Privacy Police

1. Data Controller

The entity responsible for processing personal data is:

**BETWEENSROOTS, Inc.**
CNPJ: 510 600 298
Rua da Bouça n.º 48
4990-755 Seara
Ponte de Lima – Portugal
Telephone: +351 917 602 414
Email: info@betweenroots.pt
Website: www.betweenroots.pt

BETWEENSROOTS, Inc. undertakes to process personal data lawfully, fairly and transparently, in accordance with the General Data Protection Regulation (GDPR), Law No. 58/2019 of August 8, and other applicable legislation.

2. Personal Data Processed

Depending on the form of contact, reservation request, and subsequent service provision, the following may be processed:

* Name;

* Email address;

* Telephone number, when provided;

* Desired check-in and check-out dates and times;

* Number of adults and children;

* Number of rooms;

* Desired accommodation;

* Information voluntarily included in the comments field;

* Data necessary for guest identification, when legally required;

* Data necessary for billing;

* Other data necessary for managing the reservation, stay, or compliance with legal obligations;

* Technical data associated with the use of the website, when necessary for its operation and security.

BETWEENSROOTS, Inc. will seek to collect only the data that is adequate, relevant, and necessary for each purpose.

3. Purposes of Processing

Personal data may be processed to:

* Respond to information requests;

* Check availability;

* Respond to and follow up on reservation requests;

* Communicate with the client regarding the desired accommodation;

* Carry out pre-contractual due diligence requested by the client;

* Confirm and manage reservations;

* Provide the contracted accommodation services;

* Manage guest check-in, stay, and check-out;

* Process payments, when applicable;

* Issue invoices and fulfill accounting and tax obligations;

* Comply with legal obligations associated with the accommodation activity;

* Manage customer complaints or other requests;

* Ensure the security and operation of the website and systems used;

* Exercise or defend rights in case of litigation.

4. Legal Basis

The processing of personal data will be carried out based on one or more of the legal bases provided for in the GDPR, depending on the specific purpose.

The processing may be based, in particular, on:

* the performance of a contract or pre-contractual due diligence requested by the data subject, including requests for availability or reservations;

* In compliance with legal obligations applicable to BETWEENSROOTS, Ltda., especially tax, accounting and accommodation-related obligations;

* In the legitimate interest of the company, when applicable and provided that the fundamental rights and freedoms of the data subject do not prevail;

* In consent, when this is the appropriate legal basis for a given purpose.

When processing is based on consent, this may be withdrawn at any time, without compromising the lawfulness of the processing previously carried out.

5. Reservation Request Form

The website provides a form through which the user can make a reservation request.

Through this form, data such as name, email, desired check-in and check-out dates and times, number of adults and children, number of rooms, desired accommodations and any observations may be requested.

This data is intended to allow BETWEENSROOTS, Ltda. to analyze the request, check availability, contact the interested party and take the necessary steps for the eventual contracting of the accommodation.

**Submitting the form constitutes a booking request and does not, in itself, mean that the booking is confirmed.**

6. Contact by email or telephone

The client may also contact BETWEENSROOTS, Lda. by email or telephone to request information or make a booking request.

The data provided by these means will be processed to the extent necessary to respond to the contact and, where applicable, to prepare, confirm and manage the booking.

7. Forms via the Mobirise/Formoid service

The forms available on this website use the Mobirise/Formoid service for processing and forwarding messages sent by users.

When a request is submitted through a form, the data entered is processed through the infrastructure associated with this service before being forwarded to the email address configured by BETWEENSROOTS, Lda.

This processing is intended exclusively to allow the receipt and forwarding of requests submitted through the website.

BETWEENSROOTS, Inc. seeks to use appropriate service providers and limit data processing to what is necessary for the provision of the respective services, in accordance with applicable data protection legislation.

8. Reservations and Stays

After a reservation is confirmed, it may be necessary to collect additional data to manage the stay, billing, and comply with legal obligations applicable to the activity.

Whenever legislation requires the communication of certain data to competent public authorities or entities, BETWEENSROOTS, Lda. will proceed with this communication in accordance with the legally established terms.

9. Data Recipients

Personal data may be communicated, when necessary and legally permitted, to:

* providers of technological services used in the operation of the website and forms, including Mobirise/Formoid services;

* website hosting, email, or form processing providers;

* accounting service providers;

* payment service providers, when applicable;

* booking platforms, when used;

* tax, administrative, police, or judicial authorities, when there is a legal obligation;

* other entities whose intervention is necessary for the provision of the contracted service or the fulfillment of legal obligations.

Personal data will not be made available to third parties for purposes incompatible with those that determined its collection.

10. Data Retention

Personal data will be kept only for the period necessary for the purposes for which it was collected.

Data relating to information requests or reservation requests that do not result in contracting will be kept only for the period reasonably necessary for the management and monitoring of the contact, unless there is another basis for its retention.

When data is associated with confirmed reservations, invoicing or other operations subject to legal retention obligations, it will be kept for the periods established by applicable legislation.

11. Data Security

BETWEENSROOTS, Inc. will adopt appropriate technical and organizational measures designed to protect personal data against loss, destruction, alteration, disclosure or unauthorized access.

12. Data Subject Rights

Under applicable law, the data subject may exercise, as appropriate, the rights to:

* access their personal data;

* Rectification of inaccurate or incomplete data;

* Erasure, when legally applicable;

* Restriction of processing;

* Objection to processing;

* Data portability, in legally foreseen cases;

* Withdrawal of consent, when processing is based on consent.

The exercise of these rights may be subject to limitations provided for in legislation, especially when retention or processing is necessary for compliance with a legal obligation or for the exercise or defense of rights.

Requests may be sent to:

**info@betweenroots.pt**

Additional information may be requested when necessary to confirm the identity of the applicant.

13. Complaints

The data subject has the right to lodge a complaint with the competent supervisory authority in Portugal:

**National Data Protection Commission (CNPD)**

14. Cookies and external services

The website may use cookies and similar technologies.

Cookies and non-essential services that depend on consent will only be activated after the user chooses them through the cookie management mechanism provided on the website.

The website includes content from third parties, namely YouTube videos and maps embedded via Google Maps. This content remains blocked until the corresponding consent is provided.

When the user authorizes the loading of this content, technical data may be communicated to the respective external providers, in accordance with their own privacy policies.

For more information, please consult the Cookie Policy.

15. Links to external websites and platforms

The website may provide links to websites, maps, social networks, booking platforms or other services belonging to third parties.

BETWEENSROOTS, Inc. does not control the privacy practices of these external services, therefore it is recommended to consult their respective privacy policies.

16. Changes to the Privacy Policy

This Policy may be updated due to legislative, regulatory, technological changes or changes in the services provided.

Periodic consultation is recommended. **Last updated: September 2026.**