Olivia Singular Houses

Privacy Policy

A. General Part

1.1 User Data Collection and Processing

This Privacy Policy aims to provide Users of the websites hosted at olivia-houses.com hereinafter and in abbreviated form (“Website”) with detailed information on how Olivia Singular Houses as the data controller will process your personal data. All personal information relating to guests or visitors using Olivia Singular Houses will be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 26 April 2016, commonly known as the General Data Protection Regulation (GDPR).

The use of Olivia Singular Houses implies acceptance of this Privacy Policy. The Olivia Singular Houses team reserves the right to change this policy without notice. Therefore, we recommend that you check our privacy policy regularly to ensure that it is always up to date.

In general, personal data is requested when the User registers on the website, requests contact, subscribes to a certain service, provides or requests information, purchases a product or establishes a contractual relationship with Olivia Singular Houses by booking a stay in one of our guesthouses.

The Personal Data collected and processed consists mainly of information relating to name, gender, date of birth, telephone, mobile phone, e-mail, address, tax identification number, credit card details (collected for payment purposes only), although it may include other personal data that may be necessary or convenient for the provision of services or for payment purposes by Olivia Singular Houses.

Olivia Singular Houses also collects and processes information about your hardware device features, IP address and browser/software settings as well as information about the web pages the User visits on the Website. This information may include your browser type, domain name, access times and links through which the User accessed the Website (“Usability Information”). We use this information only to improve the quality of your visit to our Website and, where you have consented, to send you marketing and sales information tailored to your profile.

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

Regarding this Privacy Policy, a contractual relationship is any contract between Olivia Singular Houses and its related entities, regardless of the respective purpose.

1.2 Data Recipients

User Data collected by Olivia Singular Houses is not shared with third parties without the User’s consent, except in situations referred to in the following paragraph. However, in the event that the User contracts with Olivia Singular Houses for services that are provided by other entities responsible for personal data processing, the User Data may be shared with and/or accessed by such entities, to the extent necessary for the provision of such services.

Subject to applicable law, Olivia Singular Houses may transmit or disclose User Data to other entities where such transmission or disclosure is necessary for the performance of the contract established between the User and Olivia Singular Houses. This includes pre-contractual procedures at the request of the User, if necessary for the fulfilment of a legal obligation to which Olivia Singular Houses is subject, or if required for the fulfilment of the legitimate interests of Olivia Singular Houses or a third party. Where User Data is shared with third parties, reasonable efforts will be made to ensure that the transferor uses the transferred User Data in a manner consistent with this Privacy Policy.

In the event that the User makes a reservation to stay in one of our houses, their personal data will be processed in order to adhere to and manage the assistance insurance available to all guests during their stay in the Olivia Singular Houses units.

I. Processing Entities

In order to process User Data, Olivia Singular Houses uses or may use third parties, subcontracted by it, to process User Data on its behalf and in accordance with its instructions, in accordance with applicable law and this Privacy Policy.

These processing entities may not transfer User Data to other entities without the prior written consent of Olivia Singular Houses.

Olivia Singular Houses undertakes to subcontract only to entities offering maximum security in the execution of appropriate technical and organisational measures, in order to ensure the defence of the User’s rights. All entities subcontracted by Olivia Singular Houses shall be bound by a written agreement that regulates, inter alia, the object and duration of the data processing, the nature and purpose of the data processing, the type of personal data, data owner categories and the rights and obligations of the parties and other requirements set out in Article 28 of the GDPR.

II. Third Party Entities

Olivia Singular Houses may also disclose to other third parties not qualified as processing entities within the meaning of Article 4, paragraph 8 of the GDPR. These entities are subject to confidentiality, and all have assumed the guarantee that they process personal data in accordance with the provisions of the GDPR.

