DATA CONTROLLER IDENTIFICATION

• Name: HOTEL PROJECT LISBOA S.A
• Registered Office: AVENIDA DA LIBERDADE 138-142 1250-001 LISBOA
• VAT Number (NIPC): 505707446
• Telephone: +351 210 410 000 (Call to the national landline network)
• E-mail: reception@138liberdadehotel.com

DUTY TO INFORM

The protection of personal data of natural persons is protected in Portugal by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and by Law No. 58/2019 of 8 August, which ensure the protection of natural persons with regard to the processing of personal data and the free movement of such data.

“Personal data” is considered to be any information of any nature and regardless of the respective support, including sound and image, relating to an identified or identifiable natural person; therefore, protection does not cover the data of legal entities.

An identifiable person is one who can be identified, directly or indirectly, namely by reference to an identification number or to one or more specific elements of their physical, physiological, mental, economic, cultural, or social identity (for example, their name associated with their telephone number or e-mail address).

By reading this Privacy Policy, the User is informed about the processing of their personal data carried out by HOTEL PROJECT LISBOA S.A through the website www.138liberdadehotel.com.

PURPOSES OF PERSONAL DATA PROCESSING

The personal data we collect and process through the Website identified above will only be used for the following purposes:

1. Managing the contracting of services carried out through the Website, such as contact requests or booking management;
2. Periodically sending communications with news related to the activity of HOTEL PROJECT LISBOA S.A and the sector to which it dedicates its activity;
3. Anonymous and aggregated analysis of the use of services, to identify habits and trends of Users, in order to improve the services offered and satisfy the specific needs of Users;
4. In the event of contracting, the data collected on this Website, together with other data obtained within the scope of the contractual relationship, will be used for human resources management, to ensure compliance with legal obligations, and to provide employees with the means necessary to carry out their professional activity;
5. Compliance with national and international legal provisions, or executing an order from competent judicial authorities;
6. Compliance with legal obligations derived from applicable legislation on data protection, as well as for the exercise of the rights of the subjects, in particular, the defence of a right in judicial proceedings.

HOTEL PROJECT LISBOA S.A guarantees the confidentiality of all data provided. Although HOTEL PROJECT LISBOA S.A proceeds with the collection and other types of data processing in a secure manner that prevents its loss or manipulation, using the most appropriate techniques for this purpose, it is important to bear in mind that the collection of data in open networks does not allow the circulation of personal data in conditions of absolute security, and there is a risk that these may be accessed and used by unauthorised third parties.

Failure to respond to data marked as mandatory may imply the impossibility of responding to the data subject’s request.

LEGITIMACY FOR THE PROCESSING OF PERSONAL DATA

HOTEL PROJECT LISBOA S.A processes User data:

1. When they express their free, specific, informed, and unequivocal consent for the processing of their personal data for certain purposes;
2. And/or when it is necessary for the performance of a contract to which the Data User is a party, or for pre-contractual steps at the request of the User;
3. And/or for compliance with legal obligations to which HOTEL PROJECT LISBOA S.A is subject;
4. And/or for the purpose of legitimate interests pursued by HOTEL PROJECT LISBOA S.A or by third parties, unless the interests or fundamental rights and freedoms of the data subject that require the protection of personal data prevail.

The User guarantees that the information provided is true, accurate, complete, and updated, and is responsible for any damage or loss, direct or indirect, that may be caused as a result of the violation of this obligation.

In the event that the data provided belongs to a third party, the User guarantees that they have informed the said third party of the aspects contained in this document and obtained their authorisation to provide their data to HOTEL PROJECT LISBOA S.A for the indicated purposes.

RETENTION PERIOD

HOTEL PROJECT LISBOA S.A only keeps and processes your personal data for the period that proves necessary or mandatory for the fulfillment of the purposes described above, applying information conservation criteria appropriate to each treatment and in line with applicable legal and regulatory obligations.

HOTEL PROJECT LISBOA S.A maintains personal data in its systems in such a way that it is possible to identify the data subjects according to the following criteria:

• For a period of time not exceeding the pursuit of the purposes for which they were collected, provided that legal or contractual obligations do not provide otherwise;
• To comply with specific legal or contractual obligations;
• When applicable and legitimate, until the eventual request for opposition or erasure by the Data Subject.

