Privacy Policy
Last updated: 30 April 2026
ATPM, Unipessoal Lda. ("we", "us", "our") operates Mercedes Country House, a boutique hotel located in Santa Barbara de Nexe, Algarve, Portugal. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and Portuguese Law 58/2019.
By using our website, making a booking, or staying at our property, you acknowledge that your personal data will be processed as described in this policy.
Data Controller
The data controller responsible for your personal data is:
ATPM, Unipessoal Lda.
NIF: 513554440
Lugar Medronhal 475Z, 8005-502 Santa Barbara de Nexe, Faro, Portugal
Email: info@mercedescountryhouse.com
Phone: +351 963 830 660
Data Protection Contact: info@mercedescountryhouse.com
What Personal Data We Collect
We collect personal data that is necessary to provide our accommodation services, comply with legal obligations, and improve your experience.
Data You Provide Directly
- Identity data: full name, date of birth, nationality, passport or identity card number
- Contact data: email address, telephone number, postal address
- Booking data: check-in and check-out dates, room preferences, number of guests, special requests
- Payment data: credit or debit card details, billing address (processed securely via our booking engine provider)
- Communication data: correspondence with us by email, telephone, or other means
- Marketing preferences: consent choices for newsletters and promotional communications
Data Collected Automatically
- Technical data: IP address, browser type and version, operating system, device identifiers
- Usage data: pages visited, time spent on pages, referral source
- Cookie data: information collected through cookies and similar technologies (see our Cookie Policy)
Data Collected From Third Parties
- Booking platforms: if you book through a third-party platform such as Booking.com or Expedia, we receive the booking details and contact information you provided to that platform
Why We Process Your Data (Legal Bases)
We process your personal data only when we have a lawful basis to do so under Article 6 of the GDPR:
| Purpose | Legal Basis | Details |
|---|---|---|
| Processing bookings and providing accommodation | Performance of a contract (Art. 6(1)(b)) | Necessary to fulfil your reservation and provide our services |
| Processing payments | Performance of a contract (Art. 6(1)(b)) | Necessary to collect payment for services rendered |
| Guest registration with AIMA via SIBA | Legal obligation (Art. 6(1)(c)) | Portuguese law requires accommodation providers to register all foreign guests with AIMA within 3 working days of arrival |
| Issuing invoices and maintaining accounting records | Legal obligation (Art. 6(1)(c)) | Portuguese fiscal law requires retention of accounting documents |
| Responding to your enquiries | Legitimate interest (Art. 6(1)(f)) | To provide customer service and respond to questions |
| Sending marketing communications | Consent (Art. 6(1)(a)) | Only with your explicit opt-in consent; you may withdraw consent at any time |
| Website analytics | Consent (Art. 6(1)(a)) | Analytics cookies are only placed after you provide explicit consent |
| Security and fraud prevention | Legitimate interest (Art. 6(1)(f)) | To protect our property, guests, and systems |
Guest Registration (SIBA/AIMA)
Under Portuguese law (Decreto-Lei 71/2019 and related regulations), all accommodation providers must register guests with AIMA (Agência para a Integração, Migrações e Asilo), the Portuguese immigration authority.
We are required to collect and transmit the following data for all foreign national guests via the SIBA (Sistema de Informação de Boletins de Alojamento) platform:
- Full name
- Date of birth
- Nationality
- Passport or identity card number and issuing country
- Country of residence
- Dates of stay
This data must be transmitted within 3 working days of check-in. We have no discretion over this requirement. The legal basis is compliance with a legal obligation (GDPR Art. 6(1)(c)).
Who We Share Your Data With
We share your personal data only where necessary and with appropriate safeguards.
