This Privacy and Personal Data Policy establishes how the Herdade do Barrocal de Baixo hotel establishment uses the personal data of its Customers and potential customers within the scope of the hotel and reservation services available on its website and the marketing policy developed by this entity.
This document aims to provide detailed information about the use and protection given to your personal data, the reason why they are processed, as well as your rights, thus complying with article 13 of the General Data Protection Regulation (Regulation (EU) 2016/679).
1 – Identification of the Person Responsible for the Treatment
ODIVEL-LAR, LDA, with legal entity and registration number 501.804.064, is the owner of the hotel establishment at Herdade do Barrocal de Baixo, and is responsible for the processing of your personal data, as it determines the purposes and the means of processing personal data.
2 – Personal Data Categories
Odivel-Lar may process personal data, namely those included in the following categories:
- Identification Data, such as gender, profession, name, age or date of birth, citizen card number, taxpayer number, foreign taxpayer number, if applicable, passport number and validity;
- Contact Data, such as address, email address, telephone and cell phone contacts, among others;
- Contractual Data, such as bank account details, including IBAN, among others.
3 – Origin of personal data
Odivel-Lar only collects and processes the personal data necessary for the provision of services or transactions to be carried out within the scope of commercial relationships with Customers or potential Customers, and such personal data may be provided by them or may result from established relationships.
It is possible that your personal data will be collected through third parties or other means, in which case Odivel-Lar will seek to provide you with information regarding the processing of your personal data.
Odivel-Lar collects personal data at various times, particularly during the first contact established, and through various communication channels, including telephone, e-mail, forms on internet pages, paper forms and postal letters.
4 – Purposes of Processing Personal Data and Legal Basis for Processing
Odivel-Lar processes the personal data of data subjects for various reasons, justified by the data protection laws applicable in the European Union and in Portugal.
The personal data of data subjects are processed for the following purposes and based on the following legal bases:
| Data Categories | Purposes | Legal Basis |
| Data Identification | · Compliance with contracts signed between Odivel-Lar and customers, namely: accommodation contract; supply of goods and services; rental of spaces or rooms; · Improvement and monitoring of service quality. | · Execution of a contract to which the data subject is a party, or for pre-contractual measures at the request of the data subject; · Compliance with legal obligations to which Odivel-Lar is subject; · Pursuit of legitimate interests of Odivel-Lar. |
| Contact Details | · Compliance with contracts signed between Odivel-Lar and customers, namely: accommodation contract; supply of goods and services; rental of spaces or rooms; · Marketing and communication, events and publicity; · Improvement and monitoring of service quality. | · Execution of a contract to which the data subject is a party, or for pre-contractual measures at the request of the data subject; · Compliance with legal obligations to which Odivel-Lar is subject; · Express and unequivocal consent of the data subject; · Pursuit of legitimate interests of Odivel-Lar |
| Contractual Data | · Compliance with contracts signed between Odivel-Lar and customers, namely: accommodation contract; supply of goods and services; rental of spaces or rooms. | · Execution of a contract to which the data subject is party, or for pre-contractual measures at the request of the data subject · Compliance with legal obligations to which Odivel-Lar is subject |
In the case of the processing of personal data for marketing and commercial communication purposes, this data processing will only be carried out with the consent of the data subject, given at the time of collection of the personal data. If you consent, the data subject may receive marketing communications via email, postal mail, telephone contact and SMS.
Consent to the processing of personal data for marketing and commercial communication purposes may be withdrawn at any time, although this right to withdraw consent does not compromise the lawfulness of the processing carried out on the basis of previously given consent nor the subsequent processing of the same data, based on another legal basis, such as, for example, execution of a contract to which the data subject is party, or for pre-contractual measures at the request of the data subject and compliance with legal obligations to which Odivel-Lar is subject.
If you wish to withdraw your consent, the data subject may contact us using the contact details indicated in this Policy.
5 – Automated processing
Odivel-Lar does not use technologies to make decisions exclusively based on the automated processing of data subjects’ data.
6 – Categories of Recipients of Personal Data
To fulfill its duties and provide a quality service, Odivel-Lar may have to communicate your personal data to other entities, including the following categories of recipients:
Public authorities, namely, Tax Authorities or police, Judicial or Administrative Courts; It is
Workers and service providers who provide services to Odivel-Lar.
When transmitting personal data to its service providers, Odivel-Lar guarantees that the subcontracting entity is bound by a subcontracting agreement that obliges it to process personal data in compliance with legislation on the protection of personal data.
Odivel-Lar may also share the data holders’ personal data with third parties following an express request from the data holders regarding the data they hold, in the exercise of their rights, in particular, the right to portability.
7 – Transfer of Personal Data to other Countries
In cases of international transfers (outside the European Union), whenever the European Commission has declared, through an adequacy decision, that the country located outside the European Union in question guarantees a level of protection of personal data equivalent to that resulting from legislation European Union, data transfer will be based on this adequacy decision.
