Privacy policy

1.1 The Data, including Personal Data, indicated below, may be processed when You interact with us in our virtual environments. The following table shows the main Personal Data processing activities according to the main purposes for the regular performance of our activities:

1.2 The use of V3RSO's features depends directly on certain Data indicated in the table above, especially your Registration Data. If You choose not to provide some of this Data, you may be unable to fully or partially enjoy our features.

1.3 User preference Data, such as environment, habits, allergy restrictions, mobility restrictions and disabilities, can be changed by You at any time in the profile editing feature.

1.4 We may process other information beyond that mentioned above, such as when You fill out a form, add information to your account, respond to surveys, open tickets with our chatbot and concierge, interact with recommendations or share your experience with us. This may include health information if You choose to share it with us.

1.5 We may process Personal Data of third parties provided by You, such as in the case of a payment instrument or contact information about another guest in a booking for which You are the holder. By providing Personal Data about other people, You guarantee that you have permission to provide such information to V3RSO for the purposes described in this Privacy Policy and that you have shared our Policy with them.

1.6 Our services are not directed at children and adolescents, and the use of our digital environments must be done only by legal adults capable of doing so. However, in the case of bookings in which one of the guests is a minor, we ask the legal guardian to provide the full name, date of birth and identity document of the child or adolescent solely to enable the provision of the service. In situations where the minor will stay without a legal guardian, an authorization document notarized before a notary public is required. We emphasize that the processing of Personal Data of children and adolescents is carried out in their best interest, pursuant to the LGPD and relevant legislation.

1.7 You are solely responsible for the accuracy, veracity or lack thereof of the Data provided, or for it becoming outdated. It is your responsibility to ensure its accuracy or keep it updated.

1.8 V3RSO will not be obliged to process any of your Data if there are reasons to believe that such processing could impute to it any violation of any applicable law, or if it is verified that You are using our application for any illegal, unlawful or immoral purposes.

1.9 The database formed through the collection of Personal Data is the property and responsibility of V3RSO, and its use, access and sharing, when necessary, will be carried out within the limits and purposes of the business described in this Policy.

1.10 The Personal Data processed is stored in Brazil, as well as in an environment using cloud computing resources and servers, specifically Google Cloud Platform, physically located in South Carolina, in the United States, meaning your Personal Data is also processed outside of Brazil.

1.11 We may use automated decisions and pre-established business rules for the purpose of personalizing service according to the preferences indicated by You. Based on the analysis of your profile, we determine the best environment settings for the accommodation and identify curation, to make your stay more pleasant and increase the compatibility of restaurant and event suggestions.

1.12 For the purposes of market intelligence research, statistical reports and improvement of our intelligence tool, the Data provided by You will be used in an anonymized form, that is, in a way that does not allow your identification.

2.1 The Data processed and the activities recorded in our application may be shared with third parties in the following cases:

• With service providers necessary for the execution of our services, always requiring such organizations to comply with Data security and protection guidelines. Sharing may be carried out to facilitate the administration of our business and for compliance purposes, which includes service providers that help us: (i) verify your identity or authenticate your identification documents for fraud prevention, security investigations and risk assessments; (ii) process booking payment and issue invoices; (iii) release access to the accommodation premises; (iv) enable the provision of V3RSO's services through third-party software platforms and tools; (v) provide customer service or advertising services, including Newsletter; (vi) enable the provision of personalized services with lighting and temperature automation; (vii) offer additional services You select; (viii) carry out product development, maintenance and debugging. We emphasize that such providers have access to your Personal Data to perform the tasks mentioned and are contractually obligated to protect your Personal Data and comply with LGPD requirements;
• With the Ministry of Tourism, arising from the National Tourism Policy - Law No. 11.771/2008 and Decree No. 7.381/2010;
• With competent judicial, administrative or governmental authorities, whenever there is a legal determination, requirement, request or court order; and
• Automatically, in the event of corporate transactions, such as merger, acquisition and incorporation.

2.2 Sharing is carried out respecting the sending of the minimum information necessary to achieve the purposes and adopting all best-practice and security measures to safeguard Personal Data.

2.3 If service providers process any Personal Data on behalf of V3RSO, they must respect the conditions stipulated in this Policy and in the information security policy.

2.4 When You access our application, you may be directed, via a link, to other portals or platforms, which may collect your Personal Data and have their own Privacy Policy. It is your responsibility to read such Policies, being your responsibility to accept or reject them. We are not responsible for third-party Privacy Policies nor for the content of any sites or services linked to environments other than our own.

