{"id":8562,"date":"2018-05-24T15:21:57","date_gmt":"2018-05-24T15:21:57","guid":{"rendered":"https:\/\/www.trypportoexpo.com\/privacy-policy\/"},"modified":"2023-09-19T16:19:43","modified_gmt":"2023-09-19T15:19:43","slug":"politique-de-confidentialite","status":"publish","type":"page","link":"https:\/\/tryp.stg3.shareit.pt\/fr\/politique-de-confidentialite\/","title":{"rendered":"Politique de confidentialit\u00e9"},"content":{"rendered":"<div id=\"pl-8562\"  class=\"panel-layout\" ><div id=\"pg-8562-0\"  class=\"panel-grid panel-no-style\" ><div id=\"pgc-8562-0-0\"  class=\"panel-grid-cell\" ><div id=\"panel-8562-0-0-0\" class=\"so-panel widget widget_sow-editor panel-first-child panel-last-child\" data-index=\"0\" ><div\n\t\t\t\n\t\t\tclass=\"so-widget-sow-editor so-widget-sow-editor-base\"\n\t\t\t\n\t\t>\n<div class=\"siteorigin-widget-tinymce textwidget\">\n\t<h2><span style=\"font-size: 12pt;\">HOTI HOT\u00c9IS PRIVACY POLICY<\/span><\/h2>\n<p><strong>1. INTRODUCTION<\/strong><\/p>\n<p>THE HOTI HOT\u00c9IS GROUP had adopted the best privacy practices and shall only use the Personal Data of its customers (physical and online, whether actual or potential customers) for clearly identified purposes and if permission is obtained to do so through an act that clearly expresses free, specific, informed and unequivocal permission to process the Personal Data in question.<\/p>\n<p>the entities that are part of the HOTI HOT\u00c9IS GROUP, are hereby represented by the HOTI \u2013 HOT\u00c9IS, SGPS, S.A. holding, with head office at Avenida D. Jo\u00e3o II, lote 1.16.02.B, 1990-083 Lisbon, and registered at Lisbon Commercial Registry Office under the single registration and tax identification No. 504.762.982, and operate in the hotel industry as hotel proprietors, operators or managers, using their own brands or others for the purpose.<\/p>\n<p>Currently, the HOTI HOT\u00c9IS Group operates and manages the following hotels:<\/p>\n<ul>\n<li>MELI\u00c1 MADEIRA MARE *****<\/li>\n<li>MELI\u00c1 BRAGA *****<\/li>\n<li>MELI\u00c1 RIA ****<\/li>\n<li>MELI\u00c1 SET\u00daBAL ****<\/li>\n<li>MELI\u00c1 CASTELO BRANCO ****<\/li>\n<li>MELI\u00c1 LISBOA ORIENTE ****<\/li>\n<li>MELI\u00c1 MAPUTO SKY ****<\/li>\n<li>MELI\u00c1 LISBOA AEROPORTO ****<\/li>\n<li>TRYP LISBOA CAPARICA MAR ****<\/li>\n<li>TRYP PORTO EXPO ****<\/li>\n<li>TRYP PORTO CENTRO ***<\/li>\n<li>TRYP LEIRIA ****<\/li>\n<li>TRYP MONTIJO PARQUE ****<\/li>\n<li>MOXY LISBOA ORIENTE ***<\/li>\n<li>STAR INN LISBON ***<\/li>\n<li>STAR INN PORTO ***<\/li>\n<li>STAR INN PENICHE ***<\/li>\n<li>HOTEL DA M\u00daSICA ****<\/li>\n<li>MADEIRA GOLDEN RESIDENCE ****<\/li>\n<\/ul>\n<p>This Privacy Policy defines how the Hoti Hot\u00e9is Group uses its customers\u2019 Personal Data.<\/p>\n<p><strong>2. PERSONAL DATA<\/strong><\/p>\n<p>Personal Data is all information, of any nature and regardless of its form, about an individual who is directly or indirectly identified or identifiable (owner of the Personal Data).<\/p>\n<p><strong>3. DATA COLLECTION<\/strong><\/p>\n<p>in undertaking its business, the hoti hot\u00e9is group requests its customers, whether actual or potential customers, for the following personal data by telephone, e-mail or through its websites:<\/p>\n<p>\u2022 Name<br \/>\n\u2022 Number, Issuer and Expiry Date of the Civil Identification Document<br \/>\n\u2022 Gender<br \/>\n\u2022 Date of Birth<br \/>\n\u2022 Telephone<br \/>\n\u2022 Mobile phone<br \/>\n\u2022 Address<br \/>\n\u2022 E-mail<br \/>\n\u2022 Tax Identification Number (for invoicing)<br \/>\n\u2022 Credit Card Details (for charging)<\/p>\n<p>The aforementioned Personal Data may be obtained through partners, associated companies or official entities, and to obtain them the respective owners must give permission for the transfer of such data.<\/p>\n<p><strong>4. DATA PROCESSING<\/strong><\/p>\n<p>The Personal Data collected by the HOTI HOT\u00c9IS GROUP is processed in compliance with the applicable laws in an honest and transparent manner to guarantee the privacy of the data for the respective owners.