Last updated: November 11, 2021.
We at TANGARA DESENVOLVIMENTO IMOBILIÁRIO E EXPLORAÇÃO HOTELEIRA LTDA ("Palácio Tangará") wish to maintain a relationship of trust and transparency with all our customers and users of our services.
Because of that, we have prepared this Privacy Notice ("Notice") to help you understand which information about you is collected, why we collect it, whether we share it, and with whom with share it. Additionally, this is to inform you of your rights regarding this information and how to exercise them with Palácio Tangará.
For us, ensuring the privacy and security of your personal data is a priority. Any information you provide us will be treated within the limits set forth herein.
If you have any questions regarding the protection of your personal data, we provide an appropriate contact channel at the end of this notice. Please do not hesitate to contact us.
1. Definitions
So you can fully understand this Notice, we have listed some terms and concepts below:
• Personal data: Any information regarding an identified or identifiable individual; an identifiable person is any person that can be identified, either directly or indirectly, particularly by reference to an identifier, such as a name, an identification number, electronic identifiers or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that specific individual.
•Sensitive personal data: Any personal data relating to someone’s racial or ethnic origin, religion, political opinion, membership with any union or organization of a religious, philosophical or political nature, as well as any data relating to someone’s health or sexual life, genetic or biometric data.
•Personal Data Processing Officer: The Person in Charge of Personal Data Processing at Palácio Tangará is the person appointed to serve as a communication channel with you and with Brazil’s National Data Protection Authority (ANPD).
•Third Parties: It refers to, but is not limited to, any individual or legal entity with which Palácio Tangará relates or may have a relationship, or any service provider, supplier, consultant, partner, contracted third party or subcontractor.
•Owner: Any individual to whom the personal data refer.
•Treatment: Any activity performed with personal data, such as collecting, receiving, sorting, using, accessing, reproducing, transmitting, distributing, processing, filing, storing, deleting, evaluating or controlling, modifying, updating, communicating, transferring, sharing and extracting information.
2. How does Palácio Tangará use your personal data?
The Personal Data that Palácio Tangará collects about you is used for the following purposes:
2.1. To fulfill the purpose for which the data was provided
We treat your Personal Data to fulfill the purposes for which the data was collected or for other purposes compatible with these purposes. For example, when you book accommodation, we ask for some information to enable you to check in and stay with us.
2.2. To comply with our legal or regulatory obligations
Your personal data may be used to fulfill our obligations established in law and/or in regulations of government agencies and orders or requests from tax authorities, the Judicial Branch and/or other competent authority. For example, we may process personal data for issuing tax invoices.
2.3. To allow the regular exercise of our rights
Even upon termination of your relationship with us, we may process some of your personal data to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitration proceedings.
2.4. To enable the activities that are critical to our organization
Based on our legitimate interest, we may also process your personal data in activities such as: communication and marketing, improvements to our products and services, relationship with our customers and partners, performance analysis and reporting and inquiries. In activities that support the interests of Palácio Tangará, we will always observe the limits of your expectations and your personal data may not be processed to the detriment of your interests, rights or fundamental freedoms.
2.5. To execute a contract you have entered into with us or to carry out pre-contract due diligence
If you are a party to a contract with Palácio Tangará or represent a company in a contract, we will process your data in order to execute and enforce the contract, for example, to ensure that the work may be done and the relevant payment may be made. Furthermore, the data will be processed to maintain our commercial relationships with customers, partners, suppliers and others.
2.6. Recruitment and Selection
We advertise our job openings on specialized websites. We also receive résumés through our website, referrals from our employees, in addition to résumés that may be left in person at our units. In these situations, we will process your personal data to analyze your résumé, check your skills, your professional information and whether or not you meet the specific requirements of the position for which you applied, as well as to continue the selection process, as appropriate, in situations such as contacting you by telephone or email and setting up interviews.
