Privacy Policy

Introduction

Dengun, Lda (hereinafter DENGUN) wants you to become familiar with how your data is collected, used and communicated to third parties, because your privacy and its protection are central to maintaining a trustworthy relationship.

The Privacy Policy practised by DENGUN complies with the GDPR (General Data Protection Regulation), a European regulation (EU 2016/679) which establishes rules on the protection, processing and free movement of personal data of citizens in the countries of the European Union. As of 25 May 2018, this law replaces the Portuguese Data Protection Law (Law no. 67/98 of 26 October).

This Policy describes the type of personal data collected, how it is used and with whom it is shared. It also describes DENGUN's general practices for dealing with Other Information (e.g. interests, demographics and service use) collected through monitoring and analytical tools. We also describe the steps we take to protect information, your choices of access, and how you can contact us about our privacy practices.

All personal information collected will be used to help us improve and make your visit to our website as productive and enjoyable as possible. Guaranteeing the confidentiality of our website users' personal data is important to DENGUN.

Use of DENGUN's website implies acceptance of this privacy agreement. We may change this agreement without prior notice, so we recommend that you review our privacy policy regularly to stay up to date.

Definitions

2.1. "Personal Information" means data relating to an identified or identifiable individual, such as:

• Name;
• Address;
• Telephone number (including landline and mobile phone numbers);
• Email address;
• Profile picture;
• Nickname on social networks (e.g. username on Facebook);
• Location information, if such information is linked to an identifiable individual;
• Personal traits;
• Browsing and consumption habits, preferences, tastes and interests.

An identifiable individual is an individual who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, psychological, mental, economic, cultural or social identity.

2.2. "Particularly Protected Data" is personal information considered especially sensitive, such as:

• Racial or ethnic origin;
• Political ideology or opinions;
• Religion or other beliefs;
• Health or illness;
• Legal background;
• Trade union membership;
• Sexual orientation.

We ask that you do not give us or reveal particularly protected data through our website, our social networks or in any other way. If you do give us any information of this nature, you consent and authorise, under your full responsibility, that we store and process it in our files for the purposes set out in this policy or those indicated when the data is communicated.

2.3. "Other Information" is, for example:

• Browser and device information;
• Information compiled through cookies, pixel tags or other technologies, as long as subsequent identification of the user is excluded;
• Demographic and geographic information.

2.4. Personal Information of other people

You may not send us or post Personal Information of others on our website, social networks or by other means, e.g. email. If you wish to submit information about other individuals, you must make sure that it is submitted directly by the person(s) concerned, regardless of the means of contact used. If, despite this warning, you send us another person's Personal Information, we will assume, under your full responsibility, that you have their prior authorisation and consent to do so, including authorisation for us to use this Personal Information as described in this Privacy Policy.

Information we collect

DENGUN is committed to processing only the personal data strictly necessary to improve your experience of using our website.

3.1. Personal data

Personal data, for the purposes of this Privacy Policy, is information that identifies you as an individual or relates to an identifiable individual.

3.1.1. Personal data submitted by the user

We collect Personal Information when it is submitted directly through our website, such as when you register a job application on the page dedicated to that purpose or submit a contact form. Personal data submitted may include your name, address, telephone number, email address, date of birth, country of residence, city, nationality, qualifications, professional experience, current professional status, level of language competence according to the Common European Framework of Reference for Languages, courses attended, completion date and the grade obtained.

3.2. Other information

Other information is any information that is not intended to disclose your specific identity, such as browser information, usage data, information collected through cookies and other technologies, demographic information, and geolocation data obtained with your consent where required by applicable law.

3.3. Automatically collected information

Our website uses only the technical cookies and data strictly necessary for it to work and for form protection. We do not use analytics or advertising tracking tools.

Regarding cookies and external monitoring tools, DENGUN is not responsible for the privacy practices of such third parties. To stay informed, we advise you to read the applicable third-party privacy policy.

3.4. Scan requests and Pipedrive

When you submit the "Hospitality AI Visibility Scan" request form, we collect the data you provide (name, professional email, hotel name, website, country, number of rooms, main priority and message), together with the page language, the page address and, where present, campaign parameters (such as UTM and GCLID).

This data is used solely to analyse your request, contact you about the Scan and manage the resulting commercial relationship. The legal basis is the pre-contractual steps taken at your request and DENGUN's legitimate interest in responding to business enquiries.

Requests are recorded in Pipedrive, the customer relationship management (CRM) platform used by DENGUN, provided by Pipedrive OÜ (Estonia, EU), which acts as a data processor on DENGUN's behalf. A minimal technical record of each submission is also kept to prevent duplicate requests. The data is not sold or shared with other third parties for marketing purposes.

