Privacy Policy

PRIVACY POLICY 1. Who is the data controller for your personal data? The data controller responsible for the collection and processing of your personal data is Be In Houses, operating under the name and trade mark “BE IN HOUSES” (hereinafter “BE IN HOUSES”), which provides Local Accommodation management services and, in this context, determines what data is collected, the means of processing and the purposes for which the data is used. BE IN HOUSES is responsible for monitoring compliance of the processing with applicable regulations, for providing clarifications and for cooperating with the National Data Protection Commission. BE IN HOUSES may be contacted via the available channels, such as [telephone number to be filled in] or mailto:info@beinhouses.com. 2. What personal data is collected and processed, and how is it obtained? Personal data is any information, of any nature and in any medium, relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified, directly or indirectly, by any element that allows their identification. The personal data processed includes, in particular, name, contact details, postal address, email addresses, telephone numbers, civil and tax identification documents, tax information and billing details, bank details (where applicable to the processing of payments or refunds), data relating to visits to the website or communications sent electronically, and information regarding bookings, stays and services contracted. The data protection rules apply only to the collection of data relating to natural persons; they do not concern data relating to companies or other legal entities. However, in the course of performing the contract, personal data relating to owners, guests, partners, managers and/or employees of partner companies may be collected. Personal data is collected as part of the process of contracting our Local Accommodation management services (including bookings made via platforms such as Booking.com, Airbnb or VRBO) or as part of pre-contractual arrangements leading to a potential contract, and may extend to third parties where necessary for the proper performance of the services to be provided. 3. How and on what legal basis do we use personal data? The personal data collected is used for pre-contractual arrangements, for the performance of the Local Accommodation management or booking contract, and also to comply with legal obligations (notably tax and guest registration obligations) and for direct marketing (on the basis of legitimate interest), as explained below. Personal data is processed to provide information requested by the customer or owner and to guide and manage the contractual relationship. Your data is also processed to comply with tax legislation, Local Accommodation registration requirements, and legislation on money laundering and terrorist financing, as well as to fulfil our legal, regulatory and risk management obligations. The legal bases for processing are: • Consent: where the data subject gives their free, informed, specific and unambiguous consent, either in writing or verbally.     • Pre-contractual measures: when you send us a request for information via email, our website, WhatsApp or any available form, in order to request information or quotes regarding our Local Accommodation management services.     • Performance of a contract: when the processing of personal data is necessary for the performance of the Local Accommodation management contract with the owner, or for the management of the guest’s booking and stay. • Compliance with a legal obligation: where the processing of personal data is necessary to comply with a legal obligation, such as the obligation to identify and register guests, the payment of the Municipal Tourist Tax (TMT), or the disclosure of data to police, judicial, tax or regulatory authorities.     • Legitimate interest: where the processing of personal data serves a legitimate interest of BE IN HOUSES, such as processing data to improve service quality and for marketing and advertising purposes relating to Local Accommodation management services. When you subscribe to the newsletter or other free content, personal data such as your name, email address and telephone number are collected for the purposes of direct marketing relating to BE IN HOUSES’s activities. The use of data for this purpose is not considered to infringe upon the fundamental interests, rights or freedoms of the data subject. In any event, the data subject is always given the option to opt out of receiving further advertising. 4. Who are the data subjects? The individual user to whom the data relates — namely guests, property owners or their representatives — even if acting on behalf of a legal entity, and who has contracted or demonstrates any intention to contract the services of BE IN HOUSES, via the website or by other means, even if this is simply by submitting a contact request. 5. What categories of personal data are processed? BOOKING MANAGEMENT (GUESTS): name, email address, telephone number, tax identification number or identity document (where required by legal obligations regarding guest registration), address, check-in/check-out details. Local Accommodation Management (OWNERS): name, email address, telephone number, tax identification number, tax address, bank details (for invoicing and payment purposes), identification document, property details and Local Accommodation registration details. COMPLETING THE CONTACT FORM: name, email address and telephone number. SCHEDULING A MEETING/VISIT: name, email address and telephone number. NEWSLETTER: email address. Municipal Tourist Tax (TMT): guest details required to fulfil reporting obligations to the relevant local authorities. [Note: this section must be reviewed and amended as soon as BE IN HOUSES has defined the specific tools and platforms used on the website and in the booking process.] 6. How long do we process your personal data? Your personal data is processed only for as long as is necessary to fulfil the defined purpose and, where applicable, in particular:     • Invoices, receipts and accounting documents: for 10 years, the data required to provide information to the Tax Authority for accounting or tax purposes.     • Name, email address, telephone number and history of bookings or communications exchanged with the customer/owner: for the duration of the contractual relationship plus 20 years, as this is the limitation period for contractual civil liability, in accordance with Article 21(3) of the GDPR.     • Guest registration data required by law: for the retention period required by the applicable legislation. Once the relevant retention period has elapsed, the data will be deleted or anonymised, in cases where it is not required to be retained for any other purpose that may still apply. 7. With whom do we share your personal data? Your personal data is not sold, rented or made available to third parties for commercial purposes. The sharing of your personal data with third parties, in accordance with the contractual and legal provisions in force, is restricted to:     • Public bodies, including, but not limited to, the Tax Authority, Social Security, local councils (for the purposes of tourist tax and the registration of Local Accommodation), amongst others.     • Booking platforms through which services are provided, such as Booking.com, Airbnb and VRBO. • Professionals who collaborate with BE IN HOUSES, either under an employment contract or a service provision agreement.     • BE IN HOUSES’ service providers, in particular IT service providers, in relation to the installation and maintenance of software used, as well as providers of marketing, customer management, accounting and legal advisory services. Where necessary or required, personal data may also be shared with regulatory authorities, courts and official bodies. Although unlikely, we may be obliged to disclose your data to comply with legal requirements. We will make reasonable efforts to notify you prior to such disclosure, unless we are legally prevented from doing so. 8. How do we protect personal data? Appropriate, necessary and sufficient logical, physical, organisational and security measures are in place to protect your personal data against destruction, loss, alteration, disclosure, unauthorised access or any other form of accidental or unlawful processing. 9. To which countries do we transfer personal data? Where the provision of services involves the use of external platforms (such as booking platforms) or interaction with entities established outside Portugal, it may be necessary to transfer your personal data to third countries. Whenever such transfers take place outside the European Economic Area (“EEA”) and to countries not covered by an adequacy decision from the European Commission, processing will be carried out in strict compliance with Chapter V of the GDPR, ensuring the adoption of appropriate safeguards, such as standard contractual clauses approved by the European Commission, binding corporate rules or other safeguards recognised by the applicable legislation. In any event, the customer will be informed, wherever possible, of the categories of recipients and the security measures adopted to safeguard their data. 10. Do we use automation technology and/or artificial intelligence? As part of the provision of our services and the management of our relationships with guests and owners, we may use technological tools that incorporate artificial intelligence (AI) features, in particular for the purposes of customer support, personalising communications, optimising internal processes and/or data analysis. Whenever the use of these technologies involves the processing of personal data, this will be carried out on a legally valid basis for each specific case, ensuring that no fully automated decisions are made that produce legal effects or significantly affect data subjects without meaningful human intervention, in accordance with Article 22 of the GDPR. Where AI systems provided by third parties are used, we ensure that such suppliers comply with the data protection standards applicable in the European Union and that appropriate contractual and technical measures are in place to safeguard the security and confidentiality of the information. 11. What are your rights and how can you exercise them? • Right of access – this is the right to obtain confirmation as to which of your personal data are being processed and information about them.     • Right to rectification – this is the right to request the rectification of your personal data if it is incorrect or out of date, or to request that incomplete data be completed.     • Right to erasure or ‘right to be forgotten’ – this is the right to have your personal data erased, provided there are no valid grounds for retaining it.     • Right to data portability – this is the right to receive the data you have provided in a commonly used, machine-readable digital format, or to request the direct transfer of your data to another party who will become the new data controller.     • Right to withdraw consent or right to object – this is the right to object to, or withdraw your consent for, the processing of your data at any time.     • Right to restriction – this is the right to request the restriction of the processing of your personal data, in the form of a suspension of processing or a limitation of the scope of processing to certain categories of data or purposes.     • Right to lodge a complaint – this is the right to lodge a complaint with the supervisory authority, the CNPD, in addition to the company. Exercising these rights is free of charge, unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged, taking into account the costs involved. Information must be provided in writing, but may be provided orally if you so request. A response to requests must be provided within a maximum of 30 days, unless the request is particularly extensive or complex. Exercise your rights via the following address: mailto:info@beinhouses.com. Furthermore, you have the right to lodge a complaint with the supervisory authority, the CNPD (www.cnpd.pt (http://www.cnpd.pt/)), if you consider that the requirements of the GDPR or applicable national legislation regarding your personal data have not been met. Our Privacy Policy may be amended at any time; we will endeavour to inform you of any changes, but we advise you to read it before making any booking or entering into any contract.