2.7. To Avoid Fraud and Ensure Your Safety
We may process your personal data to ensure your safety (and that of third parties) and to prevent identification fraud, especially when you access our institutional website and internal systems, or when you enter or visit our facilities.
2.8. Advertising
Finally, we may use your Personal Data to segment target audiences and to promote, in a more appropriate way, updated contents for the marketing campaigns of Palácio Tangará. In this case, the option to unsubscribe from our database will always be available at the end of each communication, with the possibility of choosing to receive information such as offers and news about the latest trends at Palácio Tangará.
3. Which Personal Data do we handle?
In order to respect your privacy, we understand that any and all processing of personal data must be limited to the minimum necessary, relevant and proportionate to allow the intended purpose to be achieved. Therefore, the personal data we collect about you will vary depending on the relationship you choose to establish with us, that is, as a customer, consumer, supplier, service provider, visitor, partner, and others.
Below, divided into categories, we present your main personal data processed by us:
• Identification information: this may include your name, date of birth, RG number, CPF number, profession, title, passport, and other information with particular relevance;
• Information that helps us to contact you: this may include your home address, postal code, landline or mobile number and your personal and/or professional e-mail;
• Financial information: this may include your checking account, bank branch and credit card number;
• Professional information: this may include your profession, place of work, position, professional history, academic qualification, diplomas and other qualification certificates, and others;
• Behavioral information: this may include your consumption or professional profile, your usage of social media, sociographic background;
• Sensitive data: we may collect and process sensitive data related to you, such as information about religion, dietary restrictions, and health information, to facilitate your stay with us.
• Attributes associated with your electronic devices: such as access provider, operating system, browser (type, version, enabled options and installed plug-ins), video settings (size/resolution and number of colors), date and time of access and pages viewed through cookies;
• Information from third parties: information shared by third parties with Palácio Tangará such as information from travel agencies and websites; and
• General data: that is, the content that you spontaneously send us that can be collected through online chat, email, blog posts, applications or any other tool that you use to send content to our servers.
4. Why do we handle your Personal Data?
The information we handle about you may have been provided directly by you to Palácio Tangará by third parties or even collected automatically through our Platform and other channels.
4.1. Provided Directly by You
From the beginning of your interaction with us, you voluntarily provide us with information about yourself. For example, when you contact us through the social media or our service channels in order to learn more about the products offered by our company.
4.2. Provided by Third Parties
In specific cases, we may also receive some of your Personal Data through Third Parties. For example, information provided by Consultants, Service Providers, Agencies and travel websites, and others.
4.3. Automatically
In some situations, we may also automatically collect Personal Data from the devices you use to access our website. This information helps us generate access statistics and, thus, better understand our audience. This is important for us to improve it more and more and adjust it to the largest possible audience. Some of this data may be collected through cookies or similar technologies, as per our Cookies Policy.
4.4 Publicly Available
We may also collect your publicly available information, including, but not limited to, social media (such as Instagram, Facebook, etc.) and databases from public authorities (e.g.: the Internal Revenue Service).
5. For how long do we store your Personal Data?
We will retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, unless a longer retention period is necessary to fulfill legal obligations, safeguard our rights or comply with any consent orders or extrajudicial agreements.
To determine the retention period for your personal data, we use the following criteria:
• If we have any legal, contractual or other obligation to retain personal data, or if it is necessary for the purposes of investigation or litigation; and
• If they are needed to keep accurate business and financial records.
6. With whom do we handle your Personal Data?
Palácio Tangará may share your personal data, in which case it will be restricted to the minimum necessary for the fulfillment of any of the specific purposes previously informed to you.
For example, we may share your Personal Data to enable the operation of communication and marketing channels, with business partners, other companies from our group, service providers, legal counsel and public authorities.
When we share your personal data with partners, we use contracts to ensure that any third-party recipient may provide them with proper protection.