Service Providers (Data Processors)
| Provider | Purpose | Data Shared | Location |
|---|---|---|---|
| Amenitiz | Booking engine and property management | Guest name, contact details, booking details, payment data | EU |
| Google Analytics (GA4) | Website analytics | Anonymised usage data, IP address (truncated) | USA (with EU Standard Contractual Clauses) |
| Google Ads | Advertising conversion tracking | Cookie identifiers, anonymised conversion data | USA (with EU Standard Contractual Clauses) |
| Meta (Facebook/Instagram) | Advertising pixels and remarketing | Cookie identifiers, anonymised conversion data | USA (with EU Standard Contractual Clauses) |
| Brevo | Email marketing and transactional email | Guest email address, name, marketing preferences | EU |
| GoHighLevel | Customer relationship management (CRM) | Guest name, contact details, booking history | USA (with EU Standard Contractual Clauses) |
| 360dialog | WhatsApp business communications | Guest name, phone number, message content | EU |
Authorities
- AIMA (via SIBA): guest registration data for foreign nationals (legal obligation)
- Autoridade Tributária e Aduaneira: tax and accounting data as required by Portuguese fiscal law
- Law enforcement or judicial authorities: when required by law or court order
We do not sell your personal data to third parties.
International Data Transfers
Some of our service providers are based outside the European Economic Area (EEA), specifically in the United States. Where personal data is transferred outside the EEA, we ensure appropriate safeguards are in place, including EU Standard Contractual Clauses (SCCs) approved by the European Commission and the EU-US Data Privacy Framework, where the recipient is certified.
You may request a copy of the safeguards in place by contacting us at info@mercedescountryhouse.com.
How Long We Keep Your Data
| Data Category | Retention Period | Reason |
|---|---|---|
| Accounting and invoicing records | 10 years from end of fiscal year | Portuguese fiscal law (Código do IRC, Art. 123) |
| SIBA guest registration records | 3 years | Portuguese immigration reporting requirements |
| Booking and guest records | 10 years | Legitimate interest and potential legal claims |
| Marketing and newsletter data | 3 years from collection, or until consent is withdrawn | Consent-based processing |
| Correspondence and complaints | 5 years | Dispute resolution and legal compliance |
Your Rights Under GDPR
Under the GDPR and Portuguese Law 58/2019, you have the following rights:
- Right of access (Art. 15): request a copy of the personal data we hold about you
- Right to rectification (Art. 16): request correction of inaccurate or incomplete data
- Right to erasure (Art. 17): request deletion of your data where there is no compelling reason for continued processing
- Right to restriction (Art. 18): request that we limit how we use your data in certain circumstances
- Right to data portability (Art. 20): receive your data in a structured, machine-readable format
- Right to object (Art. 21): object to processing based on legitimate interests or direct marketing
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
- Right not to be subject to automated decision-making (Art. 22): we do not use automated decision-making or profiling that produces legal effects
How to Exercise Your Rights
To exercise any of these rights, contact us at:
Email: info@mercedescountryhouse.com
Post: ATPM, Unipessoal Lda., Lugar Medronhal 475Z, 8005-502 Santa Barbara de Nexe, Faro, Portugal
We will respond to your request within 30 days. We may ask you to verify your identity before processing your request.
Complaints
If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Portuguese data protection authority:
Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, Portugal
Website: www.cnpd.pt
Email: geral@cnpd.pt
UK residents may also contact the Information Commissioner's Office (ICO).
Security of Your Data
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encrypted transmission (SSL/TLS), PCI DSS-compliant payment processing, and access controls limiting data to authorised personnel only.
Children's Data
We do not knowingly collect personal data from children under the age of 16 without parental consent, in accordance with Article 8 of the GDPR and Portuguese Law 58/2019. If you believe we have collected data from a child without appropriate consent, please contact us so we can delete it.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on this page with a revised "Last updated" date.
Contact Us
ATPM, Unipessoal Lda.
Lugar Medronhal 475Z, 8005-502 Santa Barbara de Nexe, Faro, Portugal
Email: info@mercedescountryhouse.com
Phone: +351 963 830 660