<\/p>\n<p>The data shall be processed for clearly identified, objective and legitimate purposes for which the owners of the Personal Data have given their permission through an act that clearly expresses their free, specific, informed and unequivocal permission to process their Personal Data. These data shall not be processed at a later date for any other purposes.<\/p>\n<p>The owners of the Personal Data may withdraw their permission, although this does not compromise the legality of the processing based on the permission initially given.<\/p>\n<p>The Personal Data may be processed without the need for permission from the respective owners if if the HOTI HOT\u00c9IS GROUP has to comply with legal obligations to fulfil a contract when the owners are one of the parties, for pre-contractual procedures requested by the owners or to defend other essential rights of the owners or third parties.<\/p>\n<p>The processing of Personal Data includes its:<\/p>\n<p>\u2022 Collection<br \/>\n\u2022 Organisation<br \/>\n\u2022 Storage<br \/>\n\u2022 Consultation<br \/>\n\u2022 Utilisation<br \/>\n\u2022 Adaptation<br \/>\n\u2022 Alteration<br \/>\n\u2022 Registration<br \/>\n\u2022 Recovery<br \/>\n\u2022 Provision<\/p>\n<p><strong>5. PURPOSE OF THE DATA PROCESSING<\/strong><\/p>\n<p>The Personal Data requested from customers shall be processed for the purpose of:<\/p>\n<p>\u2022 Complying with the hoti hot\u00e9is group\u2019s legal obligations as a business supplying hotel services, including the supply of information to the relevant authorities(Foreigners and Borders Service, Tax Authority and National Statistics Institute, among others);<br \/>\n\u2022 Fulfilling pre-contractual procedures requested by the customers;<br \/>\n\u2022 Establishing contractual relationships;<br \/>\n\u2022 Providing a range of hotel services such as accommodation, restaurant, laundry, car parking, health club, SPA treatment and tourist services, among others that are commonly provided by hotels;<br \/>\n\u2022 Guiding the services on offer to match the customer preferences;<br \/>\n\u2022 Invoicing and charging the customers for the services provided;<br \/>\n\u2022 Contacting customers by telephone, post, e-mail or another means of communication;<br \/>\n\u2022 Informing the customers about new products and services, offers, campaigns, promotions, updated information or other content, including newsletters and opinion surveys, as well as general marketing initiatives of the HOTI HOT\u00c9IS GROUP and its hotels;<br \/>\n\u2022 Improving the navigation experience of the websites of the HOTI HOT\u00c9IS GROUP;<br \/>\n\u2022 Registering the user on websites of the HOTI HOT\u00c9IS GROUP'S domain;<br \/>\n\u2022 Allowing access to the restricted areas of the websites of the HOTI HOT\u00c9IS GROUP;<br \/>\n\u2022 Managing customer membership or loyalty clubs or cards;<br \/>\n\u2022 Recording telephone calls for any of the purposes listed above.<\/p>\n<p>In websites with its own domain, the HOTI HOT\u00c9IS GROUP also collects information about the users\u2019 hardware device and their browser\/software, and information about the pages of the websites visited.<\/p>\n<p>The users of these websites will be asked for permission to create and save a text file (Cookie) in their respective computers to allow easier and faster access to the websites, as well as the customisation in accordance with the user preferences.<\/p>\n<p>Most browsers accept Cookies, but the users may delete them or define their settings to block them. Check the \u201cHelp\u201d menu of your respective browser to define these settings.<\/p>\n<p>If the users do not allow Cookies to be used, some of the functionalities of the websites may not be available.<\/p>\n<p><strong>6. DATA STORAGE TERM<\/strong><\/p>\n<p>The time period during which the Personal Data is stored varies depending on the purpose for which the information is processed, with legal requirements making it mandatory to store the data for a minimum time period.<\/p>\n<p>Whenever there is no specific legal obligation, the Personal Data shall be stored only for the minimum period necessary for the purposes for which they were collected or are being processed, and shall then be deleted.