Azorean Living places particular importance on the privacy and protection of the personal data of its guests, clients, property owners, partners, professionals and website users.
This Privacy & Cookie Policy explains, in a transparent manner, how personal data processed within the scope of Azorean Living’s activities is collected, used, stored and protected, as well as the rules applicable to the use of cookies and similar technologies on the website www.azoreanliving.com.
Personal data is processed in accordance with Regulation (EU) 2016/679 — General Data Protection Regulation (GDPR), applicable Portuguese legislation and, whenever relevant, the rules and obligations applicable to Short-Term Rental Accommodation (Alojamento Local) in the Autonomous Region of the Azores.
The data controller responsible for the processing of personal data is:
MR Lodge Management, Lda.
Trading under the brand Azorean Living
Avenida D. João III, n.º 3, 3.º D
9500-310 Ponta Delgada
Azores — Portugal
Email: geral@azoreanliving.com
Website: www.azoreanliving.com
For any matter relating to privacy, personal data protection or the exercise of the rights provided for in this Policy, you may contact Azorean Living using the email address indicated above.
This Policy applies to the processing of personal data carried out by Azorean Living within the scope of its activities, including through:
Azorean Living undertakes to process personal data in accordance with the principles established by applicable legislation, namely:
Only data considered adequate, relevant and necessary for the identified purposes will be collected and processed.
The data processed varies depending on the relationship established with Azorean Living.
This may include:
This may include:
This may include:
This may include:
Data processed may include:
Whenever payment is made through a specialised provider, full card details or other banking data required for the transaction may be processed directly by that entity and not by Azorean Living.
Communications relating to the following may be retained:
The following may be processed:
This may include:
Personal data may be obtained:
Where a person provides personal data relating to third parties, namely when making a booking for several guests, that person must ensure that they are legally entitled to provide the necessary data.
Azorean Living only processes personal data where there is a specific purpose and a valid legal basis.
Data may be processed to:
Legal basis: pre-contractual measures and performance of the contract.
Data may be used to:
Legal basis: pre-contractual measures, performance of a contract and, where applicable, legitimate interests.
The necessary data may be processed for the issuance of invoices, accounting organisation, compliance with reporting obligations and other tax obligations.
Legal basis: compliance with a legal obligation.
Data may be processed in order to comply with legal, regulatory, administrative and statistical obligations relating to the operation of Short-Term Rental Accommodation establishments.
Legal basis: compliance with a legal obligation.
Data may be processed to respond to requests, questions, incidents or complaints.
Legal basis: performance of a contract, pre-contractual measures or legitimate interests, as applicable.
Data strictly necessary for the following purposes may be processed:
Legal basis: legitimate interests.
Data may be retained and used where necessary for the establishment, exercise or defence of rights in administrative, judicial or extrajudicial proceedings.
Legal basis: legitimate interests and, where applicable, compliance with a legal obligation.
Short-Term Rental Accommodation activities carried out in the Autonomous Region of the Azores are subject to specific tourism, statistical, tax and administrative obligations.
In this context, Azorean Living may process the information necessary to comply with these obligations, including for:
Whenever the processing of personal data is necessary to comply with these obligations, such processing will be limited to the required data and carried out on the basis of compliance with a legal obligation.
Where legally required, certain data relating to foreign guests may have to be reported through the Sistema de Informação de Boletins de Alojamento — SIBA, or through any system that legally replaces it.
For this purpose, Azorean Living may collect and process the identification data necessary to comply with the obligation to report guests’ accommodation and departure.
Processing carried out for this purpose arises from a legal obligation and does not depend on the guest’s consent.
Where information contained in identification documents is requested, it will only be used to the extent necessary for the management of the stay and compliance with legally applicable obligations.
Azorean Living will always seek to apply the principle of data minimisation, avoiding the collection or retention of information that is not necessary.
The presentation of an identification document does not, in itself, mean that a full copy of the document will be retained.
Where only certain information is necessary, only that information will be processed, unless a legal obligation requires otherwise.
