Privacy Policies

For Enotel Hotels & Resorts, a private law legal entity, regularly registered in the Registry of Legal Entities under number 03.787.288/0001-84, the privacy and security of the personal data of guests, investors, visitors and other partners are aspects that assume crucial importance for the company.

This policy applies to all systems, people and processes that make up the information system of Enotel Hotels & Resorts. The commitment to the security of personal data has been assumed by the Management of Enotel Hotels & Resorts and extends to all employees of the organization. Enotel Hotels & Resorts promotes information security and protection in the processing of personal data held by the institution and collected through traditional operators and tourist agencies and online operators (OTA), online reservation center (incorporated in the website https://www.enotel.com/). This Policy explains how your Personal Data is collected, used and disclosed by Enotel Hotels & Resorts. It also informs you how you can access and update your Personal Data and make decisions about how your Personal Data is processed.

This Policy covers both our online and offline data collection activities, covering Personal Data that We collect through our various channels, including but not limited to Websites, Applications, Third Party Social Networks, Customer Service, Points of Sale, Surveys and Events. Please note that We may aggregate Personal Data combined from different sources (e.g., our websites and offline events).

Enotel Hotels & Resorts is defining procedures for the company's compliance with the principles described and requirements based on the new General Data Protection Law (LGPD), for existing information systems and to carry out a prior impact assessment and implementation of privacy measures in new data processing to be carried out in the future.

To find out more details about how we collect, use, share, process and protect the personal data we obtain, please consult the following sections of this Privacy Policy.

1. O Enotel Hotels & Resorts

Enotel Hotels & Resorts is a hotel group with a presence in Porto de Galinhas – PE, Brazil and Madeira Island, Portugal, dedicated to guest accommodation and related services related to well-being and leisure. The person responsible for processing personal data at Enotel Hotels & Resorts is located at Rodovia PE09 – Gleba 6A – Porto de Galinhas - Ipojuca – PE, CEP: 55.590-000.

2. Categories of Personal Data processed by Enotel Hotels & Resorts

When processing personal data, we respect your privacy and reiterate our commitment to implementing compliance measures, in particular to ensure:

1. Lawful processing, supported by a legal basis, legitimate interest or consent of the data subject;
2. That the processing is limited to the purpose for which the data were made available;
3. That there are mechanisms to obtain accuracy and completeness of the data provided by you;
4. Minimizing the data required, requesting only that which is appropriate for the purpose;
5. The limitation on data storage, in accordance with the defined retention periods; and
6. The implementation of measures for the integrity and confidentiality of information.

During your interaction with Enotel, using one of the previously mentioned collection sources, we may collect various types of personal data about You, as set out below:

