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Privacy Policy

Last updated: December 12, 2025

This Privacy Policy is owned and operated by: ▪ Company: Pura Teoria, Lda., owner of the COOLIVIN brand and responsible for the COOLIVIN Platform (COOLIVIN). ▪ Headquarters: Bairro do Bacelo, Rua do Canteiro 15 R/C, 7005-424 Évora, Portugal. ▪ NIPC: 517 072 890. ▪ Contact for any questions and/or clarifications: [email protected]. The COOLIVIN Platform includes all the accommodation promotion channels used by COOLIVIN, in particular the website coolivin.com and its respective pages. COOLIVIN offers an online service to offer, search, and book accommodation. If you are a Guest or a Host on the COOLIVIN Platform, a prospective employee, a partner, or just a User of the Platform (together, User(s)), we recommend that you read this Privacy Policy and the Cookies Policy.

1. COMMITMENT

1.1. COOLIVIN guarantees that personal data is processed lawfully, fairly, and transparently, in accordance with good practice.

1.2. COOLIVIN undertakes to collect only the data that it deems appropriate and relevant, limiting itself to what is necessary, and to process it only for clearly identified purposes.

1.3. COOLIVIN adopts appropriate technical and organizational security measures to protect the personal data provided and processed.

2. PERSONAL DATA - WHAT IS IT?

2.1 Essentially, and as stated in the General Data Protection Regulation (GDPR), personal data is any information which, directly or indirectly (in combination with other data), allows an individual to be identified.

3. PERSONAL DATA SUBJECTS - WHO ARE THEY?

3.1 The holders of personal data are all Users, including representatives of an entity/legal person, to whom the personal data relate, and who use or intend to use the services provided by COOLIVIN.

3.2 Whenever the User is an entity represented by a natural person who shares personal data, the entity must ensure that the data of its representatives/employees are collected and transmitted to COOLIVIN in a lawful manner.

4. CATEGORIES OF PERSONAL DATA COLLECTED

4.1. COOLIVIN collects different categories of personal data from Users, depending on the services they wish to use. The collection of personal data is not compulsory, and it is at the discretion of the User. However, without the collection of the personal data listed below, COOLIVIN may not be able to provide and fulfill the services requested.

4.2. Personal data: Information that allows personal identification, such as name, postal address, e-mail address, and telephone number, as well as demographic information, such as age, gender, place of birth, tax data, identification documents, and interests, among others. This data is provided voluntarily when the User registers on the COOLIVIN Platform, when he/she wishes to place an advertisement or make a reservation, or when he/she chooses to participate in various activities related to the COOLIVIN Platform, such as online chat and message boards.

4.3. Financial information: Data related to payment methods (e.g. valid credit card number, card brand, expiration date, IBAN, among others) that COOLIVIN collects when the User wishes to book, purchase, order, refund, exchange, or request information about the services on the COOLIVIN Platform.

4.4. COOLIVIN stores only very limited financial information. Otherwise, all financial information is stored by the payment processor contracted by COOLIVIN (e.g. PayPal, Stripe, Google Pay, Apple Pay, MBWay, bank transfer, among others). It is recommended that Users consult the privacy policy of these services and contact them directly if they need clarification.

4.5. Google or Facebook permissions: By default, the COOLIVIN Platform can access the basic information of the User's Google and/or Facebook account, including their name, email address, gender, birthday, current city of residence, and profile picture URL, as well as other information that the User chooses to make public. The COOLIVIN Platform may also request access to other permissions associated with the Google or FB account, such as friends, checkins and likes. The User can choose to grant or deny access to each of these permissions individually. For more information on Google or Facebook permissions, see the Reference page of the respective services.

4.6. Social Media information: User information on social media websites/applications, such as Facebook, Instagram, Twitter, TikTok, including name, social media username, location, gender, date of birth, email address, profile picture, and public contact information, if you link your account to such social media.

4.7. Contests and Surveys: Personal information and other information that the User may provide when participating in contests and/or responding to surveys.

