Data Protection and Privacy Policy

INTRODUCTION
The privacy policy described below offers you a general perspective of the way in which Vinha Boutique Hotel (VBH) manages and processes your personal data and of your rights regarding this matter, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and Council – General Data Protection Regulation (GDPR) and other current legislation in matters of privacy and data protection.
Specific personal data that will be processed and the way it will be used depends, to a large extent, on the services requested and agreed by you.


The present privacy policy applies to personal data gathered from the Users of our Sites, Customers, Suppliers and Job Candidates, whenever these are individual persons.

Each time you use the Vinha Boutique Hotel website, you are subject to the application of the Privacy and Cookies Policy in effect at the present moment, we therefore suggest that you read the policies in question carefully, in order to verify that you are in agreement with the respective terms.


Occasionally, we may alter the present privacy policy.  If you want to remain informed of any changes, visit this page, since any changes will be published here.


For the effects of current legislation in matters concerning data protection, the person responsible for the processing of your personal data will be a person who occupies an administrative role in the Department of Human Resources of Vinha Boutique Hotel.
 
 The Vinha Boutique Hotel website may, occasionally, contain links, banners or hyperlinks to websites and services of other companies that have their own privacy policies, and/or services provided by third parties in your device may allow access to information by them. We recommend that our Website Users read the privacy policies of these third parties carefully before submitting any personal data to these websites. Vinha Boutique Hotel has no control over the content of these websites, it is, therefore, not responsible for the content of the privacy policies of these third parties nor for the way in which your personal data is processed by them.
 
 
GLOSSARY
Erase- we will permanently erase your personal data as soon as the period of retention ends or when we receive a valid request from you to do this, and provided that there are no legitimate interests that justify the continued retention of your personal data.
 
Candidates – Includes candidates for all functions advertised or organised by Vinha Boutique Hotel, including permanent, part-time and temporary functions, and functions as an independent worker (trabalhador independente) at Vinha Boutique Hotel; as well as anyone who spontaneously presents a curriculum to Vinha Boutique Hotel not related to any specific job offer. Individual contractors, self employed workers and the staff of suppliers, or other third parties, who apply for functions at Vinha Boutique Hotel will be treated as Candidates for the effects of this present Privacy Policy.
 
Personal Data: Any information relating to an individual person by which they can be identified directly or that makes them identifiable, directly or indirectly, especially in reference to an identifying feature.
 
Customers - customers, and others, to whom the Vinha Boutique Hotel provides services or goods during the course of its activity.
 
Suppliers - This refers to partners, consultants, traders (including individual traders) and independent workers or any other entity that provides goods or services to the Vinha Boutique Hotel. In certain circumstances, Vinha Boutique Hotel will subcontract the services it provides to customers to third party suppliers to carry out the services on behalf of Vinha Boutique Hotel, they being equally covered by this definition and by this present Privacy Policy.
 
Staff - includes employed workers, as well as trainees, involved directly in the activity of Vinha Boutique Hotel.
General Data Protection Regulation (GDPR) – a legal instrument of the European Union aimed at harmonizing European legislation in matters of data protection. It came into effect on 25 May, 2018 and any references relating to it must be interpreted in accordance with any legislation that alters, expands on or relates to its implementation. 
Vinha Boutique Hotel - whenever we speak of Vinha Boutique Hotel, we are referring both to the entity responsible for the processing of the personal data of "Website Users”, and to the entity responsible for the processing of the personal data of Customers, Suppliers, Job Candidates and the emergency contacts for Staff.
 
Website Users - any person who visits the Vinha Boutique Hotel website.
 
WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?
 
Vinha Boutique Hotel collects various types of personal data relating to different purposes, in accordance with the explanation below.  In any event, we would like to point out that we do not intentionally collect personal information about anyone under the age of 18 years old. If we detect that we have unknowingly gathered personal information relating to someone under 18 years old, we will take the necessary measures to delete the information as soon as possible, except when we are obliged by current legislation to retain it.

