Summary

1. Definition

2. Personal data collected

3. Personal data use

4. Personal data share

5. Your rights

6. How we protect your personal data

7. How long do we keep your personal data

8. Links to other websites

9. Changes to our Privacy Policy

10. How to contact us

1. Definition

This Privacy Policy applies to personal data that we collect when:

• you or third parties make a search or reservation;
• you stay at the hotel or hire any event service;
• you access our websites; and
• any kind of communication that happens with you.

The following sections of this Privacy Policy describe the types of personal data collected; how and for what purposes we use this personal data; with whom we share them, the choices and rights available for you about the use of your personal data. Finally, we describe the measures we take to protect the personal data we process and how to contact us about our privacy practices and how you can exercise your rights.

• Personal data collected;
• Use of personal data;
• Share of personal data;
• Your rights;
• How we protect your personal data;
• For how long we keep your personal data;
• Links to others websites;
• Updates of our Privacy Policy; and
• How to contact us.

2. Personal data collected

2.1 Personal data that you willingly provide while accessing our websites.

We will collect, store and process the information you willingly provide through the contact forms available on the website:

2.1.1 OTHON.COM.BR 

• Contact: 

Name, email and phone.

• Events: 

Name, last name, email, phone and company name.

• Reservations: 

The data collected is an external service provider responsibility, which collects the name, last name, email, phone, identity or travel document, birthday, credit card number and cardholder name.

• Work with us:

The data collected is an external service provider responsibility, which collects the name, last name, email, phone, birthday, identity documents and full address.

2.1.2 CIAHOTEISOTHON.COM.BR 

• Talk to RI: 

Full name, email, phone and company.

2.2 Personal data automatically collected when you visit our websites.

When you access the website OTHON.COM.BR and/or CIAHOTEISOTHON.COM.BR, we may collect some data through the use of "cookies" and other automated means. Cookies are small data files stored by your browser on your computer's hard drive. This collected data is an external service provider responsibility and may include the following information:

• Date and time;
• IP address source;
• Domain name;
• Browser and operating system used (if provided by the browser);
• URL of visited page (if provided by the browser);
• Requested object;
• Order completion status;
• Geographic location; and
• Language references.
• 
  

To learn more about cookies and how you can exercise your choice regarding the collection of information, access our management tool available on the websites.

2.3 Personal data that you willingly provide through different means, according to the offered service by Hotéis Othon.

• Sales and Reservations: 

Full name, nationality, birthday, email, phone, occupation, marital status, gender, identity documents (CPF for brazilians or Passport/CNR for foreigners), full address (zip code, city, state and country), identity documents copies (CPF for brazilians or Passport/CNR for foreigners), CNPJ, company name and social contract copy.

• Events: 

Full name, email, phone, CPF, full address (zip code, city, state and country), CNPJ, company name and social contract copy.

• Company registration: 

Full name, email, phone, CNPJ and function of the person responsible for the registration.

• Reception:

Adult - full name, nationality, birthday, email, phone, occupation, marital status, gender, identity documents (CPF for brazilians or Passport/CNR for foreigners), full address (zip code, city, state and country) and identity documents copies (CPF for brazilians or Passport/CNR for foreigners).

Minors (under 18 years old) - full name, nationality, birthday, identity documents (CPF/RG/Birthday Certificate for brazilians or Passport/CNR for foreigners), father’s full name, mother’s full name, guardian's full name, guardian's full address (zip code, city, state and country), guardian’s phone number, guardian’s identity documents (RG/CPF for brazilians or Passport/CNR for foreigners), minor’s identity documents copies (CPF/RG/Birthday Certificate for brazilians or Passport/CNR for foreigners), guardian’s identity documents copies (RG/CPF for brazilians or Passport/CNR for foreigners) and a guardian’s authorization copy authenticated by a notary's office or by the competent judicial authority (for the unaccompanied minor).

• Kids Area:

Guardian's full name, guardian's phone number and minor’s full name.

• WI-FI Access:

The collected data is an external service provider responsibility, which collects full name, email and birthday.

2.4 Personal data collected by third parties.

We may receive your personal data, through sharing, by a third party that acts as an intermediary between you and Hotéis Othon for reservations. In this process, third parties use their own means to collect and share your data with us, being responsible for consents and authorizations.

2.5 Sensitive personal data.

We do not collect data that is sensitive (e.g., genetic data, biometric data, racial or ethnic origin data, political opinions, sex life, sexual orientation, religion or other beliefs, health-related data, criminal record or trade union) unless you willingly prodive them to us.

We will only use sensitive personal data when you provide them with your explicit consent, to meet your needs to the best of our ability.

