VANDOMA LIVING SUITES values the protection for your personal data and is committed to respecting your Privacy.
In this Privacy Policy, we inform you how we collect and process the personal data of all those who use our Service, as well as those who access and use our Website and Platform. We also inform you about your rights as a data subject.
This Policy should be read and interpreted together with our Terms and Conditions, available here.
We have tried to make this Policy as clear and transparent as possible, but if anything is unclear, please contact us at the following email address reservations@vandoma.co.
LEGAL FRAMEWORK
Your personal data will always be processed in a way as that ensures strict compliance with the applicable legislation on personal data protection, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 or General Data Protection Regulation (“GPDR”), Law No. 58/2019 of August 8, which ensures the implementation of the GPDR in the Portuguese legal system, and other applicable sectoral legislation.
CONTROLLER OF YOUR PERSONAL DATA
VISERION, LDA., a private limited Company registered at the Commercial Registry Office under the legal person Identification number 516.506.277, with its registered office at Rua do Passeio Alegre, n.º 264, 3.º direito, 4150 - 571 Porto, parish of Aldoar, Foz do Douro and Nevogilde, municipality and district of Porto, also referred to as the “Data controller”, is the entity responsible for processing your personal data.
VISERION, LDA. is an entity that provides services in the tourism sector, namely hotel and local accommodation activities. To that extent, in order to provide our Service, we will process your personal data.
Throughout this Policy, references to “VANDOMA LIVING SUITES”, “we” or “our” refer to VISERION, LDA. We will also refer to “you”, the person visiting our Website or using our Platform and who is the data subject.
If you have any questions about this Privacy Policy or how we process your personal data, please contact us. To do so, please refer to the “CONTACTS” section (below).
PERSONAL DATA
Personal data is any information, of any nature and regardless of its medium, relating to an identified or identifiable natural person.
According to the GDPR, an identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to a name, identification number, location data, electronic identifier, or one or more specific elements of their physical, physiological, genetic, mental, economic, cultural or social identity.
The information we collect about you and how we do so may vary depending on the Services you use and/or contract.
We only collect the data we consider essential for navigating our Website and/or providing our Platform, to offer you the Services you request, manage your bookings, register and invoice your orders, ensure that they are provided to you, and, if you demonstrate any interest, to inform you of our news.
To consult the purposes and legal bases for processing your personal data, please consult the section “PURPOSE(S) AND LEGAL BASIS(ES) FOR PROCESSING” (below).
CATEGORIES OF PERSONAL DATA
Identification data: name, nationality, ID number and country of issue, tax number, date and place of birth, company.
Contact data: address, e-mail address, telephone contact.
Purchase and billing data: billing address, card number.
PURPOSES AND LEGAL BASES FOR PROCESSING
VANDOMA LIVING SUITES will process your personal data on the following legal bases:
Compliance with contractual obligations or precontractual due diligences;
Compliance with applicable legal obligations;
For some processing activities, we will need your consent;
Legitimate interest, provided that the processing of personal data is balanced with the interests or fundamental rights and freedoms of the data subject.
We use the data you provide to offer you the best possible experience. In particular, we collect and process personal data to:
Provide the Service;
Compliance with applicable sector-specific legislation;
Communication with the Customer;
Clarification of doubts;
Information requests;
Communication of offers, new services, commercial campaigns, satisfaction surveys and other advertising and marketing communications.
Reservations for accomodation can be made directly through the Website (https://www.vandomalivingsuites.com/pt), which will redirect the Customer to the Booking Engine (https://booking.roomraccoon.pt/viserion-lda/pt), or they can be made indirectly through other operators, namely Booking.com, Expedia, among others.
If you make your reservation directly, i.e. through our Platform, we will collect and process some of your personal data under the terms set out in this Policy, acting as the Data Controller, as defined in Article 4(7) of the General Data Protection Regulation.
If you make a reservation indirectly, i.e., through the operators mentioned above (namely Booking.com, Expedia, among others), we inform you that these platforms will be, for all purposes, the Data Controllers of your data, so if you want to know how your personal data is processed by these operators, we recommend that you refer to their respective Privacy Policies.
We collect only the strictly necessary data to pursue the purposes of processing, with full transparency and guarantees of security and confidentiality, in accordance with the description below:
Booking reservations through the Platform
Categorias of data:
Identification data
Contact data
Purchase and billing data.