5. GROUNDS AND PURPOSES FOR PROCESSING PERSONAL DATA

5.1. COOLIVIN collects personal data and other information about the User to provide, as much as possible, a pleasant, organized, efficient and personalized user and service experience. In particular, the information collected through the COOLIVIN Platform may be used to:

i. Manage contests, surveys, promotions, and competitions.

ii. Compile anonymous statistical data and analyses for internal use or by third parties.

iii. Create and manage the User registration.

iv. Deliver targeted advertising, coupons, newsletters and promotions, and other information related to the COOLIVIN Platform.

v. Sending emails about User registration, reservations, and other.

vi. Create a personal profile of the User to make future visits to the COOLIVIN Platform more personalized.

vii. Improve the efficiency and operation of the COOLIVIN Platform.

viii. Monitor and analyse usage and trends to improve the User experience with the COOLIVIN Platform.

ix. Promote and offer new products, services and/or recommendations.

x. Carry out other commercial activities as required.

xi. Process payments and refunds.

xii. Request feedback and make contacts to evaluate the use of the COOLIVIN Platform.

xiii. Resolving problems and disputes.

xiv. Responding to requests for information, providing products and customer support services.

xv. Sending newsletters.

6. TRANSMISSION OF PERSONAL DATA

6.1. In certain situations, COOLIVIN may communicate the data it collects about the User, which may be transmitted in the following ways:

6.2. Marketing and advertising: COOLIVIN may use third party advertising companies to display advertisements when the User visits the Platform. These companies may use information about the User's visits to the COOLIVIN Platform and other websites that are contained in cookies, to provide advertisements about goods and services of interest to the User.

6.3. Affiliates: COOLIVIN may share User information with affiliated companies, which must comply with this Privacy Policy. Affiliates may include any group company, joint venture partner or other company with which COOLIVIN has a controlling relationship.

6.4. Business partners: COOLIVIN may share User information with its business partners to offer certain products, services, or promotions.

6.5. Social networks: If the User registers or otherwise connects to the COOLIVIN Platform through social networks, the contacts of that social network will have access to the name, profile photo and description of the activity.

6.6. Sale or bankruptcy: If COOLIVIN goes through a reorganization, or if all or part of its assets are transferred to a third party, or if there is any other type of transaction, COOLIVIN may transfer your information to the successor entity. If COOLIVIN goes out of business or becomes insolvent, your information may be an asset to be transferred to a third party. The User acknowledges that such transfers may occur, and that the transferee may not honor the commitments made in this Privacy Policy. COOLIVIN is not responsible for the actions of third parties with whom you share personal or sensitive data and has no authority to manage or control third party requests. If you no longer wish to receive letters, emails, or other communications from third parties, it is the User’s responsibility to contact them directly.

6.7. Platform Performance: COOLIVIN may partner with selected third parties (e.g. Google Analytics, Mixpanel, Hubspot, Hotjar) to enable tracking technologies and remarketing services on the COOLIVIN Platform through the use of cookies to, among other things, analyze and track User’s use of the Platform, determine the popularity of certain content and better understand online activity. By accessing the Platform, the User consents to the collection and use of his/her information by these third parties. COOLIVIN does not share personal data with these third parties. However, if the User does not intend information to be collected and used by tracking technologies, you can visit the third party or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

7. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

7.1. As part of COOLIVIN's commercial activity, User's personal data may be transferred or disclosed to third party companies. These companies may be located outside the European Economic Area (EEA), i.e. in third countries. Such processing is carried out exclusively for the fulfillment of contractual and commercial obligations, in particular within the framework of the business relationship between the User and COOLIVIN. COOLIVIN will inform of the details of the transfer where appropriate or relevant.

7.2. Some third countries have been certified by the European Commission, through so-called Adequacy Decisions, as providing data protection comparable to EEA rules (a list of these countries, and a copy of the adequacy decisions, can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). Other third countries to which personal data may be transferred do not have a consistent level of data protection due to a lack of legal regulation. If this is the case, it is up to COOLIVIN to ensure that data protection is adequately guaranteed by suitable means.

