ESTANPLAZA PRIVACY POLICY
PURPOSE OF THIS PRIVACY POLICY
This Policy applies to all individuals or legal entities that provide their personal data to ESTANPLAZA, and explains how your Personal Data is collected, used and shared, and how to exercise your rights in relation to it.
Please be advised that this Policy may be changed periodically, as informed at the end of the document, and that its content is essential for you to understand the way in which we collect, store and process your data.
A SUMMARY TO FACILITATE YOUR READING
Personal Data is all information that concerns someone, whether that person is an individual or a legal entity, and we can use as an example the name, CPF registration, email address, among others.
Some data are called Sensitive Data, which are limited to racial or ethnic origin, religious beliefs, political opinions, membership of a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to You and such data deserve even greater caution and care in its treatment by ESTANPLAZA.
There is also the figure of Anonymized Data, which is that relating to a holder who cannot be identified.
It is also important for you to know that all information collected will be included in the ESTANPLAZA Database, which is a structured set of personal data, established in one or more locations, in electronic or physical support.
Personal Data Processing means any operation, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction, carried out with personal data.
ESTANPLAZA, in this relationship established with you due to the processing of data, is called Controller, which can be a natural or legal person, under public or private law, who is responsible for decisions regarding the processing of personal data;
And to facilitate your communication with ESTANPLAZA when it comes to the processing of your data, we have chosen dpo.lgpd@estancorp.com.br, which is occupied by the DPO (Data Protection Office) or Person in Charge, which is the person appointed by the controller to act as a communication channel between the controller, data subjects and the National Data Protection Authority (ANPD).
WHERE ESTANPLAZA COLLECTS YOUR DATA
ESTANPLAZA Websites – Reservations Websites aimed at future guests, managed by or for ESTANPLAZA, including websites operated under its own domain (URLs) and commercial pages maintained on third-party social networks.
ESTANPLAZA Websites/Mobile Applications. Consumer-facing websites or mobile applications managed by or for ESTANPLAZA.
Email, text messages and other electronic messages. Interactions that ESTANPLAZA carries out with its guests.
FNRH – National Guest Registration Form – Established by Law 11.771/08, later regulated by Ordinance MINTUR 177/11, and which can be completed when checking in at one of the ESTANPLAZA Units.
Interactions with advertisements. Interactions with advertisements or digital tourism agencies or articles published on Electronic Information Portals.
Data from other sources. Facebook, Google, Instagram and others, ESTANPLAZA promotional partners, Data that has been made public, as well as others always with your consent.
WHAT DATA IS COLLECTED BY ESTANPLAZA
Personal contact information. This includes any information you provide that will allow us to contact you, such as your full name, CPF, date of birth, sexual orientation, email, period of stay, reason for stay, social media details, telephone number, etc.
Account Login Information. Any information that is necessary to give you access to your specific account profile, such as your username, password in unrecoverable format, and/or security question and answer.
Demographic and Interest Information. Any information that describes your demographics or behavioral characteristics, such as age or age range, geographic location, interests, and family information or the reason for your trip.
Accommodation information: information that allows ESTANPLAZA to understand your accommodation profile, the dates that suit your profile, and the ESTANPLAZA Units that can best meet your needs, type of Unit chosen, period of travel, accompanied by family or not, consumption expenses incurred during accommodation, travel by plane or car, etc.
Technical information about your computer/mobile device. Any information about the computer system or other device used to access our website or app, such as your IP address, operating system type, and web browser type and version, including if you use a mobile device such as a smartphone, the information collected will also include your phone’s unique device ID, advertising ID, geolocation, and other similar mobile device data, always with your consent.
Website/communication usage information. Automatic data collection technology on certain information about your actions during your navigation is used by ESTANPLAZA, (links, pages or content viewed, similar information and statistics about interactions, etc.) are captured through automated technologies (Cookies among others).
Guest experience feedback. Information shared with ESTANPLAZA about your experience in our Units, such as complaints, satisfaction surveys and requests for improvements.
Consumer Generated Content. Information generated and shared by our guests with ESTANPLAZA on third-party social networks or through posts on one of our websites or applications, including the use of third-party social networking applications such as Facebook (photos, videos, personal stories or other similar content and media)
Third-party social media information. Any information that you share publicly on a third-party social media network or information that is part of your profile on a third-party social media network (Facebook, Instagram, etc.).
