What does TurPortugal do?
TurPortugal provides an online marketplace for people to search for and rent short-term vacation properties or list their properties to be rented. Properties can be listed via our Online Services. We offer customer support to you through our customer services team to deal with any issues you have with your listing or booking such as complaints.
Key things you should know about how we use your information:
We use your information (and the information of those travelling with you) for purpose of enabling travel bookings.
This includes sharing your booking information with our Suppliers or Owners in order for them to fulfil your booking.
We also engage other third-party vendors who provide services or functions on our behalf.
Where you choose to receive marketing information, we will let you know about any special offers that may be of interest to you, including our loyalty programs. You are able to opt-out at any time by visiting our Preference Center, the Customer Services Portal or unsubscribing as instructed in our communications.
You can contact us about updating or accessing your information through our Customer Services Portal.
We use information like cookies to improve your experience on Online Services; provide us with analytics information that will help us improve our Services generally; and to collect information about travel destinations of interest to you so that you may see travel ads that are more relevant to you.
From time to time and usually following an interaction with us, we will ask you for your feedback to ensure we are providing the best service we can.
If you have any questions or concerns about our use of your personal information, then please contact us via our Customer Services Portal found in the “Contact Us” section at the bottom of this policy.
If any parts of our Online Services link you to other websites or Apps, those newly opened links do not operate under this Privacy Notice. We therefore recommend you examine the privacy notices/statements/policies posted on those other online areas to understand their procedures for collecting, using, and disclosing personal information.
What personal information do we collect and why?
Information that you provide directly to us.
We may ask you to provide personal information directly to us. For example, we may ask you to provide your contact details such as full name, telephone number and email address in order to:
enable your travel booking;
create or register an account with us;
provide the services and information you request such as details about your booking;
have an emergency contact number for you;
update frequent flyer or loyalty program information;
subscribe you to our marketing communications; and/or
submit your enquiries.
You will also need to provide your billing information (such as credit card number, cardholder name and expiration date) to make a payment.
You may also provide information about any Travellers on your booking, your marketing preferences and when you participate in a survey or competition. When creating an account, you will provide a login name/member ID as well as a password.
If you’re an employee of a corporate account, a vendor or other type of business partner such as an Owner, travel agent, other information collected can include employer, employee identification number, or other relevant details.
For Owners, additional personal information may be collected for listing a property, communicating with a user or Traveller and when you set up financial account information for payment processing.
Special Categories of Personal Information
Certain types of personal information, such as some government-issued identification numbers, religion, health or sexuality, are considered sensitive and require additional protection under applicable laws. We limit the circumstances under which we may collect sensitive personal information; examples of this information include the following:
Health-related information may be needed for you to arrange or book appropriate travel accommodation and accessibility or facility requirements.
Government-issued identification numbers like passport or driver’s license number may be required for vehicle rental or other travel reservation.
Other information that you can specify at your option and which may imply or suggest information like religion, health or other information, such as dietary needs.
Information Voluntarily Provided About Your Travel Companion(s)
If you make a reservation with our customer service team over the phone, and if as part of that reservation you wish to purchase additional travel products on behalf of someone else, we will request personal information about that individual. You should obtain the consent of any other individual(s) prior to providing us with their personal information. Should your travel companion want to amend or delete their information themselves they can contact us directly at the information in the “Contact Us” section at the bottom of this policy.
Information that we collect automatically
When you visit us on our Online Services, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type (such as Firefox, Safari, or Internet Explorer), your Internet Service Provider (ISP), your operating system and carrier. For website users, details of any referring website or exit pages as well as broad geographic location (e.g., country or city-level location) and also collected. We may also collect other technical information such as how your device has interacted with our Online Services, including the pages accessed and links clicked, i.e., trips viewed and the time and date of these.
Collecting this information enables us to better understand the visitors who come to our Online Services, where they come from, and what content on our Online Services is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Online Services for our visitors, for example, to customize your user experience, tailor your searches and show you advertisements that may be of interest. We also use this automatic information to prevent and detect fraud.
Information we collect when you use Apps
When you use one of your smart phone app, tablet app, or applications for other platforms (collectively “App” or “Apps” as applicable), we also collect:
Information about the functionality of the Apps you access and use. This allows us to identify those areas of the Apps that are of interest to our customers so that we can refine and continuously improve the Apps.
Each App sends us the device’s unique device identifier (or “UID”), a sequence of numbers or characters that are unique to your device. We use this only on the first opening of the App so that we can confirm to our advertising networks the number of downloads resulting from clicks on their respective ad banners and other marketing tools. When an email address is provided, we associate this with your current UID/cookie ID for the purposes of providing a seamless experience across your devices.