CUSTOMER DATA: We only collect data necessary for the preparation, compliance and implementation of any contract celebrated between the Customer and Vinha Boutique Hotel, and in order to respond to any ensuing complaint regarding the same. Normally, we only require your contact data (such as name, telephone number, e-mail address, postal address and post code), to ensure that our relationship proceeds smoothly. We also possess information related to your online involvement, that we use to ensure that marketing communications we direct to you are relevant and opportune, in accordance with the consent you have given us. We may also possess images from the CCTV system if you have frequented our premises, and information that, directly or through someone from your company, you have decided to share with us (evaluation of our services and products, allergies, physical and health conditions and dietary restrictions). If, for any reason, we require any supplementary data you will be informed.
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SUPPLIER DATA: We only collect data necessary for the preparation, compliance and implementation of any contract celebrated between the supplier and Vinha Boutique Hotel, and in order to respond and manage any complaints related to the same. We collect personal contact data, including that of your company, such as names, telephone numbers and e-mail addresses. We also collect banking data, in order to pay you. We may also possess information, which directly or through someone from your company, you have decided to share with us, as well images from the CCTV system, if you have frequented our premises.

WEBSITE USERS: We only collect data necessary to ensure a good experience in using the Website and to ensure that you can use all the capabilities and features it offers, as well as to help us manage the services that we provide. This includes information about how you use our website, the frequency with which you access our website, the browser you use, your IP address, the location from which you consult our site, the language you choose to visualize it with and the time at which our website is most popular, as well as other information better described in our cookies policy below. If you contact us through the website using, for example, the chat function, we will gather any information you provide us with, for example your name and contact data.
 
CANDIDATE DATA: Depending on the relevant circumstances and laws and local regulations applicable, we can gather the totality or a part of the information listed below:
-  Identifying Data: such as name, contact data (telephone and e-mail),  immigration status ( in case a work permit is required),  a photograph of yourself.
- Situation and professional activity, as well as data about education; job history;  present salary, pensions and dispositions related to benefits,  if necessary for the vacancy which you intend to apply for.
-  Supplementary information you choose to share with us, namely in your presentation letter, curriculum vitae or in interviews; 
-  Supplementary information that our Customers may share about you or which we discover from other third party sources  (common knowledge, references); 
-  IP address; dates, times and frequency with which you access our services and /or website; and
- CCTV images, if you frequent our premises.
Be aware that the list above of categories of personal data that we can collect is not exhaustive.
 
 Additionally, as we have already mentioned, registration through social networks (implies the use of your social network credentials, such as information at the beginning of the session as a Facebook and Google + user to set up your Vinha Boutique Hotel account and begin the session with it) it also allows us to collect personal data: when you use the option of initiating the session through social networks, Vinha Boutique Hotel  will only use the public information of the profile necessary for the creation of your VBH account. Vinha Boutique Hotel will not process any information it receives through social networks that is irrelevant for this purpose. Once the account is set up, the user will be able to complete it with any information they would like to share with us and that allows a better experience when they interact with us. Any additional information that you provide us with will only be used for the purposes referred to in this present privacy policy.
 
AM I OBLIGED TO PROVIDE MY DATA? 
 In the context of a business or labour relationship, you have to provide the personal data needed to establish and create this relationship and to fulfil the derived pre-contractual and contractual obligations and diligences, as well as the data we are legally required to collect. As a general rule, without this data, we would have to refuse the celebration or implementation of the contract or we wouldn’t be able to maintain the contract, and would have to cancel it.

 if you fail to provide the necessary information and the documentation, we won’t be able to establish or continue the commercial or labour relationship you had intended, or to follow up on any requests you may have made to us.
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HOW WE COLLECT YOUR PERSONAL DATA?
 We can collect your personal data in the various ways:
 Personal data we receive directly from you, should you contact us proactively, normally by telephone or e-mail; and/or should we contact you by telephone or by e-mail or through our commercial operations in general.
 There are various ways of sharing your information with us. Everything depends on what is appropriate for you.  These can include:
-  Introducing your data on the Vinha Boutique Hotel website through the form as part of the registration process; or 
-  Sending your curriculum by e-mail or delivering a copy of your curriculum on paper;
-  Taking part in a competition through a social network channel, such as our Facebook or Twitter, Instagram, Pinterest or other;
-  Subscribing to our newsletter or some of our events; 
-  Through the chat on the website.
 
 Personal data we receive from other sources, normally through due commercial diligence or other market information, including list of participants in relevant events.  We also receive personal data from other sources, for example if you activate "Like" on our Facebook page or " follow us" on Twitter or Instagram, we will receive personal information from these sites. 
 
