Privacy Policy | Hurb

Privacy Policy

Our commitment...

Hurb is committed to protecting the personal data entrusted to it. In this way, all personal information is treated and protected with all due diligence, in compliance with the General Regulation on Data Protection, the ePrivacy Directive and other applicable legislation.

It is our commitment to put into service only the personal data necessary to provide our customers with the best services, taking responsibility for their data in a transparent and conscientious manner.

In this Privacy Policy, we inform you about how and for what purposes we utilize your personal data, with the guarantee that we collect, share and preserve it in a safe manner, having as reference the best practices in the field of security and data protection of personal data.

Who is responsible for processing personal data?

The person responsible for processing the personal data of users located in Europe is HURB CO, SA (hereinafter “Hurb”), whose collective person number is 515500224, headquartered at: 6 Avenida da República, 1st Esq., Lisbon, Portugal.

For what purposes do we need your data and on what grounds do we utilize it?

We use your personal data for a variety of purposes and always in accordance with a legality foundation provided for by the law, namely:

  1. Accommodation reservation: whenever you make a reservation for an accomodation through our website, we process your personal data to complete and manage your reservation. This includes sending you e-mails and/or messages about confirmations, modifications and/or reminders about your reservation. In this case, the use of your data is necessary to carry out pre-contractual steps toward your order, or to execute the service provision contract. If you do not provide your data, we will not be able to provide you with the requested or contracted services.

  2. Costumer support: we provide an international customer support service. In order to provide you with this service, we will need to process certain data, such as your booking information or information about your user account. Your personal data will be processed, for analysis and so that we can resolve the situation underlying your contact, based on the performance of the contract to which you are a party.

    For the purpose of monitoring the quality of the service provided in customer support, we keep all calls recorded on chat, leaving such service linked to the customer's account for the purpose of internal monitoring, this data is not made available to customers.

  3. Marketing: with your consent, we may process your personal data for marketing activities. These activities may include the regular sending of information about products and services related to your reservations or accommodations that are prepared based on your interactions with our products and or services. This data processing will be carried out only with your consent. You can opt-out of receiving these communications quickly, easily and at any time by clicking on the "Cancel subscription" link that is included in all communications.

  4. Communicate with you: your opinion is very important to us, so there may be situations in which we will contact you, by email, in order to answer a satisfaction questionnaire related to the services provided by Hurb. Your personal data will be processed based on our legitimate interests and in order to improve the services we provide to you.

  5. Compliance with applicable provisions and fraud prevention: when applicable, it may be necessary to process your personal data to ensure effective compliance with applicable legal provisions, our terms and conditions, namely preventing fraud situations, as well as resolving disputes and/or corroborate requests of collaboration made by public authorities. Your data will be processed based on the fulfillment of a legal obligation to which Hurb is subject to, or based on the legitimate interests of Hurb, as applicable.

What types of personal data do we process?

  1. We process the personal data you provide us to make reservations for accomodations. You can make a reservation as a "visitor" or by authentication, by creating an account on Hurb or with your Facebook account.

    • If you make a reservation as a "visitor", we ask that you provide us with the following personal data: email, payment details, date of birth and telephone contact.
    • If you make a reservation through an account previously created at Hurb, we request, at the time of creation of that account, the following personal data: name, surname, email and password.
    • If you make the reservation through authentication with your Facebook account, the following personal data will be processed by Hurb: name, surname, email and profile photo.

    By authenticating with your account created at Hurb or with your Facebook account, we request, in addition, during the purchase process, payment details, date of birth and telephone contact. You can also optionally provide us with more data in the personalization panel of your account profile.

  2. We also process the personal data you provide when you contact us through our customer support, as well as when you answer our satisfaction questionnaires related to the services provided by Hurb.

  3. We may process data, collecting information of and about devices that you use, including how it interacts with the Platform and information about the device itself, such as hardware model, operating system, IP address, cookie information, mobile device settings, advertising, browser type, language and time zone. Apple's iOS Advertising Identifier (IDFA) and Google's Android advertising ID are examples of device identifiers. This information allows us to recognize and associate user activities and provide personalized content and advertising on a consistent basis.

  4. We also process the personal data of third parties that you provide to us, in the case of other guests who accompany you on your travels.

Usage information

The use of the collected data serves to improve the Platform in order to provide a better experience to all who browse our Platform. In this way, we achieve a better interaction with the Platform. Besides that:

  • Cookies: We use cookies so that our Platform can be navigable.
  • Location data: When you use certain features of the Platform, we may collect data about your general location (IP address). We use this data to provide location-based services.
  • Software Development Kits: We can use, including our business partners and service providers, SDKs to collect information and data related to how mobile devices interact with the Platform.

