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PRIVACY POLICY

As part of the availability of the website hosted at www.theleafboutiquehotel.com and the services and communications available there, NovaPlatina. – Gestão e Exploração Hoteleira Lda, headquartered Estrada 4 Castelos Lot 129 2950-805 Quinta do Anjo Portugal., Registered at the Commercial Registry Office of Lisbon under the unique and tax identification number 514 624 906. may request the User to provide data that is, information provided by the User that allows The Leaf Boutique Hotel to identify and / or contact you (“Personal Data”).

As a rule, Personal Data is requested when the User registers on the Site, requests a contact and / or sends newsletters, subscribes to a particular Service, purchases a product or establishes a contractual relationship with The Leaf Boutique Hotel.

The Personal Data collected and processed consists of information regarding the name, gender, date of birth, telephone, mobile phone, email, address, tax identification number, credit card data (collected only for billing purposes), although they may come other Personal Data may be collected that may be necessary or convenient for the provision of Services by The Leaf Boutique Hotel.

We may also collect data regarding your health if you use our Gym, in which case we will ask for your express consent.

When collecting Personal Data, The Leaf Boutique Hotel provides the User with detailed information about the nature of the data collected and about the purpose and treatment that will be carried out in relation to Personal Data, as well as the information mentioned in clause 8.

The Leaf Boutique Hotel also collects and handles information about your hardware and software, as well as information about the pages visited by the User within the Site. This information may include: your browser type, domain name, access times and the links through which the User accessed the Site (“Usability Information”). We use this information only to improve the quality of your visit to our Site.

Usability Information and Personal Data are referred to in this Privacy Policy as “User Data”.

SUBCONTRACTORS

As part of the processing of User Data, you use it or may use third parties, subcontracted by you, to, on behalf of The Leaf Boutique Hotel, and in accordance with the instructions given by it, proceed with the processing of User Data, in strict compliance with the provisions of the law and this Privacy Policy.

These subcontracted entities will not be able to transmit User Data to other entities unless The Leaf Boutique Hotel has previously given written authorization to do so, and they are also prevented from hiring other entities without prior authorization from The Leaf Boutique Hotel.

The Leaf Boutique Hotel is committed to subcontracting only entities that have sufficient guarantees of execution of the appropriate technical and organizational measures, in order to ensure the defense of the User’s rights. All entities subcontracted by The Leaf Boutique Hotel are linked to the latter through a written contract which regulates, namely, the object and duration of the treatment, the nature and purpose of the treatment, the type of personal data, the categories of data subjects and the rights and obligations of the parties.

When collecting personal data, The Leaf Boutique Hotel provides the User with information about the categories of subcontracted entities that, in the specific case, can carry out data processing on behalf of The Leaf Boutique Hotel.

DATA COLLECTION CHANNELS

The Leaf Boutique Hotel may collect data directly (i.e., directly from the User) or indirectly (i.e., through partner entities or third parties). Collection can be done through the following channels:

Direct collection: in person, by phone, e-mail and through the Site;

Indirect collection: through partners or group companies and entities officers.

GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA

In terms of general principles regarding the processing of personal data, The Leaf Boutique Hotel is committed to ensuring that the User Data processed by you is:

Subject to lawful, fair and transparent treatment in relation to the User;

Collected for specific, explicit and legitimate purposes, not later being treated in a way incompatible with those purposes;

Adequate, relevant and limited to what is necessary in relation to the purposes for which they are treated;

Accurate and updated whenever necessary, taking all appropriate measures so that the inaccurate data, taking into account the purposes for which they are processed, are erased or rectified without delay;

Kept in a way that allows the identification of the User only for the period necessary for the purposes for which the data are processed;

Treated in a way that guarantees your safety, including protection against unauthorized or unlawful treatment and against accidental loss, destruction or damage, with technical or organizational measures being adopted

The data processing carried out by The Leaf Boutique Hotel is lawful when at least one of the following situations occurs:

The User has given his explicit consent to the treatment of the User Data for one or more specific purposes;

Processing is necessary for the performance of a contract to which the User is a party, or for pre-contractual steps at the request of the User;

Treatment is necessary to fulfill a legal obligation to which The Leaf Boutique Hotel is subject;

The treatment is necessary to defend the vital interests of the User or of another natural person;

Treatment is necessary for the purpose of the legitimate interests pursued by The Leaf Boutique Hotel or by third parties (unless the fundamental interests or rights and freedoms of the User that require the protection of personal data prevail).

