Privacy Policy - Dona Filipa Hotel

Your Personal Information Privacy Matters to Us at Lusotel – Indústria Hoteleira S.A.

This Statement is designed to provide you with appropriate information, assurance, and confidence that we handle your data securely and professionally, with the respect it deserves. It outlines the types of personal information we collect and how we handle the personal data shared with us. Please read it carefully to understand our views and internal practices.

For the purposes of the General Data Protection Regulation (GDPR), the Data Controller is Dona Filipa Hotel. Regional contact for data protection is available via email marketing@hoteldonafilipa.pt

WHO IS Lusotel – Indústria Hoteleira S.A.?

This Privacy Statement is issued by Lusotel – Indústria Hoteleira S.A. (collectively referred to as “Lusotel”, “we”, “us” or “our” in this Privacy Statement), which includes Lusotel’s direct and indirect subsidiaries and covers information collected and used by us during the course of our business. When we mention Lusotel, “we”, “us” or “our”, we are referring to the company processing your personal data.
Your information may also be collected and used by hotels operating under the Lusotel brand. In most cases, these hotels are independently owned, and their use of your information is covered only under the Privacy Statement where specifically indicated.

INFORMATION WE COLLECT AND HOW WE USE AND SHARE IT

We collect and use personal data when you make a reservation through our booking system, stay at a hotel under the Lusotel brand, or interact with us through our corporate website. We usually collect this information directly from you, but in some cases, we may obtain your data from other sources. For instance, we occasionally promote special offers on hotel websites. In such cases, we always ask for your permission to retain the personal data of those who respond. We also collect data via third-party technologies such as pixels, web beacons, tracking tools, and similar technologies.
You are not required to provide your personal data; however, in some cases, failure to do so may mean you won’t be able to access certain services—for example, we might not be able to complete your booking.
We also collect and use personal data when you subscribe to our newsletters or other special offers, download one of our mobile apps, or participate in one of our services. In these situations, we collect information necessary to operate the promotion or service you’ve chosen. This information may include personal details such as your name, address, and some demographic data. In every case, we handle your data according to the general principles outlined in this Privacy Statement, unless otherwise specified.
Additionally, when you browse our website, use our mobile apps, or engage with services at a Lusotel hotel, we may automatically collect data like your country, IP address, media access control, and other system/device characteristics. This data is used functionally and to improve your experience. It may also be used for aggregated statistics and to deliver more relevant ads.

Legal Basis for Processing Your Personal Data

We are committed to collecting and using your data in accordance with applicable data protection laws.
We will only collect, use, and share your data if we are satisfied that we have an appropriate legal basis for doing so, such as:
You have given us your consent;
The use of your personal data is necessary to fulfil our contract with you (e.g., to make and manage your booking);
We need to comply with our legal obligations (e.g., tax or law enforcement requirements);
The use of your data is in our legitimate interests as a business, such as operating and improving our services or keeping people informed about our products and services (including profiling and targeted advertising)—and in these cases, we will ensure your rights and interests are protected, and you have the right to object.
If you have given consent to process your information, you can withdraw it at any time by contacting the National Data Protection Authority at https://www.cnpd.pt.

Use of Our Websites, Mobile Apps, and Other Technologies

We and our third-party service providers use cookies, pixels, web beacons, tracking tools, and similar technologies on our websites, mobile apps, and other business areas to collect information, provide requested services, and deliver targeted advertising. Subject to local consent requirements, we may also use this data (e.g., hashed email addresses) to help identify your other devices (such as phones or tablets). This cross-device tracking helps us and our providers serve you with relevant ads and improve services across platforms.

Cookies and Tracking Technologies

What is a cookie: A cookie is a small text file placed in a user’s web browser or internet device that helps remember and gather data about that part. You may receive a cookie when you visit our websites or use our mobile apps. In some cases, and where permitted by law, cookies may also be used for email campaign purposes.