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Olivia Singular Houses discloses data to other recipients, namely:

Temporary employment agencies – Temporary assignment of workers
Companies to whom the operation of commercial premises on the premises of Olivia Singular Houses is transferred – Additional and support services provided to guests
Insurance companies – Customer assistance insurance
Companies providing various services during the guest’s stay at Olivia Singular Houses – Parking, car hire and garden maintenance services
Travel agencies and tour operators – Booking of holidays and hotel services
Consultants and Lawyers – Provision of legal advice and services
Consultants and Lawyers – Provision of legal advice and services

1.3 Data Collection Channels

Olivia Singular Houses may collect data directly (i.e. directly from the user) or indirectly (i.e. through partner entities or third parties). Data collection may be made through the following channels:

Direct collection: in person, by telephone, by e-mail and via the Website;
Indirect collection: via partners or group companies and official entities.

2. General Principles for Processing User Data

In general principles regarding the processing of personal data, Olivia Singular Houses undertakes that the User Data processed thereby will be:

Subject to processing in accordance with the law, fair and transparent to the User;
Collected for specified, objective and legitimate purposes, not further processed in a way contrary to those purposes;
Adequate, justified and limited to what is necessary for the purposes for which they are processed;
Accurate and updated whenever necessary, taking all necessary steps to ensure that data which is inaccurate, in regard to the purposes for which it is processed, is erased or corrected without delay;
Kept in such a way as to allow the identification of the User only for as long as is necessary for the purposes for which the data is processed;
Processed in such a way as to ensure its security, including protection against unauthorised or unlawful processing and against loss, destruction or unanticipated damage, with the adoption of appropriate technical or organisational measures.
Data processing by Olivia Singular Houses is authorised and legitimate when at least one of the following situations occurs:

The User has given its free, affirmative, tacit and unequivocal consent to the processing of User Data for one or more specific purposes;
Data processing is necessary for the performance of a contract to which the User is a party, or for pre-contractual procedures at the User’s request;
Data processing is necessary to fulfil a legal obligation to which Olivia Singular Houses is subject;
Data processing is necessary to protect the vital interests of the User or another person;
Data processing is necessary for the legitimate interests pursued by Olivia Singular Houses or by third parties (unless the interests or fundamental rights and liberties of the User, which require personal data protection, prevail).
Olivia Singular Houses undertakes that the processing of User Data will only be carried out under the conditions listed above and in accordance with the above principles.

Where Olivia Singular Houses processes User Data based on your consent, you have the right to withdraw your consent at any time. However, withdrawal of consent does not affect the lawfulness of the processing carried out by Olivia Singular Houses based on the consent previously given by the User.

The length of time for which data is stored and retained varies according to the purpose for which the information is processed, being stored only for the time necessary to achieve the purposes for which it is processed, taking into account the Data Retention Policy approved by Olivia Singular Houses.

Indeed, there are legal requirements that oblige us to retain data for a minimum period. Thus, in the absence of a specific legal obligation, data will only be stored and retained for the minimum period necessary for the purposes for which it was collected or further processed, which will be deleted at the end of such a period.

3. Processing Purpose and Use of User Data

In general, Olivia Singular Houses uses User Data for the following purposes:

Provision of hospitality and related services (restaurants, bars, etc.);
The purchase of vouchers;
Management of contacts with the User and response to requests for quotations;
Invoicing and charging the User;
Inform the User, upon request, of new products and services available on the Website and/or in the hotels, special offers and campaigns, updated information on the activity of Olivia Singular Houses and, in general, for marketing purposes of Olivia Singular Houses and its guesthouses, by any means of communication, including electronic media;
Ensure that the Website meets the needs of the User, by developing and publishing content that is as appropriate as possible to the demands and type of User, by improving the Website’s search resources and functionalities and by obtaining associated or statistical information concerning the profile of the User (consumption profile analysis);
Subscription and management of the assistance insurance available to all guests during their stay in our Singular Houses;
Submit satisfaction surveys;
Recording of telephone calls that may be made in order to request or provide information on bookings, vouchers and other products or services and their commercial and usage conditions, as well as the establishment of any contractual relationship, either during the contractual phase or during its duration.