• Contact Information: Includes any type of information that may facilitate our contact with You, including your physical mailing address, telephone numbers, email addresses, websites and social media profiles;
• Login information: Includes information to identify and authenticate yourself in services provided by Enotel, including your registration name (login), password in unrecoverable format (encrypted), and security questions;
• Online Pre-Check-in: Includes information on the website, email or application such as name, contact details (email/telephone), Check-in date, Check-out date, not limited to these data, with the purpose of offering you the expected level of hospitality and to be able to provide the best level of service, with the aim of speeding up your service and avoiding crowding at Reception, based on the legal basis of the Ministry of Tourism;
• Child check-in: The child check-in form includes information such as name, date of birth of the minor/guardian, details of the guardian, degree of kinship, age of the minor/guardian, guardian's email, guardian's telephone number and consent to carry out recreational activities with the Enotel Sports & Leisure Team;
• Demographic information and your interests: Any information that may describe your demographic data, habits or behavioral characteristics, including items such as your birthday, date of birth, age or age range, gender, geographic location, favorite products, hobbies and pastimes, other interests and family or lifestyle information;
• Technical information about your computer equipment or mobile device: Details about your computer or other portable device that was used to access one of our websites, Wi-Fi, services or applications, including the IP address used to connect your computer or device to the internet, including your geographical location, operating system type and version and web browser type and version. If you access an Enotel website or application using a mobile device, such as a mobile phone or tablet, the information collected will also include, where permitted, your phone’s unique device ID, geographical location and other similar mobile device data;
• Information about how you use our websites and services. During your interaction with our websites and services, we use automatic data collection technologies to capture information about the actions you take. This may include details such as which links you click, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is collected through automated technologies such as cookies (browser cookies, Flash cookies and similar) and web beacons, and also via third party tracking. You are free to object to the use of such technologies, for details see the Section “About your rights regarding personal data”;
• Market research and consumer feedback: This is information that you voluntarily share with Enotel about your experience using our products and services;
• Consumer Generated Content: This includes any content that You create and share with Enotel on third-party social networks or by uploading it to one of our websites, applications and other online and offline services, including through the use of third-party social networking applications such as Facebook, Instagram, Linkedin and similar. This data includes text, comments, articles, photos, videos, personal stories or other similar content and media. Where permitted, We collect and publish consumer generated content in connection with a variety of activities, including advertising of Enotel products and services, contests, giveaways and other promotions, website community features, consumer engagement and third-party social networks;
• Third-Party Social Network Information: This is any information that You share publicly on a third-party social network or information that is part of Your profile on a third-party social network (such as Facebook, Instagram, Linkedin and similar) and that You allow the third-party social network to share with Us. This information may include details such as Your basic account information (name, email address, gender, date of birth, current city, profile picture, user ID, friends list and similar information) and any other additional information or activities that You allow the third-party social network to share with Us. We receive Your third-party social network profile information (or parts thereof) whenever You download an item or interact with an Enotel application or web service on a third-party social network, whenever You use a social network feature that is integrated into an Enotel website or whenever You interact with Us through a third-party social network. To learn more about how your information from a third party social network is obtained by Enotel or to opt out of sharing such social network information, please visit the website of the specific third party social network;
• Financial and payment information: Any data that Enotel needs to fulfill an order, or that You use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other payment methods used. Enotel or our payment processing service providers handle your financial and payment information in compliance with applicable laws, regulations and security standards, such as the PCI DSS (“Payment Card Industry Security Standards Council”);
• Contacts with our Customer Service and Sales Center: Your interactions with our Customer Service and Sales Center may be recorded or listened to, in accordance with applicable laws, for Enotel's operational needs. Financial and payment details are not recorded. Where required by law, you will be informed of such recording at the beginning of your call;
• Personal Collections on Property: We collect additional personal information at check-in, including information required by legislation of the Ministry of Tourism. We may also use closed-circuit television and other security measures at our hotel that may capture or record images and videos of guests and visitors in public areas. In addition, we may collect audio recordings of the reading of the Verification Term of the Contract signed between Enotel and the Customer, at the time of sale of the Enotel Club vacation program. At this time, the customer attests that he/she has read the main contractual clauses, being informed and only with his/her consent, the recording of the confirmation of the Term will be made for the security of the data and the contract being signed, and the customer may obtain a copy of the audio if he/she wishes. We may also collect additional personal information in connection with on-site services, such as Concierge services in the Enotel app;
• Job Application: If you choose to apply for a job at Enotel, please see our Candidate Privacy Policy on our websites;
• Social Media: If you choose to participate in social media activities or offers sponsored by Enotel, we may collect certain information from your social media account in accordance with your social media service settings, such as location, check-ins, activities, interests, photos and status updates. We may also allow you to enter sweepstakes to provide photos, such as those from your stay with us, which you can share with your social media contacts for voting, shared offers and other promotions;
• Event Profiles: If you plan an event with us, we record the meeting and event specifications, the date of the event, the number of guests, room details, and, for corporate events, information about your organization (name, annual budget, number of events sponsored per year). We also collect information about the guests who are part of your group or event. If you visit us as part of a group, we may have personal information about you, provided to us by the group, and we may make commercial offers to you following your stay with a group or attendance at an event. If you are an event planner, we may also share information about your event with third party service providers who may offer event services to you;
• Sensitive Personal Data: Enotel does not normally handle Personal Data considered sensitive according to current legislation, therefore we do not intend to collect or process sensitive personal data in the normal course of your interactions with our products or services. When there is a legitimate interest or it is necessary to process your sensitive personal data, for any reason, we will obtain your prior, express and formal consent. If we process your sensitive personal data for other purposes, we rely on the following hypotheses: (i) compliance with a legal or regulatory obligation by the controller (ii) shared processing of data necessary for the execution, by the public administration, of public policies provided for in laws or regulations; (iii) conducting studies by a research body, ensuring, whenever possible, the anonymization of sensitive personal data; (iv) regular exercise of rights, including in contracts and in judicial, administrative and arbitration proceedings, the latter under the terms of Law No. 9,307, of September 23, 1996 (Arbitration Law); (v) protection of the life or physical safety of the holder or third party; (vi) health protection, in a procedure carried out by health professionals or health entities; or (vii) guarantee of fraud prevention and data subject security, in the identification and authentication processes for registration in electronic systems, safeguarding the rights mentioned in art. 9 of this Law and except in the case where fundamental rights and freedoms of the data subject prevail, which require the protection of personal data.