Each App will also send us error-reporting information in the event that it crashes or hangs. This enables us to investigate the error and to improve the stability of the App for future releases. As part of these error reports, the App sends us information about the mobile device type and version, the UID, the time the error occurred, the feature being used and the state of the application when the error occurred. We do not use this information for any purpose other than investigating and remedying the error.
You always have the ability to control what information a App sends to us. You can exercise this control either by changing the settings of the App under its setting menu or changing the settings of your mobile device. Alternatively, you can remove the App from your device entirely and access our services through our website.
Information that we obtain from third party sources
Periodically, we lawfully obtain personal information about you from affiliated entities, business partners and other independent third-party sources and add it to our account information. Examples of information we may receive include: updated contact information like email, purchase history, and demographic information.
Information we collect when you communicate with us via the following methods
When using a social media feature, if you have chosen to include it in your social media account, we may access information such as your name, profile picture, gender, birthday, email address, town or district and any other information you have chosen to make available. Subject to your privacy settings, we access information that you provide to a social media provider regarding your respective locations (“Location Data”) to provide you with relevant content. We do not store or use any data related to the friends you are connected with on a social media site.
Call Monitoring and Recording:
Other Online Communications:
When you choose to communicate with an Owner via our Online Services, your name and other information you supply will be visible to the relevant Owner so that they can reply to you. Such communications are subject to the Traveller Terms and Conditions posted on our site.
Games: We may reserve the right to provide from time to time games on the Site. These games might allow for connectivity with other users or third parties. If that is the case, you consent to your personal information being transferred accordingly.
Traveller and Owner Reviews
We may collect reviews written by Travellers on a property they have stayed in (“Traveller Review”) and/or written by Owners on a Traveller’s stay (“Owner Reviews”). Traveller Reviews are displayed on our Site, while Owner Reviews will only be disclosed to Owners who receive an inquiry or booking request from that Traveller. Both Owners and Travellers must comply with the Content Guidelines. Owner Reviews enable an Owner to know more about the Traveller who has contacted them and therefore increase trust in our platform. Owners must comply with the Owner Terms and Conditions and applicable law and this includes not using any information about a Traveller to discriminate against such Traveller.
We are not responsible for the Owner deducing your identity from the content of your review and contacting you directly.
Cookies and similar tracking technology
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.
Who do we share your personal information with?
We may disclose your personal information to the following categories of recipients:
they send to choose not to receive such email messages in the future.
Third party services providers who provide data processing services to us (for example, to support the delivery of; provide functionality on; or help to enhance the security of our Online Services), or who otherwise process personal information for purposes such as credit card processing, business analytics, customer service, marketing, distribution of surveys or sweepstakes programs, to facilitate the delivery of online advertising tailored to your interests and fraud prevention. Where third-party service providers have access to data they will only collect information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
Business partners with whom we may jointly offer products or services, or whose products or services may be offered on our Online Services. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasions share information about you, including your personal information, with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
If you were referred to our Online Services via a hyperlink from an external site of one of our partners, we will share your personal information, browsing activity on our Online Services, and purchase information with the referring partner.
Your online profile may be viewable by other users, including Owners, of our Online Services. For Owners, property listings may display statistics of usage, such as information related to the responsiveness of owners.
If you connect your TurPortugal account to a social media provider, such as through “Facebook Connect,” we may make available on that social media provider’s platform the information related to your use of our Services, such as any rewards and loyalty program we may introduce or the reviews you post on our Online Services. Such information may also be published on that social media provider’s websites or services. Information made available on the social media provider’s platform will be attributed to the social media provider account to which your TurPortugal account is connected.
You may choose to disable automatic publishing by the social media provider of such information by editing your privacy settings for that social media provider. We will not provide any other social media provider with access to your TurPortugal account number or information. If you connect your TurPortugal account to a social media provider, we may also share your user name and your profile picture from that social media provider to other TurPortugal members. You may choose to disable such sharing of information by editing your privacy settings on that social media provider’s site.
Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. This includes applicable tax authorities or other authorities allowed to collect taxes, where necessary to pay taxes from or on behalf of Travellers or Owners to tax authorities in accordance with the Online Services Terms and Conditions and to comply with any valid request;
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this website, our customers, or others; and in connection with our Terms and Conditions and other agreements;
On occasion, we share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular properties and vacation destinations. This information does not contain any personal information and is used to develop content and services we hope will be of interest to our users.
How do we use your information?
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
How do we determine what our Legitimate Business Interests are?
We carry out an assessment to ensure that:
(i) Our interest in the use of your data is legitimate (i.e., we have a clear business need); and
(ii) The business need, on balance, does not override your privacy rights.
When determining this, we assess the potential impact a specific use of the data may have on you as a customer and weigh this against our own business needs to ensure that we get the balance right. We also apply a series of security measures to minimise any potential risks.
