Privacy Policy

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A. GENERAL PART

A.1. The DHM Group

The Discovery Hotel Management Group, which includes DISCOVERY FUND HOTEL MANAGEMENT I, SA (“Discovery FHMI”), with registered office at Largo Jean Monnet, 1 – 7.º, 1269-068 Lisbon, Portugal, with the unique registration and corporate tax number 515312738, and a set of Hotel Units more specifically identified here: www.dhmportugal.com (collectively, the “DHM Group”), acts to ensure the protection of the personal data of its Clients within the scope of the services provided through our Hotel Units and of Users who visit our Websites. This includes information provided by the Client and/or User that allows the DHM Group to identify and/or contact them (“Personal Data”).

We have compiled the main points regarding the processing of our Clients' and Users' personal data in this Privacy Policy, thus ensuring that the necessary information is provided in a transparent, concise and easily understandable manner, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on Data Protection (“GDPR”).

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A.2. DHM GROUP ENTITIES RESPONSIBLE FOR PROCESSING PERSONAL DATA

Accommodation in Hotel Units

Generally, when a Client contacts one of our Hotel Units (for example, one of the Octant Hotels, or our Hotels & Resorts such as the Monte Real Hotel or the Dolce Campo Real), it is the Hotel Units themselves that provide the services related to the stay and determine how their data is processed in the context of those services. Therefore, whenever you book a stay at one of our Hotel Units, the entity responsible for processing the data necessary for the provision of hotel services and associated services (restaurants, bars, use of health clubs or spas), managing contacts with Clients, and invoicing and collection will be the Hotel Unit providing those services.

The Personal Data collected and processed for these purposes consists of information relating to name, gender, date of birth, telephone number, mobile phone number, email address, postal address, tax identification number, credit card details (collected only for billing purposes), although other Personal Data that may be necessary or convenient for the provision of services by the Hotel Units may also be collected.

The Hotel Units will also be responsible for the processing of data carried out for the purposes of protecting people and property and security within the Hotel Units (through video surveillance systems).

In summary, whenever Hotel Units process Personal Data, they must always have a legal basis for doing so (as explained in section B below), in accordance with the GDPR.

In this context, the legal bases used by the Hotel Units for the aforementioned treatments are as follows:

Purpose: Managing reservations and customer contact.
Legal basis: Performance of a contractual relationship

Purpose: Provision of hotel services
Legal basis: Performance of a contractual relationship, consent

Purpose: Billing and collection
Legal basis: Compliance with a legal obligation.

Purpose: Video surveillance
Legal basis: Legitimate interest (protection of people and property)

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Website and Marketing

On the other hand, with regard to the website hosted at www.dhmportugal.com and the services and communications available there, Discovery FHMI is the entity responsible for processing Users' Personal Data.

Generally, Personal Data is requested when the User registers on the Website, requests contact and/or the sending of newsletters, subscribes to a particular Service, purchases a product or establishes a contractual relationship with Discovery FHMI.

Discovery FHMI also collects and processes information about your hardware and software, as well as information about the pages you visit on the Website. This information may include: browser type, domain name, access times, and the hyperlinks through which you accessed the Website (“Usability Information”). This information is used only to improve the quality of your visit to the Website.

Discovery FHMI will process Users' Personal Data and Usability Information for the following purposes:

User registration on the Website;
To inform the User, upon their request, about new products and services available on the Website and/or in the hotel units, special offers and campaigns, updated information about the activities of Discovery FHMI or the hotel units of the DHM Group, and in general for marketing purposes of Discovery FHMI and the hotel units of the DHM Group, through any means of communication, including electronic media;
Allow access to restricted areas of the Website, in accordance with previously established conditions;
To ensure that the Website meets the User's needs by developing and publishing content that is as tailored as possible to the User's requests and type, improving the Website's search capabilities and functionalities, and obtaining aggregated or statistical information about the typical User profile (consumer profile analysis);
Provision of services and other services such as newsletters, opinion surveys or other information or products requested or purchased by the User;
Record of telephone calls made within the scope of the contractual relationship, both during the contract formation phase and during its validity.