 When you access our site or read or click on an e-mail from us, when appropriate and in compliance with the law and local regulations, we can also collect your data through you or automatically. When you visit our site there is certain information that we can collect automatically, whether you decide or not to use our services. This includes your IP address, the day, time and frequency with which you access our site and the way you navigate the respective content, all in accordance with the cookies policy described below. We also collect your data when you contact us through the website using, for example, the chat function.
 
 We collect your data automatically through cookies, in accordance with the cookies settings of your browser. If you are also a Candidate or Customer of Vinha Boutique Hotel, we can use the data of your use of our sites to improve other aspects of our communication with you or the services we provide to you.
 Why can we process your data (purpose of processing) and on what legal basis?
 Supply of products and services:
Vinha Boutique Hotel can use your personal data when it is necessary for implementing the contract celebrated between yourself and Vinha Boutique Hotel, as well as to identify you with. We can also use your Personal Data to prevent and investigate their possible incorrect usage.

Marketing Activities
 We can, periodically, send you information we consider to be of interest to you. In particular, we can use your data for the purposes listed below when appropriate:
-  To allow us to develop commercial actions or marketing actions, namely to share information with you about new features or new products and services;
-  To send you data on reports, promotions, offers, events and establishing contacts;
- To provide you with information about certain discounts and offers that you are entitled to, given your relationship with Vinha Boutique Hotel;
-  To allow us to send newsletters, which can contain information relating to promotional campaigns, information about events, discounts, promotions and offers, invitations, reminders relating to reservations, actions advertising new features or new products or services and to send information about participation in competitions and draws, in accordance with the topics you have indicated you are interested in, by e-mail;
- To provide you with information about personalised and exclusive offers of products and services identified on the basis of your personal preferences and behaviour, as well as from your use of products, services, and navigations of sites.
 
When you have provided us with your electronic contact coordinates in the context of the sale of a product or service, we can use them for marketing purposes of our own products and services or similar products and services. If, however, you do not agree with our marketing approach you can, at no cost, decline the sending of these communications both during the respective collecting of the data, and on the occasion of each message you can exclude yourself. As regards the sending of any other type of electronic communication, we will ask for your prior and express consent in advance. We need your consent for certain aspects of these activities that are not covered by our legitimate interests (especially in the collecting of data through cookies and the providing of direct marketing to you through digital channels). 
 If you do not agree with our marketing approach, you have the right to withdraw your consent at any time. All our marketing is based on what we think will best serve our Customers and Candidates, but we are aware we may not always get it right. We may use your data to present you with advertising of the Vinha Boutique Hotel and other content on other sites such as, for example, Facebook. If you would prefer us not to use your data in this way, deactivate the option "Advertising Cookies" (consult our Cookies Policy). 
 
Other purposes
 
-  In order to store (and update when necessary) your information on our database, so that we can contact you in relation to contracts that you intend to celebrate / or have celebrated with us;
-  to offer services and to obtain support and services on your behalf;
-  to comply with  certain legal obligations;
-  to help us  direct suitable marketing  campaigns, Vinha Boutique Hotel  can adopt  automatized decisions, including definition of profiles; 
-  in rare circumstances, to help us in the establishment, exercise or defence of a legal claim.
-  to defend the vital interests of the person whose data it is. 
 
 We can also use your personal data, if we consider it necessary to do so in defence of our legitimate interests.
 
Development of products and services
 
Vinha Boutique Hotel can use your personal data to develop its products and services. However we will predominantly use aggregate data and statistical information for this purpose. Vinha Boutique Hotel keeps track of the pages that our customers visit on our websites in order to determine the most viewed services/products.
 
 
 In this case, information is collected relating to the computer or device (including mobile devices) that you use to access our site, in particular your IP address, the website through which you have accessed ours, the type and language of your browser, operative system, cookies, the country from which you are accessing, referring and exit pages, URL, type of platform, the number of clicks made, domain names, landing pages, pages visited and the order in which they were visited, the time spent on a certain page, the date and time at which you accessed our website, access errors and other similar information that your browser has sent us.
 
Communication
 
Vinha Boutique Hotel can use your personal data to communicate with you, most especially, to send you news relating to our products or services, or to provide assistance in aspects related to customer support, such as replying and dealing with requests from the user through the customer service channels, as well as monitoring the quality of our service.
In this case your full name, e-mail address and telephone number are collected.
 