Olivia Singular Houses may combine Usability Information with anonymous demographic data for research purposes, and may use the result thereof to provide relevant content on the website. With the user’s consent, in certain restricted areas of the website, Olivia Singular Houses may combine Personal Data with Usability Information to provide you with more personalized content.

4. Implementation of Technical, Organisational and Security Measures

To ensure the security of User Data and its confidentiality, Olivia Singular Houses processes the information you provide us as confidential, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated as necessary, as well as the applicable legal requirements.

Depending on the nature, scope, context and purposes of the data processing, as well as the risks arising from the processing to the rights and liberties of the user, Olivia Singular Houses undertakes, both in determining the means of processing and in the processing itself, to implement the technical and organisational measures necessary and appropriate for the protection of the User Data and compliance with the law.

We also undertake to ensure that, by default, only the data necessary for each specific purpose is processed and that this data is not made accessible without human intervention to an indeterminate number of persons.

Communication between the user’s device and the Olivia Singular Houses website takes place via secure communication channels that use HTTPS and the SSL security standard.

5. Use of Cookies

When you visit our website, small text files (cookies) are created and stored on your computer’s hard drive. These text files allow for a more personalised and efficient browsing experience. Each time you visit the website, your internet browser sends these cookies back to the website so that the identity of users and their usage preferences can be recognised and stored. These cookies are only installed with your tacit consent, except in cases where consent is required for the operation of the website.

In addition, you can manage your preferences regarding the collection of cookies at any time in the preferences manager available on the bottom left corner of this website.

6. Third-party Tools Embedded into the Website

Facebook, Instagram and LinkedIn:

Our Website interacts with third-party social networks such as Facebook, Instagram and LinkedIn, through a connection to the servers of these social networks. This will allow identifying the website that the user is visiting and possibly store other data, such as the IP address. If the User has logged on to Facebook and/or Instagram and/or LinkedIn, the data will be associated with their accounts. To prevent this from happening, the User must log out of their Facebook, Instagram and LinkedIn account before visiting the website.

B. User Rights (Data Owners)

7. Right to Information

7.1. Information provided to the User by Olivia Singular Houses (where data is collected directly from the User):

The identity and contact details of the data controller and, if applicable, of its representative;
The Data Protection Officer’s contact details;
The purposes of the processing for which the personal data are intended and, where appropriate, the legal grounds for the data processing;
If the data processing is based on the legitimate interests of Olivia Singular Houses or a third party, information regarding those interests;
Where applicable, the recipients or categories of personal data recipients;
Where applicable, indication that personal data will be transferred to a third country or international organisation, and whether or not there is a decision adopted by the Commission or a reference to appropriate or adequate transfer safeguards;
Duration of personal data retention;
The right to request from Olivia Singular Houses the authorisation of personal data, as well as its correction, erasure or limitation, the right to object to the processing and the right to access the data;
If the data processing is based on the User’s consent, the right to withdraw it at any time, without compromising the lawfulness of the data processing carried out based on consent previously given;
The right to complain to the CNPD or any other supervisory authority;
Inform whether or not the provision of personal data is a legal or contractual obligation, or a necessary requirement for entering into a contract, as well as whether the data owner is obliged to provide personal data and the possible consequences of not providing such data;
Where applicable, the existence of automated decisions, including profiling and information on the basic concept, as well as the significance and expected consequences of such processing for the data owner.
In the event that the User Data is not collected directly by Olivia Singular Houses from the User, in addition to the information mentioned above, the User is also informed of the personal data categories processed and, thus, the origin of the data and, possibly, whether it comes from publicly available sources.

If Olivia Singular Houses intends to process the User Data for a purpose other than that for which the data was collected, prior to such processing, Olivia Singular Houses will provide the User with information about that purpose and any other information of interest, in the abovementioned terms.

