PRIVACY POLICY AND PROCESSING OF PERSONAL DATA

I. QUALITY OF THE ENTITY IN TERMS OF THE GDPR:

A. COMMITMENT AS RESPONSIBLE FOR DATA TREATMENT

7Gaia Roaster Apartments, Lda., hence referred as 7Gaia, understands the value of every citizen’s privacy and we, therefore, seriously assume, as maximum priority, the protection and lawful treatment of the collected data and our demeanour strictly follows, at all times, the regulations of the legal norms and principles deriving from The General Data and Protection Regulation and from the Law n.º 58/2019, from 8th August that ensures their execution in the Portuguese judicial order.

It is our goal to transmit in a transparent, loyal and clear way, through the declaration of the privacy policy which duties and rules conduct our actions during the process of collecting and processing personal data, as well as, which the rights of the data subject are and how they can enforce them in a simple and prompt way.

We, therefore, adopt operational and technical methods in constant evolution and improvement which allow us to foster safety, accuracy and secrecy patterns, in order to decrease the risk during the process of collecting and processing personal data.

Hence, we respectfully request the best attention to the full reading of the current document.

Definitions:

In order to facilitate the understanding of the privacy policy and data treatment, 7Gaia Roaster Apartments, Lda. shares the following definitions:

Personal Data

any information, of any nature and irrespectively of the format, including sound and image, concerning an individual identified or identifiable (‘data subject’); an identifiable person is the one who can be directly or indirectly identified, namely by reference to an identification number or to one or more specific elements of its physical, physiological. psychic, economic, cultural or social nature;

Data Treatment

an operation or a set of procedures applied to personal data, whether those operations are automated or not, such as collecting, recording, organising, structuring, storing, modifying or altering, recovery, consulting, usage , publishing by transmitting, broadcasting or any form of transmitting, comparing or interconnection, limitation, erasure or destruction;

Subcontractor

the natural or legal person, the public authority, the service or any other organism that treats personal data when subcontracted by the data collector.

Consent of the data subject:

a free, specific, informed and explicit display of will, under which the data subject accepts, by means of a declaration or an unequivocal positive act, that the personal data which concern them can be the object of processing.

Responsible for the treatment:

the natural or legal person, the public authority, the agency or any other organism which, individually or along with others, determines the purposes and means of treatment of personal data, whenever the purposes and means of that treatment are determined by the law of the European Union or a Member State, the responsible for the data treatment or the specific criteria applicable to their nomination can be predicted by the law of the Union or of a Member State.

Who is responsible for my data treatment?

7Gaia Roaster Apartments, Lda., legal person with the identification nº 513836845 is responsible for collecting and processing your personal data. The data subjects and users can use the email dados@7groaster.pt to contact us, in case they want to express any doubt or complaint, or, in case they want to enforce their consecrated legal rights, by this means and at their disposal as the right to revoke consent and the right of access.

Alternatively, the data subjects may send a letter to the address: Rua de França n.º 52, 4400-174 em Vila Nova de Gaia.

The data subject may still get in touch with the responsible entity in case they wish to alter, rectify or erase collected data in situations where that is possible, in which case, 7Gaia has the possibility of asking for proof of identity to verify that the data sharing is made with the rightful data subject.

We also provide, for further questions, the following address www.cnpd.pt which corresponds to the website of the Comissão Nacional de Proteção de Dados, the responsible authority for monitoring and controlling the legal compliance of the General Data and Protection Regulation.

What data do we collect?

7Gaia Roaster Apartments, Lda. seeks to minimise collected data , treating just personal data that are considered absolutely necessary for the strict enforcement of contract and legal obligations they are bound to.

Data collecting will always be made on legal and transparent grounds, being, therefore, guaranteed by 7Gaia Roaster Apartments that the collected data are not used in an unlawful way for other purposes.Thus, when the user acquires a product or provides a service to 7Gaia Roaster Apartments Lda., the required information will only be the one which is proved essential to guarantee the right offer is carried out.

As a example, in case you make an order of a certain product through our website or book our local accommodation, it can be necessary to collect the following personal data:

A) Name;

B) Address;

C) Taxpayer N.º;

D) Date of birth;

E) Phone number or email;

F) Identification or passport;

G) IBAN or International bank account number;

H) Credit card number and expiration date;

I) Check-In and Check-Out dates.