 Subscription to the Vinha Boutique Hotel Newsletter can imply the use of personal data in order to proceed to the personalised advertising of our products and services available to the user through electronic mail, push notifications through any other electronic means or third parties.
You can cancel your subscription to the newsletter at any time, by following the information that is available in each communication.
 
Vinha Boutique Hotel can use data we have identified as a basis for your personal and behavioural preferences that we have collected from your interactions with us, whether through the site, app, customer support line, as well as through the use of products, in order to send you personalised offers.
In such case, the following personal data will be collected: gender and preferences for services or products.
 
The processing of data with the purpose of drawing up profiles and market studies is also based on the legitimate interest of Vinha Boutique Hotel. To this end, Vinha Boutique Hotel considered the interests and rights of the person concerned, and the measures adopted by the person responsible to fulfil their general obligations in terms of reasonableness and transparency, having concluded that:
a) the impact on people’s fundamental rights and liberties and guarantees are minimal;
b) the above-mentioned processing will be seen as  reasonable by the person concerned;
c) the processing of data for the purposes mentioned earlier, does not result in exclusion, discrimination, defamation or situations that put at risk the reputation of the data subject and/or their negotiating power.
 
If you think the above-mentioned processing could generate any type of emotional repercussions, you can exercise your right of access and/or opposition, as well as removing yourself voluntarily without the need for any justification.
 
We would like to inform you that you can restrict this purpose and exercise your right to object by writing an e-mail to any of the contacts indicated in "Contacts”.
 
Improving services available to the user

 Your Personal Data relating to your purchases at the physical shop or online shop, tastes and preferences can be used for the effects of analysis, to create user profiles, market studies, quality surveys and for the improvement of our interaction with the customer.
 
Recruitment activities
To fill vacancies, we can develop internal recruitment activities. We list below various forms by which we can use and process your personal data for this purpose:
 
-  Collecting data through you or from another source, such as LinkedIn;
-  Storing your data (and updating it when necessary) on our database, so that we can contact you in relation to recruitment;
-  Evaluating data about you in relation to vacancies we think might be suitable for you;
- To allow you to send your curriculum, apply to online job offers or subscribe to alerts about job offers that we think would be in your interests;
-  To fulfil our obligations in relation to any contract celebrated between us;
-  To fulfil our obligations in relation to any contract celebrated between Vinha Boutique Hotel and third parties relating to your recruitment;
-  To speed up our processes of payments of salaries and invoices;
- To verify data you have provided, using third party resources (such as psychometric tests or skills tests) or ask for information (such as references, to the extent in that it would be appropriate under the terms of the current legislation and where you have provided us with the contact information of your reference and obtained prior authorisation from them for the transmission of their personal data, as well as having authorised us to contact them); And
-   To fulfil our legal obligations, including, in particular, those concerning the detection of crime or tax collection or legal claims.
 
 We process previously mentioned personal data in accordance with the provisions laid out in the GDPR and other current legislation in this context, basing its processing, essentially, on pre-contractual diligences and the implementation of contracts, the fulfilment of a legal obligation or the pursuance of the legitimate interests of Vinha Boutique Hotel or for the protection of the vital interests of the data subject.
 
 In other words, we will use and process your personal data for the management and implementation of contracts or other diligences requested by the data subject (Art. 6.º n.º.1 line b) GDPR);  in the context of a legitimate interest (Art. 6.º n.º1 line f) GDPR);  based on your consent (Art. 6.º n.º 1 line a) GDPR)  and by legal imperative or for the benefit of the public interest (Art. 6.º n.º 1 line c) e e) GDPR).
 