<\/p>\n<p><strong>7. DATA TRANSFER<\/strong><\/p>\n<p>The Personal Data collected by the Hoti Hot\u00e9is Group are not shared with third parties without the permission of the respective owners, unless:<\/p>\n<p>\u2022 Such is necessary to comply with a legal obligation the HOTI HOT\u00c9IS Group is subject to;<br \/>\n\u2022 It becomes necessary to defend other essential interests of the owners of the Personal Data or third parties;<br \/>\n\u2022 the owners acquire services through HOTI HOT\u00c9IS provided by other entities responsible for processing the Personal Data, whereby these entities may consult or access such data insofar as necessary for the provision of the aforementioned services;<br \/>\n\u2022 With the due applicable legal limits, the communication or transmission of Personal Data is necessary for the fulfilment of the contract established between the respective owners and the Hoti Hot\u00e9is Group or for pre-contractual procedures requested by the owners.<\/p>\n<p>If Personal Data is transmitted to third parties, every reasonable effort will be made to ensure they are transmitted using appropriate means in compliance with this Privacy Policy.<br \/>\nThe personal data collected and used by the HOTI HOT\u00c9IS GROUP are not supplied to third parties outside the European Union. However, if in the future such a transfer occurs for any reason, the HOTI HOT\u00c9IS GROUP undertakes to ensure it complies with the applicable legal stipulations, namely as regards ascertaining that the country in question provides suitable protection of Personal Data and has requirements in place concerning such transfers, in addition to making sure the entity or subcontractor responsible for the data processing complies with the General Data Protection Regulation.<\/p>\n<p><strong>8. SUBCONTRACTED ENTITIES<\/strong><\/p>\n<p>The HOTI HOT\u00c9IS GROUP may hire subcontractors to process the personal data on behalf of the HOTI HOT\u00c9IS Group. In this case, in accordance with the instructions given, the subcontractors shall process the Personal Data in compliance with the laws in force and this Privacy Policy.<\/p>\n<p>These subcontractors may not transmit the Personal Data to other entities without the HOTI HOT\u00c9IS GROUP first giving its written permission to do so, and they are also forbidden from outsourcing this task to other entities without prior permission from the HOTI HOT\u00c9IS GROUP.<\/p>\n<p>THE HOTI HOT\u00c9IS Group undertakes to subcontract only the entities who provide maximum security in terms of their technical and organisational resources, to guarantee the rights of the owners of the Personal Data are safeguarded.<\/p>\n<p>All the entities subcontracted by the HOTI HOT\u00c9IS Group are legally bound to the Group through a written contract that regulates the object, duration, nature and purpose of the processing, the kind of Personal Data in question, the categories of the owners of the data and the rights and obligations of the parties.<\/p>\n<p>After collecting the Personal Data, the Hoti Hot\u00e9is Group will provide the owners of the Personal Data with information about the categories of entities subcontracted which, in this specific case, may affect the processing of data in the name of the HOTI HOT\u00c9IS GROUP.<\/p>\n<p>In the case of individuals or companies, public authorities, agencies or other entities that process Personal Data on behalf of THE HOTI HOT\u00c9IS GROUP, the entities subcontracted have been assessed and the respective contracts reviewed, and the prior assessment of new subcontractors will be carried out, whereby a regime of joint liability specifically stipulated in the contract shall be implemented.