The Leaf Boutique Hotel undertakes to ensure that the processing of User Data is only carried out under the conditions listed above and with respect for the principles mentioned above.

When the processing of User Data is carried out by The Leaf Boutique Hotel based on the User’s consent, the User has the right to withdraw his consent at any time. The withdrawal of consent, however, does not compromise the lawfulness of the treatment performed by The Leaf Boutique Hotel based on the consent previously given by the User.

The period of time during which data is stored and preserved varies according to the purpose for which the information is processed.

Effectively, there are legal requirements that require data to be kept for a minimum period of time. Thus, and whenever there is no specific legal requirement, the data will be stored and preserved only for the minimum period necessary for the purposes that motivated its collection or its further treatment, after which they will be eliminated.

 

USE AND PURPOSES OF USER DATA PROCESSING

In general terms, The Leaf Boutique Hotel uses User Data for the following purposes:

Provision of hotel services and associated services (restaurants, bars, etc.);

User contact management;

User billing and collection;

User Registration on the Site;

Inform the User, who has requested it, of new products and services made available on the Site and / or in the hotel units, special offers and campaigns, updated information on the activity of The Leaf Boutique Hotel and, in general, for marketing purposes The Leaf Boutique Hotel and its hotel units, through any means of communication, including electronic support;

Allow access to restricted areas of the Site, according to previously established terms;

Ensuring that the Site meets the needs of the User, through the development and publication of content as adapted as possible to the requests and type of User, the improvement of the search capabilities and functionalities of the Site and the obtaining of aggregated or statistical information regarding the user’s type profile (analysis of consumption profiles);

Provision of Services, and other services, such as newsletters, opinion polls, or other information or products requested or purchased by the User;

Recording of telephone calls that may be made within the scope of the contractual relationship, either during the contract formation phase or during its term;

The Leaf Boutique Hotel may combine Usability Information with anonymous demographic information for research purposes, and we may use the result of that combination to provide more relevant content on In certain restricted areas of the Site, The Leaf Boutique Hotel may combine Personal Data with Information Usability to provide the User with more personalized content.

The User Data collected by The Leaf Boutique Hotel is not shared with third parties without the User’s consent, except for the situations referred to in the following paragraph. However, in case the User contracts with The Leaf Boutique Hotel services that are provided by other entities responsible for the processing of personal data, the User Data may be consulted or accessed by those entities, to the extent necessary for the provision of said services.

Under the applicable legal terms, The Leaf Boutique Hotel may transmit or communicate User Data to other entities in the event that such transmission or communication is necessary for the performance of the contract established between the User and The Leaf Boutique Hotel or for pre- contractual at the request of the User, in case it is necessary to fulfill a legal obligation to which The Leaf Boutique Hotel is subject or if it is necessary for the purpose of pursuing legitimate interests of The Leaf Boutique Hotel or third party. In the event of a transmission of User Data to third parties, we will use reasonable efforts to ensure that the transferee uses the User Data transmitted in accordance with our Privacy Policy.

IMPLEMENTED TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES

To ensure the security of User Data and maximum confidentiality, we treat the information you have provided to us in an absolutely confidential manner, in accordance with our internal security and confidentiality policies and procedures, which are periodically updated according to needs, as well as in accordance with the legally provided terms and conditions.

