TP Group is the group comprising several companies operating in the tourism and hospitality sectors (collectively, “TP Group”): (i) Teresa Perez Viagens e Turismo Ltda.; (ii) New Age Viagens e Turismo Ltda.; (iii) Monza Travel Agência de Viagens e Turismo Ltda.; (iv) TP Corporate Viagens e Eventos Ltda.; (v) EBK Travel Agência de Viagens e Turismo Ltda.; (vi) OIÁ Hospitality Ltda.; (vii) Dunas Hotéis e Residências Ltda.; and (viii) Traveller World Editora Ltda.
This Policy was created by TP Group to reaffirm its commitment to the security and privacy of the Personal Data (as defined below) of each individual who accesses its websites or reservation systems and/or otherwise interacts with any of the companies comprising TP Group (“Data Subject”), with the purpose of providing transparency and clarifying the practices adopted in the processing of Personal Data collected from and/or provided by the Data Subject.
Accordingly, the Data Subject should read this Policy in its entirety and carefully before accessing and/or submitting any Personal Data to TP Group, whether through any of its websites or by any other means.
This Policy also applies to the Personal Data of the Data Subject’s accompanying persons (including children, adolescents, employees, and other accompanying persons, whether family members or not) provided to TP Group by the Data Subject or by its partners, in which case references to the Data Subject shall be understood to include such individuals.
For the purposes of this Policy, “Personal Data” means any information that may identify the Data Subject (e.g., name, identification document number, email address, telephone number).
“Sensitive Personal Data” means certain Personal Data considered more sensitive (e.g., racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or religious, philosophical or political organization, health or sexual life information, genetic or biometric data) and which, therefore, must be subject to differentiated treatment. For the avoidance of doubt, Sensitive Personal Data is included within the definition of Personal Data for the purposes of this Policy.
For the purpose of safeguarding privacy and protecting Personal Data, TP Group limits the collection and processing of Personal Data to what is strictly necessary and proportionate to achieve the intended purpose.
The main categories of Personal Data collected/processed by TP Group are listed below:
♣ Identification information, such as name, identification document number, Brazilian individual taxpayer registration number (CPF), marital status, gender, nationality, date of birth, among others;
♣ Contact information, such as residential address, ZIP code, landline or mobile telephone number, and email address;
♣ Financial information, such as bank account and branch details and/or credit card number;
♣ Information relating to the health of the Data Subject and accompanying persons, such as vaccination records, allergies, dietary and/or mobility restrictions, or special needs, which may be necessary to ensure their safety and provide services appropriately;
♣ Behavioral information, such as consumption profile or flight habits and destinations of interest;
♣ Any other Personal Data necessary to comply with applicable laws or regulations.
TP Group may share Personal Data among the companies comprising TP Group for the processing purposes set forth herein, including for sending communications and/or marketing campaigns. In such cases, email communications may be canceled at any time through the “Unsubscribe” link contained in any email received from any of the TP Group companies.
TP Group does not share Personal Data with third parties unless: (i) expressly requested or authorized by the Data Subject or by individuals who demonstrate legal authority to act on behalf of the Data Subject (such as attorneys-in-fact, for example); (ii) the Personal Data must be provided to comply with applicable laws or with a search warrant, subpoena and/or judicial or administrative order; (iii) this is necessary to perform an agreement with the Data Subject or resolve disputes/claims, or to protect the rights of TP Group, its employees, customers or partners; (iv) this is necessary to address emergencies or events of chance or force majeure; or (v) the Personal Data is necessary for TP Group’s partners to perform functions on its behalf and/or for fraud and chargeback prevention purposes, subject to the limits of this Policy and applicable law.
TP Group may also be required to provide or disclose Personal Data stored by it, in whole or in part, in order to investigate and/or take any action against a suspected or actual violation of this Policy or applicable law. In such cases, TP Group undertakes to provide only the minimum information necessary to comply with the applicable requirement, while always observing its professional confidentiality obligations.
