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.
Why this policy is new
The current Hotel Hola site runs a cookie banner on consent by continuing — “Ao clicar em ‘ok’ e continuar navegando, você concorda com a nossa política de privacidade”. Continuing to browse is not consent under the LGPD: consent must be a free, informed and unambiguous affirmative act. The current banner also offers no way to refuse. This document and the new banner fix both: refusing is exactly as easy as accepting, and nothing non-essential runs before it is switched on.
WhatsApp service and the four departments
Hotel Hola runs four WhatsApp departments — Reservations, Questions or Information, Compliments/Suggestions/Complaints, and Cancel a Booking. Messages sent through that channel sit on the hotel’s device and on WhatsApp’s own servers, subject to Meta’s privacy policy. We use the channel only to handle your enquiry. [CONFIRM whether all four departments use the same number].
Availability enquiries
The availability widget on this site does not process a booking: it composes a message carrying your dates and guest count and hands it to the Reservations department on WhatsApp. No third-party booking engine processes that data here. [CONFIRM which booking engine or OTA channel is in use].
Guest data during a stay
Lodging businesses in Brazil process identification data under a legal and regulatory obligation, including the national guest register (LGPD, art. 7, II). That data is not used for marketing. [CONFIRM the retention period].
Controller and data-subject contact
[CONFIRM the registered name, the CNPJ and a real email address] — today no email address is published on any page of the site, which leaves a data subject with no written channel through which to exercise their rights. Publishing a real address is part of the fix.