This Privacy Policy for the Website: (hereinafter the “WEBSITE”) explains how we collect and process the personal data necessary to the provision of the services available through the WEBSITE, describing the practices adopted for that effect in a general and abstract form, wherefore the information that is provided may be supplemented or removed, in whole or in part, with other policies, notices or information of more specific nature that have eventually been, or may become, made available in the context of certain types of personal data management. This Privacy Policy applies exclusively to the processing of personal data collected through the WEBSITE and below we describe who we are, the personal data we might gather, for what purposes we can use your data, how we treat it, with whom we share it, how long we keep it, as well as ways to contact us and exercise your rights. 1. Who are we? Who is responsible for the Treatment of your Data? BONUSCOURAGE, LDA., hereinafter referred to as “BONUSCOURAGE”, is a company dedicated, amongst other things, to the management and administration of own and third-party real estate, the purchase, sale and leasing of real estate and the resale of real estate acquired for this purpose, real estate promotion, real estate consultancy and the provision of services related to these activities. BONUSCOURAGE is the company responsible for processing your personal data as laid down in the General Regulation on Data Protection and additional legislation on personal data protection in force in the countries in which the company operates. For any questions that arise about the treatment of personal data, please contact BONUSCOURAGE through the following contacts: • Head Office: Rua do Passeio Alegre, n.º 576, 4150-576 Porto • Telephone: +351 220 437 620 • Email: 2. Commitment BONUSCOURAGE is committed to protecting your privacy and is (depending on the reason behind your interaction with us) responsible for processing your personal data within the meaning of the data protection laws applicable in the European Union ("EU") and the European Economic Area ("EEA"). Therefore, it operates based on trust and transparency and has a strong commitment to the privacy and rights of personal data holders, acting in accordance with the provisions of the General Data Protection Regulation (GDPR) and other applicable legislation. This commitment is transposed into our daily relationship with our customers, staff, and suppliers. The privacy and safety of data which you entrusted us with are our priority. We undertake to only collect, store, process, convey or eliminate with transparency your personal data, which are essential for providing the best services. 3. Personal Data It is considered as Personal Data any and all information regarding a natural person (“data holder”) who is identified or identifiable, directly or indirectly, in particular by reference to an identifier. Examples of identifiers are the name, ID number, “email”, “IP address”, and/or one or more specific elements of physical, physiological, genetic, mental, economic, cultural, or social identity of the natural person. Your personal data may include, for example your name and contact details (physical or electronic) and your reservations. We may also receive your personal data from other companies, namely when they have gathered, processed, or stored such information in connection with a contract for the provision of services. BONUSCOURAGE may gather the personal data necessary for the provision of the contracted services, information requests or pre-contractual management, namely: • Customer data: full or abbreviated name, address, telephone, email, details of reservation – whenever they book with BONUSCOURAGE; • Credit card details: card holder name, card type, number, expiration date and security code – when payment is made using a credit card. This data will be managed by a third entity on the Website: • Customer data for signing up of newsletters: name, email, and country; • Contact details of user: name, email, telephone, type of question and message – whenever asked to be contacted. 3.1. What is the legal basis and purpose of the processing of personal data? The fundamentals that legitimize the processing of your personal data by BONUSCOURAGE are as follows: a) Consent: your personal data may be processed by manifestation of free, informed, and explicit will, in which you accept, by declaration, or unequivocal positive act, that your data will be processed by BONUSCOURAGE. By accepting the terms and conditions of the WEBSITE you are consenting the processing of your personal data. The provision of consent does not constitute a legal or contractual obligation. b) Legitimate Interest: Your personal data will be processed based on the legitimate interest of BONUSCOURAGE, to give response to contact requests forwarded to us, except in cases where your privacy and data protection rights legally prevail. c) In the context of the provision of services: your personal data will be processed to the extent strictly necessary for the provision of services contracted by you. If services are contracted from BONUSCOURAGE, the data collected through the website, just as any other obtained in the context of the relationship, will be used for the management of the quality of services as well as to allow their provision. d) Other purposes: BONUSCOURAGE may also use the personal data available for: • Management of service contracting through website contacts, as well as meetings scheduling; • Sending newsletters and other institutional communications actions within the activities of BONUSCOURAGE and FVC Group, including the companies that integrate it. 3.2. Why do we process your information? Your personal data may be collected and processed by BONUSCOURAGE for the following purposes: a) For the fulfilment of legal obligations to which the accommodation is subject, namely communications to the Immigration and Border Service, Invoicing Services, etc. b) For the purposes of executing the Temporary Accommodation Agreement for Tourists or the Local Accommodation Management Agreement entered into with each accommodation, namely payment transactions, entry and exit management, guest management, security deposits, provision of complementary services to the stay such as cleaning, transfers, management of contractual obligations or for the purposes of pre-contractual procedures. c) For the purposes of Marketing and Customer management, to inform via email, mobile and digital platforms, about highlights and offers that may interest you and to replay to your information requests. d) For the purpose of protecting property owned or in the custody of each accommodation, as well as for the purposes of statistical analysis. Failure to provide personal data for the purposes set out in points a) and b), implies the breach of legal obligations imposed on it and, consequently, the possibility of terminating the Temporary Accommodation Agreement for Tourists or the Local Accommodation Management Agreement concluded, without the right to any compensation, as well as a deficient supply of services by each accommodation that cannot be attributed to it. The processing of your personal data will be carried out based on the performance of the Temporary Accommodation Agreement for Tourists, the Local Accommodation Management Agreement and the fulfilment of legal obligations imposed on each accommodation, namely by legislation on matters of Entry, Stay and Departure of Foreigners in the National Territory and tax legislation. 3.3. What is the retention period of your personal data? BONUSCOURAGE conserves your personal data only for the period strictly necessary to the pursuance of the finality for which they were collected. Within the provision of services, we will conserve your personal data in conformity with the legal time limits applicable to the processing at hand. If there is no specific legal obligation your data will be processed only for the period strictly necessary to fulfil the purposes that motivated its collection, if legitimate ground remain, or as long as you give consent and allow its retention by BONUSCOURAGE. Once the maximum retention period has been reached or if you withdraw your consent, all personal data will be irreversibly anonymised and may be stored or destroyed/deleted in a secure manner. 3.4. Who can we share your personal data with? BONUSCOURAGE commits to only transmit your personal data when that reveals necessary to the pursuit of the purposes described, in particular to the provision of services, for the fulfilment of legal obligations to which BONUSCOURAGE is subject, as well as to send communications authorized by you. BONUSCOURAGE suppliers and/or service providers are contractually subjected to the same terms and conditions of personal data processing as the former, and are prohibited of using, transferring, disclosing, or recording the personal data of the user for any other purpose than the one that for which they were specifically contracted. Additionally, we may share your personal data with other organizations/third parties in the following circumstances: • if we are required by applicable laws or a public authority to share information about you; • if we need to share information about you, in order to establish, exercise, defend or protect the rights, property or safety of our business, our customers, or others. This includes, in specific cases, exchanging information with other organisations for fraud protection purposes; and • to successors or replacement operators of all or part of our respective businesses. 3.5. What are your rights? BONUSCOURAGE guarantees to the holders of the personal data the exercise of their rights, established in the Data Protection Legislation, namely, the right o