VHC - PRIVACY POLICY

Vacation Homes Collection ("VHC Hospitality" or "VHC") and the CVC Corp group companies value the protection of the personal data of all its potential and final consumers ("Clients", "Client" or "You") and are committed to the protection and security of personal data, treating them with confidentiality and respecting the right to privacy.

This Privacy Policy aims to provide Clients with clear and accurate information about the collection, use, storage and other types of processing of their personal data performed in the context of our activities in the vacation rental sector in Brazil and abroad, in addition to informing how Client privacy is protected in the course of VHC's relationship with You.

1. WHO DOES THIS PRIVACY POLICY APPLY TO?

VHC is, as a rule, the controller of the personal data the processing of which is described in this Privacy Policy, processing them together with other controllers and operators as described here in.

VHC provides property management and rental services for vacation tourism. Thus, this document applies to all individuals whose personal data is processed by VHC for the purpose of renting vacation properties, including through the website www.vacationhomescollection.com ("Platform").

This Privacy Policy does not apply to data processing activities conducted by other service providers and third parties involved in conducting our activities, and relates solely to data processed by VHC.

2. WHAT INFORMATION IS PROCESSED?

VHC may collect and process Client personal data for the purposes described in this Privacy Policy. The types of personal data processed in the course of providing services may include:

VHC does not handle data from children and adolescents, and always makes all bookings in the name of their parents or guardians.

As mentioned above, VHC may use cookies when You browse the Platform. Cookies are only associated with an anonymous user and their computer, and do not provide references enabling the user's first and last names to be deduced. Thanks to cookies, VHC is able to recognize registered users right after their registration, without having to log in each visit. In addition, third parties may also be allowed to collect information about your online activities through cookies and other technologies. Please note that VHC has no access to or control over the cookies or other technologies these third parties may use to collect information about your interests, and the information management practices of these third parties are not covered by this Privacy Policy. You can configure your browser to be notified of the receipt of cookies and to prevent their installation. Please refer to the instructions and manuals for your browser to expand on this information. You are not required to allow installation of the cookies sent in order to use the Platform, but your browsing and experience may be affected if You disable VHC's cookies.

Personal data processed by VHC may also vary depending on the service or package of services contracted by the Client and on specificities and preferences that the Client may report or request.

3. HOW IS THE INFORMATION COLLECTED?

For the provision of VHC's services, the data You provide on the website www.vacationhomescollection.com, will be collected as you are making your reservation and in our on-line check-in system, accessing www.checkinvhc.com.

Moreover, providers engaged by VHC to provide services to Clients, pursuant to the terms of the agreement with the Client, may share data about the service and its consumption throughout the provision of the service with VHC.

In all cases, we at VHC undertake to maintain absolute confidentiality of all data, processing only the personal data necessary to provide the services, to comply with any legal obligation, or in other situations permitted by law.

4. WHAT ARE THE PURPOSES OF PROCESSING YOUR INFORMATION?

Your information and personal data will be processed for the following purposes:


5. WHO IS THE INFORMATION SHARED WITH?

As you know, VHC provides its services to the Client, as well as contracting suppliers, with whom it has partnerships, from various areas. Such suppliers may be local service providers or companies that provide pick-up and drop-off services for the Client at the travel location, among others. Accordingly, VHC may share your personal information with these third parties or other business partners necessary for the purposes of providing the services. Such sharing occurs with the following partners, based on the following criteria and for the purposes described below.

In addition to the above suppliers, VHC may use third party service providers in the provision of its own services. In this case, such providers will not have any decision-making power over personal information that they process on behalf of VHC.

Client's personal data may also be shared with third parties (including governmental agencies) in order to respond to investigations, prosecutions, judicial proceedings, or to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the security of any entity or as otherwise required by law.

If VHC is involved in a merger, acquisition or sale of all or a portion of its assets, Client personal data may be shared with the acquiring company or entity.

VHC may share certain non-personal information (anonymized data that does not identify Clients individually) with third party service providers, trusted partners or approved researchers in order to better understand which adverts and services may interest you, to improve the overall quality and effectiveness of the services provided and contracted, or to contribute to academic research.

6. INFORMATION TRANSFERS OUTSIDE BRAZIL

VHC may transfer Clients' personal data to service providers located overseas, including cloud service providers. If You contract service packages with a destination outside Brazil, it will be necessary to transfer Your personal data so that the suppliers can provide these services. When a Client's personal data is transferred outside Brazil, appropriate measures will be taken to ensure adequate protection of this data in compliance with the requirements of the applicable data protection legislation.

7. HOW LONG IS YOUR INFORMATION STORED FOR?

VHC strives to ensure that personal data is kept as up-to-date as possible and that unnecessary or excessive data is deleted or anonymized whenever and as soon as possible.

In general, the Client's personal data will be retained as long as necessary to fulfill the purpose for which it was collected. This will be, as a rule, the period from the execution of the contract until the end of the contracted service. Moreover, VHC may retain the Client's personal data for a period corresponding to the duration of any applicable statutory period after the relationship with the Client ends.

Thus, the Client's personal information and data may be stored and kept for as long as there is a relationship/connection with the Client to comply with legal obligations, or for as long as necessary to preserve your or our legitimate interests.

Client's personal data will cease to be processed when it is found:

In such cases, subject to the cases established by applicable law or by this Privacy Policy, personal data will be deleted or anonymized by VHC so that the data completely loses the ability to identify the original holder of the data.

8. CLIENT'S RIGHTS AS THE HOLDER OF THE PERSONAL DATA

Client will have certain rights with respect to their personal data, as established by applicable personal data protection law. Such rights include, but are not limited to:

For more information about Client Rights or to exercise any of these rights, Client may contact the Data Protection team at privacidade@cvccorp.com.br. Before processing such request, VHC may request further information about Client for the purpose of authenticating their identity, thereby ensuring that information is only shared with Client or someone with the power to represent them.

9. PROTECTION OF INFORMATION AND PERSONAL DATA

VHC treats Clients’ information and personal data with a high level of protection, confidentiality and care, using appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction or damage, acting responsibly and ethically, in compliance with the terms of applicable data privacy laws and regulations.

10. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is a dynamic tool and may be updated periodically to ensure that the information it provides is in compliance with data protection laws. Accordingly, VHC reserves the right to change this Privacy Policy at any time by posting the updated version on our Site. In the event of significant changes to this document, Client may receive a notification to that effect or it may be communicated through the official communication channels.

11. CONTACT DETAILS

Questions regarding this Client Privacy Policy or other matters relating to the protection of personal data should be addressed to the Data Protection Officer for personal data processing using the e-mail address privacidade@cvccorp.com.br.

This Privacy Policy was updated and revised in March 2021.