Depending on the nature, scope, context and purposes of processing the data, as well as the risks arising from the treatment for the rights and freedoms of the User, The Leaf Boutique Hotel undertakes to apply, both when defining the data means of treatment as at the time of the treatment itself, the technical and organizational measures necessary and appropriate for the protection of User Data and the fulfillment of legal requirements.

It also undertakes to ensure that, by default, only the data that is necessary for each specific purpose of treatment are processed and that these data are not made available without human intervention to an undetermined number of people.

In terms of general measures, The Leaf Boutique Hotel adopts the following:

Regular audits to assess the effectiveness of the technical and organizational measures implemented;Awareness and training of staff involved in data processing operations;

Pseudonymization and encryption of personal data;

Mechanisms capable of ensuring the confidentiality, availability and permanent resilience of information systems;

Mechanisms that ensure the restoration of information systems and access to personal data in a timely manner in the event of a physical or technical incident;

 

INTERNATIONAL DATA TRANSFER

The personal data collected and used by The Leaf Boutique Hotel are not made available to third parties established outside the European Union. If, in the future, this transfer takes place for the reasons mentioned above, The Leaf Boutique Hotel undertakes to ensure that the transfer complies with the applicable legal provisions, namely regarding the determination of the suitability of that country with regard to data protection and requirements applicable to such transfers.

USE OF COOKIES

Cookies are small information files that are sent to your computer or mobile phone when you visit a website. Cookies are sent back to the originating site on each subsequent visit or to another site that recognizes that cookie. Cookies are useful because they allow a website to recognize the user’s device, allowing him to efficiently browse pages, also remembering his preferences and improving the user experience in general. Some of the cookies issued by the server will only have the duration of the session and will expire when you close the browser. Other cookies are used to remember when a user returns to a website and have a longer duration. Most browsers accept cookies automatically. You can modify your browser configuration to not accept or to be notified each time a cookie is created.

You can get more information about cookies, including how to see the cookies that have been created on your device and how to manage or delete them using different types of browsers, at www.allaboutcookies.org.

The ability to activate, deactivate or delete cookies can also be performed in your browser. To do this, follow the instructions in your browser (usually located in the options “Help”, “Tools” or “Edit”). Deactivating a cookie or a category of cookies does not delete the cookie from your browser, for this you need to manually delete it.

By blocking or eliminating cookies used by The Leaf Boutique Hotel, you may not be able to fully enjoy the website’s features.

RIGHT TO INFORMATION

A VIEW TO COMPLYING WITH THE RIGHT TO INFORMATIONPROCEDURES AND MEASURES IMPLEMENTED WITH A VIEW TO COMPLYING WITH THE RIGHT TO INFORMATION

The information referred to in C.1.1 is provided in writing (including by electronic means) by The Leaf Boutique Hotel to the User prior to the processing of personal data in question. Under the terms of the applicable law, The Leaf Boutique Hotel has no obligation to provide the User with the information mentioned in C.1.1 when and to the extent that the User is already aware of it.

The information is provided by The Leaf Boutique Hotel free of charge.

RIGHT OF ACCESS TO PERSONAL DATA

The Leaf Boutique Hotel guarantees the means that allow the User to access their Personal data.

The User has the right to obtain from The Leaf Boutique Hotel the confirmation that the personal data concerning him are or are not subject to treatment and, if applicable, the right to access his personal data and the following information:

The purposes of data processing;

The categories of personal data in question;

The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or belonging to international organizations;

The period of conservation of personal data;

Right to ask The Leaf Boutique Hotel to rectify, erase or limit the processing of personal data, or the right to object to such treatment;

Right to file a complaint with the CNPD or other supervisory authority;

If the data has not been collected from the User, the information available on the source of such data;

The existence of automated decisions, including the definition of profiles, and information related to the underlying logic, as well as the importance and expected consequences of such treatment for the data subject;

Right to be informed about adequate guarantees associated with the transfer of data to third countries or international organizations.

Upon request, The Leaf Boutique Hotel will provide the User, free of charge, with a copy of the User Data that is being processed. The supply of other copies requested by the User may incur administrative costs.

