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Privacy Policy:

The privacy and security of your personal data are of adamant importance to Hotel The Vine.

This policy is applicable to all systems, people and processes that constitute the information system of Hotel The Vine. The commitment with security of personal data was assumed by the Management of The Vine and extends to all employees of the organization. The Hotel The Vine, promotes the security of the information and protection in the treatment of the personal data kept by the institution and collected through Online Travel Agencies, Traditional Tour Operators and by our own website. SynXis is associated to Hotel The Vine, who is responsible for the booking engine of the site, which operates under the authority of Hotel The Vine.

In the treatment of personal data we respect your privacy, and we reiterate our commitment to the implementation of compliance measures, in particular to ensure:

a) a licit treatment, supported by a legal basis, legitimate interest or consent of the data holder;

b) that the treatment is limited to the purpose for which the data was made available;

c) that mechanisms exist to get accuracy and completeness of the data made available by you;

d) the minimization of the required data, requesting only those who are appropriate for the purpose;

e) the limitation in the data storage, according with the defined retention deadlines;

f) the implementation of measures for the integrity and confidentiality of the information.

Hotel The Vine is implementing this procedure for the company compliance with the principles described above and requirements of the new Regulation for Protection of Personal Data (RGPD), for the existing information systems and to proceed to an impact preview evaluation and implementation of measures to the privacy in new treatments of data to realize in the future.

To learn more about how we collect, use, share and protect the personal information collected, we appreciate that you verify the next sections of this Privacy Policy.

1. Hotel The Vine

Hotel The Vine is a hotel design modern 5-star located in Funchal, Madeira Island that is dedicated to guest accommodation and provision of Food and Beverage services and SPA, as well as organization of conferences, business and private events.

2. Personal Data category treated by The Vine

In order to perform the necessary assignments and to provide guests a personalized service during their stay, Hotel The Vine, as the entity responsible for the personal data treatment of their holders, collects the following data categories:

a) Identification information (e.g. name, passport number);

b) Demographic data (e.g. gender, date of birth, nationality and country of residence);

c) Contact data (e.g. cell phone, email);

d) Sensitive data (dietary restrictions, personal preferences, health history)

e) Financial data (e.g. credit card)

3. Treatment purposes of personal data, per legal obligation, contractual relationship or legitimate interest

In the pursuit of its attributions, by means of contractual relationship, legal obligation and/or legitimate interest, The Vine may treat your personal data for the purposes described below for each type of entity.

The personal data it will be preserved during the mandatory period by law depending on the purposes for which the personal data are destined by the constant retention period of the mandatory deadlines by legitimate interest, regulation or legal imperative, being applied information retention criteria appropriate to each treatment and in line with legal and regulations obligations to which The Vine is subject.

The treatment of personal data for minors under 13 years old of age will only be made with the explicit parents or responsible for parental ownership consent (whatever applicable to each particular case).

3.1. Guests

• Reservation Management (e.g. name, email, cell phone number and passport details);

• Billing instructions (e.g. name, NIF, address);

• Promotion of a pleasant stay and guest safety (e.g. dietary restrictions, special health requirements);

• Personalized intervention in SPA treatments (e.g. allergies, medical restrictions);

• Segmentation of promotional offers (e.g. by clients’ interests, contacts).

4. Treatment purposes of personal data by explicit consent of the data holder

With the explicit consent your personal data will be used for the following purposes:

• Sending newsletters containing promotional information, events and offers from The Vine, through the email address provided. You can at any moment oppose the receipt of the newsletter by unsubscribing at the bottom of the email(s) received in the area “unsubscribe”.

• Conservation of your personal preferences by Hotel The Vine (e.g. preferences, interests, restrictions or dietary preferences, special physical needs, SPA preferences) to promote a more pleasant stay and future interactions.

5. Treatment purposes of personal data and Cookies from the site www.hotelthevine.com

General Information

To access our website, various information is collected by the informatic systems automatically such as your IP address, version and the type of browser, the operating system, domains and the access hour. We use this data anonymized and only for statistical purposes in order to get improve the way we present the content to our users.

We may collect additional information such as email, cell phone number, address and name provided by you when using our site. You may use our site without providing personal data, using a pseudonym or anonymizing your data.

In our website you can subscribe our newsletter and select your areas of interest in order to receive relevant information from us. We will use this data to share with you, information that is only relevant and interesting for you.

Cookies

Our site uses cookies for statistical purposes. Cookies are small files stored in your computer that control the activity while using our site, providing essential data to make your navigation in the site simpler. When stored in your computer, cookies allow you to navigate with no need to introduce all the data each time you use the site. These data allow us personalize the site according to your preferences and provide you navigation according to your needs.

If you don’t want the cookies to stay stored on your computer, you can through the definitions of your browser oppose the cookies from our site. To know how to set up the definitions of your browser to manage your cookies, navigate on the browser Help that you are using. You can eliminate your cookies that are already on your device at any time, but be aware that disabling cookies may restrict certain functions that will prevent you from navigating according to your preferences.

Google Analytics

This website uses Google Analytics as an analysis service supported by Google that helps us customize the site to promote a better experience according to your preferences. This service uses cookies to understand your visit, for example the time you navigate on our site and the visited pages. But be aware that no personal data is collected on our Google Analytics account, which means that we can’t visualize who access to our site. You can obtain more information about Google Analytics at the official Google Analytics page.

Google AdWords Remarketing

We use Google AdWords Remarketing for advertising purposes on the internet.

