LGPD · Law 13.709/2018
Privacy Policy
Last updated: [CONFIRM date]
[CONFIRM — this document is a structural template within the mockup. It must be reviewed by a lawyer and completed with the company's real details before launch. No company name, CNPJ, address, email or period below is real.]
1. Data controller
The controller of personal data processed through this site is [CONFIRM registered company name], CNPJ [CONFIRM], registered office at [CONFIRM full address], Florianópolis — Santa Catarina, Brazil.
Privacy contact: [CONFIRM DPO email]. Data Protection Officer: [CONFIRM name or “not applicable”].
2. What we collect and why
| Data | When | Purpose | Legal basis (LGPD art. 7) |
|---|---|---|---|
| Name | Booking form | Identify the booking | Pre-contractual steps (item V) |
| Email and phone / WhatsApp | Booking form | Confirm the booking | Pre-contractual steps (item V) |
| Check-in / check-out dates, guests | Booking form | Check availability | Pre-contractual steps (item V) |
| Special requests | Booking form | Handle the request | Consent (item I) |
| Guest details required at check-in | At check-in, in person | National guest register (FNRH) | Legal obligation (item II) |
| Newsletter, if subscribed | Send communications | Consent (item I) | |
| Analytics cookies | Browsing, if permitted | Measure site usage | Consent (item I) |
| Marketing cookies | Browsing, if permitted | Measure campaigns | Consent (item I) |
3. Cookies
Essential cookies keep the site working and remember your consent choice; they cannot be switched off. Analytics and marketing cookies are off by default and are only enabled if you tick the matching option in the banner. You can revisit your choice at any time by clearing site data in your browser.
| Category | Default | Examples | Retention |
|---|---|---|---|
| Essential | Always on | Consent record (stored in your browser) | [CONFIRM] |
| Analytics | Off | [CONFIRM tool — e.g. Google Analytics 4] | [CONFIRM] |
| Marketing | Off | [CONFIRM tool — e.g. Meta Pixel] | [CONFIRM] |
4. WhatsApp
The buttons on this site open a WhatsApp conversation with a pre-filled message. From the moment you send that message, the processing of your data in that app is also governed by Meta Platforms' privacy policy, over which we have no control.
5. Sharing
We do not sell personal data. We share it only with processors necessary to deliver the service:
- Website hosting — [CONFIRM]
- Analytics tool, if permitted — [CONFIRM]
- WhatsApp / Meta Platforms, when you start the conversation
- Public authorities, where legally required
International transfers: [CONFIRM — likely, if hosting or analytics sit outside Brazil. State the countries and safeguards.]
6. How long we keep it
Contact data and enquiries: [CONFIRM period]. Consent records: [CONFIRM period]. After that, data is deleted or anonymised, unless a legal retention duty applies.
7. Your rights (LGPD art. 18)
At any time, free of charge, you may request:
- confirmation that processing exists;
- access to your data;
- correction of incomplete, inaccurate or out-of-date data;
- anonymisation, blocking or deletion of unnecessary or non-compliant data;
- portability to another provider;
- deletion of data processed on the basis of consent;
- information about who we share your data with;
- information about your right to refuse consent and the consequences;
- withdrawal of consent.
To exercise any of these, write to [CONFIRM email]. We will reply within the statutory period. You may also petition the ANPD, Brazil's data protection authority.
8. Security
We apply technical and administrative measures to protect personal data. [CONFIRM measures — e.g. HTTPS, access control, backups]. In the event of a significant security incident we will notify you and the ANPD under art. 48.
9. Minors
This site is not directed at people under 18 and does not knowingly collect children's data. No image on this site depicts children or minors.
10. Changes
We may update this policy. The date at the top shows the last revision. Material changes will be flagged on the site.
A policy that did not exist before
No privacy policy was found on the published Haute Haus site, and the current contact form collects a name, an email address and a message with no visible consent checkbox at all. This document and the consent checkbox on the forms fix both. [CONFIRM whether a policy already exists at another address].
Availability enquiries
When you use the availability widget you send us check-in and check-out dates, a number of guests and a view preference. That goes straight into the service conversation and is used only to answer your enquiry and, if you book, to perform the stay (LGPD, art. 7, V). No third-party booking engine processes that data on this site. [CONFIRM which booking engine or OTA channel is in use today, if any].
Event enquiries
The events form collects a name, a WhatsApp number, the type of event, an approximate date and a guest count, solely to quote for and answer that enquiry. It is a separate funnel from room bookings and the data is not cross-used between the two.
Guest data during a stay
During a stay, lodging businesses in Brazil process identification data under a legal and regulatory obligation, including the national guest register (Ficha Nacional de Registro de Hóspedes) (LGPD, art. 7, II). That data is not used for marketing. [CONFIRM the retention period adopted].
Reviews and staff names
The reviews shown on the Haute Haus site today do not name the platform they came from, and some of them name staff members. No employee name is published without documented consent, and no review is displayed without an attributed source or anonymisation. No aggregate score is asserted.