In cases where the transfer is made to countries or organizations located outside the European Union, in relation to which there is no adequacy decision by the Commission, Odivel-Lar has implemented guarantees to ensure the protection of your data.
8 – Personal data retention periods
The processing of data by Odivel-Lar will continue as long as it proves necessary or mandatory to fulfill the purposes indicated above.
Once the contractual relationship has ended, personal data, the processing of personal data and the respective data conservation will be maintained for mandatory legal periods or until the rights arising therefrom prescribe, under the terms of the law. In any case, once the relationship with customers has ended, their data will no longer be processed for commercial purposes.
9 – Rights of Personal Data Holders
Under applicable law, Customers, as data holders, have the following rights:
- right of access: whenever you request it, you can access your personal data, obtain information related to the processing of your data and also obtain a copy of your personal data being processed.
- right to rectification: whenever you consider that your personal data is incomplete or incorrect, you can request its rectification or for it to be completed.
- right to erasure: without prejudice to legal and regulatory obligations that may limit the exercise of this right, you may request the erasure of your personal data when one of the following situations occurs: (i) the personal data is no longer necessary for the purpose for which it was motivated its collection or processing; (ii) withdraw the consent on which the data processing is based and there is no other legal basis for it; (iii) opposes the processing of data and there are no prevailing legitimate interests, to be assessed on a case-by-case basis, that justify the processing; (iv) personal data must be deleted under a legal obligation to which Odivel-Lar is subject; or (v) the personal data was collected in the context of offering information society services.
The right to erasure does not apply when processing is necessary (i) to exercise freedom of expression and information; (ii) to comply with a legal obligation that requires processing; (iii) for reasons of public interest in the field of public health; (iv) for archiving purposes of public interest, scientific or historical research purposes or statistical purposes, to the extent that the exercise of the right to erasure seriously prejudices the achievement of the objectives of such processing; or (v) for the purposes of declaring, exercising or defending a right in legal proceedings.
- right to limitation of processing: you can request the limitation of the processing of your personal data in the following cases: (i) if you contest the accuracy of your personal data, for a period of time that allows you to verify its accuracy; (ii) if the processing is unlawful and you oppose the erasure of the data, requesting, in return, the limitation of its use; (iii) if Odivel-Lar no longer needs the personal data for processing purposes, but if these data are necessary for the purposes of declaring, exercising or defending a right in legal proceedings; or (iv) if you have objected to the processing, until it is verified that Odivel-Lar’s legitimate interests prevail over yours.
- right of portability: when the processing is based on express consent or the execution of a contract and when the processing in question is carried out by automated means, you can request the delivery, in a structured, commonly used and machine-readable format, of personal data provided by you. You also have the right to request that Odivel-Lar transmit this data to another data controller, as long as this is technically possible.
- right to object: you have the right to object to the processing of your personal data in the following situations: (i) when the processing is based on the legitimate interests of Odivel-Lar; or (ii) when the processing is carried out for purposes other than those for which the data were collected, but which are compatible with them. If you object to the processing, Odivel-Lar will stop processing your personal data, unless it has legitimate reasons to carry out such processing and these prevail over your interests. You can also object to the processing of your data for direct marketing purposes, including profiling in connection with such marketing.
- right not to be subject to exclusively automated individual decisions: in the processing of data based on automated processes, you have the right to (i) obtain human intervention and analysis; (ii) express your point of view; and (iii) contest the decision taken.
- right to withdraw your consent: in cases where data processing is based on your consent, you can withdraw consent at any time. In this case, your personal data will no longer be processed, unless there is another basis that justifies such processing by Odivel-Lar.
- right to lodge complaints with the CNPD: you have the right to lodge complaints regarding matters related to the processing of your personal data with the National Data Protection Commission.
To exercise any of your rights:
E-mail: you can exercise your rights via the address: hbb@grupolopesrosa.pt
10 – Cookies and Analytical Data
We use Google Analytics for aggregated, anonymous analysis of website traffic. To track session usage, Google drops a cookie (_ga) with a randomly generated ClientID in your browser. This ID is anonymous and does not contain identifiable information such as email, phone number, name, etc. We also send Google your IP address. We use GA to track aggregate website behavior, such as which pages you visited, for how long, and so on. This information is important to us to improve your user experience and determine the effectiveness of the site. If you would like to access the browsing information we have – or request that we delete any GA data – please delete your _ga cookies, please contact us via this form and/or install the Google Analytics Opt-Out Browser Add-On.
11 – Changes to the Privacy Policy
Odivel-Lar may change or update this Privacy and Personal Data Policy in accordance with new legal or regulatory requirements, as well as following improvements in the quality of its services and the development of our commitment to the protection of personal data. Changes to this Policy will be duly publicized.