Where we share data with a third parties located out of Brazil, such as Germany, France and England, in addition to ensuring the safety and protection of personal data through a contract, Palácio Tangará will use one of the legal options of international transfer provided for in the legislation.
7. How do we handle your Personal Data?
We have internal policies and protocols that determine how personal data should be handled by Palácio Tangará.
These rules aim to ensure the proper and lawful processing of the personal data we hold, including yours.
In addition to these organizational and governance measures, we have adopted several others of a technical nature that ensure even greater safety for your personal data, such as:
•Strict control of the processing of personal data, including access limitation, and password-protected access;
• An information security program
• Segregation of access to personal data;
• Password protection guidelines; and
• Access to services exclusively through secure networks.
8. What are your rights and how can you exercise them at Palácio Tangará?
Whichever relationship you choose to establish with Palácio Tangará, you are assured all rights relating to your personal data provided for by law, including, but not limited to:
1) Finding out if we are processing any of your personal data;
2) Finding out which of your personal data is processed by us;
3)Editing incomplete, inaccurate or outdated data;
4)Requesting the anonymization, blocking or deletion of unnecessary or excessive data or any data that may have been processed in violation of the law;
5)Requesting portability of the data to another service provider or product supplier;
6)Requesting the review of solely automated decisions that affect your interests;
7)Requesting the deletion of data processed with your consent;
8) Obtaining information about the public or private entities with which we share your data; and
9)When the processing activity requires your consent, you can refuse consent. In this case, we will inform you of the consequences of not carrying out such activity. If you consent to it, you can revoke it at any time.
In order to exercise your rights, you may contact our personal data processing Officer by sending an e-mail to [email protected].
In specific circumstances, your request may not be granted. In these cases, we will explain the reasons for not granting it.
No requests involving personal data and/or documents owned by others will be granted, except by means of a power of attorney, parental authority or any other circumstance authorizing the exercise of the right of another owner by you.
9. Cookies
To learn more about Cookies and how we use them, please visit our Cookies Policy.
10. Social Media
Palácio Tangará is present on social media including Instagram, Facebook, YouTube, WeChat, SINA Weibo, etc.
Your access to these social media websites implies the acceptance of the terms defined by each platform, for the processing of personal data, regardless of whether Palácio Tangará maintains any profiles on such social media websites. To find out more about the processing of personal data and how your data is protected on these social media websites, we recommend reading their Privacy Notices:
•Facebook
•Instagram
•YouTube and YouTube - Google
Palácio Tangará may collect some personal information from your access to our pages on social media websites when you "like" our pages, share any content or follow us on a certain social media website.
Also, if you choose to log in or connect with us using your social media profile, some information is shared with us. According to the settings of each social media, location details, check-ins, activities, interests, photos, status updates, as well as your personal data that may be part of a friend's profile may be shared.
11. Privacy by Design and by Default
Palácio Tangará undertakes to integrate the protection of personal data by design into services or any other tools related to the processing of personal data, particularly with the minimization of Personal Data, limitation of purposes, respect for the integrity and confidentiality of data and limitation of retention periods.
Furthermore, in order to respect the principle of accountability, Palácio Tangará:
•adjusts internal procedures in order to ensure compliance with the legislation applicable to the protection of personal data (information letter, personal data protection letter, etc.);
•maintains documentary records of any processing performed under its responsibility or under that of the processor (processing records, confidentiality agreements for employees and service providers, the company’s security policy, access, rectification and opposition request management procedures); and
•performs Privacy Impact assessments for processing operations that pose particular risks with respect to rights and freedoms.
The purpose of those is to provide the necessary documentation to demonstrate compliance with Data Protection rules at all times.
12. Any questions?
If you have any questions, you may contact our Personal Data Processing Officer at OPICE BLUM, BRUNO E VAINZOF ADVOGADOS by sending an e-mail to [email protected].
13. Updates
Some of the information provided here may be updated or changed. Therefore, we encourage you to review this Privacy Notice periodically.
Updated on November 11, 2021