I. GENERAL PART
1.1 CUSTOMER DATA COLLECTION AND TREATMENT
The protection of privacy and personal data constitutes a fundamental commitment of HOTEL SANTA MARTA, SA (hereinafter referred to as INSPIRA SANTA MARTA HOTEL) to its Customers.
INSPIRA SANTA MARTA HOTEL collects data directly, namely from the Customer, in person, by phone, by e-mail or through the Site.
1.2. THE DATA PROCESSING CONTROLLER AND THE DATA PROTECTION SUPERVISOR
The person responsible for collecting and processing your personal data will be INSPIRA SANTA MARTA HOTEL, which provides hotel, restaurant, bars, leisure facilities, gym rooms, rooms offering health treatments with water, game rooms, excluding gambling and games of luck, conference rooms, spaces for trade or services, car parking and the organization of all types of tourist activities and events. In this context, INSPIRA SANTA MARTA HOTEL decides what data is collected, the means by which it is treated and the purposes for which the data is used.
INSPIRA SANTA MARTA HOTEL also has a Data Protection Officer (DPO), who (i) monitors the compliance of data processing with applicable standards, (ii) is a point of contact with the Customer in regards to the clarification of matters relating to the processing of your data and (iii) cooperates with the supervisory authority.
1.3. PERSONAL DATA, PERSONAL DATA HOLDERS AND PERSONAL DATA CATEGORIES
Personal Data is any information relating to an identified or identifiable natural person (data subject) of any nature and on any medium.
The Personal Data collected and processed by INSPIRA SANTA MARTA HOTEL consists essentially of information regarding the name, gender, date of birth, telephone, mobile phone, email, address, tax identification number, consumer profile, and other Personal Data that may be necessary or convenient for providing services or billing by INSPIRA SANTA MARTA HOTEL.
1.4. SUBCONTRACTED ENTITIES
Nevertheless, these subcontracted entities may not transmit the Customer Data to other entities without INSPIRA SANTA MARTA HOTEL having given previous written authorization to do so. They are also prevented from contracting other entities without previous authorization from INSPIRA SANTA MARTA HOTEL.
Seeing as the privacy of our Customers constitutes a fundamental commitment for INSPIRA SANTA MARTA HOTEL, INSPIRA SANTA MARTA HOTEL commits to subcontract only entities that offer the maximum security in the execution of the appropriate technical and organizational measures in order to guarantee the protection of Customer's rights. All entities subcontracted by INSPIRA SANTA MARTA HOTEL shall be bound to the latter by means of a written agreement in which the object and duration of the treatment, the nature and purpose of the treatment, the type of personal data, the categories of the rights and obligations of the parties, are regulated.
After the collection of personal data, INSPIRA SANTA MARTA HOTEL provides the Customer with information about the categories of the subcontracted entities that, in the specific case, can process data on its behalf.
2. GENERAL PRINCIPLES APPLICABLE TO CUSTOMER DATA PROCESSING
INSPIRA SANTA MARTA HOTEL undertakes to ensure that the Customer Data it processes is:
i) object of treatment in accordance with the law, fair and transparent in relation to the Customer;
(ii) collected for specified, objective and legitimate purposes and not subsequently treated in a manner contrary to those purposes;
(iii) appropriate and limited to the purposes for which it is processed;
(iv) accurate and up-to-date when necessary, with all necessary measures taken to ensure that inaccurate data, taking into account the purposes for which it is processed, is erased or corrected without delay;
v) Preserved in a manner that allows the Customer to be identified only for the period necessary for the purposes for which the data is processed;
(vi) Treated in a manner that ensures its safety, including protection against unauthorized or unlawful treatment and against loss, destruction or unforeseen damage. To this end, appropriate technical or organizational measures are taken.
Data processing performed by INSPIRA SANTA MARTA HOTEL is permitted and legal when at least one of the following situations occurs:
(i.e. The Customer has given, freely, specific, informed and explicitly consent for the processing of his personal data for one or more specific and established purposes;
(i.e. Processing is necessary for the execution of a contract in which the Customer is a party, or for pre-contractual procedures at the Customer's request;
(i.e. The treatment is necessary for the fulfillment of a legal obligation to which INSPIRA SANTA MARTA HOTEL is subject;
(i.e. Treatment is necessary for the defense of the fundamental interests of the Customer or of another natural person;
(i.e. The processing is necessary for the legal interests pursued by INSPIRA SANTA MARTA HOTEL or by third parties (except if the interests or fundamental rights and freedoms of the Customer that requires the protection of personal data prevail).
INSPIRA SANTA MARTA HOTEL undertakes to ensure that the processing of Personal Data is only done under the conditions listed above and with respect to the principles mentioned above.
When the processing of Personal Data is based on the Customer's Consent, the Customer has the right to withdraw its consent at any time. The withdrawal of the consent, however, does not compromise the legality of the treatment carried out until then by INSPIRA SANTA MARTA HOTEL and which was based on the consent previously given.
The length of time during which the data is stored and maintained varies according to the purpose for which the information is processed.
Effectively, there are legal requirements that require the data to be retained for a minimum period of time. Thus, and when there is no specific legal obligation, the data will be stored and kept only for the minimum period necessary for the purposes that led to its collection or subsequent processing, and in the end of this period it will be eliminated.