<\/p>\n<p><strong>9. RIGHTS OF THE DATA OWNERS<br \/>\n<\/strong><br \/>\nThe owners of the Personal Data have the following rights:<\/p>\n<p>\u2022 Right to information<br \/>\nThe owners of the Personal Data are entitled to be informed about:<br \/>\n\u2022 The identity and contacts of the hoti hot\u00e9is group, the entity\/person responsible for processing the personal data, and if applicable, its representative;;<br \/>\n\u2022 The contacts of the Data Protection Officer or confirmation that the company does not employ a DPO,<br \/>\n\u2022 The purposes of processing the Personal Data, and if applicable the legal reasons for this processing;<br \/>\n\u2022 If the processing of the Personal Data is based on the legitimate interests of the HOTI HOT\u00c9IS GROUP or a third party, what these interests are;<br \/>\n\u2022 If applicable, the receivers or categories of receivers of the Personal Data;<br \/>\n\u2022 If applicable, an indication that the Personal Data will be transferred to a third country or an international organisation and whether or not the European Commission has issued an opinion about its suitability, or reference to guarantees of appropriate or suitable transfer methods;<br \/>\n\u2022 The Personal Data storage term;<br \/>\n\u2022 The right to request the hoti hot\u00e9is group for permission to the personal data, as well as their rectification, deletion or limitation, the right to oppose their processing and the right to access to the data;<br \/>\n\u2022 If the processing of the Personal Data is based on permission granted by the owner, the right to withdraw this permission at any time, without compromising the legality of the processing based on the permission given beforehand;<br \/>\n\u2022 The right to make a complaint to the National Data Protection Commission or regulatory authority;<br \/>\n\u2022 Indication of whether the communication of Personal Data comprises a legal or contractual obligation or not, or is a requirement needed to sign a contract, as well as whether the owner is obliged to supply the Personal Data and any consequences of not supplying these data;<br \/>\n\u2022 If applicable, the existence of automatic decisions, including the definition of profiles, and basic concept information, as well as the importance and consequences of such processing for the owner of the Personal Data;<br \/>\n\u2022 If the Personal Data are not being collected directly by the HOTI HOT\u00c9IS GROUP from the respective owner, as well as the information mentioned above, the owner must be informed about the categories of Personal Data that will be processed, and about the origin of the data, and possibly if the sources are accessible to the public;<br \/>\n\u2022 if the hoti hot\u00e9is group intends to process the personal data subsequently for a purpose different to the purpose for which the data were collected, before doing so the HOTI HOT\u00c9IS GROUP shall inform the owner about this purpose and any other information of interest, under the terms outlined above.<\/p>\n<p><strong>\u2022 Right of Access<\/strong><\/p>\n<p>THE HOTI HOT\u00c9IS GROUP guarantees it has the resources to allow the owner of the Personal Data to check the data.<\/p>\n<p>The owners are entitled to obtain confirmation from the HOTI HOT\u00c9IS GROUP about whether their Personal Data is being processed, and if so the owners have the right to access their Personal Data and to have the following information:<\/p>\n<p>\u2022 The purposes of processing the data;<br \/>\n\u2022 The categories of the Personal Data in question;<br \/>\n\u2022 The receivers or categories of receivers the Personal Data have been or will be disclosed to, especially the receivers based in third countries or belonging to international organisations;<br \/>\n\u2022 The Personal Data storage term;<br \/>\n\u2022 If the data have not be collected from the owner, the information available about the origin of these data;<br \/>\n\u2022 The existence of automatic decisions, including the definition of profiles, information relative to the underlying logic, as well as the importance and consequences of such processing for the data owner;<br \/>\n\u2022 Suitable guarantees regarding the transfer of data to third countries or international organisations;<\/p>\n<p>Upon request, the HOTI HOT\u00c9IS GROUP will supply the owners with a copy of their Personal Data that is being processed free of charge.<\/p>\n<p>The supply of extra copies requested by the owner may require the payment of administrative costs.