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
 When appropriate and in compliance with the laws and local regulations, we can share your personal data in various ways and for various reasons with the following categories of people:
-  In the course of an investigation, complaint or procedure, to fiscal and auditing authorities, Administration, government agencies, courts, immigration services ("SEF”)  and security forces responsible for the matter at hand, and internally to the areas or departments of Vinha Boutique Hotel  that cooperate in the collecting of information and communication of facts to the competent authority;
-  Third-party providers of services carried out on our behalf (including external consultants, business partners and professional advisers such as lawyers, auditors and accountants, recruitment companies, technical support and IT consultants that carry out tests and developmental work on our company’s technology systems);
-  Third-party providers of IT services and storage of outsourced documents, in cases in which we have made an appropriate contract for processing data (or similar protection);
- Platforms and suppliers of marketing technology;
-  In the event of purchase or business or asset disposal, we can share your personal data with potential buyers of the business or assets. 
-  In the case of payments to credit entities and other suppliers of payment services, as well as providers of technology services related to payment services to whom the data is transmitted to carry out the transaction, and who may be obliged by the state legislation under which they operate, or by agreements undertaken by them, to facilitate information about the transactions to the authorities or official agencies of other countries, situated both within and outside the European union, in the context of combatting terrorism funding, serious forms of organised crime and the prevention of money-laundering. 
 In certain circumstances, our website and app provide you with social plugins to various social networks. If you decide to interact with a social network like Facebook, Twitter, Google + ( for example, by registering an account),  your activity on our website and on our app will also be available to the respective social network. If you are connected to one of these social networks during your visit to our website or app and if you are interacting through one of the above mentioned social plugins, the social network can include this information in your profile on the said social network, in accordance with your privacy settings. If you want to avoid this type of transference of data, close your account session on the social network before entering our website or app or alter your privacy settings. Whenever possible, we recommend you read the privacy policies of the social networks that you use to obtain detailed information about the collecting and transference of personal information, learn about your rights and what privacy settings you should select that are appropriate for your profile.
 
HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
 
 We are committed to adopting all reasonable and appropriate measures to protect the personal information we possess from any undue use, accidental or illicit alterations, loss and unauthorised dissemination or access. To this effect, Vinha Boutique Hotel uses security systems, rules and other procedures, in order to guarantee the protection of your personal data, as well as to prevent unauthorised access of your data, its improper use, and its dissemination, loss or destruction. 
Should you suspect improper use, loss or unauthorised access of your personal information, please inform us immediately.  
 
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
 
 We will only retain your personal information for the time necessary to fulfil the purpose for which we collected it for, to respond to your needs, to the requests you have directed to us, or to fulfil our contractual and legal obligations.

 To determine the appropriate retention period for your data, we use criteria referred to below. If several criteria apply at the same time, we will retain your personal data according to the criteria that implies the retention of your personal data for the longest period of time. 
a)           When you purchase products and services, we will retain your personal data for the duration of our commercial relationship, including any eventual complaints that could arise, as well as a period of 10 years after the cessation of such a relationship, without prejudice to the fulfilment of the legal obligations of the person responsible for the processing of the data;
b)           When you contact us to ask questions, request information and clarifications, we will retain your personal data for the period of time necessary to answer your question/provide you with information and/or deal with your enquiry;
c)           When you set up a customer account, that is, when you register on our website, we will retain your data until you ask us to erase it or after a period of inactivity of two (2) years; 
d)           When you have consented to the sending of direct marketing, we will retain your personal data whilst the purpose of the collecting of your data is ongoing, or until you cancel your subscription or ask us to erase it;
e)           In relation to images captured on the CCTV system, for a maximum period of thirty (30) days;
f) In relation to data collected in the process of recruitment, for a maximum duration of five (5) years after the termination of the recruitment process;
g)           In relation to the use of cookies, we will retain it as long as it is necessary to achieve certain inherent purposes, as detailed in our cookies policy;
h)           The period of time defined by current legislation; or 
i) Until the specific purpose applicable to certain data no longer exists.

We can also retain some of your personal data if it is deemed necessary for the fulfilment of our legal obligations, as well as for administering or asserting our rights, specifically through legal or administrative recourse. 
In any one of the above-mentioned situations, if there are judicial or administrative proceedings pending, the data will be retained during the period of the proceedings and up to 6 months after a final legal decision (res judicata) has been given.
 At the end of the retention periods referred to above, the personal data will be removed and/or erased in an absolutely safe way.
 
HOW CAN YOU ACCESS, ALTER OR REMOVE PERSONAL DATA YOU HAVE PROVIDED TO US?
 
One of the main objectives of the GDPR is to protect and clarify the rights of EU and non-EU citizens as regards data privacy. This means that you possess various rights in relation to your data, even when it has been provided by you. These rights are described in further detail below.
 
We try to deal with your request without undo delay and, in any case, within the period of a month (subject to any extensions of time permitted by law).  Be aware that we may maintain a record of your communications to us to help in any questions raised by you.
 
Right to object:  this right allows you to object to the processing of your personal data by us, for reasons related to your particular situation when your personal data is being processed for one of the following reasons: (i) our legitimate interests; (ii) to allow us to carry out a task in the public interest or in exercising official authority; (iii)  to send you direct marketing  materials, including definition of profiles;  and (iv)  scientific, historical, investigative or statistical purposes.