RIGHT TO RECTIFY PERSONAL DATA

The User has the right to request, at any time, the rectification of his Personal Data, as well as the right to have his incomplete personal data completed, including by means of an additional declaration.

In case of rectification of the data, The Leaf Boutique Hotel communicates to each recipient to whom the data has been transmitted the respective rectification, unless such communication proves impossible or involves a disproportionate effort to The Leaf Boutique Hotel.

 

RIGHT TO DELETE PERSONAL DATA (“RIGHT TO BE FORGOTTEN”)

The User has the right to obtain, from The Leaf Boutique Hotel, the deletion of your data when one of the following reasons applies:

User Data is no longer necessary for the purpose that motivated its collection or treatment;

The User withdraws the consent on which the treatment of the data is based and there is no other legal basis for said treatment;

The User opposes the treatment under the right of opposition and there are no prevailing legitimate interests that justify the treatment;

If the User Data is processed illegally;

If the User Data has to be erased in order to comply with a legal obligation to which DHM is subject;

Under applicable legal terms, The Leaf Boutique Hotel is under no obligation to delete User Data to the extent that the treatment proves necessary to fulfill a legal obligation to which DHM is subject or for the purposes of declaration, exercise or defense a right of The Leaf Boutique Hotel in a lawsuit.

In case of data deletion, The Leaf Boutique Hotel communicates to each recipient / entity to whom the data has been transmitted the respective deletion, unless such communication proves impossible or involves a disproportionate effort for The Leaf Boutique Hotel.

When The Leaf Boutique Hotel has made User Data public and is obliged to delete it under the right of deletion, The Leaf Boutique Hotel undertakes to ensure reasonable measures, including technical measures, taking into account taking into account the available technology and the costs of its application, to inform those responsible for the effective processing of personal data that the User has requested that they delete the links to that personal data, as well as copies or reproductions thereof.

 

RIGHT TO LIMIT THE PROCESSING OF PERSONAL DATA

The User has the right to obtain, from The Leaf Boutique Hotel, the limitation of the processing of User Data, if one of the following situations applies (the limitation is to insert a mark in the personal data kept with the aim of limiting the treatment in the future):

If you dispute the accuracy of personal data, for a period that allows The Leaf Boutique Hotel to verify its accuracy;

If the treatment is illegal and the User opposes the deletion of the data, requesting, in return, the limitation of its use;

If The Leaf Boutique Hotel no longer needs User Data for processing purposes, but such data is required by the User for the purposes of declaring, exercising or defending a right in a judicial process;

If the User has opposed the treatment, until it is found that the legitimate reasons of The Leaf Boutique Hotel prevail over those of the User.

When User Data is subject to limitation, it may only, with the exception of conservation, be treated with the User’s consent or for the purpose of declaring, exercising or defending a right in a judicial proceeding, defending the rights of another natural person or collective action, or for reasons of public interest provided for by law.

The User who has obtained a limitation in the treatment of his data in the cases referred to above will be informed by The Leaf Boutique Hotel before the limitation to treatment is canceled.

In case of limitation in the processing of data, The Leaf Boutique Hotel will communicate to each recipient to whom the data has been transmitted the respective limitation, unless such communication proves impossible or involves a disproportionate effort for The Leaf Boutique Hotel.

RIGHT TO PORTABILITY OF PERSONAL DATA

The User has the right to receive the personal data that concerns him and that he has provided to The Leaf Boutique Hotel, in a structured format, in common use and automatic reading, and the right to transmit that data to another controller, if :

Treatment is based on consent or a contract to which the User is a party; and Treatment is carried out by means.

The portability right does not include inferred data or derived data, i.e., personal data that is generated by The Leaf Boutique Hotel as a consequence or result of the analysis of the data being processed.

The User has the right to have personal data transmitted directly between those responsible for processing, whenever this is technically possible.

