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Minor respects the privacy of its customers and suppliers. This Privacy Policy describes who we are, the purposes for which we may use your data, how we process it, with whom we share it, how long we retain it, and how to contact us and exercise your rights.

WHO ARE WE?

Your data will be processed by the companies belonging to the Minor Hotels Group^[1], hereinafter referred to as “Minor” or “we”. This company is the data controller within the meaning of the General Data Protection Regulation. For matters relating to the processing of your personal data, please contact our Minor Data Privacy Officer at: dpo.mhpt@minorhotels.com

WHY DO WE NEED YOUR INFORMATION?

As a rule, your data is collected directly when you register on our website, visit our hotels, contact us by phone, email or chat, request contact and/or newsletter subscriptions, subscribe to a particular service, provide or request information, purchase a product or enter into a contractual relationship with Minor online or offline. However, Minor may also collect your data indirectly through partners and official entities.

Minor will process your personal data for the following purposes:

Customer management
The processing of your data is necessary for the performance of the contract to be concluded between you and Minor, or for the carrying out of pre-contractual measures at your request. If you do not provide your data, we will be unable to provide the requested or contracted services. In some circumstances, we may request data about relatives and companions, such as the names and ages of children.

During your stay, we may collect images, audio and video data through security cameras located in public areas such as corridors and lobbies at our properties.

If you send us personal data relating to other individuals (for example, when making a reservation on behalf of another person or purchasing a product as a gift), we consider that we also have a legitimate interest in processing such data in accordance with our privacy policy.

Your data will be retained for this purpose for 5 years after your last stay at a Minor hotel, without prejudice to compliance with applicable legal provisions requiring retention for a longer period.

Customers’ personal data may also be processed by Minor for dispute management purposes. The legal basis is Minor’s legitimate interest, and the data will be retained for the period necessary for the exercise of the relevant rights.

Prospective customer management
The processing of your data is necessary for the carrying out of pre-contractual measures at your request with a view to concluding a contract between you and Minor. If you do not provide your data, we will be unable to provide the requested or pre-contracted services. Your data will be retained for this purpose for 120 days, without prejudice to compliance with applicable legal provisions requiring retention for a longer period.

Marketing
Minor may process your data to send you information about its products and services. This data processing will only be carried out with your consent, given at the time of data collection or through a form specifically completed for that purpose. If you consent, you will receive marketing communications by email or another means indicated by you. Failure to provide your personal data (name and email address) prevents Minor from sending you commercial communications.

Your data will be retained for this purpose until you instruct otherwise or, at most, for 5 years after your last stay at a Minor hotel.

Profiling
Minor may process your personal data and combine information relating to personal preferences, interests and behaviour in order to improve the products and services we provide to you.

This data processing will only be carried out with your consent, given at the time of data collection or through a form specifically completed for that purpose.

You may object to this data processing at any time.

Your data will be retained for this purpose until you instruct otherwise or, at most, for 5 years after your last stay at a Minor hotel.

Management of complaints and enquiries received by Minor
You may send us suggestions or complaints regarding Minor’s services at dpo.mhpt@minorhotels.com. Your personal data will be processed on the basis of Minor’s legitimate interests and your consent. Minor collects your data in order to analyse and resolve the matter underlying your suggestion or complaint. Your data will be retained for this purpose for the time necessary to resolve your query, up to a maximum of 2 years after the conclusion of the process.

Supplier / Service provider / Subcontractor management
The processing of your data is necessary for the performance of the contract to be concluded between you and Minor, or for the carrying out of pre-contractual measures at your request. If you do not provide your data, we will be unable to fulfil our contractual obligations. Your data will be retained for this purpose for the duration of the relevant contract or contractual relationship, without prejudice to compliance with applicable legal provisions requiring retention for a longer period. Suppliers’ personal data may be processed by Minor for dispute management purposes. The legal basis is Minor’s legitimate interest, and the data will be retained for the period necessary for the exercise of the relevant rights.

WILL YOUR PERSONAL DATA BE SHARED WITH OTHERS?