 Should you exercise your right to object, we will end the processing of data you object to, unless:
-  we can demonstrate we have legitimate mandatory reasons for the processing which supersedes your interests; or
-  we are proceeding in the processing of your data for the establishment, exercise or defence of a legal claim.
 
Right to withdraw consent: If we have obtained your consent to proceed in the processing of your personal data for certain activities (for example, for marketing purposes),  you can withdraw this consent at any time and we will cease to carry out the specific activity that you had previously consented to, unless we consider that there is an alternative reason to justify the continued processing by us of your data for this purpose, if such is the case we will  inform you about this condition. 
 
Requests for Access from the Data Subject:  you can, at any time, ask us to confirm the information we have available about you, as well as asking for additional information about the purposes of the data processing, the time period during which we retain your data, the existence of automatized decisions, the recipients with whom the data is shared, among other information laid down under article 15.º of the GDPR.  We can ask you for proof of identity and more information about your request. If we grant you access to the information we possess about you, we will not charge for this access, unless your request is " manifestly unfounded or excessive".  If you ask us for additional copies of this information we may charge a reasonable administrative cost, when this is legally permitted. In cases when we are legally permitted, we can deny your request. If we deny your request, you will always be informed of the motives for us doing so.
 
Right to be forgotten/erasure: In certain circumstances, you have the right to request us to delete your personal data. Normally, the exercising of this right must observe one of the following criteria:
-  the data is no longer necessary for the purpose for which it was originally collected and/or processed;
-  when you have withdrawn your consent for us to proceed with the processing of your data and there is no other valid reason for us to continue processing it;
-  if you object to this processing and there are no prevailing legitimate interests  that would justify it:
-  the data was unlawfully subject to processing ( in other words, in a way that did not comply with GDPR); or
-  the data needs to be erased, in order to fulfil our legal obligations as the organisation responsible for the processing.
 This right, however, can be overridden and Vinha Boutique Hotel can continue to process your data lawfully when it is shown to be necessary:
-  to exercise the right of freedom of expression and information;
-  to fulfil legal obligations or to carry out a task of public interest or in the exercise of official authority;
- for reasons of public health in the public interest;
-  for reasons of  historical or scientific research or statistics; or
-  to exercise or defend a legal claim.
 In fulfilling a valid request for data erasure, we adopt all reasonable practical measures for erasing the data.
 
Right to restrict processing:  in certain circumstances, you have the right to restrict the processing we carry out on your personal data. This means we can only continue to store your data and we cannot carry out any more activities of the processing of it until: (i) one of the circumstances listed below is resolved; (ii) we have obtained your consent; or (iii)  additional processing will be necessary for the establishment, exercise or  defence of a legal claim, the protection of rights of another person or for important reasons of public interest for the EU or a member state.
 
 The circumstances in which you have the right to request the restriction of the processing of your personal data are:
-  if you contest the  accuracy of the personal data we have processed about you. In this case, we will restrict the processing of the personal data for the period during which the accuracy of the data is verified;
-  If you object to the processing of your personal data on the grounds of our legitimate interest.  In this situation, you can request that the data be restricted whilst we verify our basis for processing your personal data;
-  if the processing we carry out on the data is unlawful, but you prefer to restrict the processing rather than request erasure; and
-  if we no longer need to proceed to the processing of your personal data, but we need the data for the establishment, exercise or defence of a legal claim.
 If we have shared your personal data with third parties, they will be notified of the restricted processing, unless it is impossible or implies a disproportionate effort. We will naturally notify you before we lift any restrictions on the processing of your personal data.
 
Right to rectification:  you have the right to ask us to rectify any inaccurate or incomplete personal data that we might possess about you. If we shared this personal data with third parties, they will be notified about the rectification unless it is impossible or implies a disproportionate effort. When appropriate, we will also tell you with which third parties we have shared inaccurate or incomplete personal data. In cases in which we consider it is reasonable not to satisfy this request, we will explain the reasons for this decision. It is important that the personal information we possess about you is precise and up-to-date. Please inform us if there are any alterations to your personal information during the period in which we retain your data.
 