Types of cookies we use:

Functional Cookies – Support the use of our websites and apps, enabling specific features to improve your experience (e.g., saving preferences or login info).
Performance Cookies – Collect data to support our websites and help us improve or identify issues (e.g., how you arrived and navigated our site).
Targeting Cookies – Used to collect information to improve our products and deliver relevant advertising across websites and apps. For more, see the “Targeted Advertising” section.

To learn more about cookies and how they are used, please visit: http://www.allaboutcookies.org/

Third-Party Cookies – As described above, we use various cookies from third-party service providers to help us manage, operate, and improve our advertising. These parties set cookies on our behalf to help us collect information and deliver advertising that we believe is relevant to you. In some cases, these third parties may also assist us by providing certain statistical and analytical information related to our marketing practices. We may also share information collected through cookies (and other tracking technologies) with third parties for their own analytical and marketing purposes.
Cookie Management and Disabling – You may choose to visit our websites without cookies, but in some cases, certain services, features, and functionalities may not be available. To visit without cookies, you can configure your browser to reject all cookies or to notify you when a cookie is being set. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences.
Other Technologies – Other technologies such as pixels and web beacons may also be used on our websites, mobile applications, email messages, and other areas of our business. These technologies are used to enhance our products and services as well as our marketing efforts.
Targeted Advertising – We and our service providers, such as third parties, may deliver targeted advertising using first-party or third-party cookies, pixels, and web beacons when you visit our website, use our mobile applications, or visit third-party websites. In some cases, these cookies may be persistent cookies. As described in the “Use of Our Websites, Mobile Applications, and Other Technology” section above, we and our third-party service providers may also use cookies and other information to try to identify other devices and web browsers you may use so that we and our third-party service providers can deliver targeted advertising on those devices. We do this to provide you with advertising that we believe may be relevant to you, as well as to improve our own products and services, including the functionality and performance of our websites and mobile applications. To learn more about opting out of certain types of targeted advertising, please refer to the “Cookie Management and Disabling” section above.
Do Not Track – At this time, our systems do not recognize “Do Not Track” browser signals. However, you may disable certain types of tracking as discussed in this section (e.g., by disabling cookies); you may also opt out of targeted advertising by following the instructions provided by the DAA and on the Network Advertising Initiative websites.

Location Information and Services

We may receive information about your location in the course of and for the purpose of providing you with the services described above through your use of our websites and mobile applications. For example, if you are using our mobile applications and have agreed to share your location information with us, that information may be collected via GPS or Bluetooth technology in order to allow us to provide you with certain services such as personalized offers and promotions. In addition to your use of our websites and mobile applications, we may also receive location information from wireless networks or cell towers near your mobile device, via your Internet Protocol (“IP”) address, or through your use of other services that we provide in our hotels. We may also access location information that you provide to us through your use of social media, such as when you tweet your location. Your location preferences can be configured or changed at the device level or by modifying your settings with the relevant social media platforms.

Use of Wi-Fi Services

When using Lusotel Wi-Fi services, we may collect and process certain additional information.

What Information We Collect

Registration and User-Provided Information: When you register to use Lusotel Wi-Fi services, we may collect personal information from you. You may also provide us with personal information in various ways when using Lusotel Wi-Fi services, for example, when sending customer service requests.

Device Identifiers: In the course of providing Lusotel Wi-Fi services, we may automatically collect a device identifier (such as your IP address, MAC address, or other unique identifier) for your computer, mobile device, technology, or other device used to access the Lusotel Wi-Fi services. A device identifier is a number that is automatically assigned to your device when you access Lusotel Wi-Fi service, and we may identify your device by its identifier. When you use Lusotel Wi-Fi service, we may view your device identifier and use this information to enhance our service.

Other Device Information: We may also automatically log certain device information, including device type, web pages, apps, or sites visited, and the dates and times you visit, access, or use Lusotel Wi-Fi service. While this information is generally pseudonymized and/or aggregated, it may be associated with your Lusotel service account information or persistent identifiers. These data help us manage our networks and provide us with information about usage of Lusotel Wi-Fi service. However, we do not collect or process the contents of email or other electronic communications that you send or receive while using Lusotel Wi-Fi service.