The term “Sensitive Personal Data” refers to information relating to racial or ethnic origin, political opinions, religion or other beliefs, health or sex life, criminal background, or trade union membership. In general, we do not collect sensitive information unless you provide it to us. We may use health data provided by you to better serve you and meet your specific needs.

3. About the use of Personal Data and,

in particular, the case of Children and Adolescents

3.1. About the use of Personal Data of Children and Adolescents

Enotel does not knowingly request, collect, process, store or share personal data from children and adolescents under the age of majority. If we discover that any type of handling of such data has occurred unintentionally, we will remove the personal data of that child or adolescent from our records promptly. However, Enotel may collect personal data from children and adolescents directly from their parents or legal guardians, and with explicit consent, and in accordance with the rules of current legislation. We ask that you do not allow your children to send personal information without your permission and/or authorization.

3.2. About the use of your Personal Data

In carrying out its duties, by way of contractual relationship, legal obligation and/or legitimate, Enotel Hotels & Resorts may process your personal data for legal purposes or those obtained through consent. Please note that not all uses below will be relevant to all individuals and may only apply in specific situations.

• Consumer Services: Your Personal Data is used for the purpose of providing consumer services, including responding to your queries, questions and suggestions. This usually requires certain personal contact information and information about the reason for your query, question or suggestion, for example, what your order was, whether there is a technical problem, a product issue or complaint, or a general query.

• Communication and Marketing: With your consent (where required by applicable law), Enotel uses your Personal Data to provide you with information about products or services, such as marketing communications, advertising campaigns or promotions. This may be done through various means of communication, including email, advertisements, SMS messaging, telephone calls and postal mail (as permitted by applicable law), push notifications, in-app messaging and other means (including in-property messaging, such as on your in-room TV), as well as our own websites and third-party social networks. In this situation, the Reason for using your Personal Data in this situation Our legitimate interests in this situation. To fulfill contractual obligations; To fulfill legal obligations; Our legitimate interests. To continually improve Enotel products and services; To continually improve the effectiveness of our customer service. 4 The use of your Personal Data is completely voluntary, which means that You can give consent or object, or even withdraw your consent at any time, to the processing of your Personal Data for these purposes. For more details on how to change your preferences regarding marketing communications, please see the “About Your Rights Regarding Personal Data” section of this policy. For more information about our contests and other Promotions, please see the rules or details posted about each contest/promotion.

• Social Networks and Third-Party Websites: We use your Personal Data when You interact with social network and third-party website functions, such as “likes,” to provide advertisements and interact with You on third-party social networks. How these interactions work, the profile data that Enotel obtains about You, and how to cancel them (“opt-out”) can be understood by reviewing the privacy policies directly on the respective social networks and third-party websites.

• Personalization (offline and online): Based on your consent (where required under applicable law), Enotel uses your Personal Data (i) to understand your preferences and habits, (ii) to anticipate your needs, based on our understanding of your profile, (iii) to improve and personalize your experience on our websites and applications; (iv) to ensure that the content of our websites and applications is optimized for You and for your computer or device; (v) to send You targeted advertising and content, and (vi) to allow You to participate in interactive functions, whenever You choose to do so. In this situation, the use of your Personal Data is completely voluntary, which means that You can object, or even withdraw Your consent at any time, to the processing of your Personal Data for these purposes. For more details, see the section “About your rights regarding Personal Data” in this policy.

• Fulfilling your orders: We use your Personal Data to process and ship your orders, as well as to inform you about the status of your orders, correct addresses, and conduct identity verification and other fraud prevention activities. This involves the use of certain Personal Data and, in certain situations, payment information.