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

• Within the Minor corporate group. We always endeavour to meet the service standards and benchmarks of our brands across the various countries in which we operate. In this context, always with your prior consent, we share your personal data with authorised internal recipients.
• Third-party service providers / Suppliers / Subcontractors of Minor. If you are our customer, service provider or supplier, your personal data may be processed by companies subcontracted by Minor, namely for website hosting, email, online store, surveys, hotel management systems, call centres and commercial partners. Only the personal data necessary for the provision of the relevant service is provided to these companies. Personal data may also be accessed by internal and external auditors of Minor, with the assurance that it will be kept confidential and will not be used for purposes unrelated to the audits.

Should personal data be transferred outside the EU, such transfer will be subject to appropriate safeguards in accordance with applicable legal requirements, such as the conclusion of contracts incorporating the standard contractual clauses approved by the European Commission. For further information, please contact us at dpo.mhpt@minorhotels.com.

Minor grants usage rights to its brands. In cases where you request reservations for hotels operating under our brand but not operated by Minor (see below)^[2], we act as subcontractors and will forward your personal data to the hotel in question; such data will be managed under the privacy policy of the company operating that hotel.

WHAT ARE YOUR RIGHTS?

At any time, you may request:

• Access to the information we hold about you;
• Rectification of information that is inaccurate or incomplete;
• Erasure or restriction of the processing of your personal data;
• Where processing is based on your consent or agreement and is carried out by automated means, you have the right to receive the personal data you have previously provided in a structured, commonly used and machine-readable format.

Your requests will be handled with particular care to ensure the effectiveness of your rights. You may be asked to verify your identity in order to ensure that personal data is only shared with its rightful owner. Please note that in certain cases (for example, due to legal requirements) your request may not be immediately fulfilled. In any event, you will be informed of the measures taken within one month of the date on which the request was made. You also have the right to lodge a complaint with the National Data Protection Commission at https://www.cnpd.pt/.

Right of access
The data subject has the right to obtain from Minor confirmation of whether or not personal data concerning them is being processed and, where applicable, to access their personal data and the information provided for by law. Should you request more than one copy of your personal data undergoing processing, Minor may charge 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 them.

Right to erasure (“right to be forgotten”)
The data subject has the right to obtain from Minor the erasure of their personal data without undue delay, and Minor is obliged to erase personal data without undue delay where one of the following grounds applies:

1. The personal data are no longer necessary in relation to the purposes for which they were collected or processed;
2. The data subject withdraws their consent on which the processing is based and there is no other legal ground for the processing;
3. The data subject objects to the processing and there are no overriding legitimate interests justifying 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:

1. The accuracy of the personal data is contested, for a period enabling Minor to verify the accuracy of the data;
2. The processing is unlawful and the data subject opposes erasure and requests restriction of use instead;
3. Minor no longer needs the personal data for processing purposes, but the data is required by the data subject for the establishment, exercise or defence of legal claims;
4. The data subject has objected to processing, pending verification of whether Minor’s legitimate grounds override those of the data subject.

Right to data portability
Where processing is based on the data subject’s consent and that consent was given by automated means, the data subject has the right to receive the personal data concerning them that they have provided to Minor in a structured, commonly used and machine-readable format.

Right to object
Where data processing is carried out for the purposes of legitimate interests pursued by Minor, or for direct marketing purposes, or for profiling, you may at any time object to the processing of your personal data.

CAN YOU WITHDRAW YOUR CONSENT LATER?

Where consent is legally required for the processing of personal data, the data subject has the right to withdraw consent at any time, although this right does not affect the lawfulness of processing carried out on the basis of consent previously given, nor the subsequent processing of the same data based on another legal basis, such as the performance of a contract or a legal obligation to which Minor is subject. Should you wish to withdraw your consent, please contact us at dpo.mhpt@minorhotels.com.

HOW DOES MINOR USE COOKIES AND SIMILAR TECHNOLOGY?

In order to provide a better service to users, we use cookies — small text files placed on your hard drive by a web server. This technology is used by Minor primarily to:

• Allow us to recognise our visitors and thereby provide a better, safer and more personalised service;
• Understand the performance of our websites and plan their update and improvement in line with the expectations of our customers.

Each visitor is assigned an individual cookie, thereby ensuring data privacy and security. Statistical data is presented in an aggregated form that does not allow individual visitors to be identified.

DO YOU HAVE ANY QUESTIONS?

If you have any questions regarding the processing of your personal data, or wish to exercise any of your rights, please contact us:
Email: dpo.mhpt@minorhotels.com

Minor will occasionally update this Privacy Policy. We ask that you review this document periodically to stay informed.