<\/p>\n<p><strong>\u2022 Right to Rectification<\/strong><\/p>\n<p>The owners are entitled to request rectification of their Personal Data at any time, as well as completion of their incomplete Personal Data, including through an additional declaration.<\/p>\n<p>In the case of rectification of the data, the HOTI HOT\u00c9IS GROUP will communicate the rectified data to each receiver of the data, unless such communication is deemed impossible or implies an unreasonable effort for the HOTI HOT\u00c9IS GROUP.<\/p>\n<p><strong>\u2022 Right to Deletion<\/strong><\/p>\n<p>The owners are entitled to request the HOTI HOT\u00c9IS GROUP to delete their Personal Data in any of the following cases:<\/p>\n<p>\u2022 The Personal Data are no longer needed for the purpose that led to their collection or processing;<br \/>\n\u2022 The owner withdraws permission to process the Personal Data and there are no other legal grounds to justify the data processing;<br \/>\n\u2022 The owners exercise their right to oppose the processing of the data and there are no prevailing legitimate interests that justify the processing;<br \/>\n\u2022 If the Personal Data are processed illegally;<br \/>\n\u2022 If the Personal Data have to be deleted to comply with a legal obligation the HOTI HOT\u00c9IS GROUP is subject to;<\/p>\n<p>Under the applicable legal terms, the HOTI HOT\u00c9IS GROUP has no obligation to eliminate the personal data if this processing is necessary to comply with a legal obligation that the HOTI HOT\u00c9IS GROUP is subject to or for the purposes of declaring, exercising or defending a right of the HOTI HOT\u00c9IS GROUP in a judicial action.<\/p>\n<p>In the case of deletion of the data, the HOTI HOT\u00c9IS GROUP will communicate that the data has been eliminated to each receiver of the data, unless such communication is deemed impossible or implies an unreasonable effort for the HOTI HOT\u00c9IS GROUP.<\/p>\n<p>when the hoti hot\u00e9is group has made the personal data public and is required to delete them in fulfilment of the owner\u2019s right to delete the data, the hoti hot\u00e9is group undertakes to ensure reasonable measures are implemented, including of a technical nature, taking into consideration the technology available and the cost of its application, to inform the entities responsible for processing the Personal Data that the owner requested the elimination of the links to these Personal Data, as well as any copies or reproductions.<\/p>\n<p><strong>\u2022 Right to Limitation<\/strong><\/p>\n<p>Limitation comprises inserting a mark in the Personal Data stored to limit its processing in the future.<\/p>\n<p>The owners are entitled to request the HOTI HOT\u00c9IS GROUP to limit the processing of their Personal Data in any of the following instances:<\/p>\n<p>\u2022 If the owners dispute the preciseness of the Personal Data for a period that allows the Hoti Hot\u00e9is Group to check its preciseness;<br \/>\n\u2022 If the processing is illicit and the owner opposes the elimination of the data, requesting instead limitation to its use;<br \/>\n\u2022 If the HOTI HOT\u00c9IS GROUP no longer need to process the Personal Data, but these data are required by the owner for the purpose of declaring, exercising or defending a right in a judicial action;<br \/>\n\u2022 If the owner has opposed the processing, until the legitimate reasons of the Hoti Hot\u00e9is Group prevail over the owner's reasons;<br \/>\n\u2022 When the owner\u2019s Personal Data is limited, the data may only, apart from the storage, be processed after permission is granted by the owner or for the purposes of declaring, exercising or defending a right in a judicial action, defending the rights of another individual or company, or for legally stipulated reasons of public interest.<\/p>\n<p>Owners who have stipulated limitation in the processing of their Personal Data in the aforementioned cases will be informed by the HOTI HOT\u00c9IS GROUP before the limitation is lifted.<\/p>\n<p>In the case of limitation of the Personal Data, the HOTI HOT\u00c9IS GROUP will communicate the respective limitation to each receiver of the data, unless such communication is deemed impossible or implies an unreasonable effort for the HOTI HOT\u00c9IS GROUP.