Financial and payment information. Information that ESTANPLAZA processes to fulfill and invoice an order, or that you use to make a reservation, such as your debit or credit card details (cardholder name, card number and expiration date) or other payment methods (if available). In any case, ESTANPLAZA or the Credit Card Administrators will process the data in accordance with applicable laws, regulations and security standards. Payment card details, such as the security code, are not recorded.
Event and attendee information: We record the meeting and event specifications, the date of the event, the number of guests. For corporate events, we request information about your organization, usually by email or messaging app such as WhatsApp, such as: details of the organizing company, data from third party suppliers will also be collected. If you visit us as part of a group, we may have your personal information and make commercial offers to you following your stay with the group or event attendance. If you are an event organizer, we may also use your data to contact you with information about our event services.
Telephone contact made by ESTANPLAZA: Telephone calls to reserve accommodation or services may be recorded and used to fill in the data required for confirmation and payment for accommodation, and it is important to highlight that payment card details are not recorded under any circumstances.
Sensitive Personal Data. No data other than that essential for the reservation and accommodation will be requested by ESTANPLAZA, therefore sensitive data defined by law must not be provided to any ESTANPLAZA employee.
Personal Data of minors: Only the personal data of minors necessary for the reservation and accommodation will be requested by ESTANPLAZA, therefore the sensitive data defined by law must not be provided to any ESTANPLAZA employee, and the data provided will not be stored.
DESTINATION OF COLLECTED DATA
Reservations: ESTANPLAZA will collect and store the data at the time of your reservation to enter it into our records and allow the initial blocking of the accommodation(s) for the period understood and requested by you, ensuring the beginning of your legal relationship with ESTANPLAZA, preserving your right to contract and ensuring that the contracted accommodation period will be respected to make your experience unforgettable.
The processing of personal data will be carried out by ESTANPLAZA in strict respect for your privacy, we reaffirm our dedication to implementing compliance measures, especially aiming to ensure:
a) Lawful processing, supported by a legal basis, legitimate interest or consent;
b) That no data will be processed that goes beyond the purpose for which the data was made available;
c) Limitation on data storage, in accordance with the defined archiving deadlines;
d) Collecting the minimum amount of data possible, requesting only that which is appropriate for the purpose
e) The implementation of measures for the security and confidentiality of information.
It is important that you know that the processing of this data after a period of 05 years (Ordinance 177/11 MINTUR, article 4, item VII, par. 2) can be discontinued upon communication to the DPO, or, if you prefer, this deletion can occur at any time even before these 05 years upon communication to the same DPO.
Your data collected by ESTANPLAZA will only be used to:
• Analyze your preferences and habits;
• Anticipate your hosting needs by analyzing your hosting profile;
• Improve and personalize your experience on our websites and applications;
• Send advertising solely about the hosting services, and
• Allow you to participate in interactive functions, when you choose to do so.
Even though the processing of data is entirely focused on your satisfaction when you stay at any of the ESTANPLAZA units, your consent is essential to authorize this use within the limits presented to you.
Legal reasons or merger/acquisition. In the event of a merger or acquisition of ESTANPLAZA by another Hotel Chain, your Personal Data will be shared with the acquirer under the terms of this privacy policy.
• When required by applicable law;
• When requested by the Police Authority;
• When requested by the Judicial Authority;
• As a procedure necessary to protect our rights, privacy, security or property;
Personalization of the experience: Use of personal data to personalize the period of stay at one of the Estanplaza Units, adapting to the guest's particular preferences.
General purposes. ESTANPLAZA uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research, and measuring the effectiveness of Our advertising campaigns. We reserve the right, if you have ESTANPLAZA accounts, to combine these accounts into a single account. We also use your Personal Data for the management and operation of our communications, IT, and security systems.
USE OF TECHNOLOGIES FOR DATA COLLECTION
A cookie is a small file added to your device or computer by websites you visit, and is used to improve the functionality of websites, to provide a personalized experience for the consumer and to provide information to website owners.
Session Cookies. These are temporary cookies that are deleted when you close your browser. When you restart your browser and return to the website that created the cookie, that website treats you as a new visitor. Example: performance cookies - These help us understand how visitors interact with our website by providing information about the areas visited, the time spent and any problems encountered, such as error messages. This helps us to improve the performance of our websites.
