PRIVACY POLICY

The Company respects the privacy of its clients and suppliers. This Privacy Policy explains who we are, the reason for which we can use your data, how we process your data, who we share your data with, for how long we retain such data and how you may contact us and exercise your rights.

WHO ARE WE? 

Your data will be processed by the companies belonging to Minor Hotels Group [1], hereinafter referred to as “Minor” or “us”. This company is responsible for the processing of personal data within the meaning of the General Data Protection Regulation. For questions relating to the processing of your personal data, please contact our Data Protection Officer to the following mail address: dpo.mhpt@minorhotels.com

As a rule, your personal data is directly requested when you register on our site, visit our hotels, communicate with us by telephone, e-mail or chat, when you request a contact and/or sending newsletters, subscribe to a certain service, provide or request information, acquire a product or establish a contractual relationship online or offline with us. However, Minor may also collect your data indirectly, through partners or official entities.

Minor use your personal data for the following purposes:

• Clients´ Management

The treatment of your data is required for the execution of the contract to be celebrated between you and Minor, or to conduct pre-contract diligences at your request. If you do not provide your data, we will not be able to provide the services requested or contracted services.

In more limited circumstances, we also collect data about family members and companions, such as names and ages of children.

During your stay we can also collect images and video and audio data via: security cameras located in public areas, such as hallways and lobbies, in our properties.

If you submit any personal data about other people to us (e.g., if you make a reservation for another individual or purchase a product to offer), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.
Your data will be stored for this purpose for 5 years after your last stay in Minor´s hotel subject to compliance with legal provisions relating to the retention of data for a longer period.
Client´s personal data may be used by Minor for managing a legal claim. The legal basis is the existence of a legitimate interest by us and the data will be stored for the period required for exercising the respective rights.

• Prospective Clients´ Management

The treatment of your data is required to conduct pre-contract diligences at your request for the execution of a contract between you and Minor. If you do not provide your data, we will not be able to provide the services requested or pre-contracted services.

Your data will be stored for this purpose for 120 days subject to compliance with legal provisions relating to the retention of data for a longer period.

• Marketing

Minor may use your data to send you information about our products and services. This treatment may only be carried out with your consent, provided at the time of data collection or through a form specifically completed for this purpose. If you consent, you will receive marketing communications by e-mail or other way specified by you. If you do not provide your personal data (name and e-mail), Minor will be unable to send you commercial communications.

You may object to this data processing at any time.

Your data will be kept for this purpose until your instructions to the contrary, or, at most, up to 5 years after your last stay in Minor´s Hotel.

• Definition of profiles
  

We use your data and treat information’s regarding personal preferences, interests and behaviour, to improve the products and services we provide you.

This treatment may only be carried out with your consent, provided at the time the data collection or through a form specifically completed for this purpose.

You may object to this processing at any time.

Your data will be kept for this purpose until your instructions to the contrary, or, at most, up to 5 years after your last stay [*].

• Management of complaints and contacts received by Minor
  

You can send us suggestions or complaints on the services provided by us via dpo.mhpt@minorhotels.com. Your data will be processed based on Minor's legitimate interests and your consent. Minor collects your data to analyse and solve the situation underlying your suggestion or complaint.
e collect your data to analyse and solve the situation underlying your suggestion or complaint.
Your data will be stored for this purpose for the time needed to solve your issue, no more than 2 years after the end of the process.

• Management of suppliers / Service Providers/Subcontractors

The treatment of your data is required for the execution of the contract to be celebrated between you and Minor, or to conduct pre-contract diligences at your request. If you do not provide your data, we will not be able to fulfil our contractual obligations.

Your data will be stored for this purpose during the contract/contractual relationship subject to compliance with legal provisions regarding data retention for a longer period.

The personal data of suppliers may be treated by Minor for litigation management. The legal basis is the existence of a legitimate interest on our part and the data will be stored for the necessary period to exercise their rights.

Minor supplier’s data may be communicated to our clients for compliance with legal or contractual obligations.

WILL YOUR PERSONAL DATA BE SHARED WITH OTHER?

For the purposes and in the terms described above, your data may be disclosed:

- Within Minor`s business group We always do our best to meet the service standards of our brands in the different countries where we are located. In this context and always with your prior consent, we share your personal data with authorized internal areas.

- Minor`s third party service providers / Service Provider / Subcontractors. If you are our client or supplier, your personal data may be use by companies subcontracted by us for website housing, email, online store, inquiries, hotel management system, call centre and commercial partners. We supply only the necessary data for the provision of the service in question.
Personal data may also be accessed by internal and external auditors of Minor, with the assurance that such data will remain confidential and will not be used for purposes other than auditing.

In case of transfer of personal data outside the EU, it will be subject to adequate safeguards against the applicable legal requirements, such as the execution of agreements which contain standard clauses in accordance with the terms approved by the European Commission. For more information you may contact us to dpo.mhpt@minorhotels.com.

Minor transfers its brands through franchise agreements. In cases where you request reservations for hotels that operate under our brand name, but which are not operated by us (see below) [2] , we act as subcontractors and will send their personal data for the hotel in question, these data being managed by the privacy policy of the company that operates it.

WHAT ARE YOUR RIGHTS?

At any time, you may request:
● Access to the information we hold on you;
● Rectification of the information should it be inaccurate or incomplete; 
● Erasure or the restriction of processing of your personal data;
● If processing requires your consent or agreement and where such processing of personal data is carried out by automated means, you are entitled to receive previously supplied personal data in a structured, commonly used, machine-readable format.