<\/p>\n<p><strong>\u2022 Right to Opposition<\/strong><\/p>\n<p>Owners of the Personal Data have the right to oppose the processing of their Personal Data by the HOTI HOT\u00c9IS GROUP based on the legitimate interests of the Group, or when the data is processed for purposes other than those for which the Personal Data was collected, including the definition of profiles, or when the Personal Data is processed for statistical purposes.<\/p>\n<p>In this case, the HOTI HOT\u00c9IS GROUP will stop processing the Personal Data, unless it presents urgent and legitimate reasons for why this data processing prevails over the interests, rights and liberties of the owner, or for the purposes of declaring, exercising or defending a right of the HOTI HOT\u00c9IS GROUP in a judicial action.<\/p>\n<p>When the Personal Data is processed for the purposes of direct marketing (Marketing or Telemarketing), the owners are entitled to oppose the processing of their data at any time, which includes the definition of profiles related to direct marketing.<\/p>\n<p>If the owners oppose the processing of their Personal Data for direct marketing, the HOTI HOT\u00c9IS GROUP will stop processing the data for this purpose.<\/p>\n<p>The owners also have the right not to be subject to any decision taken exclusively based on automatic processing, including the definition of profiles, which has legal effects or which significantly affects the owners in a similar way, unless such decision:<\/p>\n<p>\u2022 Is necessary to sign or fulfil a contract between the owner and the HOTI HOT\u00c9IS GROUP;<br \/>\n\u2022 Is authorised by the law that the Hoti Hot\u00e9is Group is subject to;<br \/>\n\u2022 Is based on the explicit permission of the owner.<\/p>\n<p><strong>\u2022 Right to Portability<\/strong><\/p>\n<p>The owners have the right to receive the Personal Data which they have supplied to the HOTI HOT\u00c9IS GROUP in a structured, currently used and automatically readable format, as well as the right to transmit these data to another entity responsible for processing the data if this processing is based on the permission granted or on a contract that the owner has signed or if the processing is automatic.<\/p>\n<p>The right to portability does not include inferred data or derived data, i.e. Personal Data generated by the HOTI HOT\u00c9IS GROUP as a consequence of or resulting from analysis of the data that is being processed.<\/p>\n<p>The owners have the right for their Personal Data to be directly transmitted between entities responsible for the processing, whenever it is technically possible to do so.<\/p>\n<p><strong>\u2022 Right to Make a Complaint<\/strong><\/p>\n<p>The owners of the Personal Data have the right to make a complaint to the Regulatory Authority (National Data Protection Commission), through the site www.cnpd.pt.<\/p>\n<p>The right to access, right to rectification, right to deletion, right to limitation, right to portability and right to opposition may be exercised by the owner by contacting the Data Protection Officer of the HOTI HOT\u00c9IS GROUP using the following e-mail dadospessoais@hotihoteis.com.<\/p>\n<p>THE HOTI HOT\u00c9IS GROUP will respond in writing (including through electronic means) upon request from the owner within a maximum deadline of one month counting from when the request is received, apart from especially complex cases, in which this deadline may be extended to two months.<\/p>\n<p>If the requests made by the owners are manifestly unjustified or excessive, especially owing to their repetitive nature, the Hoti Hot\u00e9is Group reserves the right to charge administrative costs or to refuse the request.<\/p>\n<p><strong>10. TECHNICAL AND ORGANISATIONAL SECURITY MEASURES IMPLEMENTED<\/strong><\/p>\n<p>To guarantee the security of the Personal Data and its maximum confidentiality, the HOTI HOT\u00c9IS GROUP processes the information in a strictly confidential manner, in line with its internal security and confidentiality policies and procedures, which are updated regularly whenever needed, and in compliance with the legal terms and conditions.