Privacy Policy

IDENTIFICATION OF THE DATA CONTROLLER

Name: Spiritani, Lda

Registered office: Rua de Santo Amaro À Estrela, Nº 51 1200-801 Lisbon

Corporate Tax Identification Number: 514007460

Telephone: +351 214 684 461 (call to the national landline network)

E-mail: spiritani@espiritanos.pt

DUTY TO PROVIDE INFORMATION

The protection of personal data of natural persons in Portugal is governed 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” means any information of any nature and regardless of the medium in which it is contained, including sound and image, relating to an identified or identifiable natural person, and therefore the protection does not cover data relating to legal persons.

An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more specific elements of their physical, physiological, psychological, 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 Spiritani, Lda through the website www.stellabraga.pt.

PURPOSES OF THE PROCESSING OF PERSONAL DATA

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

  1. Managing the contracting of services carried out through the Website, such as contact requests or reservation management;
  2. Periodically sending communications containing news related to the activity of Spiritani, Lda and the sector in which it operates;
  3. Anonymous and aggregated analysis of the use of the services, in order to identify Users’ habits and trends, with a view to improving the services offered and meeting the specific needs of Users;
  4. In the event of contracting, the data collected through 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 activities;
  5. Compliance with national and international legal provisions, or execution of an order issued by the competent judicial authorities;
  6. Compliance with legal obligations arising from applicable data protection legislation, as well as the exercise of data subjects’ rights, in particular the defence of a right in legal proceedings.

Spiritani, Lda guarantees the confidentiality of all data provided. Although Spiritani, Lda collects and otherwise processes data securely and takes measures to prevent its loss or manipulation, using the most appropriate techniques for this purpose, it should be noted that data collection over open networks does not allow personal data to circulate under conditions of absolute security, and there is a risk that such data may be accessed and used by unauthorised third parties.

Failure to provide data marked as mandatory may make it impossible to respond to the data subject’s request.

LAWFULNESS OF THE PROCESSING OF PERSONAL DATA

Spiritani, Lda processes Users’ data:

  1. when they give their free, specific, informed and unambiguous consent to the processing of their personal data for specific purposes; and/or
  2. when it is necessary for the performance of a contract to which the User is a party, or for taking steps at the User’s request prior to entering into a contract; and/or
  3. for compliance with legal obligations to which Spiritani, Lda is subject; and/or
  4. for the purposes of the legitimate interests pursued by Spiritani, Lda or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

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

Where the data provided belongs to a third party, the User guarantees that they have informed the third party of the aspects contained in this document and obtained their authorisation to provide their data to Spiritani, Lda for the purposes indicated.

RETENTION PERIOD

Spiritani, Lda only retains and processes your personal data for the period that is necessary or mandatory to fulfil the purposes described above, applying appropriate information retention criteria to each processing activity and in accordance with the applicable legal and regulatory obligations.

Spiritani, Lda keeps 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 no longer than that required to pursue the purposes for which the data was collected, unless legal or contractual obligations provide otherwise;
  • to comply with specific legal or contractual obligations;
  • where applicable and lawful, until the Data Subject potentially requests objection or erasure.

DATA DISCLOSURE

In addition to disclosures made in compliance with legal obligations, the personal data of the Data Subject may be accessed, in addition to Spiritani, Lda, by:

  • external service providers of Spiritani, Lda, acting in their capacity as processors;
  • national and international companies belonging to the same group as Spiritani, Lda;
  • authorities in general, administrations, public entities and bodies, both national and international;
  • Spiritani, Lda

INTERNATIONAL DATA TRANSFERS

The personal data collected will be processed within the European Economic Area, with 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 take place following the adoption of appropriate safeguards and the required level of protection, in accordance with personal data protection legislation.

INFORMATION SECURITY

Spiritani, Lda has implemented appropriate technical and organisational security measures to ensure the security of the personal data provided by the User, with a view to preventing its alteration, loss, processing and/or unauthorised access, taking into account the current state of technology, the nature of the data stored and the risks to which it is exposed.

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

If Spiritani, Lda subcontracts other entities to provide services involving the disclosure of personal data, such entities will be required to adopt the necessary technical and organisational measures 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, restriction of processing, erasure, portability, objection and withdrawal of consent, under the terms of the GDPR, by submitting a written request through any of the following means, specifying the right or rights they wish to exercise:

SUPERVISORY AUTHORITY

The User also has the right to lodge a complaint with the Portuguese Data Protection Authority in relation to matters concerning 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 to or redirects to pages and services of providers, advertisers, affiliates, sponsors of Spiritani, Lda and other third parties.

However, Spiritani, Lda does not control the content or links that appear on such pages and is not responsible for the practices used by those pages or websites. Spiritani, Lda advises Users to consult the privacy policy of such pages, as well as their terms and conditions.

Browsing or interacting with any other website, including those that have an external link to the Website, is subject to the terms and conditions of that website, and Spiritani, Lda shall in no case be responsible for such access and use.

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

Without prejudice to the processing of data collected through the Website being the responsibility of Spiritani, Lda, as identified above in Section 1 of this Privacy Policy, we inform the User that MIRAIFUTURE PORTUGAL, LDA., with registered office at Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil and Corporate Tax Identification Number 515 139 092, may, in specific situations, act as a Data Controller, independently determining the purposes and means of processing.

This occurs, in particular, in relation to data processed to ensure the operation, maintenance and security of the booking engine.

In such situations, the User’s data will be processed in accordance with the information below:

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

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

The User may exercise the rights referred to in Section 9 by submitting a written request 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 User may also exercise the rights provided for in Section 10.

CHANGES TO THE PRIVACY POLICY

In order to ensure that the document remains appropriate, Spiritani, Lda reserves the right to review this Policy at any time it deems appropriate. Users are therefore advised to check this privacy policy regularly and/or each time they access the Website.

Updated on 09/09/2026.