Persistent Cookies. These are Cookies that remain in your browser until you delete them manually or until your browser deletes them according to the duration period established by the Cookie. These Cookies will recognize you as a return visitor.
Necessary Cookies. These are Cookies that are strictly necessary for the operation of an ESTANPLAZA website. They allow you to navigate the website and use our features. You cannot object to this processing or disable these Cookies. Cookies that send us information about you. These are Cookies placed by Us on an ESTANPLAZA website and can only be read by that website. These are known as “first-party” Cookies.
We also place Cookies in ESTANPLAZA advertisements that appear on third-party websites (such as Facebook). We obtain information through these Cookies when You click on or interact with the advertisement. In this situation, ESTANPLAZA is placing a “third-party” Cookie. ESTANPLAZA may use the information obtained by these Cookies to send You other advertisements that are relevant or of interest to You based on Your previous online behavior.
Cookies that send information to other companies: These are Cookies placed on an ESTANPLAZA website by our partner companies (such as Facebook or other advertisers). They may use the data collected by these Cookies to anonymously send you targeted advertisements on other websites, based on your visit to the ESTANPLAZA website. For example, if you use a social widget, such as Facebook, on an ESTANPLAZA website, it will record your “share” or “like”. Facebook (being the company that placed the Cookie) will collect this data.
Example: Social Sharing Cookie - The social sharing offered on the Website is run by third parties. These third parties may place Cookies on your computer when You use social sharing features on the Website, or if You have already logged in to them. These Cookies help to improve Your experience on the Website by enabling You to share comments/reviews/pages/recommendations and help to provide access to social networks and online social tools more easily.
Other similar technologies. ESTANPLAZA websites also use other tracking technologies, including IP addresses, log files, and web beacons, which also help us tailor Our websites to your personal needs.
IP Address. An IP Address is a number used by computers on the network to identify your computer each time you connect to the Internet. We may log IP Addresses for the following purposes: (i) to troubleshoot technical issues (problems that a product, process or operating system may have); (ii) to maintain the safety and security of the Site; (iii) to better understand how Our Sites are used; and (iv) to better tailor content to your needs, depending on the country in which you are located.
Log Files. We (or a third party on our behalf) may collect information in the form of Log Files that record website activity and gather statistics about your browsing habits. These log files are generally generated anonymously and help us collect (i) your browser type and operating system; (ii) user session information (such as your referring URL, the date, time, and which pages you visited on Our Site and how long you spent on it); and, (iii) other navigational or click-count data.
Web Beacons. We use Web Beacons (or clear GIFs) on ESTANPLAZA websites. Web beacons (also known as “web bugs”) are small strings of code that enable the delivery of a graphic image on a web page for the purpose of transferring data back to Us. We use the information from Web beacons for a variety of purposes, including information on how a user responds to email campaigns (e.g., what time the email is opened, what link the user clicks on from the email), site traffic reporting, unique visitor counting, email and ad auditing and reporting, and personalization.
Managing your Cookies/preferences. You can manage and disable Cookies in your browser settings. You can even configure your browser to warn you before accepting Cookies or simply refuse them. But remember, some of them are necessary to enable you to use our websites. You do not need to have Cookies to use or browse most of ESTANPLAZA’s websites, although you will probably not be able to access all of their features in this case. See the “help” button of your browser (such as Internet Explorer, Google Chrome or Firefox) to find out how you can manage this. If you use different computers in different locations, you will need to ensure that each browser is adjusted according to your Cookie preferences.
WITH WHOM WILL ESTANPLAZA SHARE YOUR PERSONAL DATA?
Service providers: These are companies used in any of the stages of the accommodation, food or event services provided by ESTANPLAZA, and any and all data processing is done with a specific purpose related to accommodation and related topics.
Credit Card Administrators: These are those with which the payment method intermediation is processed so that ESTANPLAZA can be remunerated for the services provided.
Travel Agencies (Physical or Electronic): These are those through which your accommodation reservation is made for any of the ESTANPLAZA Units.
Debt collection agencies: External companies that ESTANPLAZA uses to charge for services rendered and not paid for in its own time and manner.
Technology Companies: Contracted to provide software maintenance, update and implementation services.
Law Firm: Professionals hired to defend the interests of ESTANPLAZA during a legal proceeding.
