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 and long-stay form | Identify the booking | Pre-contractual steps (item V) |
| WhatsApp / phone | Booking / WhatsApp | Reply and send the access code | Pre-contractual steps (item V) |
| Booking and the My Bookings area | Confirmations and account access | Pre-contractual steps (item V) | |
| Dates, room type and bed count | Booking widget | Check availability | Pre-contractual steps (item V) |
| Identity document | At check-in, off the website | Guest registration required by law | Legal obligation (item II) |
| Building access code | Generated for your stay | Let you in without a reception | Pre-contractual steps (item V) |
| My Bookings account | If you create one | Keep the history of your bookings | Consent (item I) |
| Analytics cookies | Browsing, if permitted | Measure site usage | Consent (item I) |
| Marketing cookies | Browsing, if permitted | Measure campaigns | Consent (item I) |
Prices and bookings. This site processes no payment and stores no card data. The booking widget hands the query to Smart Hostel's booking engine [CONFIRM which one], and the long-stay form only composes a WhatsApp message that you send yourself — nothing is stored here and nothing is emailed with your details in the URL.
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.
My Bookings — the account area
Smart Hostel already runs a guest login. An account area holds personal data continuously, not just for the duration of a booking, so it needs three things written down and working: a lawful basis for each piece of data held, a stated retention period, and a deletion path the guest can use unaided. [CONFIRM all three]
The building access code
Because there is no reception, the access code is a security credential rather than an operational detail. Which channel it is sent through, how long it stays valid and when it is revoked [CONFIRM]. It should never travel over an open channel unnecessarily, and it should stop working at the end of the stay.
Guest registration
Accommodation carries its own registration obligations. Which documents are required by law, how long they are kept and who has access [CONFIRM]. That data is collected at check-in, not by this website.