<\/p>\n<p>In line with the nature, scope, context and purposes of the processing of the Personal Data, as well as the risks deriving from processing them in terms of the owners\u2019 rights and liberties, THE HOTI HOT\u00c9IS GROUP undertakes to apply the necessary and appropriate technical and organisational measures to protect the Personal Data and comply with the legal regulations when defining the processing methods and when actually processing the data.<\/p>\n<p>It also undertakes to ensure, through default, that only the data needed for each specific purpose is processed and that these data are not available without human intervention to unauthorised people.<\/p>\n<p>Communication between the owners of the Personal Data and the websites of the HOTI HOT\u00c9IS GROUP takes place through secure and communication channels that use the HTTPS protocol and SSL security standard.<\/p>\n<p>With a view to guaranteeing the privacy and security of its customers and staff\u2019s Personal Data, the HOTI HOT\u00c9IS GROUP has implemented the following technical and organisational security measures:<\/p>\n<p>\u2022 The Personal Data collected are appropriate, justified and limited to what is strictly necessary for the purposes for which they are processed;<br \/>\n\u2022 The Personal Data are exact and updated whenever necessary, implementing all the measures necessary to ensure the data are exact, taking into account the purposes for which they are processed, and are deleted and rectified immediately;<br \/>\n\u2022 The Personal Data are stored in a way that allows the identification of the owners only for the period needed for the purposes for which the data are processed;<br \/>\n\u2022 The Personal Data are processed using methods that guarantee their security, including protection against their unauthorised or illegal processing and against their unexpected loss, destruction or damage;<br \/>\n\u2022 Carry out the risk assessment by mapping the data flows and carrying out impact assessments;<br \/>\n\u2022 Adoption of internal rules that ensue the rapid and effective exercising of the rights of the Personal Data owners and the implementation of procedures for this purposes that are free of charge for the owners;<br \/>\n\u2022 Use of pseudonymisation of the Personal Data, i.e. the Personal Data is processed using methods that do not allow them to be attributed to a specific owner without supplementary information, whereby this supplementary information is stored separately and subject to technical and organisational measures to make sure that the Personal Data cannot be attributed to an identified or identifiable individual;<br \/>\n\u2022 Encrypt the Personal Data;<br \/>\n\u2022 Guarantee permanent confidentiality, integrity, availability and resilience of the processing systems and services;<br \/>\n\u2022 Guarantee the capacity to promptly re-establish the availability and access to the Personal Data in the event of a physical or technical incident;<br \/>\n\u2022 Implement a process that enables the regular testing and assessment of the measures adopted to guarantee the security of the processing;<br \/>\n\u2022 Protect the data from the moment of their conception, i.e. take the risk of privacy into account throughout the process to create a new product or service, instead of considering questions of privacy afterwards;<br \/>\n\u2022 Carefully assess and implement appropriate technical and organisational measures and procedures from the start to guarantee the processing is in compliance with the legislation in force and protect the rights of the data owners;<br \/>\n\u2022 Protect the data by default, i.e. make sure that mechanisms are in place to guarantee that, through default, only the quantity necessary of Personal Data for each task shall be collected, used and stored. This obligation applies to all the processing, length of storage and accessibility of the data.