By way of example in practice we would consider that the collection of our customers’ marketing preferences in the course of a booking is a legitimate business interest to have as an online ecommerce company. We believe that this does not unduly impact your privacy rights as you may, most definitely, want to hear about our products and services going forward. However, to protect your privacy rights we ensure that you can opt out of these communications at any time, in your account, in the email itself or through customer services.
In accordance with the legal grounds above, we use the information we collect to:
fulfil the transactions that you make, such as for Travellers: booking a property or hotel, or for Owners: to list a property;
provide you with travel confirmations and important travel updates for your upcoming trip (via email or SMS);
verify your identity for fraud prevention purposes;
manage your account, including processing payments;
communicate with you in general, particularly if there is a change to your booking;
provide customer services related to your booking or to respond to any inquiry you make;
facilitate communication between you and Owner;
measure interest in and improve our products, services, and website functionality;
notify you about special offers, coupons, sweepstakes and travel-related products and services that may be of interest to you. You may receive these by email, post or via advertisements on third-party sites, including through social media;
otherwise customize your experience with this website or App;
reward you as part of any reward and recognition program you choose to join (whether this is our program or that of a third party);
obtain information from you, including through feedback you give or surveys you complete;
carry out statistical analysis about the use of our website and Apps and the services we offer to improve each aspect of what we do;
protect our rights as a company including our intellectual property for example;
resolve disputes, collect fees, or troubleshoot problems;
prevent potentially prohibited or illegal activities;
enforce our Terms and Conditions; and
as otherwise described to you at the point of collection.
How do we protect your personal information?
We want you to feel confident about using our Online Services to make travel arrangements, and we are committed to protecting the information we collect. While no Online Services can guarantee absolute security, we have implemented appropriate technical and organisational measures to protect the personal information that we collect and process about you. For example, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your information. In addition, only authorised employees are permitted to access personal information, and they may only do so for permitted business functions.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident and outside of the EEA. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, the servers of our Online Services are located in the US, and our group companies and third party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries.
We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice when transferred outside of the EEA. Any data transfers between our group companies are governed by our intergroup agreement which incorporates strict data transfer terms approved by the European Commission (known as Standard Contractual Clauses) and requires all group companies to protect the personal information they process from the EEA in accordance with European Union data protection law.
We ensure that any of our third-party service providers to whom a data transfer is made has appropriate safeguards in place to protection your personal information. The adequacy mechanism may be i, adequate country status, i.e., based in a country that the European Commission has deemed “adequate” since its data protection standards are similar to the European Union; ii, Standard Contractual Clauses; or iii, EU-US and Swiss-US Privacy Shield.
We retain the personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise the data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We will anonymise or aggregate your data if we intend to use it for analytical purposes or trend analysis over longer periods.
Your information rights
You can access or update your contact information in the Account section of our Online Services. You can de-activate your account at any time either by contacting us through the Customer Services Portal or at the email address listed below. After you de-activate an account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time. If you wish to delete your data, please contact us through the Customer Services Portal listed below.
If you wish to contact us in relation to any personal information that is not displayed in your account, you can contact us through the Customer Services Portal provided below.
Your data protection rights
If you are a resident of the European Economic Area, you have the following data protection rights:
If you request access to your personal data we will confirm whether we hold your information and provide you with a copy, explaining how we process it and why, how long we store it for and your rights associated with it.
If you request deletion of your personal information, we will erase it. Please do note that we will need to retain any information that we require to fulfil our legal obligations or to establish, exercise or defend a legal claim.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Display of Tailored Advertising/Your Choices
Data collected by this website to serve you with relevant advertising. We are committed to providing you with relevant content and information. To do this, we may, through cookies and other technologies, collect information about your travel-related searches, such as whether you are looking for properties or hotels. We use this information, together with other information we have collected about you, to serve you with more relevant ads on our website, across the internet, and on other devices that you may use. So, for example, if you search for a property in London on this site, you may see an ad for a London travel package on this site or on another website you visit.
Data collected by companies that operate cookie-based exchanges to serve you with relevant advertising. Like other companies operating online, we participate in cookie-based exchanges where anonymous information is collected about your browsing behavior through cookies and other technologies and segmented into different topics of interest (such as travel). These topics of interest are then shared with third parties, including advertisers and ad networks, so they can tailor advertisements to your apparent interests. We do not share personal information (such as your email address) with these companies and we do not permit these companies to collect any such information about you on our site. Please click here to learn more about cookie-based exchanges, including how to access information about the topics of interest associated with cookies on your computer and how to decline participation in these programs.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Participants in the leading Internet standards-setting organization that is addressing this issue are in the process of determining what, if anything, websites should do when they receive such signals. We currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
Changes to This Notice and How to Contact Us
If you have any questions or concerns about our use of your personal information, please contact us via the Privacy Section on our Customer Services Portal here.
The Data Controller of your personal information is Sentido Capital SA.