Your requests will be carefully handled to ensure that your rights are complied. You may be requested to prove your identity to ensure that personal data is only shared with the respective data subject.
It must be borne in mind that in certain cases (e.g., due to legal requirements), your request may not be immediately satisfied.
However, you will be informed of the measures implemented in this regard within one month after your request has been submitted.
You are also entitled to submit a complaint to the the Portuguese Data Protection Authority https://www.cnpd.pt/. 

Right of access

The data owner has the right to obtain from Minor confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the information laid down in law.

Should you wish to receive more than one copy of your personal data which are being processed, Minor will request the payment of a fee to cover administrative costs.

Right to rectification

The data subject has the right to obtain from Minor without undue delay the rectification of inaccurate or incomplete personal data concerning him or her.

Right to erasure (‘right to be forgotten’)

The data subject has the right to obtain from Minor the erasure of personal data concerning him or her without undue delay and we are required to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based (in cases where processing is based on consent), and where there is no other legal ground for the said processing;
c) The data subject objects to the processing and there are no overriding legitimate grounds for the processing.

Right to restriction of processing

The data subject has the right to obtain from Minor restriction of processing where one of the following applies:
a) the accuracy of the personal data is contested by the data subject, for a period enabling us to verify the accuracy of the personal data;
b) the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) Minor no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
d) the data subject has objected to processing pending the verification whether the legitimate grounds of the person in charge of such processing override those of the data subject.

Right to data portability

If processing requires the consent of the data subject and such consent has been provided by automated means, the data subject has the right to receive the personal data concerning him or her and which has been supplied to Minor in a structured, commonly used, machine-readable format.

Right to object

Where personal data are processed 1) for purposes of legitimate interests pursued by Minor; or 2) direct marketing purposes; or 3) to create profiles, the data subject may object at any time to processing of personal data concerning him or her.

CAN YOU WITHDRAW YOUR CONSENT AT A LATER DATE?

If consent is legally required to process personal data, the data subject has the right to withdraw his or her consent at any time, although this right does not compromise the lawfulness of the processing carried out based on previously provided consent or subsequent processing of the same personal data on another legal basis, such as for the performance of a contract or a legal obligation to which Minor is subject. Should you wish to withdraw your consent, you can contact us at dpo.mhpt@minorhotels.com

HOW DOES MINOR USE COOKIES AND SIMILAR TECHNOLOGY?

To provide a better service to users, we use cookies. Cookies are small text files which are placed on your hard disk by a web page server. This technology is used by Minor mainly to:

• Allow us to know who our visitors are and, as such, provide a better, safer and more personalised service;
• Understand the performance of our sites and consider improving and updating them to meet the expectations of our clients. Every visitor has an individual cookie, thus ensuring the privacy and security of data. Statistical data are presented in a combined manner, and visitors cannot be identified individually.

DO YOU HAVE ANY QUERIES?

If you have any queries with regard to the processing of your personal data, or wish to exercise any of your rights, please contact us: E-mail: dpo.mhpt@minorhotels.com 
Occasionally, the Company will update this Privacy Policy. We would like to ask you to periodically review this document to keep up to date. 

Last review. June 2018

[1] MINOR CONTINENTAL PORTUGAL, SA., a company incorporated and operating under Portuguese law, with registered office at Rua barata Salgueiro nº 37, 7º, 1250-042 Lisbon, Portugal, with the taxpayer number 513 275 797, company that operates the Hotels Tivoli Avenida Liberdade, Avani Avenida Liberdade, Tivoli Sintra and Tivoli Palácio de Seteais;

MARINOTEIS – Sociedade de Promoção e Construção de Hotéis, S.A., a company incorporated and operating under Portuguese law, with registered office at Tivoli Marina de Vilamoura Hotel, 8125-401 Vilamoura, Portugal, with the taxpayer number 500 183 457, company that operates the Hotels / Resorts Tivoli Marina Vilamoura, Anantara Vilamoura and Victoria Residences Vilamoura managed by Tivoli;

TIVOLI GARE DO ORIENTE - Sociedade Gestão Hoteleira, S.A., a company incorporated and operating under Portuguese law, with registered office at Av.ª D. João II, nº 27, 1990-083 Lisbon, Portugal, with the taxpayer number 505 544 989,  company that operates Tivoli Oriente Hotel;

COIMBRA JARDIM HOTEL – Sociedade de Gestão Hoteleira, S.A., a company incorporated and operating under Portuguese law, with registered office at Avenida da Liberdade, n.º 185, 1269-050 Lisbon, Portugal, with the taxpayer number 501 992 090, company that operates Tivoli Coimbra Hotel;

HOTELAGOS, S.A., a company incorporated and operating under Portuguese law, with registered office at Hotel de Lagos, Rua António Crisógono dos Santos, 8600-678 Lagos, Portugal, with the taxpayer number 500 173 702, , company that operates the Hotels Tivoli Lagos and Tivoli Marina Portimão;

SOTAL – Sociedade de Gestão Hoteleira, S.A., a company incorporated and operating under Portuguese law, with registered office at Hotel Tivoli Carvoeiro, Vale Covo, 8401-911 Carvoeiro LGA, Portugal, with the taxpayer number 502 306 874, company that operates Tivoli Carvoeiro Hotel.

[2] Tivoli Évora Ecoresort – operated by TAPADA DA MATA, INVESTIMENTOS HOTELEIROS E TURÍSTICOS, S.A. a company incorporated and operating under Portuguese law, with registered office at Quinta da Deserta e da Malina, 7005-800 Évora, with the taxpayer number 506 647 153.