3.1 V3RSO uses its best efforts to maintain the privacy and security of your Data, aiming to prevent unauthorized access or accidental or unlawful situations of destruction, loss, alteration, disclosure or any form of improper or unlawful processing, through the adoption of the following technical, physical and administrative security measures:

• Technical measures, such as the transmission of Personal Data through a secure web page, storage of Data in electronic media that maintain high security standards, use of a system whose access is controlled, adoption of vulnerability detection tools, regular backups, automatic updating of the database software version and sharing of Data with partners via encrypted and authenticated connections;
• Physical measures, such as restricted control to authorized persons maintained in facilities and use of market security tools;
• Administrative measures, such as the adoption of information security and data governance policies and standards, training and employee awareness efforts;

3.2 The Personal Data processed by V3RSO is accessed only by duly authorized professionals, respecting the principles of proportionality, necessity and relevance for the purposes of the services provided in our environments, in addition to the commitment to confidentiality and preservation of your privacy under the terms of this Policy.

4.1 Personal Data is stored in a secure and controlled environment, for a minimum period that may vary according to its category, purpose and legal basis for processing. It may be stored:

• For as long as the legal relationship between the parties lasts, and the Data may also be kept for a longer period, provided there is a legal basis for doing so, such as to comply with legal obligations or for the exercise of rights;
• There is no request for deletion of Data processed based on consent, or revocation of consent, under the terms of Article 9, item II, of the General Personal Data Protection Law;
• 5 (five) years after the end of the relationship, in accordance with Article 27 of the Consumer Protection Code;
• 6 (six) months, in accordance with Article 15 of the Brazilian Internet Civil Framework;

4.2 For audit, security, fraud control and rights preservation purposes, V3RSO may retain the record history of your Data for a longer period in cases where the law or regulatory standard so establishes, or for the preservation of rights.

4.3 Once the retention period and legal necessity have ended, Personal Data will be deleted using secure disposal methods or used in an anonymized form for statistical purposes.

5.1 You may exercise the following rights with respect to your Personal Data and Information, through our support channel privacidade@v3rso.com.br:

• Confirmation of the existence of Data processing by V3RSO;
• Access to or correction of your Personal Data;
• Anonymization, blocking or elimination of Data that is unnecessary, excessive or processed in non-compliance with the law;
• Objection to processing carried out based on one of the grounds for waiver of consent;
• Revocation of consent regarding the use of your Personal Data;
• Request for deletion of your Personal Data processed based on consent;
• Request for review of decisions made solely based on automated processing of Personal Data and obtaining information about the criteria and procedures used;

5.2 If You object to processing linked to purposes that are fundamental to the regular operation of our environments, the services offered may become unavailable to You.

5.3 It is important for You to know that the exercise of your rights is not unlimited. We may, in specific cases authorized by law, deny a request. If this occurs, You will be informed of the reason for our refusal.

5.4 You are also aware that if a request to access your Personal Data concerns specific documents, especially those involving Personal Data of other people, only your Personal Data will be provided, not the entirety of the documents.

5.5 V3RSO undertakes to respond to all requests within a reasonable time, always in compliance with applicable law.

6.1 This Policy is subject to constant improvement and enhancement, and V3RSO reserves the right to modify it at any time, according to the purpose or need, such as for adaptation and compliance with a legal or regulatory provision with equivalent legal force, it being your responsibility to check it whenever you access our environments.

6.2 In the event of a change to this Privacy Policy, we will publish the new version with the updated date at the top, at least 30 (thirty) days before the effective date of the new terms.

6.3 If You do not agree with the revised Privacy Policy, you may cancel your account. If You do not cancel your account before the effective date of the revised Privacy Policy, your continued access and/or use of our environments will be subject to the new Policy.

6.4 If any point of this Policy is considered inapplicable by a Data Protection Authority or Judicial Authority, the remaining conditions will remain in full force and effect.

6.5 You acknowledge that all communication made by email (to the addresses provided in your registration), SMS, instant messaging applications or any other digital form is also valid, effective and sufficient for disclosing any matter related to our environments, your Data, as well as any other related matter, with the only exception being what this Policy provides as such.

6.6 In case of any doubt regarding the provisions of this Privacy Policy and Data Processing, You can contact us through our support channel, available at the email privacidade@v3rso.com.br.