Where a booking is made through an external platform, Azorean Living may receive the data necessary for the management of the booking and stay.
Such platforms may process personal data independently and in accordance with their respective privacy policies.
This Policy applies to processing carried out by Azorean Living after receiving the data.
The data subject should also consult the privacy policy of the platform through which the booking was made.
Some of the accommodation marketed or managed by Azorean Living is owned by third parties.
Where necessary for the management of the property, compliance with legal obligations, performance of the management agreement or resolution of a particular incident, only the data strictly necessary for the purpose concerned may be made available to the property owner.
Azorean Living will not make personal data available to property owners for purposes unrelated to the management of the property or the corresponding contractual relationship without an appropriate legal basis.
Depending on the specific nature of the processing, Azorean Living and the property owner may assume different responsibilities in relation to the data processed, in accordance with applicable legislation and the contractual relationship established.
Payments made through the website may be processed by specialised payment service providers.
Azorean Living may receive only the information necessary to:
Payment service providers may act as independent data controllers in relation to the data necessary to process the transaction, in accordance with their respective privacy policies and legal obligations.
Azorean Living does not sell or trade personal data.
Data may only be disclosed where necessary for the provision of services, the management of the business or compliance with a legal obligation.
Depending on the circumstances, recipients of the data may include:
Where a third party processes personal data on behalf of and in accordance with the instructions of Azorean Living, the contractually required measures will be adopted to ensure the confidentiality, security and protection of such data.
Some technology providers may store or process personal data outside the European Economic Area.
Where an international transfer of data takes place, Azorean Living will seek to ensure that it is carried out through a legally recognised mechanism, including:
The data subject may request additional information regarding the applicable safeguards using the contact details provided in this Policy.
Personal data will only be retained for the period necessary for the purpose for which it was collected.
Where a statutory or regulatory retention period applies, that period will be observed.
In the absence of a specific period, Azorean Living will determine the retention period taking into account:
In particular:
When there is no longer a legal basis for retention, the data will be deleted, anonymised or made inaccessible in accordance with appropriate procedures.
Azorean Living adopts appropriate technical and organisational measures to protect personal data against:
Access to data shall be limited to persons who require such information for the performance of their duties.
Service providers that have access to data on behalf of Azorean Living are also subject to the confidentiality and security obligations applicable by law.
No system can guarantee absolute security. However, Azorean Living will seek to maintain measures proportionate to the risk and update them whenever necessary.
In the event of a personal data breach, the legally required procedures will be adopted, including, where applicable, notification to the supervisory authority and affected data subjects.
Under applicable legislation and where the relevant conditions are met, the data subject may exercise the following rights:
The exercise of these rights may be subject to the limitations provided for by law.
In particular, a request for erasure does not require the deletion of data that must be retained in order to comply with a legal obligation or for the establishment, exercise or defence of rights.
The data subject may exercise their rights by contacting:
The request must provide sufficient information to identify:
Azorean Living may request additional information strictly necessary to verify the identity of the applicant and prevent unauthorised access to third-party data.
Requests will be handled within the time limits established by applicable law.
The exercise of rights is, as a rule, free of charge, without prejudice to exceptional circumstances provided for by law.
The data subject has the right to lodge a complaint with the competent supervisory authority if they consider that the processing of their personal data infringes applicable legislation.
In Portugal, the supervisory authority is:
Comissão Nacional de Proteção de Dados — CNPD
The data subject may contact Azorean Living beforehand in order to seek clarification or resolve any matter relating to the processing of their data, without this limiting their right to lodge a complaint with the CNPD.
Azorean Living may send communications relating to accommodation, services, campaigns, content or news where there is a legal basis permitting it to do so.
Where consent is required for the sending of commercial communications, it will be requested freely, specifically, on an informed basis and unambiguously.
Within an existing commercial relationship, and where legally permitted, communications relating to Azorean Living’s own products or services similar to those previously contracted may be sent, while always ensuring that the recipient is able to object in a simple and free manner.
Each commercial communication sent by electronic means shall provide an appropriate method for opting out of future communications.