The data is kept while there is commercial interest or until you ask for it to be deleted. You may exercise your rights of access, rectification, erasure, restriction and objection at any time by writing to [email protected].

How we use your personal data, other information and automatically collected information

DENGUN ensures that your personal data will be processed only for the purposes communicated to you and will not be used for any other purpose. We process your personal data to guarantee the quality of the service we provide and to respond better to your needs.

4.1. Measure and improve our products and services

All personal information collected will be used to make your visit to our website as productive and enjoyable as possible, including: processing a job application; processing a contact request; measuring interactions with specific website pages; providing customer support; and improving the interface of our website so that navigation is intuitive and satisfying.

4.2. Improve website content

To make your experience more interesting and personalised, we may use any of the Personal Data and Other Information collected so that the content of the website reflects the preferences of its users, for example by presenting blog posts relevant to visitors based on their browsing habits.

4.3. To get in touch with you

On our website you can interact with us in different ways: by email, contact form or job application. We may also use your information (including any telephone number and email address you have provided for this purpose) to contact you and to respond to your comments, enquiries or requests.

4.4. To ensure your rights and DENGUN's rights

Under the data protection legislation in force in the European Union (General Data Protection Regulation), the use of personal data must be justified under at least one legal basis. The legal basis applicable to the collection and use of your personal data for customer service and marketing purposes is your consent.

Legal bases for the processing of personal data:

• When you have given consent to the processing of your personal data (you will be presented with a consent form for this purpose, and consent may subsequently be withdrawn);
• When the processing is necessary to enter into or perform a contract with you;
• When the processing is necessary to fulfil the legal obligations to which DENGUN is subject;
• When the processing is necessary to pursue a legitimate interest and our reasons for it prevail over your data protection rights;
• When the processing is necessary for us to establish, exercise or defend a right in legal proceedings against you, us or a third party.

How we keep your personal data safe

We use a variety of security measures, including encryption and authentication tools, to help protect and maintain the security, integrity and availability of your personal information.

Although data transmission via the internet or a website cannot guarantee complete security against intrusion, we and our service providers and business partners make every effort to implement and maintain physical, electronic and procedural safeguards to protect your personal data in accordance with applicable data protection requirements. Among others, we have implemented the following:

• Access to your personal data restricted on a need-to-know basis and only within the scope of the purposes communicated;
• Transfer of collected data only in encrypted form;
• Storage of highly confidential data (such as credit card information) only in encrypted form;
• Protection of information technology systems through firewalls to prevent unauthorised access to your personal data;
• Continuous monitoring of access to information technology systems to prevent and detect misuse of your personal data.

How long we keep your personal information

We store your data only for as long as necessary for the purpose for which it was collected.

Once the maximum retention period has been reached, your personal data will be irreversibly anonymised (anonymised data may be retained) or securely destroyed.

For the purposes described in this Privacy Policy (customer service), your personal data will be kept for a maximum of 5 years from the date of your consent or the last contact made (whichever is later), provided you have not withdrawn your consent within that period. For marketing purposes, your contact details will remain with us until you unsubscribe or otherwise indicate that you no longer wish to hear from us.

How you can change or withdraw your consent

You may change or withdraw your consent at any time, with effect for the future.

Once you have fully withdrawn your consent, you will no longer be contacted or receive communications for the purposes described in this Privacy Policy.

Consent granted to DENGUN can be withdrawn by calling +351 915 259 722 or by emailing [email protected].

If you have any questions about our use of your personal data, please contact us first. Subject to certain conditions, you may have the right to request:

• Additional information about how we use your personal information;
• A copy of the personal data you have provided to us;
• Transfer of the personal data you have provided to another data controller, at your request;
• Correction of any inaccuracies in the personal data we hold;
• Deletion of personal data whose use is no longer legitimate;
• Restriction of the way we use your personal data while a complaint is being investigated.

The exercise of these rights is subject to certain exceptions intended to safeguard the public interest (e.g. the prevention or detection of crime) or our interests (e.g. maintaining professional secrecy).

Data retention periods

Personal data is kept only for the period necessary for the purposes for which it was collected or subsequently processed, and compliance with all applicable legal rules on archiving is ensured.

Consumer information

Under article 18 of Law no. 144/2015, in the event of a dispute, the consumer may contact an Arbitration Centre for Consumer Disputes:

CIMAAL – Centro de Informação, Mediação e Arbitragem de Conflitos de Consumo do Algarve.

• Address: Ninho de Empresas, Edifício ANJE, Estrada da Penha, 3.º andar, sala 26, 8000 Faro;
• Tel.: 289 823 135;
• Email: [email protected];
• Website: www.consumidoronline.pt