<\/p>\n<p><strong>11. BREACH OF PERSONAL DATA<\/strong><\/p>\n<p>In the event of a breach of the data that leads to a high risk for the rights and liberties of the owner, THE HOTI HOT\u00c9IS GROUP undertakes to communicate this breach of Personal Data to the owner in question within seventy-two hours of detecting the incident.<\/p>\n<p>THE HOTI HOT\u00c9IS GROUP undertakes to notify the Regulatory Authority as soon as possible, with no unjustified delay, within seventy-two hours of learning about the breach of data.<\/p>\n<p>The HOTI HOT\u00c9IS GROUP has created internal mechanisms to detect and communicate any security breaches that allow swift action to be taken, namely as regards discovering the kind of breach of data, which data were lost, destroyed, disclosed, changed or accessed improperly, and notification to the Regulatory Authority and how to communicate the incident to the owners of the data.<\/p>\n<p>Under the legal terms, communication to the owner is not required in the following cases:<\/p>\n<p>\u2022 If the HOTI HOT\u00c9IS GROUP has applied appropriate measures of protection, both in technical and organisational terms, and if 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 person not authorised to access these data, such as encryption;<br \/>\n\u2022 If the HOTI HOT\u00c9IS GROUP has taken subsequent measures that ensure the high risk of breach of the rights and liberties of the owner does not come to pass;<br \/>\n\u2022 If communication to the owner implies an unreasonable effort by the HOTI HOT\u00c9IS GROUP, in which case the HOTI HOT\u00c9IS GROUP will make a public announcement or take similar measures through which the owner shall be informed.<\/p>\n<p><strong>12. DATA PROTECTION OFFICER (DPO)<\/strong><\/p>\n<p>No DPO was appointed given that the Hoti Hot\u00e9is Group is not a public authority or entity, and does not regularly and systematically monitor the owners of the Personal Data on a large scale and does not process sensitive Personal Data on a large scale.<\/p>\n<p>The entity responsible for processing the Personal Data in the HOTI HOT\u00c9IS GROUP is HOTI \u2013 HOT\u00c9IS, SGPS, S.A., which is better identified in point 1 of this Privacy Policy.<\/p>\n<p><strong>13. CHANGES TO THE PRIVACY POLICY<\/strong><\/p>\n<p>The HOTI HOT\u00c9IS GROUP reserves the right to change this privacy policy at any time.<\/p>\n<p>If the changes are substantial, a notice will be issued in the websites of the HOTI HOT\u00c9IS GROUP.<\/p>\n<p><strong>14. APPLICABLE LAW AND COURT<\/strong><\/p>\n<p>The Privacy Policy and the collection, processing or transmission of Personal Data is regulated by the Regulation (EU) 2016\/679, of the European Parliament and Council, of 27 April 2016, and by the laws and regulations applicable in Portugal.<\/p>\n<p>Any litigation deriving from the validity, interpretation or implementation of this Privacy Policy or which is related to the collection, processing or transmission of Personal Data must be submitted exclusively to the jurisdiction and judicial courts of the district of Lisbon, notwithstanding the overriding applicable legal regulations.<\/p>\n<\/div>\n<\/div><\/div><\/div><\/div><\/div>","protected":false},"excerpt":{"rendered":"<p>HOTI HOT\u00c9IS PRIVACY POLICY 1. INTRODUCTION THE HOTI HOT\u00c9IS GROUP had adopted the best privacy practices and shall only use [&hellip;]<\/p>\n","protected":false},"author":3,"featured_media":0,"parent":0,"menu_order":34,"comment_status":"closed","ping_status":"closed","template":"","meta":{"inline_featured_image":false},"acf":[],"publishpress_future_action":{"enabled":false,"date":"2026-04-15 09:01:09","action":"draft","terms":[],"taxonomy":"translation_priority"},"_links":{"self":[{"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/pages\/8562"}],"collection":[{"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/comments?post=8562"}],"version-history":[{"count":3,"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/pages\/8562\/revisions"}],"predecessor-version":[{"id":30968,"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/pages\/8562\/revisions\/30968"}],"wp:attachment":[{"href":"https:\/\/tryp.stg3.shareit.pt\/fr\/wp-json\/wp\/v2\/media?parent=8562"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}