How long do we keep your data?

We keep your personal data for as long as necessary for the execution of the contract and for the fulfillment of legal obligations to which Hurb is subject to, after which we proceed with the elimination of said data.

How do we use cookies?

Cookies are small text files or information that are stored on your computer or mobile device when you visit our digital platforms, working as identifiers of your device, but not of the user itself. We use cookies to align our services to your interests and needs, easing the use of our digital platforms. All cookies that are not considered necessary for the strict functioning of our digital platforms will only be used if given your consent. You can find out more information in our Cookies Policy.

What are your rights?

At any time, you can ask us:

  • Access to your personal data;
  • The rectification of your personal data;
  • Opposition, deletion or limitation of the processing of your personal data, when applicable;
  • The portability of the personal data provided, in a structured way, in a compatible and readable format, when applicable.

You also have the right to withdraw your consent at any given moment, the withdrawal of which does not compromise the lawfulness of the treatment carried out based on the consent previously given or on another legal ground, as is the case of compliance and execution of the contract, or a legal obligation to which Hurb is subject to.

To exercise your rights, please contact us via the email address of our Data Protection Officer, which you can find at the end of this Privacy Policy. Your requests will be treated with special care, so that we can ensure the effective exercise of your rights.

You should keep in mind, however, that in certain cases, under the terms of the applicable law, your request may not be immediately or fully satisfied.

You may be asked to prove your identity in order to ensure that the exercise of rights is only carried out by the holder.

In any case, you will be informed of the measures taken in this direction, within one month from the moment the order is placed.

You also have the right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your usual residence, your place of work or the place where the infringement was allegedly committed.

How do we treat minors' personal data?

Hurb does not offer services to children under 13. In the event that minors' data is included in a reservation, such as packages for families, or travel-related services, Hurb may process this data only if it is made available by the reservation holder who meets the conditions to be able to use the services from Hurb. The basis for processing data on minors in these situations is based on the consent given by the legal representatives of the minor.

Connecting to social networks

You can sign up and log in to Hurb through your Facebook account. If you sign up via Facebook, Facebook will ask for your permission to provide us with certain data that appears on your Facebook account.

You should be aware that Facebook, as a social network, has its own privacy policies, so we advise you to read them carefully.

You can restrict and control the information we receive from Facebook using the privacy settings of your Facebook account. The legality ground for connecting to the Facebook social network is based on your consent.

If you sign up for the Hurb platform through Facebook, your Hurb account will be automatically linked to your Facebook account and information about your activities on our website can be shared by you on Facebook and published in your timeline and newsfeed

Hurb's mobile applications for IOS and Android

We offer a completely free application for the Android and iOS platforms, these applications for mobile devices process the personal data that the user provides us in a similar way to that of our website. They also allow our users to use their location data to find the nearest hotels and services, always with their consent. We can also send push notifications with promotions, information about your reservation, etc. In the iOS environment through the user's permission and soon also on Android.

We make use of analytics tools to improve the user experience, as well as our services and marketing activities. This can be done with or without the use of cookies.

Who do we share your data with?

Your data is transferred to our partners, so that they can provide you with the requested service. Service providers will only receive your data to the extent necessary for the processing of your order and/or reservation.

Your data may also be accessed and processed by subcontracted third parties, namely: Reservation services of the website (cloud), e-mail, digital marketing, customer service, among others. These entities will only be provided with the personal data necessary for the provision of the service in question.

Hurb may also have to share its data with competent public authorities legally mandated, upon their request, duly analyzed.

Your data may also be shared within the Group of which Hurb is a part of.

Whenever it is necessary to share information within the Group, or service provider partners or with subcontracted third parties, we will ensure that this occurs in accordance with the applicable data protection legislation.

International transfers of personal data

Your personal data is stored on a server located outside the European Union and may be transferred to partners, namely Hotels. When transferring data to countries outside the European Economic Area, Hurb ensures that an adequate level of protection is established. For this purpose, Hurb, as a data exporter, when transferring its data to countries whose level of adequacy of data protection has not yet been recognized by the European Commission, assumes the additional guarantee obligations necessary to guarantee data security. You can ask us for a copy of the documentation that proves that we have adopted the appropriate guarantees by contacting our Data Protection Officer.

Doubts or other clarifications

If you have any questions regarding this Policy, have other privacy issues, or wish to exercise any of your rights, please contact our Data Protection Officer at dpo@hurb.com.