Introduction

Svaito LTD ("We" or "Svaito") is committed to protecting the privacy of our users, which includes clients and their consumers ("Users"). We adhere to GDPR principles, ensuring data is processed lawfully, fairly, transparently, and securely. This Privacy Policy ("Policy") explains how we collect, use, share, and protect personal data when users interact with our AI-powered booking assistant platform.

1. Definitions

• Site Visitors: any individual who accesses or navigates through our website.

• Client: Duly contracted companies using Svaito’s AI-powered booking assistant.

• Client Collaborators: Employees or representatives of the Client using the platform.

• Client Consumers: End-users or customers of the Client interacting with the platform.

• Personal Data: Information relating to an identified or identifiable natural person.

2. The Controller

The controller for the processing described herein is:
Svaito LTD
68 Rua de Santo Antonio
8000-283 Faro
Portugal

3. Types of Data Collected

Providing your personal data is necessary to use our platform's features. If you choose not to provide certain data, we may be unable to offer some services. The type and amount of data we collect vary depending on the interaction:

3.1 Site Visitors

• Purpose: Access Site

  • Personal Data: IP address, date and time of access, and cookies.

• Purpose: Contact Our Experts

  • Personal Data: Name, email, telephone, company, and company type.

3.2 Svaito Client Collaborators

• Purpose: Platform Access

  • Personal Data: IP address, date and time of access.

• Purpose: Platform Registration

  • Personal Data: Name and employer.

• Purpose: Communication

  • Personal Data: Name, messages sent to the consumer (service provided by an individual).

• Purpose: Platform Usage Statistics

  • Personal Data: Number of services, time of service, use of platform features (event tracking).

3.3 Svaito Client Consumers

• Purpose: Communication Identification

  • Personal Data: Name, email, telephone (varies based on client requirements).

• Purpose: Communication Interaction

  • Personal Data: Messages sent by the consumer (service history).

• Purpose: Pre-Check-in

  • Personal Data: Name, profession, nationality, telephone, age, sex, ID document, residence, origin, destination, reason for travel, companions, signature, check-in and check-out dates.

• Purpose: Platform Usage Statistics and New Product Development

  • Personal Data: IP, browser/communication channel used, URL, tags, location via IP, language, service history.

4. Purposes and Legal Bases of Processing

• Usage Contract: Data is processed to fulfil the services offered on our platform (Article 6(1)(b) GDPR).

• Promotional Communication: With your consent, we process contact data to send information and offers (Article 6(1)(a) GDPR).

• Automated Communication: We automate parts of our communication for efficient service delivery (Article 6(1)(b) GDPR).

• Fraud Prevention and Legal Claims: We process data to prevent fraud, ensure network and information security, and establish, exercise, or defend legal claims. This is necessary to protect our legitimate interests and those of our clients. (Article 6(1)(f) GDPR).

5. Sharing of Your Data

• Service Providers: We use third-party providers for hosting, data storage, and analytics, who process data on our behalf.

• Clients: Information collected by our platform may be shared with the client you are interacting with.

• Legal Requirements: We may share data to comply with legal obligations or protect our rights.

• International Transfers: Personal data may be transferred to countries outside the EEA, such as the United States. In such cases, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission. You may request a copy of these safeguards by contacting us.

6. Joint Controllers

For certain processing activities, Svaito LTD and our Clients act as joint controllers in determining the purposes and means of processing personal data of Client Consumers. We have established agreements defining our respective responsibilities to ensure compliance with GDPR obligations.

• Svaito's Responsibilities: Managing the platform's technical operations, ensuring data security, and facilitating the processing of personal data as per the platform's functionalities.

• Client's Responsibilities: Determining the specific purposes for which the personal data is processed within their use of the platform and ensuring lawful collection of personal data from their consumers.

If you have questions regarding the processing of your personal data, you may contact either Svaito LTD or the relevant Client directly.

7. Data Retention

We retain your personal data only as long as necessary for the purposes for which it was collected, including compliance with legal obligations. The retention periods for personal data are as follows:

7.1 Site Visitors

• Personal Data: IP address, date and time of access, cookies.

• Retention Period: Up to 12 months from the date of collection.

7.2 Svaito Client Collaborators

• Personal Data: Name, employer, IP address, date and time of access, messages sent to the consumer, platform usage statistics.

• Retention Period: Duration of the contractual relationship plus 5 years, to comply with legal and contractual obligations.

7.3 Svaito Client Consumers

• Personal Data: Name, email, telephone, messages sent by the consumer, pre-check-in information, platform usage statistics.

• Retention Period: As long as necessary to fulfil contractual obligations and legal requirements, typically not exceeding 7 years from the date of the last interaction.

After these periods, personal data will be securely deleted or anonymized, unless we are required by law to retain it for a longer period.

8. Your Rights

8.1 Your Rights

You have the following rights regarding your personal data:

• Access: Request confirmation as to whether we process your personal data and access to the personal data we hold about you.

• Rectification: Request correction of inaccurate or incomplete personal data.

• Deletion: Request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent.

• Objection: Object to the processing of your personal data based on legitimate interests or for direct marketing purposes.

• Portability: Receive your personal data in a structured, commonly used, and machine-readable format and have it transmitted to another controller.

• Restriction of Processing: Request the restriction of processing under certain conditions.

• Withdrawal of Consent: Withdraw consent where processing is based on consent.

To exercise any of these rights, please contact us by email or post:

Svaito LTD, 68 Rua de Santo António, 8000-283 Faro, Portugal

We will respond to your request within one month of receipt. This period may be extended by two further months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request.

8.2 Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with a supervisory authority responsible for data protection. In Portugal, this is the National Data Protection Commission (Comissão Nacional de Proteção de Dados - CNPD).

Contact Details for CNPD:

• Address: Av. D. Carlos I, 134 - 1.º, 1200-651 Lisbon, Portugal

• Phone: +351 213 928 400

• Email: geral@cnpd.pt

• Website: www.cnpd.pt

Alternatively, you may lodge a complaint with the supervisory authority in your country of residence within the European Union.

9. Data Security

We employ industry-standard security measures, including encryption, firewalls, secure socket layer (SSL) technology, and regular security assessments to protect your data.

10. Policy Updates

This Policy may be updated periodically. Significant changes will be communicated via email or a prominent notice on our platform, and your continued use of our platform constitutes acceptance of the changes.

11. Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16 years of age. If you are under 16, please do not provide any personal information through our platform. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly. If you believe that we might have any information from or about a child under 16, please contact us.

12. Children's Privacy

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our platform, analyse usage, and assist in our marketing efforts.

Types of Cookies We Use:

• Essential Cookies: Necessary for the website to function properly.

• Analytical/Performance Cookies: Help us understand how visitors interact with our site.

• Functionality Cookies: Remember your preferences to personalize your experience.

Managing Cookies:

You can control the use of cookies at the individual browser level. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling cookies may affect the functionality of our website.

13. Contact Information

If you have any questions, concerns, or requests regarding this Policy or how we handle your personal data, please contact us at:

Svaito LTD
68 Rua de Santo António
8000-283 Faro
Portugal