1. Information we collect
We collect information in the following ways:
1.1. Information provided by the user
In order to provide you with our service and for you to enjoy the features of our application, we need to collect, with your consent, some personal data:
1.2. Information we collect from your use of our services
1.2.1. Device Information
In the case of GuestU Apps we collect the following information about your device:
- Hardware model;
- Operating system version.
1.2.2. Navigation information
We may collect information about your use of the application, including the menus and screens visited, always anonymously. We use information about how you navigate the application to be able to measure the interest generated by each of the contents presented.
1.2.3. Location Information
We may collect and process information about your current location, always anonymously.
We use the information about your location to provide you with the most appropriate tourist information, such as by ordering content by proximity.
2. How we use the information we collect
We use the information we collect in connection with the provision of our services but also to provide, maintain, protect and improve these services and to develop new services, as well as to guarantee the exercise of users’ rights.
We may use the name given in the GuestU user profile in the provision of our services.
We use the language or nationality preferences of a user in order to present our services in the language of his choice. When we run ads, we don’t associate identifiers from cookies or similar technologies with special categories of data, such as those based on race, religion, sexual orientation or health.
GuestU processes personal information on Microsoft company servers located in Europe. We may process a user’s personal information on a server located outside the country of residence.
We communicate anonymous data to the Google Analytics service in order to get reports on how our app is used.
We use pseudonymized data through a Google algorithm to monitor application usage.
Finally, we retain the nationality data for statistical purposes.
3. Information we share
We don’t share personal information with companies, entities and individuals outside GuestU, except in the following circumstances:
3.1. With the Hotels, Apartments or other Entities for which we develop the App
The Apps developed by GuestU are associated with an entity that provides services to the App users. This entity can be a Hotel, Apartment or another type of entity that has built and published an App with the GuestU platform.
User’s personal data is deleted or anonymised after the guest’s check-out or after the data expiration period defined by GuestU (see Data retention period).
We may share anonymised information, that is, information that doesn’t contain personally identifiable information, publicly and with our partners, including information to show trends in relation to the general use of our services.
3.2. With the platforms we use to build the GuestU solution
The GuestU solution is built using third-party platforms for software development, software hosting, component access, frameworks, and service access APIs required to build the GuestU solution.
The entities that we use for this purpose are identified here and don’t have access to users’ personal data or authorization to access them.
- Microsoft – Solution development and hosting support;
- Google – Solution development and hosting support;
- Apple – Support for iOS Apps hosting;
- Twilio – Support VoIP calls, not having access to the identification of the users who make the calls;
- Crashlytics – Solution development support;
- Cabify – Integration for the purposes of transport requests;
- Uber – Integration for the purposes of transport requests, using the personal account of the user to which the GuestU doesn’t have access;
- City Mapper – Integration for the purpose of requesting information of public transport, using the personal account of the user to which the GuestU doesn’t have access.
3.3. For legal reasons
We will share information with other entities external to GuestU as long as it is necessary to:
- Fulfilment of a legal obligation to which GuestU is subject;
- Defense of vital interests of the data owner or another single person;
- Exercise of functions of public interest;
- Effect of legitimate interests pursued by GuestU, since the interests or fundamental rights and freedoms of the holder that require the protection of personal data should not prevail.
4. Information security
We carefully protect GuestU and our users from unauthorised access, alteration, disclosure or destruction of information in our possession. Specifically:
- Encrypted access to our services using SSL;
- Browsing in GuestU solutions uses a secure channel;
- We review our practices of collecting, processing and storing information, including physical security measures, to protect against unauthorised system access;
- We restrict access to GuestU databases and systems to GuestU’s employees and subcontractors who need them for the performance of their duties and are subject to strict contractual confidentiality obligations whose non-compliance may lead to disciplinary action or termination of contract.
5. Data retention period
Your personal data will be kept for the period of time necessary to provide our services through the GuestU application, until you delete your user account, or until you exercise your right of opposition, withdraw your consent for the treatment or ask for the elimination of data.
However, your personal data will never be retained for more than a year, after which it will be erased or, when relevant for statistical purposes, anonymised.
6. Rights of users of the GuestU service
Users of the GuestU service – data owners – have the right to access, rectify and delete their data, as well as the right to limit treatment, the right to object to data processing, the right to data portability and still have the right to withdraw consent at any time (without affecting the lawfulness of the treatment made on the basis of the consent previously given).
These rights can be exercised through the e-mail firstname.lastname@example.org.
Users may submit a complaint to the Data Protection Authority (CNPD) for any violation of data protection legislation.
8. Compliance and cooperation with regulatory authorities
10. International transfers of personal data
Using the GuestU application may imply the transfer of your data outside of Portugal.
In such a case, GuestU shall comply strictly with the applicable legal provisions, in particular as regards the determination of the adequacy of the level of protection of the personal data of the recipient country of the transfer, as well as the requirements applicable to the transfer.