7Gaia Roaster Apartments can also collect certain personal data, against explicit previous consent, aiming to improve the experience and comfort of their guests' stay, for instance, in data related to certain food preferences.

7Gaia Roaster Apartments, Lda., by the nature of the activity it develops doesn’t collect personal data lawfully defined as special or sensitive.

On what grounds and with what purpose do we collect data?

7Gaia Roaster Apartments, Lda., based on the lawfulness purpose, will only collect personal data in duly fundamented situations and with a specific purpose, as follows:

A) To guarantee the correct and prompt execution of pre-contractual diligences and of the several contracts celebrated with our clients, for instance, to allow the user registration in our online store or to allow the delivery of packages in places of a client’s preference, for issuing invoices or receipts or to permit the correct identification of a booking holder in the accommodation services provided by our establishment or even management of reservations.

B) To enforce any legal requirement or judicial order, namely to send an accommodation form to the Immigration and Borders Service (SEF), or to the enforcement of the duty of collecting and filing invoicing and accounting data for the Tax Authority, for the minimum established period.

C) Through explicit consent of the data holder for data treatment, in cases that are not predicted in the above situations, for promotional campaign purposes and advertising offers which can be sent to contacts previously provided by the client, but bearing in mind that the data holder can, at any time, fully revoke the given consent.

To whom are the data transmitted?

7Gaia Roaster Apartments guarantees that the personal data rightfully collected are only shared with third parties in strictly necessary cases, as legally imposed situations or with subcontractors that are contractually bound to the utmost respect of the legal norms and terms of the current privacy policy.

In addition to all the previous information, the responsible entity states that these personal data will not be in any situation subjected to any illicit circumstance or trading.

For how long are the data stored?

7Gaia Apartments, Lda. strictly abides by the principles listed in the General Data Protection Regulation and we have adopted regular revision measures to ensure that the collected data are safely stored for the strictly necessary period to enforce the purposes that motivated the data collecting and their treatment. Certain data will be stored for a minimum time period imposed by the applicable law, and once that time period ends, 7Gaia Apartments, Lda. will immediately delete the referred data.

Which rights are available to the data holder?

Right of access Data holders shall have the right to access the collected data, as well as obtain information about the data processing by 7Gaia mainly related to: the specific purposes of the processing, the storage period of the data or the applicable fixing criteria, the categories of personal processed data, listing and existing information concerning the rights of the data subject in the scope of personal data processing, the origin of the source of collected data, third parties to whom the data might be communicated, information in case data are eventually transmitted to anywhere outside the European Economic Area, information concerning the right to complain to the rightful control authority (CNPD).

The right to rectification In case the data holder identifies an eventual inaccuracy or if the collected data are outdated, they have the right to request their correction by the competent data controller, except in situations where such change cannot be enforced by legal reasons.

Right to erasure / or the right to be forgotten: The right to erasure or the right to be forgotten allows the data subject to request the immediate erasure of collected personal data, as stated in Art. 17 of the GDPR, when one of the following ground applies:

a) personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b) the data subject withdraws consent on which the processing is legally based according to article 6.o, n.o 1, point a), ou article 9.o, n.o 2, point a) and where there is no other legal ground for the processing.

c) the data subject opposes the processing according to article 21.o, n.o 1 and there are no overriding legitimate grounds for the processing or the data subject objects to the processing according to article 21.o, n.o 2;

d) The personal data have been unlawfully processed;

e) Personal data have to be erased for compliance with a legal obligation in the European Union or a Member State the data controller is subjected to;

Right to data portability:

The data subject has the right to receive from 7Gaia their personal data, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller, only if the given data treatment is consent or contract based and is processed by automatic means.

Right to object:

The data subject has the right to oppose, at any time, to processing of personal data concerning him or her for reasons concerning his or her particular situation, in any of these situations:

-the pursuit of legitimate interests of the controller or a third party;

-reusing data for a different purpose from the one which motivated the initial collection, including the definition of profiles.

Current Privacy Policy for this entity, updated on 30th november 2021.

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