Examples of sensitive personal data that we may collect and process include:

• Food allergies;
• Dietary requirements that may imply or suggest your religion and/or health;
• Mobility needs; and
• Medical conditions.
  

3. Personal data use

Hotéis Othon, as a provider of hospitality experiences, has a legitimate business interest to use and process your personal data. Do not worry, as we will only use your personal data if its processing doesn’t harm your interests, rights and freedoms.

Your personal data may be processed by automated and manual means to:

• Comply with any legal and/or regulatory provisions;
• Ensure the safety and security of our guests and visitors;
• Provide the products or services you have requested, including personalized services;
• Help us create content that is relevant to our guests and visitors;
• Make improvements to our websites and social media to ensure that our content is presented in the most effective way to you;
• Provide you with information, products or services that you request or that we believe may interest you;
• Rate and help us understand general trends and patterns related to our business.
• 
  

We may use them in other ways, always providing prior and specific notice, and asking, if necessary, your consent.

We may also use your personal data to avoid and prevent fraud, claims and other liabilities and to comply with or apply legal requirements relevant to the business. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights.

We will only process your personal data for marketing purposes when you give us your prior and specific consent. You have the right to withdraw your consent at any time:

The decision to provide us with personal data (including sensitive personal data) is voluntary. However, if you do not provide such personal data, you may not be able to benefit from our services.

4. Personal data share

We only disclose or share data we collect and maintain about you in the situations described below:

• Shares with other members of Hotéis Othon, who may use this data to meet legal requirements and offer products or services to you, respecting the purposes stated in this Privacy Policy;
• Third party service providers who have been designated as data processors to perform functions and services on our behalf, and who will receive only the personal data necessary to perform the services on our behalf; and that are not authorized to use this data for any other contracted purposes;
• Third-party providers of any holiday package, excursion, transfer, activity/experience organized by a concierge or any other service that we arrange at your request;
• To our consultants and insurers in the event of a claim, dispute or when necessary; and
• If we are required to do so by law or in accordance with a legal process or to comply with any applicable rules or regulations, or in response to a request from law enforcement or other Government officials.

5. Your rights

If you are a "data holder", you will have the following rights about your personal data processed by us:

• Right of access - request confirmation of the processing of your personal data and, if so, request a copy of that personal data;
• Right of correction - request that we rectify or update any personal data that is inaccurate, incomplete or out of date;
• Right of exclusion - request that we erase your personal data in certain circumstances. Except cases where the treatment is based on law or government regulation;
• Right to withdraw your consent - when you have given us consent to process your personal data and have decided to withdraw your consent. If you withdraw your consent, we may not be able to provide certain services; and
• Right to data portability - request the transfer of your personal information to another service provider.

To help protect your privacy and maintain your information secure, we may take steps to verify your identity before processing your request.

6. How do we protect your personal data

Hotéis Othon adopts administrative, technical and physical measures designed to protect the personal data against destruction, loss, change, access, disclosure or accidental, illegal or unauthorized use.

Service providers and hired people who may have access to your data to provide services on our behalf will be contractually obligated to keep such data confidential, provide proper information security measures and may not use such data for any other purpose.

7. How long do we keep your personal data

We only keep your personal data for as long as necessary to fulfill the purposes for which they were collected, unless we are required or permitted by law to keep it longer.

8. Links to other websites

Our websites may provide links to other websites for your convenience and information. These sites are not linked to Hotéis Othon. Therefore, we are not responsible for the content, as well any use or privacy practices of these sites. As we do not own them and do not control them, we suggest that, before any navigation, you review them, checking the terms of use and their policies.

9. Changes to our Privacy Policy

This Privacy Policy may be updated periodically and without notice to reflect changes in the handling of your personal data and privacy practices. We will post a notice on our website to notify you of any relevant changes to our Privacy Policy, indicate at its top when it was last updated and provide a link to previous versions.

10. How to contact us

Hotéis Othon provides an exclusive channel for matters related to data protection.

If you have any questions or comments about this Privacy Policy or the use of cookies, if you want us to update your personal data, your preferences, or to exercise your rights, please send an email to our data protection officer.

Data Protection Officer/DPO of Hotéis Othon:

• Name: Roberto Razuck
• Location: Av. Atlântica, 3264 / Sala 526 - Copacabana - Rio de Janeiro - RJ, 22070-001
• Office hours: Monday to Friday, working days, 09:00 a.m. to 6 p.m.
• Initial form of contact: Email
• Email address: dpo@othon.com.br

After we receive your email, we will provide you a protocol number so that we can track the progress of your request together. During the analysis of your communication, we will keep you informed through email or phone.

In order to establish contact quickly, inform your full name, phone number, email address and a detailed description of the reason for the contact correctly.