RIGHT OF OPPOSITION TO TREATMENT

The User has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him based on the exercise of legitimate interests pursued by The Leaf Boutique Hotel or when the treatment is carried out for purposes other than those for which personal data were collected, including the definition of profiles, or when personal data are processed for statistical purposes.

The Leaf Boutique Hotel will cease the processing of User Data, unless it presents imperative and legitimate reasons for such treatment that prevail over the interests, rights and freedoms of the User, or for the purposes of declaring, exercising or defending a right of The Leaf Boutique Hotel in a lawsuit.

 

When User Data is processed for the purposes of direct marketing (marketing), the User has the right to object at any time to the processing of data concerning him for the purposes of said marketing, which covers the definition of profiles in insofar as it relates to direct marketing. If the User opposes the processing of his data for the purpose of direct marketing, The Leaf Boutique Hotel stops processing the data for that purpose.

The User also has the right not to be subject to any decision taken exclusively on the basis of automated treatment, including the definition of profiles, which has effects in its legal sphere or which significantly affects him in a similar way, unless the decision:

It is necessary for the conclusion or execution of a contract between the User and The Leaf Boutique Hotel;

It is authorized by legislation to which The Leaf Boutique Hotel DHM is subject; or is based on the User’s explicit consent.

PROCEDURES FOR THE EXERCISE OF RIGHTS BY THE USER

The right of access, the right to rectification, the right to erase, the right to limit, the right to portability and the right to object can be exercised by the User by contacting the Data Protection Officer, The Leaf Boutique Hotel, through welcome@theleafboutiquehotel.com. The Leaf Boutique Hotel will respond in writing (including by electronic means) to the User’s request within a maximum period of one month from receipt of the request, except in cases of special complexity, where this period may be extended up to two months.

If the requests submitted by the User are manifestly unfounded or excessive, namely due to their repetitive nature, The Leaf Boutique Hotel reserves the right to charge administrative costs or to refuse to proceed with the request.

PERSONAL DATA BREACHES

In the event of a data breach and to the extent that such breach is likely to imply a high risk to the User’s rights and freedoms, The Leaf Boutique Hotel undertakes to report the breach of personal data to the User concerned within 72 hours after knowledge of the incident.

Under legal terms, communication to the User is not required in the following cases:

If The Leaf Boutique Hotel has applied appropriate protection measures, both technical and organizational, and these measures have been applied to the personal data affected by the breach of personal data, especially measures that make the personal data incomprehensible to any unauthorized person to access such data, such as encryption;

If The Leaf Boutique Hotel has taken subsequent measures to ensure that the high risk to the User’s rights and freedoms is no longer likely to materialize; or

If communication to the User implies a disproportionate effort for The Leaf Boutique Hotel. In that case, DHM will make a public communication or take a similar measure whereby the User will be informed.

EMAIL CONFIDENTIALITY

The e-mails sent by DHM and all its attachments are CONFIDENTIAL and are intended exclusively for those listed as recipients. If you read any message and are not the intended recipient, you are notified that any use, distribution, forwarding or other form of disclosure to others, printing or copying of the message is expressly prohibited under the terms of the legislation in force. If you received an error message, we require that you notify us immediately to the email dpo@discoveryportugal.com and proceed to its immediate elimination. The Leaf Boutique Hotel is fully responsible for the content of email messages that are altered or falsified.

CHANGES TO THE PRIVACY POLICY

The Leaf Boutique Hotel reserves the right to change this Privacy Policy at all times. In case of modification of the Privacy Policy, the date of the last change, available at the top of this page, is also updated. If the change is substantial, a notice will be posted on the Site.

 

APPLICABLE LAW AND JURISDICTION

The Privacy Policy, as well as the collection, processing or transmission of User Data, are governed by the provisions of Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016 and by the applicable laws and regulations in Portugal.

Any disputes arising from the validity, interpretation or enforcement of the Privacy Policy, or which are related to the collection, processing or transmission of User Data, must be submitted exclusively to the jurisdiction of the judicial courts of the Lisbon District, without prejudice to the legal rules applicable imperatives.

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