The program AdWords Remarketing allows the view relevant ads based on the pages you've visited on The Vine's website. This cookie does not identify any personal information or allows access to your computer.

With the program Google AdWords Remarketing we can customize our marketing actions according to your needs and only present the ads that are relevant to you.

Facebook: Custom Audience Pixel

Is a part of the JavaScript installed in each page of our website that collects and transmits pre-defined data to Facebook's marketing program. We use this service to collect data about users behavior on our site. Some of the information collected by the pixel includes the browser that is sent to Facebook with the Facebook user ID and URL of the site that the user visited. Each Facebook user has a unique Facebook ID which is device independent, which helps to monitor site users when they access the site from multiple devices. We use this information for business purposes, specifically suitable ads on Facebook platforms.

Personal Data transference with other entities

While user of the site any kind of data that you share with us or that we collect while using our site, will stay only be in our possession, unless it is required by legal obligation the sharing of these data or when there exists a contractual relationship allowed by the user. Other partner entities as online payment services will only have access to your data when needed to process your order.

As a guest and so that The Vine can be able to comply its assignments and in order to provide you a quality service, The Vine may have to communicate or give access to your personal data to other entities. In these cases, The Vine will only transmit your personal data the following categories of recipients:

a) Entities and Authorities to whom personal data must be communicated by virtue of a legal obligation (SEF and police authorities)

b) Reverse Central (when Your reservation was made by this way)

c) Tributary Authority

The Vine it’s not responsible for the data which empowers to the other entities. We only act to ensure that any data shared with us from other entities is in compliance with legal requirements as described in our privacy policy.

6. Rights of Data Holders

The clients, in the quality of data holders, enjoy the following rights:

6.1. Right of access

Whenever you request it, you can obtain information about your personal data that are being used by The Vine. You can still access your personal data, as well as obtaining the following information:

• The purposes for which your personal data are processed;

• The type of personal data that are treated;

• The entities to whom your personal data may be communicated, including entities of the European Union or international organizations;

• The period of retention of your data or, if this is not possible, the criteria to set this deadline;

• The rights it enjoys in relation to the treatment of its personal data;

• If the personal data haven’t been collected from you, information on its origin and type of data in question.

6.2. Right of rectification

Whenever you consider that your personal data (provided by you) is incomplete, you can ask them to complete it, or may request the rectification if it is found to be incorrect (e.g. address, NIF, contacts, personal preferences).

6.3. Right to deletion

In certain circumstances the holder data may request deletion of your personal data. The Hotel The Vine will inform the possibility or not to satisfy this right in respect of existing retention obligations by means of legal imposition or legitimate interest.

6.4. Right to limit treatment

The right to limit treatment of your personal data allows you to request the person who is responsible for their treatment that restrict the ambit of access and the treatment of your personal data or to suspend treatment activities. Can request the limitation of the processing of your personal data in the following cases:

• if you contest the accuracy of your personal data, during a period of time that allows The Vine to verify its accuracy;

• if the Hotel The Vine no longer need personal data for treatment purposes, but if such data are necessary for the purposes of declarations, exercise or defense of a right in a legal proceeding.

6.5. Right to portability

You can ask The Vine to deliver, in a structured format, current use and autonomous reading, of the personal data provided by you. You still have the right to ask The Vine to transmit this data on to another responsible for processing, as long as this is technically possible.

The right to portability only applies in the following cases:

• when the treatment is based on explicit consent or execution of a contract;

• when the treatment in question is performed by automated means.

6.6. Right of opposition

Has the right to object to the treatment of your personal data at any moment, for reasons relating to their particular situation, and when the treatment is performed for other purposes than those who which the data have been collected, but that are compatible with them.

The Vine will, in such cases, cease to treat your personal data, unless you have legitimate reasons to perform this treatment and these will prevail over yours interests.

The exercise of their right of opposition may result in the suspension or cessation, total or partial, of the benefits associated with the purpose of the processing of the data in cause.

May also opposed to the treatment of your data for direct marketing purposes.

6.7. Right to withdraw their consent

In cases where the treatment of the data is done on the basis of your consent, you have the right to withdraw your consent at any time.

If you withdraw your consent, your personal data will no longer be processed, unless otherwise provided, such as legal and regulatory obligations or the public interest of The Vine, which justifies such treatment.

Revocation of Your consent may imply, among others, the impossibility to receive exclusive offers from The Vine and future recognition in case you return to the Hotel.

6.8. Right to file complaints with The Vine Hotel or the control authority

The exercise of their rights is free of charge, unless the application is manifestly unfounded or excessive, may, in such cases, be charged a reasonable fee considering the associated costs.

The reply to your requests must be provided within a maximum of 30 days, unless it is a particularly complex request, in which case this deadline may be longer.

The Vine has appointed a personal Data Protection Officer, pursuant to Articles 37, 38 and 39 of the General Regulations for Data Protection. You can contact The Vine's DPO and exercise your rights through the following channel:

- Email: to the address dataprotection@hotelthevine.com;

If you want to file a complaint regarding matters relating to the treatment of your personal data you may do so with the National Data Protection Commission, competent control authority in Portugal (www.cnpd.pt).

7. Changes to this policy

Hotel The Vine may change this Privacy Police at any time to reflect the current privacy practices. When we make changes on this declaration, we review the “update date” in the footer of the document. We advise the periodically reading of this Privacy Police so that you are aware of how The Vine protects your information.

Last Update: 07-august-2018