7.2. Procedures and measures implemented for compliance with the right to information.

The information referred to in 7.1 shall be provided in writing (including electronically) by Olivia Singular Houses to the User prior to the personal data processing in question. In accordance with applicable law, Olivia Singular Houses is not obliged to provide the User with the information referred to in 7.1 where and to the extent that the User is already aware of such information.

The information is provided free of charge by Olivia Singular Houses.

8. Right of Access

Olivia Singular Houses guarantees the means by which the User can consult its Personal Data.
The User has the right to obtain from Olivia Singular Houses confirmation as to whether or not personal data relating thereto is being processed and, if so, the right to access its personal data and the following information:

Data processing purposes;
Personal data categories;
Recipients or categories of recipients to whom the personal data has been or will be disclosed, namely recipients established in third countries or belonging to international organisations;
How long your personal data will be retained;
Right to request Olivia Singular Houses to rectify, delete or restrict the processing of personal data, or the right to prevent such processing;
Right to complain to the CNPD or other supervisory authority;
If the data has not been collected from the User, the available information on the origin of the data;
The existence of automated decisions, including profiling, and information about the underlying logic and the significance and expected consequences of such processing for the data owner;
The right to be informed of the appropriate safeguards associated with the transfer of data to third countries or international organisations.

Upon request, Olivia Singular Houses will provide the User with a copy of the User Data that is processed free of charge. The provision of further copies requested by the User may incur an administrative fee.

9. Right to Rectification

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

In case of data rectification, Olivia Singular Houses will communicate the respective rectification to each data recipient to whom the data has been transmitted, unless such communication is deemed impossible or involves a disproportionate effort for Olivia Singular Houses.

10. Right to Erasure ("Right to Be Forgotten")

The User has the right to obtain from Olivia Singular Houses the deletion of its data where any of the following reasons apply:

User Data is no longer necessary for the purpose for which it was collected or processed;
The User withdraws its consent on which the data processing is based and there is no other legal basis for such processing;
The User objects to the processing by virtue of the right to object and there are no legitimate interests that justify the data processing;
If the User Data is processed unlawfully;
If the User Data must be deleted to comply with a legal obligation to which Olivia Singular Houses is subject;
Subject to applicable law, Olivia Singular Houses has no obligation to delete User Data to the extent that processing is necessary to fulfil a legal obligation to which Olivia Singular Houses is subject or for the purpose of reporting, exercising or defending Olivia Singular Houses in a lawsuit.
In the event of data deletion, Olivia Singular Houses shall inform each recipient/entity to whom the data was transmitted of the respective deletion, unless such communication proves impossible or involves a disproportionate effort for Olivia Singular Houses.

Where Olivia Singular Houses has made User Data public, and is obliged to delete it pursuant to the right to erasure, Olivia Singular Houses undertakes to take reasonable steps, including those of a technical nature, having regard to the technology available and the costs of its application. Olivia Singular Houses shall inform those responsible for the actual processing of personal data that the User has requested the deletion of links to such personal data, as well as copies or reproductions thereof.

11. Right to Restrict Processing

The User is entitled to obtain from Olivia Singular Houses the limitation of User Data processing, if any of the following situations apply (this limitation consists of inserting a mark in the retained personal data to limit its processing in the future):

If you challenge the accuracy of the personal data, for a period that allows Olivia Singular Houses to verify its accuracy;
If the data processing is unlawful and the User objects to the deletion of the data, requesting, in return, the limitation of its use;
If Olivia Singular Houses no longer requires the User Data for processing, but the User Data is required by the User for the purpose of asserting, exercising or defending a right in a legal proceeding;
If the User has objected to the processing, until it is found that the legitimate reasons of Olivia Singular Houses prevail over those of the User.
Where User Data is subject to limitation, it may only be processed with the User consent, except in case of data retention, for the purposes of asserting, exercising or defending a legal claim, defending the rights of another individual or legal entity, or for reasons of public interest as legally provided.

Olivia Singular Houses will inform the User who has obtained the limitation of its data processing in the cases mentioned above, before the limitation of the data processing is cancelled.

