TRUL HOTÉIS PRIVACY POLICY

BRAINY HOTEL CONSULTING LTDA under CNPJ number 20.777.649/0001-20 recognizes the importance of privacy, intimacy, security and data protection for its customers and for all data holders who may have their Personal Data (as per defined below) or otherwise processed through the hotel's systems.
BRAINY HOTEL CONSULTING LTDA uses its best efforts to provide adequate protections in all its operations and to implement the most consistent and rigorous policies and procedures.
This Privacy Policy informs our practices to you, who visit our website or who provide data, regardless of its nature (“You”), in addition to indicating the choices that You can make regarding the collection and use of data.
For the purposes of this Privacy Policy, personal data
(“Personal Data”) means any data that refers to an identified or identifiable natural person. Personal Data will be of the nature of Personal Data whenever there is the possibility of You being identified, directly or indirectly, by reference to a unique identifier such as, for example, your name, an identification number, location data, or other specific factors of your identity.
In relation to A BRAINY HOTEL CONSULTING LTDA, Data
Partner Personal Data are not, in principle, considered Personal Data.
This Privacy Policy describes the processing – which includes the collection or access, use and storage – of your Personal Data by BRAINY HOTEL CONSULTING LTDA.
By agreeing to this Privacy Policy, You declare and
you agree that A BRAINY HOTEL CONSULTING LTDA may process your Personal Data in accordance with the terms established here.

THIRD PARTY APPLICATIONS
This Privacy Policy does not apply to third-party applications, products, services, websites or social media features that may be accessed through links we provide for your convenience and information (“Third-Party Applications”). Accessing these links will take You out of our hotels' virtual environment and may result in the collection or sharing of information about You by third parties.
BRAINY HOTEL CONSULTING LTDA does not control, endorse,
makes any warranties or representations regarding Third Party Applications or their privacy practices. In this regard, we encourage You to carefully read the privacy policies of any Third-Party Application with which You interact before allowing the collection and use of Your Personal Data.

PERSONAL DATA COLLECTED BY THE WEBSITE AND APPLICATION
BRAINY HOTEL CONSULTING LTDA collects your Data
Personal when You access our website. When contacting us for reservation purposes, You must provide us with your name, your contact information such as email address and telephone number, and your credit card number.
Whenever You visit the website, BRAINY HOTEL CONSULTING
LTDA also receives and records on its servers your browser logs, including the type and version of the operating system of your computer or mobile device, browser type and language, IP address and geographic areas derived from your IP address, cookie data, archive data, timestamps of access and duration of visits, the websites visited before accessing the hotel websites. We may relate this data to the Personal Data that You provide for the purposes described in this Privacy Policy.
When You use our device applications (sites)
mobile devices, we also automatically collect information about your mobile device and your use and activity on our mobile applications. For example, we collect Your device's mobile operating system type and version, browser type, device type, geolocation data, Wi-Fi network connection data, Internet Protocol (IP) address, device identifiers, records of date and time of access and duration of visits and other data.

PERSONAL DATA COLLECTED BY THIRD PARTIES
We may receive your Personal Data when You provide it
to third parties for the purpose of making reservations at our hotels. In this process, third parties use their own means to collect data relating to You and, through a Contract, they allow our company to also have access to this data so that reservations can be made.
Third parties that collect data have a legal obligation to obtain the respective consents and authorizations (the “Consents”) that You freely and unequivocally wish to give for the processing of your Personal Data. BRAINY HOTEL CONSULTING LTDA relies on the content and
scope of these Consents to provide appropriate treatment to your Personal Data, exempting itself from any liability arising from any inadequacy of these Consents.
In relation to Personal Data obtained through third parties, our company's commitment is limited, in principle, to providing You with the greatest possible transparency regarding the way in which we access, store and use your Personal Data. This is done as a way of establishing a relationship of trust with You, there is no legal obligation to do so.

PERSONAL DATA COLLECTED DURING THE STAY
BRAINY HOTEL CONSULTING LTDA values excellence in
offering its hotel services. To provide an increasingly efficient and personalized service, we collect, store and use Personal Data from our guests during their stay at the hotel.
The Personal Data collected during the stay concerns
to the characteristics, preferences and history of each guest. For example, Personal Data about past incidents at the hotel, shoe size, clothing size, dietary restrictions, allergies, specific requests, likes, predilections, aversions and habits may be collected during the stay.
Personal Data collected during your stay in our
hotels, are treated for the benefit of the respective guest, with the aim of providing an individual and unique service. We understand that the Personal Data collected during the stay may relate to the privacy of your guests. Therefore, Personal Data collected during your stay is kept confidential and secure, is only accessible to our internal team and is used when necessary to provide guest service.
When checking in for a stay at one of our
hotels, You understand and agree that your Personal Data may be collected during your stay, including by observing your behavior, characteristics and predilections, and that it will be used during your stay or on future occasions. Considering that the personalization of the hotel service is a process that is consolidated over time and with guest experiences, Personal Data collected during the stay remains stored
permanently. You may exercise, in accordance with applicable legislation and this Policy, your rights in relation to Personal Data collected during your stay, including the right to delete your Personal Data.

