Privacy Policy

VHC - PRIVACY POLICY

Vacation Home Collection ("VHC Hospitality" or "VHC") and the CVC Corp group companies value the protection of the personal data of all its potential and final consumers ("Clients", "Client" or "You>") and are committed to the protection and security of personal data, treating them with confidentiality and respecting the right to privacy.

This Privacy Policy aims to provide Clients with clear and accurate information about the collection, use, storage and other types of processing of their personal data performed in the context of our activities in the vacation rental sector in Brazil and abroad, in addition to informing how Client privacy is protected in the course of VHC's relationship with You.

1. WHO DOES THIS PRIVACY POLICY APPLY TO?

VHC is, as a rule, the controller of the personal data the processing of which is described in this Privacy Policy, processing them together with other controllers and operators as described here in.

VHC provides property management and rental services for vacation tourism. Thus, this document applies to all individuals whose personal data is processed by VHC for the purpose of renting vacation properties, including through the website vhcstay.com ("Platform").

This Privacy Policy does not apply to data processing activities conducted by other service providers and third parties involved in conducting our activities, and relates solely to data processed by VHC.

2. WHAT INFORMATION IS PROCESSED?

VHC may collect and process Client personal data for the purposes described in this Privacy Policy. The types of personal data processed in the course of providing services may include:

• Registration information. In order to provide the services, VHC will need to collect some registration data about you, such as your full name, an identification document number, e-mail address, date of birth, among other necessary identification data. Such information may also be collected if You contact VHC, for example, with a question.


• Bank Details and Payment Data. Upon your contracting its services, VHC may work in conjunction with third party online payment management companies to process this. It is important You are aware that such companies may collect and store your information and data, including bank and credit card information.


• Information about other people. If You contract a service for You and a companion(s), You must provide the necessary information to enable the provision of VHC services to the companion(s) as well.


• IP addresses, cookies and identifiers. When You visit or access our Platform, certain information may be automatically collected from your computer or mobile device such as session data, IP address, web browser software, referring site, dates and times of interactions with our Platform, and geolocation. Information may also be collected about your online activity such as content viewed, pages visited, and searches or reservations You have made or make. One of the purposes of collecting such automatic information is to help understand your interests and preferences, as well as to personalize and enhance your experience on the VHC Platform, such as by pre-filling data, and to show you certain adverts of interest to you.

VHC does not handle data from children and adolescents, and always makes all bookings in the name of their parents or guardians.

As mentioned above, VHC may use cookies when You browse the Platform. Cookies are only associated with an anonymous user and their computer, and do not provide references enabling the user's first and last names to be deduced. Thanks to cookies, VHC is able to recognize registered users right after their registration, without having to log in each visit. In addition, third parties may also be allowed to collect information about your online activities through cookies and other technologies. Please note that VHC has no access to or control over the cookies or other technologies these third parties may use to collect information about your interests, and the information management practices of these third parties are not covered by this Privacy Policy. You can configure your browser to be notified of the receipt of cookies and to prevent their installation. Please refer to the instructions and manuals for your browser to expand on this information. You are not required to allow installation of the cookies sent in order to use the Platform, but your browsing and experience may be affected if You disable VHC's cookies.

Personal data processed by VHC may also vary depending on the service or package of services contracted by the Client and on specificities and preferences that the Client may report or request.

3. HOW IS THE INFORMATION COLLECTED?

For the provision of VHC's services, the data You provide on the website vhcstay.com, will be collected as you are making your reservation and in our on-line check-in system, accessing www.checkinvhc.com.

Moreover, providers engaged by VHC to provide services to Clients, pursuant to the terms of the agreement with the Client, may share data about the service and its consumption throughout the provision of the service with VHC.

In all cases, we at VHC undertake to maintain absolute confidentiality of all data, processing only the personal data necessary to provide the services, to comply with any legal obligation, or in other situations permitted by law.

4. WHAT ARE THE PURPOSES OF PROCESSING YOUR INFORMATION?

Your information and personal data will be processed for the following purposes:

• Processing financial transactions;


• Providing VHC services, such as making a reservation or registering as a guest;


• Hiring the suppliers necessary for the provision of VHC services (for example, cleaning services, chefs, actors for birthday parties, among others, depending on the specific case) and making payment to such suppliers;


• Analyzing refund requests, reviewing fines, and no-shows;


• Analyzing credit card fraud or chargeback;


• After-sales service;


• Dealing with doubts, complaints or suggestions You send via the service channels;


• VHC performance monitoring and enhancing sales and promotional initiatives, including by providing and supplying advertising.

5. WHO IS THE INFORMATION SHARED WITH?

As you know, VHC provides its services to the Client, as well as contracting suppliers, with whom it has partnerships, from various areas. Such suppliers may be local service providers or companies that provide pick-up and drop-off services for the Client at the travel location, among others. Accordingly, VHC may share your personal information with these third parties or other business partners necessary for the purposes of providing the services. Such sharing occurs with the following partners, based on the following criteria and for the purposes described below.

• Service providers for the purpose of providing software and other information technology systems that assist in the delivery of services;


• Suppliers necessary for the provision of services, depending on the package You contract. There is intensive data sharing with such suppliers, which is essential to enable the provision of services to the Client;


• Providers of value-added services the Client may purchase (for example, travel insurance).

In addition to the above suppliers, VHC may use third party service providers in the provision of its own services. In this case, such providers will not have any decision-making power over personal information that they process on behalf of VHC.

Client's personal data may also be shared with third parties (including governmental agencies) in order to respond to investigations, prosecutions, judicial proceedings, or to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the security of any entity or as otherwise required by law.