Auditing Company: Professionals hired to audit accounts and processes in the continuous search for excellence in the services provided.
HOW LONG WILL ESTANPLAZA STORE YOUR DATA?
MINTUR Ordinance number 177/11, in its article 4, item VII, paragraph 2, requires the custody of National Guest Registration Forms for a period of 05 years, and as it is a legal determination this will be the period of custody and storage of your data.
ESTANPLAZA RESPECTS YOUR RIGHTS
Access, review, find out whether we carry out any processing of your Personal Data and request an electronic copy of the information we have about You;
Correct or request the correction of incomplete, inaccurate or outdated Personal Data;
Request the anonymization, blocking or deletion of unnecessary and excessive Personal Data;
Request the portability of Personal Data to another provider of similar products or services;
Request the deletion of Personal Data collected and used based on your consent;
Obtain information about the public or private entities with which we share your Personal Data;
When the processing activity requires your consent, you may refuse to consent. In this case, we will inform you of the consequences of not carrying out such activity;
When the processing activity requires your consent, you may revoke it at any time.
HOW DOES ESTANPLAZA PROTECT YOUR DATA?
People who can access your Personal Data. Personal Data will be processed by operators for specific purposes related to hosting and related services.
Measures adopted in operational environments. Data is stored in operational environments with reasonable security measures to prevent unauthorized access, and with the adoption of protection protocols within the security limits provided for data transit over the Internet.
Security measures require constant review and updating in light of available technological advances.
ESTANPLAZA NEEDS YOUR CONSENT
Cookies/Similar Technologies. You can manage your consent through your browser settings.
Advertising, marketing and promotions. You may consent to your Personal Data being used by ESTANPLAZA to promote its services, and this consent may be revoked at any time by notifying ESTANPLAZA through its DPO.
Personalization (offline and online): You may consent to your Personal Data being used by ESTANPLAZA to provide you with a personalized experience or exclusive advertising and content, and at any time this consent may be revoked by communicating this to ESTANPLAZA through your DPO.
Targeted advertising. You may enjoy exclusive benefits provided by our Partners who will use information collected through Personal Data collection channels used by ESTANPLAZA, and this consent may be revoked at any time by communicating this to ESTANPLAZA through its DPO.
DATA SUBJECT RIGHTS
As legitimate data subjects, customers enjoy the following rights:
Right of access and confirmation of processing: the data subject may request information reports on their data, as well as confirmation of which data is processed, how it is done and with which agents it is shared. This may be done at any time and free of charge.
Right to anonymization, blocking or revocation: some circumstances allow data to be corrected, updated, anonymized, deleted or processing stopped. When you request any of these options, ESTANPLAZA will verify and inform you about the possibility of meeting the request, given the retention obligations, by legal obligation or legitimate interest.
Right to correction: whenever you consider that the data provided by you is incomplete and/or incorrect, you may at any time request its completion or rectification.
Right to portability: Upon express request, you may ask ESTANPLAZA to transfer your personal data to another provider in the same segment.
Right to restriction: You may request that the person responsible for processing your data restrict access to your data or that processing activities be restricted.
Right to object: You may object to the processing of your data, whenever it is carried out and intended for purposes other than those intended, whenever it is contrary to compliance rules and/or for a personal reason.
Right to withdraw consent: You may revoke your consent for data processing at any time. ESTANPLAZA will stop processing your data if you withdraw your consent, unless there is a legal, regulatory or public interest obligation that justifies the non-deletion and continued processing.
The rights expressed here will be exercised in strict compliance with the General Data Protection Law (Law No. 13,709) and must be requested to ESTANPLAZA via email dpo.lgpd@estancorp.com.br
ESTANPLAZA POLICY UPDATE
Changes and updates to this policy may be made to improve its understanding and comprehensiveness, so it is recommended that you access it frequently.
CONTACT ESTANPLAZA THROUGH OUR DPO.
To ask questions or make comments about this Policy and our privacy practices or to make a complaint, please contact us by email: dpo.lgpd@estancorp.com.br by phone (11) 3888-7400, or at our address, Rua Pitu, 72 Cj. 93 - Cidade Monções, CEP: 04567-060, São Paulo - SP - Brazil.
In order for Personal Data to be processed correctly, any and all information will only be provided with the authorization of the Holder, proven by a copy of a personal document.