• Legal reasons or merger/acquisition: If Enotel or its assets are acquired by or merged with another company, including as a result of bankruptcy, we will share your Personal Data with our legal successors, in compliance with the requirements of applicable law. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent legal authority; (iv) to protect our rights, privacy, safety or property; or (v) to enforce the terms of any agreement or the terms of our website, products and services, in accordance with applicable law.

• Other purposes and situations in general: In accordance with applicable law, Enotel uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of our advertising campaigns. We reserve the right, if you have Enotel accounts, to integrate these accounts into a single account. We also use your Personal Data for the management and operation of our communications, IT and security and data protection systems.

• Service Improvements: We may use personal information to improve our services and to ensure that our website, products and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in your room and throughout our properties. This may include providing you with the ability to control your room technologies through apps on your personal devices;

3.3. About the End of Data Processing

Enotel Hotels & Resorts will process your data in accordance with this Privacy Policy, assuming that the processing of your personal data will end in accordance with Articles 15 and 16 of the General Data Protection Law No. 13,709/2018.

3.4. About the use of your Data - Enotel Club Customer

If you are an Enotel Club Customer, we use your data to administer the Enotel Club Customer loyalty program, to personalize and enhance your experience with all of our services, to communicate news, promotional and transactional materials for the various services offered by Enotel Club, and to personalize advertisements and content delivered to you online, via email, mobile, display advertising, and also on our website, app, and through our Customer Relationship Center. In addition, if you submit an online “pre-application” for a vacation program or submit a reservation, request information online, or participate in a “chat” type feature, we may ask you to provide information from your contract or reservation. If you participate in an Enotel Club event or sweepstakes, we may ask you to provide information about your family composition, travel preferences and frequency, and other vacation history information. If you contact the Enotel Club customer relations or quality department, we may also ask you to provide your user ID, as well as your membership numbers, reservation or other information related to your contract to ensure your identity.

4. Sources of Personal Data

We collect your Personal Data through the following sources:

• Enotel Hotels & Resorts websites: All of our websites may be used to collect personal data. This includes both websites that we operate directly through our domains and IP addresses, as well as websites or pages that we establish on third-party services, such as Facebook, Instagram, Linkedin, YouTube and other third parties that offer this type of service;
• Electronic mail and instant messaging systems: Services used to maintain electronic communications between You and Enotel, including those made available directly by Us, or third-party services such as WhatsApp, Telegram, SMS (short message service) and similar;
• Enotel Hotels & Resorts mobile applications: Mobile applications provided directly by Enotel and its platforms or through third-party services such as Google or Apple;
• Customer service and sales center: Communications made with You through our customer service and sales centers;
• Advertisements, publicity and online forms: Interactions with any type of Enotel advertisements, publicity and online forms;
• Offline records: Records completed offline, distributed during events and other interactions with Enotel;
• Data received from third parties: Including, but not limited to, social networks and third-party websites such as Facebook, Instagram, Linkedin, and similar, data aggregator services, Enotel partners, public sources and data received during the acquisition of other companies

5. About the use of Cookies, log files and similar

Cookies are small text files that may be placed on your computer or portable device by websites or web services that you use. They are used to ensure the proper functioning of websites and other online services, as well as to provide information to the owners of the website or online service. Cookies are used to improve the usability and functionality of Enotel websites and other compatible web services and to better understand how our visitors use our websites and online services, as well as the tools and services they offer. Cookies make it easier for us to adapt Enotel websites to your personal needs, making their use easier whenever possible, and to receive feedback on the satisfaction of our consumers.

