PRIVACY POLICY

OF THE WEBSITE www.heritagepalace.pt

DATA CONTROLLER IDENTIFICATION

Name: HBJ – HOTEL MANAGEMENT, S.A.
Registered Office: Lugar do Bom Jesus 4715 056 Tenões, Braga
Tax ID (NIPC): 515924296
Phone:
Email: info@heritagepalace.pt

DUTY TO INFORM

The protection of personal data of individuals is governed in Portugal by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and by Law No. 58/2019, of 8 August, which ensure the protection of individuals with regard to the processing of personal data and the free movement of such data.

“Personal data” is considered to be any information, of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable individual, and therefore this protection does not cover data relating to legal entities.

An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more elements specific to their physical, physiological, psychological, economic, cultural, or social identity (for example, their name associated with their phone number or email address).

By reading this Privacy Policy, the User is informed about the processing of their personal data carried out by HBJ – HOTEL MANAGEMENT, S.A. through the website [www.heritagepalace.pt](https://www.heritagepalace.pt).

PURPOSES OF PERSONAL DATA PROCESSING

The personal data we collect and process through the Website identified above will be used solely for the following purposes:

  • To manage the contracting of services carried out through the Website, such as contact requests or booking management;
  • To periodically send communications with news related to the activity of HBJ – HOTEL MANAGEMENT, S.A. and to the sector to which its activity is dedicated;
  • Anonymous and aggregated analysis of service usage, to identify User habits and trends, in order to improve the services offered and meet the specific needs of Users;
  • In the event of contracting, the data collected on this Website, together with other data obtained within the scope of the contractual relationship, will be used for human resources management, to ensure compliance with legal obligations, and to provide employees with the means necessary to carry out their professional activity;
  • Compliance with national and international legal provisions, or to execute an order from the competent judicial authorities;
  • Compliance with legal obligations arising from applicable data protection legislation, as well as for the exercise of data subjects’ rights, in particular, the defense of a right in judicial proceedings.

HBJ – HOTEL MANAGEMENT, S.A. guarantees the confidentiality of all data provided.

Although HBJ – HOTEL MANAGEMENT, S.A. collects and otherwise processes data securely and in a manner that prevents its loss or manipulation, using the most appropriate techniques for this purpose, it should be noted that the collection of data on open networks does not allow personal data to circulate in conditions of absolute security, and there is a risk that it may be accessed and used by unauthorized third parties.

Failure to provide the data marked as mandatory may result in the inability to respond to the data subject’s request.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

HBJ – HOTEL MANAGEMENT, S.A. processes Users’ data:

  • when they give their free, specific, informed, and unambiguous consent to the processing of their personal data for certain purposes; and/or
  • when necessary for the performance of a contract to which the data User is party, or for pre-contractual steps taken at the User’s request; and/or
  • to comply with legal obligations to which HBJ – HOTEL MANAGEMENT, S.A. is subject; and/or
  • for the purposes of the legitimate interests pursued by HBJ – HOTEL MANAGEMENT, S.A. or by third parties, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring protection of personal data.

The User guarantees that the information provided is true, accurate, complete, and up to date, and is responsible for any damage or loss, direct or indirect, that may be caused as a result of breaching this obligation.

If the data provided belongs to a third party, the User guarantees that they have informed said third party of the aspects contained in this document and have obtained their authorization to provide their data to HBJ – HOTEL MANAGEMENT, S.A. for the purposes indicated.

DATA RETENTION PERIOD

HBJ – HOTEL MANAGEMENT, S.A. only retains and processes your personal data for the period necessary or required to fulfill the purposes described above, applying data retention criteria appropriate to each type of processing and in line with applicable legal and regulatory obligations.

HBJ – HOTEL MANAGEMENT, S.A. keeps personal data in its systems in such a way that data subjects can be identified according to the following criteria:

  • for a period not exceeding what is necessary for the purposes for which the data was collected, unless legal or contractual obligations provide otherwise;
  • to comply with specific legal or contractual obligations;
  • where applicable and legitimate, until any request for objection or erasure by the Data Subject.