3. USE AND PURPOSES OF CUSTOMER DATA PROCESSING
In general terms, INSPIRA SANTA MARTA HOTEL uses Personal Data for the following purposes:
• Provision of hotel services, catering, bars, leisure spaces, gym rooms, rooms offering health treatments with water, game rooms, excluding gambling and games of luck, conference rooms, spaces for trade or services, car parking and the organization of all kinds of activities and tourist events;
• Contact management with the Customer;
• Customer invoicing and billing;
• Customer Registration on the Site;
• Inform the Customer, who has requested it, of new services made available, special offers and campaigns, updated information about their activity and, generally, for the marketing purposes of INSPIRA SANTA MARTA HOTEL and its enterprises, by any means of communication including electronic media;
• Provision of Services, such as newsletters, opinion surveys, or other information or services provided or treatments performed to the Customer.
4. TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES IMPLEMENTED
In order to guarantee the security of the Customer's Data and maximum confidentiality, INSPIRA SANTA MARTA HOTEL treats the information in a completely confidential way, committing itself to apply the technical and organizational measures necessary and adequate for the protection of the Personal Data and the fulfillment of the legal requirements.
INSPIRA SANTA MARTA HOTEL also undertakes to ensure that only data that is necessary for each specific purpose of treatment is processed.
The communication between the Customer's device and the INSPIRA SANTA MARTA HOTEL Website is carried out through secure channels and communications that use the HTTPS protocol and the SSL security standard.
In general terms, INSPIRA SANTA MARTA HOTEL adopts the following measures to implement the rules and principles established by the Data Protection Regulation:
• Regular audits to identify the competence of the technical and organizational measures implemented;
• Sensitization and training of the personnel involved in data processing operations;
• Pseudonymization and coding of personal data;
• Mechanisms capable of ensuring the permanent confidentiality, availability and resilience of information systems;
• Mechanisms to ensure the restoration of information systems and access to personal data quickly in the event of a physical or technical incident.
5. USING COOKIES
II. CUSTOMER RIGHTS (DATA HOLDERS)
7. RIGHT TO INFORMATION
Information provided to the Customer by INSPIRA SANTA MARTA HOTEL (when the data is collected directly from Customer):
• The identity and contacts of INSPIRA SANTA MARTA HOTEL, responsible for the treatment;
• The contacts of the Data Protection Officer;
• The purposes of the treatment to which the personal data is intended, as well as, if applicable, the legal reasons for the treatment;
• If the processing of the data is based on the legitimate interests of INSPIRA SANTA MARTA HOTEL or a third party, the indication of such interests;
• If applicable, recipients or categories of recipients of personal data;
• Deadline for the preservation of personal data;
• The right to request INSPIRA SANTA MARTA HOTEL for permission to personal data, as well as its correction, elimination or limitation, the right to oppose treatment and the right to access the data;
• If the processing of the data is based on the consent of the holder, the right to withdraw it at any time;
• The right to file a complaint with the CNPD or other supervisory authority;
8. RIGHT OF ACCESS TO PERSONAL DATA
The Customer has the right to obtain from INSPIRA SANTA MARTA HOTEL the confirmation of if the personal data concerning him or her is targeted for treatment or not and, if applicable, the right to access this personal data.
Upon request, INSPIRA SANTA MARTA HOTEL will provide, free of charge, a copy of the Customer Data that is being processed. The supply of other copies requested by the Customer may entail administrative costs.
9. RIGHT TO RETIFICATION OF PERSONAL DATA
The Customer has the right to request, at any time, the rectification of his Personal Data and also the right to have incomplete personal data completed.
In case of rectification of the data, INSPIRA SANTA MARTA HOTEL communicates to each addressee to whom the data had been forwarded the respective rectification, unless such communication is considered impossible or involves a disproportionate effort for INSPIRA SANTA MARTA HOTEL.
10. RIGHT TO THE DELETION OF PERSONAL DATA ("RIGHT TO FORGET")
The Customer has the right to obtain, from INSPIRA SANTA MARTA HOTEL, the elimination of their data when one of the following reasons applies:
• Customer Data is no longer required for the purpose for which it was collected or processed;
• The Customer withdraws the consent on which the data treatment is based and there is no other legal basis for such treatment;
• The Customer opposes to the treatment under the right of opposition and there are no prevailing legitimate interests justifying the treatment;
• In case the Personal Data is treated illegally;
Under the applicable legal terms, INSPIRA SANTA MARTA HOTEL is under no obligation to delete Customer Data as long as the treatment proves necessary to fulfill a legal obligation to which INSPIRA SANTA MARTA HOTEL is subject to or for the purposes of declaration, exercise or defense of an INSPIRA SANTA MARTA HOTEL right in any litigation.
In case of the elimination of the data, INSPIRA SANTA MARTA HOTEL notifies each recipient/entity to whom the data has been transmitted of the deletion, unless such communication proves impossible or involves a disproportionate effort.
12. RIGHT OF PORTABILITY OF PERSONAL DATA
The Customer has the right to receive the personal data that concerns him or her and which he or she has provided to INSPIRA SANTA MARTA HOTEL, in a structured format, of current use and of automatic reading, and the right to transmit this data to another person responsible for the treatment, at all times when that is technically possible if:
(i.e. The processing is based on consent or on a contract to which the Customer is a party;
(i.e. The treatment is performed by automated means.
13. PROCEDURES FOR THE EXERCISE OF CUSTOMER RIGHTS
The right of access, the right of rectification, the right of elimination and the right of portability may be exercised by the Customer through contact with the Data Protection Officer of INSPIRA SANTA MARTA HOTEL, by email [●].
14. VIOLATIONS OF PERSONAL DATA
In case of violation of personal data, INSPIRA SANTA MARTA HOTEL will notify the National Data Protection Commission within 72 hours. It also undertakes to report such violation to the Customer, to whom the data in question refers.
III. FINAL PART
In case of a change, the date of this change will be visible at the top of this page.
16. APPLICABLE LAW AND JURISDICTION