If VHC is involved in a merger, acquisition or sale of all or a portion of its assets, Client personal data may be shared with the acquiring company or entity.

VHC may share certain non-personal information (anonymized data that does not identify Clients individually) with third party service providers, trusted partners or approved researchers in order to better understand which adverts and services may interest you, to improve the overall quality and effectiveness of the services provided and contracted, or to contribute to academic research.

6. INFORMATION TRANSFERS OUTSIDE BRAZIL

VHC may transfer Clients' personal data to service providers located overseas, including cloud service providers. If You contract service packages with a destination outside Brazil, it will be necessary to transfer Your personal data so that the suppliers can provide these services. When a Client's personal data is transferred outside Brazil, appropriate measures will be taken to ensure adequate protection of this data in compliance with the requirements of the applicable data protection legislation.

7. HOW LONG IS YOUR INFORMATION STORED FOR?

VHC strives to ensure that personal data is kept as up-to-date as possible and that unnecessary or excessive data is deleted or anonymized whenever and as soon as possible.

In general, the Client's personal data will be retained as long as necessary to fulfill the purpose for which it was collected. This will be, as a rule, the period from the execution of the contract until the end of the contracted service. Moreover, VHC may retain the Client's personal data for a period corresponding to the duration of any applicable statutory period after the relationship with the Client ends.

Thus, the Client's personal information and data may be stored and kept for as long as there is a relationship/connection with the Client to comply with legal obligations, or for as long as necessary to preserve your or our legitimate interests.

Client's personal data will cease to be processed when it is found:

• That the purpose for which the personal data were collected has been achieved or that the personal data collected are no longer necessary or relevant for achieving the specific purpose desired;


• A statement from the Client to this effect, especially for situations in which VHC receives the Client's consent to certain processing of personal data, if any; or


• In the event of a legal ruling.

In such cases, subject to the cases established by applicable law or by this Privacy Policy, personal data will be deleted or anonymized by VHC so that the data completely loses the ability to identify the original holder of the data.

8. CLIENT'S RIGHTS AS THE HOLDER OF THE PERSONAL DATA

Client will have certain rights with respect to their personal data, as established by applicable personal data protection law. Such rights include, but are not limited to:

• Confirmation of the existence of the personal data processing. Upon request and identity validation, VHC will provide the Client with confirmation of the existence of personal data processing, under the terms of the applicable legislation;


• Access to personal data. Upon identity validation, Client may request access to their personal data collected and stored at VHC. When processing is justified with Client's consent or in the performance of a contract, Client may also request a full electronic copy of their personal data in a format enabling its subsequent use;


• Correction of incomplete, inaccurate or outdated data. It is in VHC's interest to keep the personal data we handle accurate and up to date, so as to proceed to update and correct the data at the request of the client, after appropriate validation of Client's identity;


• Information about shared data usage. Information about the sharing of personal data can be found in this Privacy Policy. Please do not hesitate to contact VHC for further clarifications;


• Deleting personal data. Client may at any time request that personal data collected by VHC with their consent be deleted, simply by stating such, at no cost and with no obstacles. Personal data may only be completely eliminated when they are personal data that are not necessary for VHC to comply with legal or contractual obligations, for the protection of its legitimate interest and in other cases permitted by law;


• Revoking consent. Client may at any time revoke any consent they have given to process their personal data for certain purposes (if there is in fact processing of personal data based on consent), simply by stating such, at no cost and with no obstacles. It should be noted that processing done before revocation of consent is ratified and that the revocation request will not result in previously processed personal data held by VHC on other legal grounds being eliminated;


• Data portability. The Client has the right to request that their personal data be transferred to another service provider, which shall be done in a structured, commonly used and machine-readable format, as technically feasible and in accordance with any regulations on the subject;


• Deletion, challenge, anonymization or blocking of personal data. In cases in which the Client does not agree to the processing and believes that VHC may be processing data that is not necessary or otherwise does not meet the requirements of the applicable legislation, Client will have the right to object to the processing or request the anonymization, deletion or blocking of their personal data, unless VHC has legitimate grounds for the processing;


• Reviewing automated decision. Client has the right to request a review of any decisions affecting their interests, including decisions intended to define their personal, professional, consumer and credit profile or aspects of their personality made solely by a computer or other automated process. Client may also request information on the criteria and procedures used in the context of this decision, within the limits accepted by applicable law;


• Complaining to the Authorities. Client has the right to lodge a complaint with the National Data Protection Authority - ANPD or other competent body if they consider that the processing of their personal data infringes any provision of the applicable law.

For more information about Client Rights or to exercise any of these rights, Client may contact the Data Protection team at privacidade@cvccorp.com.br. Before processing such request, VHC may request further information about Client for the purpose of authenticating their identity, thereby ensuring that information is only shared with Client or someone with the power to represent them.

9. PROTECTION OF INFORMATION AND PERSONAL DATA

VHC treats Clients’ information and personal data with a high level of protection, confidentiality and care, using appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction or damage, acting responsibly and ethically, in compliance with the terms of applicable data privacy laws and regulations.

10. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is a dynamic tool and may be updated periodically to ensure that the information it provides is in compliance with data protection laws. Accordingly, VHC reserves the right to change this Privacy Policy at any time by posting the updated version on our Site. In the event of significant changes to this document, Client may receive a notification to that effect or it may be communicated through the official communication channels.

11. CONTACT DETAILS

Questions regarding this Client Privacy Policy or other matters relating to the protection of personal data should be addressed to the Data Protection Officer for personal data processing using the e-mail address privacidade@cvccorp.com.br.

This Privacy Policy was updated and revised in March 2021.