DATA COMMUNICATION

In addition to communications made in compliance with legal obligations, the Data Subject’s personal data may be known to, besides HBJ – HOTEL MANAGEMENT, S.A., the following:

  • external service providers of HBJ – HOTEL MANAGEMENT, S.A., acting as subcontractors;
  • national and international companies belonging to the same group as HBJ – HOTEL MANAGEMENT, S.A.;
  • authorities in general, administrations, entities, and public bodies, both national and international;
  • HBJ – HOTEL MANAGEMENT, S.A.

INTERNATIONAL DATA TRANSFERS

The personal data collected will be processed within the European Economic Area, with no international data transfers to third countries or international organizations.

In the event of any processing of personal data outside the European Economic Area, this will only occur upon adoption of appropriate safeguards and the required level of protection, in accordance with personal data protection legislation.

INFORMATION SECURITY

HBJ – HOTEL MANAGEMENT, S.A. has implemented appropriate technical and organizational security measures to ensure the security of the personal data provided by the User, aiming to prevent its unauthorized alteration, loss, processing, and/or access, taking into account the current state of technology, the nature of the stored data, and the risks to which they are exposed.

Personal data is processed with the level of protection legally required to ensure its security and prevent unauthorized alteration, loss, processing, or access, taking into account the state of technology, with the User being aware of and accepting that internet security measures are not impregnable.

If HBJ – HOTEL MANAGEMENT, S.A. subcontracts other entities to provide services involving the transfer of personal data, those entities will be required to adopt the necessary technical and organizational measures to protect personal data against destruction, loss, alteration, unauthorized disclosure or access, or any other type of unlawful processing.

EXERCISE OF RIGHTS

In accordance with the provisions of the GDPR, the User may exercise their rights of access, rectification and, where applicable, restriction of processing, erasure, portability, objection, and withdrawal of consent, in accordance with the GDPR, by submitting a written request through any of the following means, specifying the right or rights they wish to exercise:

Email: info@heritagepalace.pt
Postal address: Rua D. Manuel II nr14 4050-365 Porto Portugal

SUPERVISORY AUTHORITY

The User also has the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (National Data Protection Authority) regarding matters related to the exercise of their rights and the protection of their personal data, should they consider that their data protection rights have been violated.

THIRD-PARTY PAGES

The Website may contain advertising, links, or other content that connects to or redirects to pages and services of suppliers, advertisers, affiliates, sponsors of HBJ – HOTEL MANAGEMENT, S.A., and other third parties.

However, HBJ – HOTEL MANAGEMENT, S.A. does not control the content or links that appear on such pages and is not responsible for the practices used by those pages or websites. HBJ – HOTEL MANAGEMENT, S.A. advises Users to review the privacy policy of such pages, as well as their terms and conditions.

Any research or interaction on any other website, including those with an external link to the Website, is subject to the terms and conditions of that website, and HBJ – HOTEL MANAGEMENT, S.A. is in no case responsible for such access and use.

DATA PROCESSING CARRIED OUT BY THE COMPANY THAT DEVELOPS AND MANAGES THE WEBSITE AS AN INDEPENDENT DATA CONTROLLER

Notwithstanding that the processing of data collected through the Website is the responsibility of HBJ – HOTEL MANAGEMENT, S.A., as identified above in Section 1 of this Privacy Policy, we inform the User that MIRAIFUTURE PORTUGAL, LDA., with registered office at Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil, and Tax ID (NIPC) 515 139 092, may act, in specific situations, as Data Controller, autonomously determining the purposes and means of processing.

This occurs, in particular, with regard to data processed to ensure the operation, maintenance, and security of the booking engine.

In such situations, the User’s data will be processed in accordance with the information below:

  • Purpose: to ensure the operability, security, and continuous improvement of the Website;
  • Legal basis: legitimate interest;
  • Retention period: for the period strictly necessary to fulfill these purposes.

Mirai ensures that, even in these situations, it only processes the data strictly necessary, adopting appropriate technical and organizational measures to guarantee its security and confidentiality.

The User may exercise the rights referred to in Section 9 by submitting a written request through any of the following means, specifying the right or rights they wish to exercise:

Email: portugal@mirai.com
Postal address: Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil

The User may also exercise the rights set out in Section 10.

CHANGES TO THE PRIVACY POLICY

In order to ensure the accuracy of this document, HBJ – HOTEL MANAGEMENT, S.A. reserves the right to review this Policy at any time it deems appropriate, and Users are therefore advised to check this privacy policy regularly and/or each time they access the Website.

Updated on 11/05/2026.