Enotel uses the following types of Cookies on its websites and compatible services:

• Session Cookies: These are temporary cookies that are deleted when you close your browser. When you restart your browser and return to the website that created the cookie, that website treats you as a new visitor.
• Persistent Cookies: These are Cookies that remain in your browser until you manually delete them or until your browser deletes them according to the duration period established by the cookie. These Cookies will recognize your return as a visitor to an Enotel website or service.
• Necessary Cookies: These are Cookies that are strictly necessary for the operation of an Enotel website or compatible service. They enable You to move around the website and use our features.
• Cookies that send us information about You: We place these types of Cookies on a compatible Enotel website or service and these types of Cookies can only be read by our compatible websites and services.
• Cookies in Enotel advertisements: We place Cookies in advertisements and ads that appear on third-party websites and compatible services. We obtain information through these Cookies when you click on or interact with the advertisement or ad. In this case, Enotel is placing a “third-party” cookie. We may use this data obtained by third-party Cookies to send you other advertisements that we believe are relevant or of interest to you based on your previous behavior.
• Cookies that share your information with third parties: These are Cookies placed on an Enotel website by our partner companies, such as online advertising services. They may use the data collected by these Cookies to anonymously send you targeted advertisements on other websites, based on your visit to Enotel's compatible websites or services.

Enotel’s websites and compatible services may also use other tracking technologies similar to Cookies, which may collect information such as IP addresses, log files, and web beacons, among other things. This data is also used to help us tailor Enotel’s websites and other compatible services to your personal needs.

See more details below:

• IP Addresses: An IP address is a number used on the Internet or a network to identify your computer. Every time you connect to the Internet, your computer is assigned an IP address by your Internet Service Provider. We may log IP addresses for the following purposes:
• Handling technical problems;
• Maintaining the protection and security of our websites and other online services;
• Obtain a better understanding of how our websites and other online services are used;
• Adapt our content to your needs, depending on your geographic location.

• Log Files: Enotel or a third party working on our behalf may collect information in the form of log files that detail website activity and gather statistics about users’ browsing habits. These logs are typically generated anonymously and help us understand details such as:
• The type of browser and operating system used by users of our websites or online services;
• Details about your user session, including the referring URL, date, time and which pages you visited on our websites and supported services and how long you spent on them;
• Other navigational or click count details including site traffic reports, unique visitor counts and similar data.

• Web Beacons: We may use web beacons (or clear GIFs) on Enotel websites. Web beacons (also known as webbugs or web beacons) are small strings of code that allow the delivery of a graphic image on a web page for the purpose of transferring data back to us. We use the information from web beacons for a variety of purposes, including:
• Understand how a user responds to email campaigns;
• Traffic reports for our websites and compatible services;
• Perform unique visitor counting, advertising and email auditing and reporting, and personalization on our websites and other compatible services.

It is important to remember that it is up to You to ensure that the settings on Your computer or handheld device reflect whether or not You consent to accept Cookies. Most browsers allow You to set rules to warn You before accepting Cookies or to simply refuse them. You do not need to have Cookies enabled to use or browse most ENOTEL websites and online services, however, we cannot guarantee that You will be able to access all of their features. We recommend that You look at the “help” button on your browser to find out how to configure this type of setting. Please remember that if You use different browsers, or even different computers and/or handheld devices in different locations, You will need to ensure that each device and browser is adjusted to Your personal Cookie preferences. Since our web beacons may be part of a web page, it is not possible to delete (“opt out”) this type of feature, but You can make it completely non-functional by activating the “opt-out” feature for the Cookies placed by that beacon.

6. Disclosure of your Personal Data

In order to provide you with the expected level of hospitality and to be able to provide the best level of service, we may share your information with our service providers, third parties and others as detailed below. In addition to the entities that are part of Enotel, we may share your Personal Data with the following types of third party organizations:

• Service Providers: These include external companies that are used by Enotel to help operate our business. Service providers and their selected employees are only authorized to access your Personal Data on behalf of Enotel for the specific tasks that are requested of them based on our direct instructions. Our service providers are contractually obligated to keep your Personal Data confidential and secure, and in cases of breach they are jointly liable in accordance with applicable law;
• Credit reporting, debt collection and financial services agencies: As permitted by applicable law, credit reporting and/or debt collection agencies are third-party companies that Enotel may use to help us verify your credit status or to collect past-due payments;
• Third parties using Personal Data for their own marketing and reservation purposes: Except where you have given your specific consent, Enotel does not license or sell your Personal Data to third parties for their own marketing and reservation purposes. In cases where such sharing occurs, the identity of these third parties will be disclosed prior to obtaining your consent;
• Third parties using your Personal Data for legal reasons or due to merger/acquisition: We will disclose your Personal Data to third parties for legal reasons or in the context of a merger or acquisition within Enotel
• Cookies in Enotel advertisements: We place Cookies in advertisements and ads that appear on third-party websites and compatible services. We obtain information through these Cookies when you click on or interact with the advertisement or ad. In this case, Enotel is placing a “third-party” cookie. We may use this data obtained by third-party Cookies to send you other advertisements that we believe are relevant or of interest to you based on your previous behavior.
• Other: In addition, Enotel may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to government inquiries or requests, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Enotel, website visitors, guests, employees or the public, (v) allow us to pursue available remedies or limit the damages that we may sustain, (vi) enforce the terms and conditions of our websites, and (vii) respond to an emergency.