In the event of sharing with partners, such partners are authorized to process Personal Data exclusively for the purposes for which they were contracted and in accordance with applicable law, and may not use such data for any other purpose.
Furthermore, TP Group only engages partners that comply with appropriate privacy and personal data protection standards and adopt appropriate measures to ensure the protection of Personal Data in accordance with applicable law, including, where necessary, entering into contractual instruments supporting international data transfers.
TP Group will process Personal Data for the following purposes:
♣ Identifying and/or verifying identities and/or information;
♣ Operating and improving the usability and interactivity of TP Group’s websites;
♣ Better understanding the needs and interests of Data Subjects, as well as developing and improving the content provided by TP Group through its websites or by any other means;
♣ Intermediating the Data Subject’s relationship with the suppliers necessary to provide the services (for example, hotels, airlines, car rental companies, parks, among others, depending on the specific case) and making payments to such suppliers;
♣ Conducting credit analysis in accordance with the credit policies of each TP Group company and assessing the Data Subject’s ability to make payments;
♣ Processing financial transactions;
♣ Analyzing fraud, chargebacks and credit card refunds;
♣ Analyzing refund requests, penalty reviews and no-show occurrences;
♣ Managing relationships with Data Subjects or partners;
♣ Providing after-sales assistance to support the purchase of seats, baggage, date changes, among other matters related to the contracted service;
♣ Handling questions, complaints or suggestions submitted through customer service channels by Data Subjects or partners;
♣ Conducting communications and/or marketing campaigns. In such cases, email communications may be canceled at any time through the “Unsubscribe” link contained in any email received from any of the TP Group companies;
♣ Investigating and/or taking measures against suspected or actual violations of this Policy or applicable laws/regulations, as well as preventing or investigating fraud and managing risks;
♣ Preparing statistical analyses or studies, as well as conducting satisfaction surveys through any communication channel, including WhatsApp, Facebook and Instagram. The Data Subject may provide Personal Data as part of their response to a survey, unless the survey can be answered anonymously and the Data Subject chooses this option;
♣ Adapting food, transportation, accessibility and assistance services that depend on information relating to the health, dietary or mobility restrictions, or special needs of the Data Subject and/or accompanying persons, so that such services can be provided appropriately;
♣ Identifying vaccination records of the Data Subject and/or accompanying persons when required for air, land, river or maritime travel, visa issuance and/or entry into certain countries;
♣ Other purposes permitted or required by applicable laws/regulations, as well as responding to orders from competent authorities or to arbitration, administrative or judicial proceedings.
Personal Data may be provided directly by the Data Subject or through partners, primarily for the purpose of purchasing products/services offered by TP Group companies.
When any partner is responsible for obtaining the consents required for the processing of Personal Data by TP Group, such partner must obtain them in a timely and appropriate manner and, whenever requested, provide supporting documentation demonstrating that such consents were duly obtained.
When providing Personal Data of third parties to TP Group, partners acknowledge their rights, obligations and the penalties provided for under Brazilian personal data protection legislation, assuming full responsibility for any improper, unlawful and/or unauthorized processing of Personal Data under their responsibility and being liable for any losses and/or damages that TP Group may incur as a result thereof.
Partners further undertake to actively cooperate with TP Group in order to enable TP Group to comply with its legal/regulatory obligations (particularly with regard to responding to Data Subject requests, where necessary) and not to withhold any information that could expose TP Group to the risk of violating applicable personal data protection laws or regulations.
Under no circumstances shall TP Group be responsible for the accuracy of the information provided by Data Subjects and/or partners or for any failure to update such information.
Personal Data collected by TP Group will be stored: (i) when in physical form, at the headquarters of each respective TP Group company; and (ii) when in electronic form, on the servers of each TP Group company and/or on the servers of an external cloud service provider contracted by the relevant TP Group company and located in Brazil.
However, in the event of the purchase of international packages or services, TP Group may be required to share Personal Data with service providers located abroad, including in countries that do not offer the same level of protection as Brazilian law.