PERSONAL DATA COLLECTED FOR WI-FI ACCESS
To access the Wi-Fi internet service on the premises of the
hotel it is possible that your personal data will be collected as a requirement for your connection, and will only be used for this purpose.

PERSONAL DATA COLLECTED AUTOMATICALLY
Cookies are text files containing small amounts
of data that is transferred to Your device, or more precisely, to the browser You use on the device, when You visit a website. The entity that places the cookies in your browser can then read the information contained in the cookie, according to the settings assigned to it. Cookies are typically classified as either “session cookies,” which do not remain on Your device after You close your browser, or “persistent cookies,” which will typically remain on Your device until You delete them or, alternatively, they expire.
When You visit our website, we place information in
your computer in the form of a cookie, which is automatically recognized the next time You visit us. Cookies allow us, for example, to adapt our website to suit your interests. If You do not want [insert hotel name] to recognize Your computer again later, set Your Web browser to delete cookies from Your computer, block all cookies, or warn You before a cookie is saved. Please note that it is possible that once You request this deletion, You will no longer be able to enjoy all the functions of the The Falls website. In this regard, please note that the hotel uses certain cookies that are not related to online advertising: (i) account access security cookies; (ii) functional cookies, which preserve the functionality of navigation elements; and (iii) language or regional setting cookies.
[insert hotel name] can also track IP addresses
for the purposes of administering your systems, to report aggregate information, for site tracking, to prevent our servers from being hacked and for other uses described in this Privacy Policy.

HOW WE USE YOUR PERSONAL DATA
BRAINY HOTEL CONSULTING LTDA uses your Data
Personnel to offer hotel services, especially to make reservations and also to ensure that your stay is an exclusive experience.
Our hotel also uses your Personal Data to improve
relationship with You and to provide You with better services, including personalizing Your interaction and experience with us. For example, we may use your Personal Data to:
● conduct our ordinary business operations, including to verify your identity, complete transactions and orders for our products or services, administer your account, process payments, and perform business research and analysis;
● for the purposes of staff training and quality assurance (which may include monitoring or logging calls to our customer support) and improving our internal operations and performance of systems, products and services, including innovation activities such as creating new products, resources and services using research and development tools and incorporating data analysis activities;
● improve Your experience with The Falls by maintaining accurate contact and registration data, offering appropriate and enhanced products, services and features that may interest You and enabling You to participate in contests and surveys;
● respond to your comments, questions and complaints;
● send You service-related information, including confirmations, invoices, technical notices, updates, security alerts, and administrative and support messages;
● inform You about promotions, upcoming events and news about products and services offered by The Falls and our Partners; ● relate or combine information about You with other data We receive from third parties, to help understand Your needs and provide You with a better, more personalized service;
● enforce our terms and conditions or protect our business, Partners or customers;
● prevent, investigate and stop fraudulent, unauthorized or illegal activities.
BRAINY HOTEL CONSULTING LTDA may transfer its
Personal Data to third parties. Upon your unequivocal Consent, we may also combine your Personal Data with data we collect automatically and with Personal Data we receive from third parties.

SHARING AND TRANSFER OF PERSONAL DATA
We do not share Personal Data with third parties unless
that You have previously agreed to this or that there is permission or obligation based on law or court decision.
We may transfer Personal Data to other entities in the
[insert hotel name]. To ensure that your Personal Data remains secure, all companies that are part of the group are contractually obliged to comply with this Privacy Policy and to observe our internal rules of conduct regarding privacy. Our internal policies and standards are also communicated to our employees annually, as part of our specific Compliance program.
Like any other company, we rely on service providers
services to manage and support, on behalf of BRAINY HOTEL CONSULTING LTDA, certain aspects of our operations. Such service providers may be located in Brazil or other countries and may provide services such as data hosting, IT and cloud computing services, debt collection, fraud management services, customer support and advertising and marketing activities. Our service providers are contractually obliged to adequately safeguard any Personal Data they receive from the hotel and are prohibited from using Personal Data for any purpose other than performing the services under their responsibility in accordance with the instructions we provide.
We may also share your Personal Data when
we believe, in good faith, that we have an obligation to: (i) comply with a law, regulation or court order; (ii) respond to requests for information made by regulatory bodies, police authorities and other public authorities, including in cases relating to national security; (iii) enforce and/or protect property or rights of the hotel or other company that belongs to the group, including to investigate fraud and help prevent security threats, including information security, or other criminal or malicious activities; or (iv) protect the legitimate interests of third parties, including the personal safety of our employees and collaborators.