7. Storage or transfer of your Personal Data

Enotel takes appropriate measures to ensure that your Personal Data is kept confidential and secure. However, these protections do not apply to information that You have chosen to share in public areas, such as third-party social networks.

• People who can access your Personal Data: Your Personal Data will be processed by our authorized employees or agents, provided that they need to have access to such information, depending on the specific purposes for which your Personal Data has been collected;
• Measures taken in operating environments: We store your Personal Data in operating environments that use reasonable security measures, both technical and administrative, to prevent any type of unauthorized access. We follow reasonable protocols to protect Personal Data;
• Steps Enotel expects You to take: It is important that You also play a role in keeping your Personal Data secure. When you create an online account, please be sure to choose a password that is strong enough to prevent unauthorized parties from guessing it. We recommend that You never reveal or share your password with anyone else. You are solely responsible for keeping this password confidential and for any actions taken through your account on Enotel websites and supported services.

If you use a shared or public computer, never choose to have your login name, email address or password remembered, and make sure you log out of your account whenever you leave your computer. You should also make use of any privacy settings or controls that Enotel provides on our website, services or applications, including those that are considered optional.

7.1. Transfer of your Personal Data

Given the nature of our business, we may have to transfer your Personal Data stored within Enotel to third parties, in accordance with the purposes set out in this Privacy Policy. For this reason, we may transfer your Personal Data to other countries, even to countries that are not part of the European Union or the European Economic Area, provided that these countries have laws and regulations compatible with those in force in Brazil.

7.2. International Data Transfer

As a global company, we strive to provide you with the same level of service that you have come to expect from Enotel, whether in Brazil or Portugal. In order to provide this service, we may share your personal information with other Enotel hotels, our service providers, partners and other third parties that may be located in countries outside your own. Although the data protection laws of these various countries may not be as comprehensive as those in your own country, we will take all reasonable steps to ensure that your personal information is treated as described in this Policy.

8. What are your choices about how we use and disclose your Personal Data?

Enotel does its utmost to give You freedom of choice over the Personal Data You provide to us. The following mechanisms give You control over the processing of Your Personal Data:

• Cookies/Similar Technologies: You can manage your consent using:
• Our Consent Management Solutions
• Your browser settings to refuse some or all Cookies and similar technologies, or to alert you when they are being used.
• Advertising, marketing and promotions: You may consent to your Personal Data being used by Enotel to promote our products or services by checking boxes located on the registration forms or by answering questions presented by our representatives.
• Personalization (offline and online): Where permitted by law, if You would like Your Personal Data to be used by Enotel to provide You with a personalized experience or targeted advertising and content, You can indicate this by ticking the relevant boxes located on the registration form or by answering questions presented by our representatives.
• Targeted Advertising: Enotel may partner with ad networks and other advertising or service providers that serve advertisements and other services on our behalf or on behalf of other companies not affiliated with Enotel. Some of these advertisements may be tailored to your interests based on information collected on Enotel websites and other supported services or on websites of organizations not affiliated with Enotel.

9. Mobile and Location-Based Services:

We provide a mobile application that can be downloaded to smartphones or mobile devices. This application offers many features that enhance the customer experience. In addition to providing services, the application may collect personal and other information that will be used in accordance with this Policy. If you allow our mobile application to access your location information from your device, we may use this location information to enhance your experience at the property by delivering push notifications and other content to your mobile device, providing navigation assistance while you are on the move, and sending you information and offers about products, services or activities that we believe may be of interest to you. If any location data is combined with personal information, the resulting information will be treated as personal information in accordance with this Policy. Concierge features are available as part of the application. For example, you may be able to communicate directly with the hotel, request services from the hotel, such as room service. The hotel will access and use your personal information (such as your name, confirmation number, check-in and check-out dates and room number) in providing these Concierge services.