Legal basis:
Performance of a contract
Manage reservations made through the Platform
Categorias of data:
Identification data
Contact data
Legal basis:
Performance of a contract
Send you newsletters and marketing communications
Categorias of data:
Contact data
Legal basis:
Consent of the data subject
Payment processing
Categorias of data:
Identification data
Contact data
Purchase and billing data
Legal basis:
Performance of a contract
Management of our relationship with the Customer (contacts, notification of changes to our terms and conditions)
Categorias of data:
Identification data
Contact data
Legal basis:
Performance of a contract
Compliance with legal obligations
Legitimate interests of the Data Controller (in particular, to understand how we can offer better services to our Clients)
Ensure the full functioning of our Website and our Platform
Categorias of data:
Identification data
Contact data
Legal basis:
Legitimate interests of the Data Controller (in particular, to keep online services fully operational and secure)
Compliance with legal obligations
Management of our relationship with the Customer (contacts, notification of changes to our terms and conditions)
Categorias of data:
Identification data
Contact data
Legal basis:
Performance of a contract
Compliance with legal obligations
Legitimate interests of the Data Controller (in particular, to understand how we can offer better services to our Clients)
Ensure compliance with portuguese legislation regarding the entry, stay, departure and exit of foreigners from the national territory
Categorias of data:
Identification data
Legal basis:
Compliance with legal obligations
DATA SHARING WITH THIRD PARTIES
In the context of providing our Service, we may use service providers and intermediaries, our processors, who need access to some of your personal data, namely:
IT service providers, such as reservation management or revenue management;
Providers of electronic payment processing services.
However, these Communications are made solely and exclusively for the fulfilment of the purposes for which the data is collected and in accordance with our instructions, in strict compliance with the rules on the processing of personal data and information security.
We may also communicate your personal data to third parties when:
You have expressly consent to this; or
The communication is made in the context of complying with a legal obligation or a court order issued by judicial, administrative, and/or regulatory authorities.
RETENTION PERIOD
Your personal data will be retained only for the period necessary to pursue the purposes for which they were collected or for the periods required by legal obligation.
Reservation and billing data will be retained during the performance of the contract and, after its termination, may still be retained for a reasonable period in case you decide to use our services again.
In some cases, to comply with the law, we will need to retain your personal data for the legally and expressly stipulated period (for example, tax obligations, obligation to report the stay of foreign citizens in local accommodation establishments).
RIGHTS OF THE DATA SUBJECT
We make every effort to ensure that your personal information is correct, up-to-date, and complete, in accordance with the purposes for which we use that information.
In accordance with the GDPR, you have the right, at any time, to access and object to the processing of your personal information, as well as the right to update, correct, and delete any data collected by us that is incomplete, incorrect, outdated, or prohibited by law. You can exercise these rights by contacting us using the contact details provided below (“CONTACTS”).
We briefly explain your rights in the description below:
RIGHT TO BE INFORMED
You have the right to obtain clear, transparent, and easily understandable information about how we use your personal data.
RIGHT OF ACCESS
You can request a copy of the data we have about you.
RIGHT TO RECTIFICATION
You have the right to rectify your personal data if it is incorrect or outdated and/or to complete if it is incomplete.
RIGHT TO ERASURE
You can request the erasure of any personal data processed at any time. However, this right is not absolute, as we may have legal grounds to retain your personal data. If this is the case, we will provide you with all necessary information.
RIGHT TO OBJECT
You have the right to object, at any time, to the processing of your personal data for reasons related to your particular situation. VANDOMA LIVING SUITES will not be able to continue processing your data in these circumstances unless we present compelling and legitimate reasons that prevail over your interests, or in the case of legal proceedings.
RIGHT TO WITHDRAW CONSENT
You may withdraw your consent given for the processing of data when that processing is based on consent. However, withdrawing consent does not affect the legality of the consent previously given.
RIGHT TO DATA PORTABILITY
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and the right to transmit those data to another organization. This applies only to the data you provided, where the processing is based on your consent or the performance of the contract, and if the processing is carried out by automated means.
RIGHT TO RESTRICITON OF PROCESSING
You can request that, for a certain period, the processing of your data be limited in its use, preventing the data from being communicated to third parties, transferred internationally, or erased.
You can also request that we restrict the use of your data solely for storage, that we stop using it for all other purposes, or that we retain data that should be deleted.
RIGHT TO LODGE A COMPLAINT WITH THE NATIONAL DATA PROTECTION AUTHORITY
You also have the right to lodge a complaint with the supervisory authority in Portugal – the “Comissão Nacional de Proteção de Dados” -, when your rights have been violated or your personal information is or has been used in a way that you believe is not in compliance with the applicable legislation. The contact details for the National Data Protection Authority are available here, along with the information on how to make a complaint.