DATA COMMUNICATION

In addition to the communications carried out in compliance with legal obligations, the personal data of the Data Subject may be known, in addition to HOTEL PROJECT LISBOA S.A, by:

• External service providers of HOTEL PROJECT LISBOA S.A, in their capacity as processors;
• National and international companies belonging to the same group as HOTEL PROJECT LISBOA S.A;
• Authorities in general, administrations, entities, and public bodies, both national and international;
• HOTEL PROJECT LISBOA S.A.

INTERNATIONAL DATA TRANSFERS

The personal data collected will be processed within the European Economic Area, and there are no international transfers of data to third countries or international organisations.

In the event of any processing of personal data outside the European Economic Area, this will only occur through the adoption of appropriate guarantees and the required level of protection, in accordance with the legislation on the protection of personal data.

INFORMATION SECURITY

HOTEL PROJECT LISBOA S.A has implemented appropriate technical and organisational security measures to ensure the security of the personal data provided to it by the User, aiming to prevent its alteration, loss, unauthorised processing and/or access, taking into account the current state of technology, the nature of the data stored, and the risks to which they are exposed.

Personal data is processed with the level of protection legally required to ensure its security and prevent its alteration, loss, unauthorised processing or access, taking into account the state of technology, and the User is aware and accepts that Internet security measures are not impregnable.

If HOTEL PROJECT LISBOA S.A subcontracts the provision of services involving the transfer of personal data to other entities, those entities will be obliged to adopt the necessary technical and organisational measures in order to protect personal data against destruction, loss, alteration, disclosure, unauthorised access, or any other type of unlawful processing.

EXERCISE OF RIGHTS

In accordance with the provisions of the GDPR, the User may exercise their rights of access, rectification and, where applicable, limitation of processing, erasure, portability, opposition, and revocation of consent, under the terms of the GDPR, by requesting it in writing through any of the following means, specifying the right or rights they wish to exercise:

• E-mail: reception@138liberdadehotel.com
• Postal address: AVENIDA DA LIBERDADE 138-142 1250-001 LISBOA

SUPERVISORY AUTHORITY

The User also has the right to lodge a complaint with the National Data Protection Commission (Comissão Nacional de Proteção de Dados) regarding matters relating to the exercise of their rights and the protection of their personal data, if they consider that their data protection rights have been violated.

THIRD-PARTY PAGES

The Website may contain advertising, links, or other content that links or redirects to pages and services of providers, advertisers, affiliates, sponsors of HOTEL PROJECT LISBOA S.A and other third parties.

However, HOTEL PROJECT LISBOA S.A does not control the content or links that appear on these pages and is not responsible for the practices used by these pages or websites. HOTEL PROJECT LISBOA S.A advises Users to visit the privacy policy of such pages, as well as their terms and conditions.

Searching or interacting on any other website, including those that have an external link to the Website, is subject to the terms and conditions of that website; in no case shall HOTEL PROJECT LISBOA S.A be responsible for such access and use.

DATA PROCESSING CARRIED OUT BY THE COMPANY THAT DEVELOPS AND MANAGES THE WEBSITE AS AN INDEPENDENT DATA CONTROLLER

Without prejudice to the fact that the processing of data collected through the Website is the responsibility of HOTEL PROJECT LISBOA S.A, as identified above in Section 1 of this Privacy Policy, we inform the User that MIRAIFUTURE PORTUGAL, LDA., with headquarters at Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil and with NIPC 515 139 092, may act, in specific situations, as a Data Controller, autonomously determining the purposes and means of processing.

This occurs, namely, regarding data processed to ensure the operation, maintenance, and security of the booking engine.

In these situations, the User’s data will be processed according to the information below:

• Purpose: to ensure the operability, security, and continuous improvement of the Website;
• Legal basis: legitimate interest;
• Retention period: for the period strictly necessary for the pursuit of these purposes.

Mirai ensures that, even in these situations, it only processes the strictly necessary data, adopting appropriate technical and organisational measures to ensure its security and confidentiality.

The User may exercise the rights referred to in Section 9 by requesting it in writing through any of the following means, specifying the right or rights they wish to exercise:

• E-mail: portugal@mirai.com;
• Postal address: Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil.

The rights provided for in Section 10 may also be exercised.

CHANGES TO THE PRIVACY POLICY

In order to ensure the suitability of the document, HOTEL PROJECT LISBOA S.A reserves the right to review this Policy at any time it deems appropriate; therefore, it is recommended that Users check this privacy policy regularly and/or each time they access the Website.

Updated on 27/04/2026.