Location Information: We may collect location information through your use of the Wi-Fi services we provide in our hotels to help us improve our service and deliver specific services such as personalized offers and promotions.

How We Use the Information We Collect

We use personal information only for the purposes described in this Statement, unless otherwise disclosed to you at the time of collection or as permitted by law or by you.
We use the personal information collected through Lusotel Wi-Fi service to operate, maintain, enhance, and provide all features of the service, deliver services and information you request, respond to comments and questions, and provide user support.
We use personal information collected through Lusotel Wi-Fi service to understand and analyze the usage trends and preferences of our users, to improve the Lusotel Wi-Fi service, and to develop new products, services, features, and functionality. If you provide your contact information, we may send you personalized offers based on your web usage and location. You may choose not to receive these offers by logging in to use Lusotel Wi-Fi services or at any time within your Lusotel Wi-Fi service account.

Use of Personal Information to Create Profiles

As described in the section above regarding cookies, we have relationships with third parties such as Google and Facebook that allow us to serve targeted advertising. In addition to the activities described under the “Targeted Advertising” heading above, we also match users on Facebook and Google across sites and devices to better understand their interests. We use this information to tailor our marketing communications to you so that we can ensure we are informing you about things most likely to be of interest. You may choose not to receive these offers by logging in to use Lusotel’s Wi-Fi services or at any time thereafter.

How We Protect Your Information

We are committed to safeguarding the confidentiality and security of the information you provide to us. To this end, technical, physical, and organizational security measures are in place to protect against unauthorized access, disclosure, damage, or loss of your information. While the collection, transmission, and storage of information can never be guaranteed to be completely secure, we take steps to ensure that appropriate security safeguards are in place to protect your information.

Managing Your Preferences and Information

We want to ensure you have the tools necessary to control the information you provide to us, including how we communicate with you. It is also important that you contact us to update your information if it becomes inaccurate or changes. Please click the relevant section below to learn more about how to control how we communicate with you and how to update, modify, and delete your information.

Through the provision of the services described above, we and in some cases our franchisees, third-party partners, and service providers may communicate with you about a reservation, through online digital services (e.g., online advertising, social media communications), or to support any other services we provide.

In some cases, you may access your account and click on the “Communication Preferences” section to review your communication settings. Additionally, an unsubscribe option will be included in each marketing communication. In all other cases, or if you have difficulty unsubscribing from a specific communication, you may find details in the “Contacts” section.

Please note that unsubscribing from one type of communication may not unsubscribe you from another. Likewise, unsubscribing from our communications may not mean you have unsubscribed from communications carried out independently by our franchisees.

Managing Your Information

If any of the information you have provided us is incorrect, has changed, or if you would like it to be deleted, you can update your information by contacting us at marketing@hoteldonafilipa.pt In some circumstances, you can update certain aspects of your personal information by accessing your account, logging in and clicking on the “Personal Information” section to update and correct your personal details. For all other cases, please contact us by email at marketing@hoteldonafilipa.pt (details can be found in the “Contact” section). We will respond to your request within a reasonable timeframe.

Please note that in some cases it may not be possible to delete certain parts of your information, and a portion may need to be retained for suppression purposes. In other cases, we may not be able to delete certain information stored on our systems or that has been provided by third parties in connection with the services discussed in this Privacy Statement.

Links to Other Sites
Our websites and applications contain links to websites that are maintained and/or operated by third parties. In some cases, these websites may be co-branded and display our logos or other registered trademarks. You can always tell if you are on one of our websites by checking the Uniform Resource Locator (“URL”) of the page you are visiting. We encourage you to review the privacy policies of these third-party websites as their privacy practices may differ from ours.