Right to data portability: if you so wish, you have the right to transfer your personal data between entities responsible for its processing. In effect, it means you can transfer the data from your Vinha Boutique Hotel account to another online platform. To enable you to do this, we will provide you with your data in a password protected, commonly used machine-readable format, so that you can transfer your data to another online platform. Alternatively, we can transfer the data directly to you. Your right to data portability applies to: (i) personal data we process automatically ( in other words, without any human intervention); (ii)  personal data provided by you;  and (iii)  personal data that we process based on your consent or to fulfil a contract.
 
Right to lodge a complaint with a supervisory authority:  you also have the right lodge a complaint with a local supervisory authority, which in Portugal is the National Commission for Data Protection. You can contact them in the following ways:
 
Telephone (+351) 213928400 / Privacy line: +351 21 393 00 39
E-mail: geral@cnpd.pt
Requests for information  online: https://www.cnpd.pt/bin/Duvidas/Duvidas_frm.aspx
Submitting a complaint online: https://www.cnpd.pt/bin/Duvidas/Queixas_frm.aspx
Address: Rua de São Bento, nº 148-3º, 1200-821 Lisboa
Fax: +351 21 397 68 32 
 
 If you intend to exercise any one of these rights or withdraw consent for the processing of your personal data (where consent is our legal basis for processing your personal data), contact us. Be aware that we may have a register of communications to help us resolve any questions solicited by you:
 
How to contact us
 If you want to exercise any of your rights described above, suspect unlawful use, loss or unauthorised access or have any comments or suggestion regarding the present privacy policy you can contact us  at the following addresses:
- Vinha Boutique Hotel, Rua Quinta Fonte da Vinha, nº 383, Vila Nova de Gaia
Telf: 22 115 41 20
 
 Alternatively, you can send an e-mail to: geral@vinhaboutiquehotel.com
 How can you contact us to update your marketing preferences? You can do so by sending us an e-mail to our general e-mails, or click on the hyperlink cancelling your subscription on any marketing e-mail we send you
 
HOW WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?
 
 The transfer of data to other countries (countries outside the European Union) only occurs when necessary for the implementation of your orders or requests (for example, invoices or the sending of products), when legally required, or if you have granted express authorisation to this effect. If recourse to providers of services from third party countries is necessary, they are obliged to comply with the written instructions in this matter through the registration of an agreement with European Union type contractual clause clauses for compliance with current data protection in the European Union. Whenever defined by law, you will receive detailed information from us separately. We want to ensure your data is stored and transferred in a safe way. Consequently, we only transfer data out of the European Economic Area EEA (in other words, member states of the European Union, together with Norway, Iceland and Liechtenstein) when it conforms to the legislation in matters of data protection and the means of transference provide adequate guarantees in relation to your data, for example:
-  through a data transfer contract, which incorporates the type of contractual clauses adopted by the European Commission for the transfer of personal data  by organisations responsible for data processing in the EEE  to an organisation or subcontractor responsible for processing data in jurisdictions that lack adequate data protection laws; or
- through membership to the framework of the US-EU Privacy Shield for the transfer of personal data from EU entities to US entities or any other equivalent agreement relating to other jurisdictions; or
- transferring your data to a country regarding which the European Commission has found there to be an adequate level of data protection through the country’s  legislation; or
-  if you have consented to the transfer of data.
 
To ensure your personal data receives an adequate level of protection, we apply appropriate procedures with the third parties with whom we are going to share your personal data to ensure that your personal information is processed by these third parties in a consistent manner and one that respects data protection law.
 
Promises and warnings
 The user promises that the personal data communicated to Vinha Boutique Hotel is correct and accurate and commits themselves to notifying it of any alteration or modification of the same and assumes exclusive responsibility for losses and damages caused by erroneous, inaccurate or incomplete data. The user is expressly warned that in revealing personal data on the Vinha Boutique Hotel’s public media, such as Facebook, Google +, Twitter and Instagram, this information can be seen and used by third parties. Vinha Boutique Hotel does not read any personal communications published on the personal webpages of its customers.
 
BROWSERS RECOMMENDED FOR VISUALISING THE PAGE CORRECTLY
 The Vinha Boutique Hotel website has been optimised for visualisation on Google Chrome, Safari, Mozilla Firefox, Microsoft Internet Explorer, Microsoft Edge. 

COOKIES POLICY

 What is a cookie?
 A cookie is an information archive that is stored on the hard disk of your computer and that registers your navigation on a site so that when you return to visit that site, it can present you with personalised options based on the information stored about your last visit. We can also use cookies on our website to analyse traffic and for publicity and marketing purposes, which do not harm your system.
 If you want to check or alter the type of cookies that you accept, you can do so in your browser settings. 
 