The data subject may also directly request that communications cease by contacting:
The withdrawal of consent or objection to commercial communications does not affect communications strictly necessary for the performance of a booking or contract.
Consent is only one of the possible legal bases for the processing of personal data.
Data necessary for the performance of a booking, provision of a service, performance of a contract or compliance with a legal obligation does not depend on the data subject’s consent and is processed on the basis of the appropriate legal ground.
Whenever consent is required, Azorean Living will seek to ensure that it is:
Consent may be withdrawn at any time and as easily as it was given.
Azorean Living’s services are not intended to be contracted directly by minors.
However, data relating to minors may be processed where they are included in a booking or stay accompanied by their respective responsible adults.
In such circumstances, only the data necessary for the management of the booking, the safety of the stay or compliance with legally applicable obligations will be processed.
As a general rule, Azorean Living does not make decisions based exclusively on automated processing of personal data that produce legal effects or similarly significantly affect the data subject.
If processing of this nature is implemented, the additional information required by law will be provided.
The website may contain links to or integrations with services belonging to third parties, including:
These entities may process personal data under their own responsibility.
The use of these services is subject to their respective privacy policies, which should be consulted by the User.
Cookies are small files or sets of information stored on the device used to access a website.
They may be used for different purposes, including:
The use of cookies and similar technologies is subject to applicable legislation concerning privacy and electronic communications.
The Azorean Living website may use the following categories:
These are essential for the operation of the website or the provision of a functionality expressly requested by the User.
They may be necessary, in particular, for:
Where they are genuinely strictly necessary for the provision of the requested service, they do not depend on the User’s consent.
These allow choices to be remembered or additional functionalities to be provided that are not strictly essential to the basic operation of the website.
Where legally required, they will only be used after consent has been given.
These make it possible to understand how the website is used and to assess its performance and may collect information about:
Where they are not strictly necessary, they will only be activated after the User has given consent.
These may be used to:
These cookies will only be used where the legally required consent has been obtained.
Some website functionalities may use services provided by third parties.
Depending on the tools actually used, these may include:
These entities may use cookies or similar technologies in accordance with their respective policies.
Where their use depends on consent, elements subject to such consent should not be activated before the User has made their choice.
An up-to-date list of the cookies in use, their provider, purpose, category and duration should be accessible through the website’s Cookie Preferences Manager.
The storage of or access to information on the User’s device depends on prior consent, except where the cookie or technology is:
For this reason, non-essential cookies subject to consent should only be activated after a valid choice has been made by the User.
Simply accessing or continuing to browse the website should not, in itself, be interpreted as consent to non-essential cookies.
When accessing the website, the User may manage their preferences through the consent mechanism provided.
It should be possible to:
Rejecting non-essential cookies will not, in principle, prevent access to the website’s basic functionalities.
Certain optional functionalities may, however, depend on the use of specific cookies.
The User may change their preferences or withdraw consent relating to non-essential cookies at any time through the Cookie Preferences Manager available on the website.
Withdrawing consent should be as easy as giving it.
Withdrawal does not affect the lawfulness of processing carried out previously.
The User may also manage certain cookies through their browser settings, although disabling strictly necessary cookies may affect the operation of certain functionalities.
Cookies may be:
Session Cookies
These remain only for the duration of the session and are normally deleted when the browser is closed.
Persistent Cookies
These remain on the device for a predefined period or until they are deleted.
The specific duration of each cookie will depend on its purpose and the relevant provider.
Information relating to the duration of the cookies actually used should be available through the Cookie Preferences Manager.
Azorean Living may update this Policy whenever necessary, including as a result of:
The version in force will be the version published on the website and identified by its respective update date.
Whenever a change has a significant impact on the processing of data or on consent previously given, any additional measures required by law will be adopted.
For matters relating to privacy, personal data protection, cookies or the exercise of data subject rights:
MR Lodge Management, Lda.
Azorean Living
Avenida D. João III, n.º 3, 3.º D
9500-310 Ponta Delgada
Azores — Portugal
Email: geral@azoreanliving.com
Website: www.azoreanliving.com