You can exercise any of these rights using the contact details provided below (“CONTACTS”).
AUTOMATED INDIVIDUAL DECISION-MAKING
We do not expect you to be subject to decisions based solely on automated means that produce legal effects concerning you or significantly affect you in a similar way. However, we will update this policy if this situation changes and will notify you of those changes.
INTERNATIONAL TRANSFERS
We do not anticipate transferring your personal data outside the EU or the EEA, i.e., to a third country. However, if this must occur (for instance, by hypothetically using processors based in a third country), we will ensure strict compliance with European legislation regarding the transfer of data to third countries and will provide all necessary information, including the indication of guarantees for such transfer, such as:
Adequacy decisions: when the European Commission determines that a third country offers an adequate level of data protection, personal data can be sent to that country without implementing any additional measures mentioned above;
Adoption of appropriate safeguards such as the use of standard contractual clauses: These contractual commitments have been adopted by the European Commission and ensure adequate protection of personal data transferred to countries outside the EU or EEA, binding the recipients of the personal data to certain data protection standards, including the obligation to implement appropriate technical and security measures.
COOKIES
VANDOMA LIVING SUITES uses automated data collection systems, namely cookies.
WHAT ARE THEY?
Cookies are small text files containing relevant information that your access device (computer, mobile phone, or tablet) loads through the internet browser when you visit a website. Cookies can be installed or stored in the memory or on the hard drive of your device, retaining information related to your preferences.
WHAT ARE COOKIES USED FOR?
Cookies help determine the usefulness, relevance, and number of visits to a website, and provide users with a faster and more efficient browsing experience by reducing the need to repeatedly enter the same information.
Except for strictly necessary cookies, in order to ensure a better experience and functionality of our Website, cookies are placed after obtaining your consent for this purpose.
WHAT TYPES OF COOKIES DO WE USE?
We use strictly necessary cookies and performance, analytical, advertising, and targeting cookies.
WHAT IS THE PURPOSE OF THE COOKIES WE USE?
Strictly necessary cookies: allow users to navigate our Website and access secure areas. Without these cookies, some services you request may not be offered.
Performance and Analytical Cookies: These collect information about how you use the website, the pages you've visited, and the links you've clicked. All data is anonymized and cannot be used to identify you.
Advertising and Targeting Cookies: These collect user information and use it to create a profile of the visitor's interests, and then display personalized ads to that specific user.
COOKIES MANAGEMENT
You can, at any time, authorize, restrict, or prohibit the cookies mentioned above.
You can also, at any time, authorize, restrict, or prohibit cookies by configuring your internet browser (Internet Explorer, Firefox, Safari, Google Chrome, Opera, etc.) as described below. Please note that any configuration may alter your internet browsing and your conditions of access to services that require the use of cookies.
The configuration of each browser is different, so we recommend that you consult your browser’s help menu:
For Chrome:
https://support.google.com/chrome/answer/114836?hl=enFor Safari:
https://support.apple.com/en-us/guide/safari/sfri4095/macFor Firefox:
https://support.mozilla.org/en-US/kb/change-firefox-privacy-and-security-settingsFor Internet Edge:
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-downloads
SECURITY MEASURES
We are continually implementing and updating the technical, physical, and organizational security measures necessary to ensure that your personal data are processed with a high level of security. The technical, organizational, and physical procedures we have in place ensure the confidentiality of your personal data, protecting it from accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access, as well as against other unlawful forms of data processing.
Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls.
We also take measures capable of ensuring the confidentiality, integrity, availability, and permanent resilience of the systems and services for processing.
We have an incident response system for personal data breaches, taking necessary measures to mitigate any potential harm to the rights and freedoms of data subjects. We have also implemented processes to regularly test, assess, and evaluate the effectiveness of the technical and organizational measures to ensure the security of processing.
Any entity we subcontract will be bound by equivalent security measures, acting continuously under our properly documented instructions.
CHANGES TO THE PRIVACY POLICY
Considering that practices regarding the processing of personal data may change from time to time, this Privacy Policy may also be updated accordingly, and with some regularity, so we recommend consulting it periodically.
If a significant change occurs to this Policy, this change will be communicated to you at the email address you have provided, with a record of the last change.
CONTACTS
If you have any questions about this Privacy Policy or would like to exercise your rights as a data subject as indicated in “RIGHTS OF THE DATA SUBJECT”, please contact us at the following email address: reservations@vandoma.co or through our address provided in “CONTROLLER OF YOUR PERSONAL DATA”.
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