8. LEGAL OBLIGATION TO PROVIDE PERSONAL DATA

8.1. COOLIVIN may be required by law to provide personal data to third parties, in particular public authorities, in accordance with Article 6 of the GDPR.

9. RETENTION PERIOD FOR PERSONAL DATA

9.1. COOLIVIN keeps the User's personal data for the duration of the contractual relationship (including the pre- and post-contractual period) or for the period necessary to fulfill the purposes for which they were collected and for as long as there is a legitimate legal basis (e.g. tax obligations).

10. LINKS TO OTHER WEBSITES

10.1. COOLIVIN is not responsible for the privacy practices of third parties whose websites are linked to the COOLIVIN Platform by hyperlink and therefore cannot guarantee or be responsible in any way for the accuracy or authenticity of the information contained therein.

10.2. COOLIVIN does not guarantee the accuracy, completeness or authenticity of the information contained in any hyperlink or other website. Personal data entered on other websites that are linked to the COOLIVIN Platform are the sole responsibility of the data subject or the owner of the website in question.

11. RIGHTS OF PERSONAL DATA SUBJECTS

11.1. COOLIVIN guarantees the exercise of the rights of data subjects in relation to their processing. When COOLIVIN processes the User's personal data, the User has the following rights:

Rights: Description

Access: Data subjects have the right to access the personal data that they have provided to COOLIVIN or that result from the use of COOLIVIN services, and the respective processing conditions.

Rectification: Data subjects have the right to request the rectification of their personal data when it is inaccurate or incomplete.

Opposition or withdrawal of consent: Data subjects have the right to object to data processing based on COOLIVIN's legitimate interest or to withdraw the consent they have given for data processing based on consent.

Disposal: Data subjects have the right to request the deletion of their personal data held by COOLIVIN, provided that there are no valid grounds for its retention.

Limitation of treatment: Data subjects have the right to request the restriction of data processing by requesting the suspension of processing or the limitation of the scope of processing to certain categories of data or processing purposes, under the terms of the Law.

Portability: Data subjects have the right to receive the personal data they have provided to COOLIVIN or to request that the data be transferred to another entity, provided that this is technically feasible.

Challenging automated decisions: Data subjects have the right to challenge or request human intervention in decisions based on fully automated processing of personal data.

File a complaint with the CNPD: Data subjects have the right to lodge complaints with the CNPD regarding matters relating to the exercise of their rights and the protection of their personal data. For more information, go to www.cnpd.pt.

11.2. The individuals may exercise their data protection rights by sending an email to support{'@'}coolivin.com. COOLIVIN will make every reasonable effort to respond to requests made in accordance with applicable law.

12. PROCEDURAL AND TECHNICAL SECURITY MEASURES

12.1. COOLIVIN uses appropriate physical, technical, and organizational security measures for the protection of personal data to protect the personal data provided against unauthorized disclosure, loss, misuse, alteration, processing, or access, as well as against any other form of unlawful processing.

12.2. The technical and organizational measures applied are intended to ensure a level of security appropriate to the risks involved in the storage and transmission of personal data.

13. COOKIES

13.1. COOLIVIN uses cookie technology to track the paths taken by the User to the COOLIVIN Platform, to help COOLIVIN record the User's activity on the Platform and to evaluate and improve the performance of the COOLIVIN Platform. Through this technology, COOLIVIN does not record information about individual Users. At any time, the User can set the browser to not accept cookies or to be warned if cookies are sent.

13.2. For more information, please consult our Cookies Policy.

14. MINOR USERS

14.1. Neither the COOLIVIN services nor the COOLIVIN Platform are intended for use by minors. It is not COOLIVIN's policy or intention to intentionally collect and process personal data from minors.

15. CHANGES TO THE PRIVACY POLICY

15.1. COOLIVIN reserves the right to make changes or updates to this Privacy Policy at any time, and such changes will be updated on this page.

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