ADVERTISING AND MARKETING
You agree that we may collect, process and use your
Personal Data for advertising or market research purposes and, in particular, to improve our services. Furthermore, we may use your Personal Data to offer you exclusive services and special opportunities that are compatible with your characteristics and predilections.

CHILDREN'S PRIVACY
BRAINY HOTEL CONSULTING LTDA only collects or processes
data of children with due authorization from their parents or guardians and strictly for the purpose of checking in and offering the necessary services during the stay. Except as provided above, The Falls does not deliberately collect or process Personal Data associated with children.
COMMUNICATIONS VIA EMAIL AND INSTANT COMMUNICATIONS
We will only use your email address and phone number
for the purposes for which You authorized the use (for example, responding to messages sent by You through our website). You will only receive our advertising by email if you have agreed to this or if we have the legal support to do so without your authorization.
If You have expressly agreed to receive
email marketing or newsletters (for example, when registering or later logging in), You will have agreed to receive communications with content selected or prepared by our company or advertising emails to the email address that You provided us. Communications from [insert name of hotel] may be made at regular or irregular intervals and may contain offers from commercial partners or third parties. You can unsubscribe from The Falls communications at any time via our email address
[email protected] or, when available, through the link present in the messages themselves.

PERSONAL DATA SECURITY – PROTECTION OF YOUR PERSONAL DATA
BRAINY HOTEL CONSULTING LTDA adopts the procedures
and the usual standards of physical, electronic and managerial security, including encryption and passwords in an effort to protect your Personal Data against unauthorized access and disclosure, as well as to prevent nuisance or unwanted communication (spam). However, please be aware that no company, including ours, can fully eliminate the security risks associated with the processing of Personal Data.
The Personal Data we collect may be retained for as long as
necessary to fulfill the Company's legitimate business purposes, including the purposes described in this Privacy Policy, or for a period of time specifically required or permitted by applicable law or regulation.

EXERCISE YOUR RIGHTS
BRAINY HOTEL CONSULTING LTDA respects the rights that
You are the holder of personal data and enable its exercise in accordance with applicable legislation.
BRAINY HOTEL CONSULTING LTDA strives to
ensure that the processing of Personal Data is in accordance with legislation and respects the rights and interests of personal data holders. If you notice that we hold Personal Data that is incomplete, inaccurate or out of date, you have the right to request that it be corrected. Likewise, if You find that The Falls processes unnecessary or excessive Personal Data or that the processing does not comply with the law, You have the right to request the anonymization, blocking or deletion of the Personal Data subject to the irregularity.
Furthermore, You have the right to request information about the possibility of not providing consent and the consequences of such denial. If you have previously granted your consent, You have the right to revoke it and request the deletion of Personal Data whose processing was authorized by means of that consent.
Furthermore, You have the right to request clarification about how we process your Personal Data. Likewise, You have the right to request information about the entities with which The Falls has shared your Personal Data.
If You want the Personal Data we hold about
You are shared with another service or product provider, You have the right to request portability.
The exercise of the rights set out above must be done via email at [email protected] and your request will be analyzed by those responsible for the company's privacy and personal data protection. In certain cases, your request may be denied based on a legitimate basis, such as when compliance with what was requested could lead to the exposure of Personal Data that concerns another holder of Personal Data, in cases where BRAINY HOTEL CONSULTING LTDA is legally prevented from disclosing such information or, even, when we are prevented from fulfilling your request due to a third party contract. In all cases of denial, the appropriate justification will be presented to You.

CHANGES
As technology and our services advance, so do
we will adapt our Privacy Policy. Whenever this happens, we will publish the new version, which will indicate the date on which the revision took place.
If you deem necessary, you may request the most updated version of our Privacy Policy by other means. In any case, You should check this page regularly to learn more about the status of this Privacy Policy.

REVOCATION
If the processing of your Personal Data is based on your
majority of your consent, know that it may be revoked at any time. In general, revocation, however, will only apply to the future use of Personal Data. You can revoke your consent by email at [email protected]. The revocation of the
Consent may mean that certain services are no longer available to You or that they are subject to restrictions or limitations.
We reserve the right to pursue our data activities on a lawful basis at any time.

CONTACT US
If You have any questions or concerns regarding this
Privacy Policy, or about our practices for collecting and using Personal Data or, even, about a possible violation or breach of confidentiality of Personal Data or privacy, You can contact us via email at lgpd@visotech. com.br .