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1. Object

This Privacy Policy is issued by PORTO KAETÉ HOTEL (the “Hotel”). This Privacy Policy document was made so you, our customer, can understand how we collect and manage your information to provide our services.

2. Important terms to the Brazilian General Data Protection Law – LGPD

Personal Data

“Personal Data” is information regarding an identified or identifiable natural person. The personal data can be given by the host or by third parties working as processors
of data.

Sensitive Personal Data

“Sensitive Personal Data” is personal data concerning racial or ethnic origin, religious belief, political opinion, trade union or religious, philosophical or political organization membership, data concerning health or sex life, genetic or biometric data, when related to a natural person.

Data Subject

Person to whom the personal data refers.

Controller of Personal Data

“Controller” is a natural person or legal entity in charge of making the decisions regarding the processing of personal data. With regard to data processing of guests, the PORTO KAETÉ HOTEL is the controller.

Processor of Personal Data

“Processor” is the natural person or legal entity that processes personal data in the name of the controller.

Data Protector Officer (DPO)

“Data Protection Officer” is the person named by the controller and processor to act as a channel of communication between the controller, the subjects of such data and
the Brazilian supervisory authorities.

The Hotel’s DPO contact is identified at the end of this Privacy Policy document.

3. Application for this Policy

For this Policy matters, Data Subject is any person who, regarding PORTO KAETÉ HOTEL, is under one of those circumstances above:

● Guest;
● Provider;
● Partner;
● User of the website;
● Any identified or identifiable person interested in our services.

4. About the customer consent for the processing of personal data

All the collection of personal data from our customers is primarily based on their consent.

When you browse our website for the first time, you will be informed about our Privacy Policy and cookies usage and be asked for your consent.

We may also process and share personal data without expressed consent for complying with national regulatory obligations such as the FNRH – Ficha Nacional de Registro de Hospedes (Law No. 11.771 of September 17, 2008).

5. Personal data we collect and process

We collect and process the information you give us. While using and interacting with our website, you may provide us with some information that personally identifies you.

We collect your personal data when you make a booking through our reservation system or when you give us your name and email address for receiving promotional offers.

We may collect your personal data when you talk to our hotel’s digital assistant.

Personal information we collect and process during the course of the reservation and during your stay may include:

● Name, email address, home or business address, phone number, signature, nationality and payment card information; and
● Information about your room preferences and some specific requests to the Hotel that can be perceived as sensitive personal data (e.g. data concerning your health or special needs).

Personal data may be provided directly from you to us when you make a reservation through our reservation system, through our website or directly at the Hotel.

We also may receive your personal data from a third party, such as when you book through a travel agency or hotel booking service website.

We collect information from you when you use our wireless internet access services. In these instances, information such as your internet protocol (IP) address and other characteristics about your system or device may be automatically collected by our servers. This information may be collected for functional purposes as well as to improve your experience when using this service.

We may also use your data for aggregated trends and statistical analysis, but we assure you to follow protocols of data anonymization to protect our guests’ privacy.

6. About the use of cookies

We use cookies on our website. Cookies are small blocks of data created by the web server while a user is browsing our website and placed on your computer or digital device by your web browser. Cookies are used to optimize your use of our website and make it faster and simpler, and they do not damage your computer or device.

The cookies we use may be session cookies or persistent cookies. The session cookies are temporary, and only exist while you are browsing our website; they expire or are deleted when you close your browser. The persistent cookies are stored on your web browser and are used every time you visit our website. They expire at a specific date or after a specific length of time, and they are used for giving you a more appropriate personal experience while browsing our website.

You can disable cookies, turning them on or off. For further details on how to disable cookies, you may access or contact the support page of your web browser.

7. How we use your personal data

We use the personal data collected from you to fulfill your hotel reservation. Prior to your stay, we send your personal data to the Hotel and use your data to send you pre-stay communications. Following your stay, we may also send you post-stay communications and satisfaction surveys to get some feedback on your experience with us.

We can email you marketing communication and promotional offers, for this we use information related to your stay to display targeted advertisements on our websites or on third party websites. In any case, we give you the option to opt-out and cease our communications.

8. Sharing your data with third party service providers

We share your personal data with third party service providers to provide services in relation to our products and services.

Thus some information and personal data may be shared with third party service providers such as:

● Hotel management platforms;
● Payment processing platforms;
● Legal and accounting advice service providers;
● Communication automation platforms for marketing purposes;
● With other service providers, as laundries and other companies that may assist PORTO KAETÉ HOTEL to provide services to the guests, as long as these providers comply with the Hotel’s policies;
● Automatically, for M&A purposes.

We only work with third party companies that are adequate to the laws of personal data protection, like the GDPR or the LGPD.

9. Securing your personal data

Your personal data security is very important to us. To keep it safe, we take the technical, physical and organizational security measures to avoid any unauthorized access, disclosure, damage or loss of your information.

While the collection, transmission and storage of data can be never guaranteed to be completely secure, we assure that we follow the proper procedures to process your personal data and remove, anonymize or discontinue their use when necessary.

In general terms, we only keep your personal data to fulfill the purposes reported on this Privacy Policy document and to comply with our legal or regulatory obligations, or to guarantee our rights protected by the law.

When you no longer want your personal data to be processed by us, we compromise to delete all your personal data, EXCEPT when we need to keep them for a certain amount of time to comply with legal or regulatory requirements imposed by the Brazilian law or authorities.

To learn more about the security of your data, please contact us.

10. Your rights over your personal data

As a data subject, you have some rights given by the Brazilian General Data Protection Law over your personal data processed in Brazilian territory.

Your rights include:

● Confirmation of the existence of the processing of personal data;
● Access to the data;
● Correction of incomplete, inaccurate or out-of-date data;
● Anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the Brazilian LGPD;
● Portability of data to another service or product provider;
● Deletion of personal data processed with the consent of the data subject;
● Information on public and private entities with which we have shared your data;
● Information about the possibility of denying your consent and the consequences of such denial;
● Revocation of consent previously given.

11. Changes to this Privacy Policy

In some instances, we may have to change, modify or amend this Privacy Policy in order to comply with the regulatory environment or the needs of our business. In case of changes, you may be informed to renew your consent or to exercise any of your rights provided by the law.

This Privacy Policy is updated to comply with the Brazilian General Data Protection Law – LGPD.

We commit ourselves to only process your personal data to the purpose of which the data was collected or to comply with legal or regulatory requirements imposed by law to us.

Last update: December 05, 2022.

DPO – FRLN Advogados – [email protected]

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