Personal Data will be retained for as long as necessary to fulfill the purpose for which it was collected. Normally, this period extends from the execution of the agreement with the partners until the end of the contracted trip.
In the case of subscriptions to specialized magazines, Personal Data may be retained after the end of the agreement for the purpose of offering future renewals.
In addition, TP Group may retain Personal Data for the period necessary to comply with any legal/regulatory obligation or for any other purpose provided for by applicable law, such as for the period necessary to regularly exercise its rights in judicial, administrative or arbitration proceedings.
To the extent permitted by applicable law, any Data Subject may contact TP Group to exercise their right to:
(i) confirm the existence of processing of Personal Data;
(ii) access their Personal Data;
(iii) correct incomplete, inaccurate or outdated Personal Data;
(iv) anonymize, block or delete unnecessary or excessive Personal Data, or Personal Data processed in violation of applicable law;
(v) port their Personal Data to another service or product provider, subject to commercial and industrial secrets;
(vi) delete Personal Data processed based on their consent;
(vii) obtain information regarding the sharing of Personal Data;
(viii) obtain information about the possibility of not providing consent and the consequences thereof;
(ix) withdraw consent, in accordance with applicable law.
For this purpose, the Data Subject may contact TP Group through the email address indicated in the “Contact” section of this Policy.
TP Group adopts all reasonable precautions to safeguard the Personal Data collected, which will be stored in a secure environment and protected in accordance with physical, technical and administrative procedures normally used to protect this type of information.
Access to the Personal Data collected is restricted to authorized individuals who need to have access to such data and who are also required to comply with this Policy.
TP Group may provide external links to third-party websites on any of its websites. However, TP Group does not validate, endorse or monitor such websites and/or their content.
This Policy applies solely and exclusively to the processing of Personal Data collected through websites and/or systems managed by TP Group companies, even where access to third-party websites occurs through links provided by TP Group itself.
TP Group (and/or any individual TP Group company) shall not be responsible for any losses or damages caused or allegedly caused by or arising from access to and use of any such third-party websites. Accordingly, the respective terms of use and privacy policies should be reviewed before using such websites and/or providing any information.
Cookies are text files automatically downloaded and stored on the device used when browsing an internet page or portal.
Cookies that may be sent by TP Group have the specific purpose of improving the performance of its websites and personalizing the user’s access experience.
Such cookies may be blocked at any time. However, blocking them may prevent the provision of a personalized experience and, in some cases, the functioning of certain features of TP Group’s websites.
TP Group values easy access to promotions, benefits and opportunities available on its websites.
Accordingly, by selecting the “Receive our promotions” option, interested individuals will periodically receive information about new updates, products and services by email.
Marketing communications may be disabled at any time through the “Unsubscribe” link contained in any email received from the relevant TP Group company.
At TP Group, the Data Protection Officer (DPO), who is appointed to act as the communication channel between TP Group, Data Subjects and the Brazilian Data Protection Authority (ANPD), is Fábio Sadao Ito.
The DPO will respond to any questions, complaints and/or comments regarding this Policy or the manner in which TP Group processes Personal Data through the email addresses listed below (according to the relevant TP Group company), within a reasonable period and in accordance with applicable law.
In the absence, impediment or vacancy of the DPO, the role will be performed by Paulo Tadeu Nunes Coura.
♣ Teresa Perez Viagens e Turismo Ltda.: privacidade@teresaperez.com.br
♣ New Age Viagens e Turismo Ltda.: privacidade@newage.tur.br
♣ Monza Travel Agência de Viagens e Turismo Ltda.: privacidade@tpair.com.br
♣ TP Corporate Viagens e Eventos Ltda.: privacidade@tpcorporate.com.br
♣ EBK Travel Agência de Viagens e Turismo Ltda.: privacidade@embarkbeyondbrasil.com
♣ OIÁ Hospitality Ltda.: privacidade@oia.com.br
♣ Dunas Hotéis e Residências Ltda.: privacidade@oia.com.br
♣ Traveller World Editora Ltda.: privacidade@thetraveller.com.br