10. Links to Third Party Sites and Services:

Our websites, Blog, and mobile application may contain links to third-party websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by these third parties. If you use and provide information on third-party websites, the privacy policy and terms of service of those websites will apply. We encourage you to read the privacy policies of the websites you visit before submitting any personal information.

Enotel may also partner with a limited number of Internet service providers to provide access to its guests. Your use of the property's Internet service is subject to the third-party Internet service provider's terms of use and privacy policy. Please be aware, however, that unfortunately no security system or system of data transmission over the Internet can be guaranteed to be completely secure.

11. Data Subject Rights

Customers, as data subjects, enjoy the following rights:

• Right of access and confirmation of the existence of processing

At any time and free of charge and simply, the holder can request reports and information about their personal data, including confirmation of how they are processed, who has access to the data, what data is being processed and with which agents it has been shared.

• Right of rectification

Whenever you consider that your personal data (provided by you) is incomplete, you can at any time ask for it to be completed, or you can request its rectification if you find that it is incorrect. (Ex.: ID, address, contacts, etc.)

• Right to restriction of processing

The right to limit the processing of your personal data allows you to request the data controller to restrict the scope of access and processing of your personal data or to suspend processing activities.

• Right to anonymization, blocking or revocation

In certain circumstances, the data subject may request the correction or updating of data, as well as the anonymization, deletion or interruption of the processing of personal data not necessary for the purpose to which he/she consented. Enotel Hotels & Resorts will inform whether or not it is possible to satisfy this right due to existing retention obligations by way of legal imposition or legitimate interest.

• Right to portability

You may request that Enotel Hotels & Resorts transfer your personal data to another provider of the same service by express request. In such cases, the business secrets of the controller must be preserved. This excludes data that has already been anonymized.

• Right to object

You have the right to object to the processing of your personal data at any time, for reasons relating to your particular situation, and when the processing is carried out for purposes other than those for which the data were collected, but which are compatible with them.

In such cases, Enotel Hotels & Resorts will stop processing your personal data, unless it has legitimate reasons to carry out such processing and these prevail over your interests.

Exercising your right to object may imply the suspension or cessation, in whole or in part, of the benefits associated with the purpose of the processing of the data in question. You may also object to the processing of your data for direct marketing purposes.

• Right to withdraw your consent

In cases where data processing is based on your consent, you may withdraw your consent at any time.

If you withdraw your consent, your personal data will no longer be processed, unless there is another basis, such as legal and regulatory obligations or the public interest of Enotel Hotels & Resorts, which justifies such processing.

• Right to lodge complaints with Enotel Hotels & Resorts or supervisory authority

The holder of personal data has the right to file a petition regarding their data against Enotel Hotels & Resorts before the Supervisory Body.

The rights set out in this Privacy Policy will be exercised as mentioned in Law No. 13,709/2018 - LGPD, upon express request from the holder or constituted legal representative, to the processing agent.

Enotel Hotels & Resorts has appointed a Personal Data Protection Officer, in accordance with article 41 of the General Data Protection Law. You have the right to confirm the existence of, access, review, modify and/or request an electronic copy of the information of your Personal Data that is processed by Enotel.

You can contact the Enotel Hotels & Resorts DPO and exercise your rights through the following channel:

- E-mail: via e-mail, to the address epd@enotel.com.br;

- Address: Highway PE09 – Plot 6A – Porto de Galinhas - Ipojuca – PE, ZIP Code: 55,590-000.

Enotel will receive, investigate and respond, within a reasonable period of time, to any request or complaint about the way in which We process your Personal Data, including complaints about disrespect for your rights under applicable privacy and Personal Data protection laws.

If you wish to file a complaint regarding matters related to the processing of your personal data, you may do so with the competent supervisory authorities in Brazil.

12. Changes to our Privacy Policy

Whenever Enotel decides to change the way we process your Personal Data, this Policy will be updated. We reserve the right to make changes to our practices and this Policy at any time, as long as we maintain compliance with current legislation.

We recommend that you visit it frequently, or whenever you have questions, to see any updates or changes to our Privacy Policy.