How do we use cookies? 
 We use cookies to do two things to track your use of our site. They allow us to understand the way in which you use the site and track eventual patterns that occur individually or in larger groups, which will help us to develop and improve our site and services in response to what our visitors want and need;

The cookies are:
Session cookies:  these are only stored in your computer during the web session and are automatically deleted when you close the browser - they normally store an anonymous ID of the session allowing you to browse the site without having to initiate a session on each page, but they don’t collect any information from your computer; or
Persistent cookies:  they are stored like a file on your computer and remain when you close your web browser. The cookie can be read by the site that created it when you visit this site again. We use persistent cookies of Google Analytics, Facebook and Mailchimp.
Strictly necessary cookies:  these are essential for you to browse the website efficiently, they can’t be deactivated. Without these cookies, the services that are provided on the site cannot be used. These cookies do not collect information about you that could be used for marketing.
Performance cookies:  these cookies allow us to monitor and improve the performance of our website. For example, they allow us count visits, identify sources of traffic and see which part of the site is most popular.
Functional cookies:  these allow our site to remember the choices you have made (such as user name, language or region from where you are browsing) and provide improved functions. For example, we can provide relevant news or updates on our website. These cookies can also be used to remind you of alterations that you may have made to the size of the text, type of text, type of font and other parts of the web page that can be personalised. They can also be used to provide services that you selected, such as visualising a video. The information these cookies collect is normally anonymised.
Personalised cookies:  these cookies are persistent (during the time you are registered with us) and mean that when you begin a session or return to the site you can see similar advertisements to those that you have previously browsed.


CONSENT
 Under the terms of Law n.º 41/2004 of 18 August, the storing of information and the possibility of access to information stored in the terminal equipment of a user (mainly through cookies)  is only used by Vinha Boutique Hotel if the user has given their prior and express consent to the installation of cookies on their equipment, so that we can ask, prior to their use of our websites that they accept the present Privacy and Cookies Policy. 
 
How can I avoid the use of Cookies on websites? 
 The Customer has the right, at any time, to withdraw their consent to the use of cookies by Vinha Boutique Hotel, deleting the cookies stored on their computer through the settings options on their Internet browser.
You can consult this information for the main web browsers at the following addresses:
  1. Chrome: at https://support.google.com/chrome/answer/95647?hl=pt  
  2. Explorer: at https://support.microsoft.com/pt-pt/help/278835/how-to-delete-cookie-files-in-internet-explorer 
  3. Firefox: at https://support.mozilla.org/pt-PT/kb/ativar-e-desativar-cookies-que-os-websites-utiliza 
  4. Safari: at https://support.apple.com/kb/ph5042?locale=pt_PT 
 
Finally, if you want to have greater control over the installation of cookies, you can install programs or add-ons to your browser, known as "do not track” tools, which allow you to choose the cookies you want to allow.
 If you block or do not authorise the use of cookies, no cookies will be stored on your computer, but it is not guaranteed that our websites will function properly, which means that customers may not get the maximum benefits from the content of the websites, since for each new access to the website, authorisation for the use of cookies will always be requested.
 
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
 It may sometimes be necessary to process personal data and when appropriate and in compliance with the laws and local regulations, sensitive personal data in relation to the exercise or defence of a legal claim. Article 9.º, n.º 2, line f of GDPR allows this processing for "the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity ".
 This could occur, for example in cases in which we need to obtain legal advice in relation to legal proceedings or in cases in which we are obliged by law to retain or share certain information as part of a judicial process.
 
ALTERATIONS TO THE DOCUMENT 
Vinha Boutique Hotel can occasionally alter this declaration and its Privacy Policy in order to reflect the image of the company and feedback from customers. We encourage our customers to periodically review our privacy policy, so that they remain aware of any updates with which Vinha Boutique Hotel is protecting their information, notwithstanding our informing you whenever a relevant alteration  occurs in our privacy policy. 
 
CONTACTS 
 Vinha Boutique Hotel welcomes your comments in relation to this privacy policy. If you believe that Vinha Boutique Hotel is not complying with this declaration, please contact us, we will try to evaluate your suggestion and respond as soon as possible. geral@vinhaboutiquehotel.com

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