In the event of a restriction on the data processing, Olivia Singular Houses will inform each recipient to whom the data has been transmitted of the respective restriction, unless such communication proves impossible or involves a disproportionate effort for Olivia Singular Houses.

12. Right to Portability

The User has the right to receive personal data relating thereto and that has been provided to Olivia Singular Houses in a structured, commonly used and machine-readable format, and the right to transmit such data to another data controller, if:

The data processing is based on consent or a contract to which the User is a party; and
The data processing is carried out by automated means.
The right to portability does not include inferred or derived data, i.e. personal data generated by Olivia Singular Houses because of or following the analysis of data that has been processed.

The User has the right to have its personal data transmitted directly between the data controllers, whenever this is technically feasible.

13. Right to Object to Processing

The User has the right to object at any time, on grounds relating to its specific situation, to the processing of personal data based on the exercise of legitimate interests pursued by Olivia Singular Houses. This includes data processing carried out for purposes other than those for which personal data was collected, including profiling, or where personal data is processed for statistical purposes.

Olivia Singular Houses shall cease processing User Data unless there are urgent and legitimate grounds for such processing, which override the interests, rights and liberties of the User, or for the purpose of asserting, exercising or defending a right of Olivia Singular Houses in a legal proceeding.

Where User Data is processed for direct marketing purposes, the User has the right to object at any time to the processing of its data for such marketing purposes, including profiling insofar as it relates to direct marketing. If the User objects to the processing of its data for direct marketing purposes, Olivia Singular Houses shall cease processing the data for such a purpose.

The User also has the right not to be subject to a decision taken solely on the basis of automated data processing, including profiling, which produces effects in the legal sphere or which significantly affects the User in a similar manner, unless the decision:

Is necessary for the attainment or execution of a contract between the User and Olivia Singular Houses;
Is authorised by law to which Olivia Singular Houses is subject; or is based on tacit consent of the User.

14. Procedures for the Enforcement of Rights by the User

The right of access, right to rectification, right to erasure, right to restrict processing, right to portability and the right to object processing can be enforced by the User via the available web platform.

For more information, please contact Olivia Singular Houses Manager by sending an email to margarida@oliviahouses.com

Olivia Singular Houses will respond in writing (this includes e-mail) to the User’s request within one month from receipt of the request, except in cases of special complexity, where this period may be extended to two months.

If the requests made by the User are deemed unjustified or excessive, in particular because of their repetitive nature, Olivia Singular Houses reserves the right to charge an administrative fee or to refuse to process such a request.

15. Personal Data Breaches

In the event of a data breach and to the extent that such breach is likely to result in a high risk to the rights and liberties of the User, Olivia Singular Houses undertakes to communicate such an event of personal data breach to the User within 72 hours of becoming aware of the incident.

According to the law, communication to the User is not required in the following cases:

If Olivia Singular Houses has applied appropriate protection measures, both technical and organisational, and whether these measures have been applied to the personal data affected by the personal data breach, namely measures that make the personal data unintelligible to any person not authorised to access such data, such as data encryption;

If Olivia Singular Houses has taken subsequent steps to ensure that the high risk to the User’s rights and liberties is no longer likely to happen; or
If communication to the User involves a disproportionate effort for Olivia Singular Houses. In this case, Olivia Singular Houses will make a public announcement or take a similar action whereby the User will be informed.

C. Miscellaneous

16. Amendments to the Privacy Policy

Olivia Singular Houses reserves the right to amend this privacy policy at any time. We recommend that you read this document regularly.

17. Right to Lodge a Complaint with a Supervisory Authority

You can always lodge a complaint with the Portuguese Data Protection Authority (CNPD), in writing to CNPD, Av. D. Carlos I, 134 – 1.º 1200-651 Lisboa, by telephone (+351) 213928400 or via email: geral@cnpd.pt.

18. Reviews

This privacy policy may be amended from time to time, so we recommend that you consult it regularly. This privacy policy was last updated on 17 June 2022.