512024162 (“Hotel do Caracol”), in carrying out its commercial activities on the website www.hoteldocaracol. com (“Website”) processes personal data, i.e. any information relating to an identified or identifiable individual (henceforth “Data Subject(s)”); an identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual (“Personal Data”).

Hotel do Caracol determines the purposes and means of processing Personal Data, acting as Data Controller, ensuring compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, and other applicable data protection and privacy legislation (“Data Protection Legislation”).

For the foregoing reasons, this Data Protection and Privacy Policy (” Privacy Policy ”) is hereby established, and Hotel do Caracol undertakes to carry out any and all processing of Personal Data in accordance with the following sections: Personal Data “).

1.Processing of Personal Data on the Website

The Personal Data of Data Subjects will be processed for:

Purposes	Processing Activities i	Legal grounds	Storage period  i
Website management	Web browsing data analysis	Enforcement of Terms and Conditions	Up to 3 months after the last visit to the website
	Account creation and access authentication		Duration of registration on the Website
Client Management	Analysis and booking of reservations	Pre-contractual steps or execution of the Terms and Conditions	For the period necessary to comply with the respective Website Terms and Conditions and/or legal obligations
	Making contacts and complaints	Consent and compliance with legal obligations	For the period necessary to manage complaints, in accordance with the applicable legal periods
Commercial and Marketing Activities	Newsletters	Consent and/or Legitimate Interest of the Data Controller	Up to 1 year after last contact

2. Dissemination and Transmission of Personal Data

Hotel do Caracol employees will process the Personal Data of Data Subjects within the scope of their work duties and will process it exclusively under the terms specified in this Privacy Policy.

Personal Data may be made available to third parties entrusted with providing services to Hotel do Caracol (“Subcontractors”), who are bound by a written contract and who process the data under the terms of this Privacy Policy, and may not process it, directly or indirectly, for any other purpose, for their own benefit or that of a third party.

Data Subjects have the right to obtain a complete and up-to-date list of the Data Controllers (if any) by submitting a request to Hotel do Caracol under the terms specified in this Privacy Policy.

In compliance with legal obligations, the Personal Data of Data Subjects may be transmitted to third parties for their own purposes, namely banks and insurance companies, judicial, administrative, supervisory or regulatory authorities, as well as to entities that lawfully carry out data collection, fraud prevention and combating actions.

Your Personal Data may also be processed by the management bodies of social networks or the functionalities available on the Website, such as for the purposes of sharing content or creating an account, in accordance with their respective privacy policies, which we recommend reading before browse the Website.

3. International Transfers

Hotel do Caracol may transfer the Data Holder's Personal Data outside the European Economic Area (“EEA”), to locations that may not guarantee the same level of protection.

However, if applicable, Hotel do Caracol will only transfer Personal Data outside the EEA in accordance with the following measures: (i) if the transfer is carried out to a location or through a method or in circumstances that the European Commission considers to be will guarantee adequate protection of Personal Data;(ii) if you have implemented standard contractual data protection clauses approved by the European Commission or a competent supervisory authority; or, (iii) if none of the above applies, but the law still authorizes such a transfer, for example, if it is necessary for the establishment, exercise or defense of a right in legal proceedings.

You may request detailed information about the security measures implemented in relation to transfers of Personal Data outside the EEA through the contact details provided in this Privacy Policy.

4.Rights of data subjects

Under the terms of current or future Data Protection Legislation, Hotel do Caracol informs you that Data Subjects have the right of access, rectification, limitation, portability, erasure and the right to object to the processing of personal data in certain circumstances, which may be exercised under the terms of this Data Protection and Privacy Policy.

If consent is withdrawn, Hotel do Caracol will immediately cease processing the Personal Data for the purpose in question, unless there is a need to process the data for compliance with legal and/or contractual obligations. Data Subjects are also informed that they may submit any complaint or request related to the protection of their personal data to the National Data Protection Commission.

Data Subjects may at any time, in writing, exercise the rights consecrated in the Data Protection Legislation and other applicable legislation through the means described in Point 7 of this Privacy Policy.

5.Confidentiality and Security

To guarantee the security and confidentiality of Personal Data, protected databases are used, including firewalls and appropriate passwords, in accordance with the provisions of Data Protection Legislation. Access to Personal Data is only possible for authorized employees who have an actual need to use the Personal Data, in accordance with the principles of security and confidentiality. Violations of this Privacy Policy by Hotel do Caracol employees may give rise to disciplinary action. Compliance with Hotel do Caracol's rules and procedures is monitored and checked periodically.

6.Cookies

For more information on how Hotel do Caracol uses cookies, please see the Cookies Policy

7.Contacting us

Data Subjects may exercise their rights by contacting Hotel do Caracol through the following means: i) Rua da Juventude, n.º 38, 9500 Ponta Delgada; or ii) by sending an e-mail to the mailbox protecaodedados@bensaude.pt .

Data Subjects may also contact Hotel do Caracol's Data Protection Officer by sending an e-mail to dpo@bensaude.pt.