Children
Our websites are not intended for children, and we do not knowingly request or collect personal information from individuals under the age of 18. If we are notified or otherwise discover that personal information from a minor has been improperly collected, we will take all commercially reasonable steps to delete that information. In limited cases, we may run a campaign or program targeted at children. In such cases, information practices will be detailed within the program’s or campaign’s terms and conditions.

Retention of Your Information in Our Systems
We generally retain your information only for as long as reasonably necessary for the purposes outlined in this Privacy Policy. In some cases, we keep transactional records (which may include your information) for longer periods where needed to comply with legal, regulatory, tax, or accounting requirements. We may also retain information if we reasonably believe there is a prospect of litigation.

We maintain a Data Retention Policy that applies to the records we hold.

How to Contact Us About Your Personal Data and How It Is Handled
If you wish to contact us about:

The way your personal data is handled
Updating your personal preferences
Exercising your personal rights
Filing a complaint

1. Send us an email at marketing@hoteldonafilipa.pt

2. Direct your request to the Data Protection Officer, Lusotel – Indústria Hoteleira S.A at marketing@hoteldonafilipa.pt

Please note that we may require proof of identity in order to fulfil certain requests. A copy of your driving license is usually sufficient, although other forms of photo ID are also acceptable.

Where EU Data Protection Laws apply, you have the right to file a complaint with your local data protection supervisory authority at any time. However, we kindly ask that you try to resolve any concerns with us first before escalating your complaint.

Changes to This Privacy Statement

In some circumstances, we may need to amend, modify, or update this Privacy Statement to reflect regulatory changes or evolving business needs. Subject to any applicable legal requirements to provide additional notice, any changes to this Privacy Statement will be communicated via our websites and mobile applications. However, if changes are made to how your personal information is used in a manner different from that stated at the time of collection, we will take necessary steps to notify you—such as posting a notice on our website for 30 days prior to the changes taking effect or by emailing you.

What Rights Do You Have Over Your Personal Information?

Under the GDPR, individuals have greater control over how their personal information is managed. There are currently eight key rights, known as Data Subject Rights, detailed as follows:

Right of Access / Subject Access Requests – This right allows you to obtain all information that Lusotel holds about you as an individual (also known as a Subject Access Request). Under the GDPR, Lusotel has one month to provide you with all the information we have about you and your address. This applies only to the person making the request. We will review all manual and electronic records in our possession and provide everything accordingly. If your request specifies which documents you are seeking, this will help us respond more efficiently.

Right to Rectification – If you believe the information Lusotel holds about you is incorrect, inaccurate, or incomplete, the right to rectification ensures you can contact us to update it accordingly. We will confirm once the update has been completed.

Right to Erasure – Under the GDPR, you have the option to have all records of your personal data held by Lusotel erased. There are, however, a number of exceptions to this right, as we may have legal or contractual obligations to retain your personal information. If you believe that Lusotel holds information that is no longer necessary for the purpose it was originally collected, your right to erasure will be upheld.

Right to Data Portability – The GDPR allows you to receive your personal information in a portable format. This means you can transfer your data to another provider without needing to resubmit it to them manually.

Right to Withdraw Consent – Lusotel would like to give you control over how we communicate with you. Under the GDPR, this is known as the Right to Withdraw Consent. If, for any reason, you no longer wish to be contacted—either entirely or through specific channels—you may exercise this right. Lusotel will then update your contact preferences in our systems and notify any third parties with whom we may have shared your information of the change.

Right to Be Informed – This right underpins the need for transparency in how we use your data and is the purpose of this entire document. It ensures Lusotel provides appropriate notice of our processing activities and does so in a concise, transparent, accessible, and clear manner, using plain language and free of charge.

Right to Restrict Processing – This allows your data to be retained but not processed for marketing purposes. If you request this right, Lusotel will place you on a suppression list so your data is no longer processed.

Right to Object – Under the GDPR, you have the right to object to processing based on legitimate interest or a task carried out in the public interest, direct marketing, and processing for scientific/historical research or statistical purposes.

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