In summary, whenever Discovery FHMI processes Personal Data, it must always have a legal basis for doing so (as explained in section B below), in accordance with the GDPR. In this context, the legal bases used by Discovery FHMI for the aforementioned processing are as follows:

Purpose: User registration on the Website
Legal basis: Pre-contractual obligations, consent

Purpose: Information about products and services, newsletters, opinion polls.
Legal basis: Consent

Purpose: Access to restricted areas of the Website
Legal basis: Performance of a contractual relationship

Purpose: To improve website functionality (content adaptation, security, and features).
Legal basis: Legitimate interest (improving the service provided to Website Users)

Purpose: Call recording
Legal basis: Consent

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A.3. DATA COLLECTION CHANNELS

DHM may collect data directly (i.e., directly from the User) or indirectly (i.e., through partners or third parties). Data may be collected through the following channels:

Direct collection: in person, by phone, by email or through the Website;
Indirect collection: through partners or group companies and official entities.

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B. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA

In terms of general principles, the DHM Group is committed to ensuring that the Personal Data it processes:

They are subject to lawful, fair and transparent treatment in relation to Clients and/or Users;
They are collected for specific, explicit and legitimate purposes and are not subsequently processed in a way that is incompatible with those purposes;
They are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
They are accurate and, where necessary, kept up to date, with all appropriate measures being taken to ensure that inaccurate data, taking into account the purposes of the processing, are erased or rectified without delay;
They are stored in a way that allows the identification of Clients and/or Users only for the period necessary for the purposes of the processing;
They are handled in a way that ensures their security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through appropriate technical or organizational measures.

The processing of data carried out by the DHM Group is lawful if at least one of the following conditions is met:

The Client and/or User has given their explicit consent to the processing of their Personal Data for one or more specific purposes;
The processing is necessary for the performance of a contract to which the Client and/or User is a party, or in order to take steps at the request of the Client and/or User prior to entering into a contract;
The treatment is necessary to comply with a legal obligation to which the DHM Group is subject;
The processing is necessary for the protection of the vital interests of the Client and/or User or of another natural person;
The processing is necessary for the purposes of the legitimate interests pursued by the DHM Group or by third parties, except where such interests are overridden by the interests or fundamental rights and freedoms of the Client and/or User which require protection of personal data.

The DHM Group is committed to ensuring that the processing of the Client's and/or User's Personal Data is only carried out under the conditions described above and in accordance with the aforementioned principles.

When processing is based on consent, the data subject has the right to withdraw it at any time, without affecting the lawfulness of processing previously carried out.

The data retention period varies depending on the purpose. Whenever there is no specific legal obligation, the data is retained only for the minimum period necessary.

B.1. USE OF COOKIES

This website uses cookies. We use cookies to personalize content and ads, provide social media features, and analyze our traffic. We also share information about your use of our site with our social media, advertising, and analytics partners, who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

Cookies are small text files that can be used by websites to make the user experience more efficient.

The law dictates that we can store cookies on your device only if they are strictly necessary for the operation of this website. For all other types of cookies, we need your permission.

This website uses different types of cookies. Some cookies are placed by third-party services that appear on our pages.

You can change or withdraw your consent at any time via the Cookie Statement on our website.

Learn more about who we are, how you can contact us, and how we handle personal data in our Privacy Policy.

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C. DATA COMMUNICATION

Subcontracted entities

In the context of processing User data, Discovery FHMI [and/or the Hotel Units] may use subcontracted third-party entities that process the data on behalf of DHM and in accordance with the instructions given.

These entities may not transmit data to third parties without prior written authorization.

DHM is committed to contracting only with entities that offer sufficient guarantees of data protection.

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Other entities in the DHM group

Personal data is not shared with third parties without consent, except when necessary for the provision of services.

They can be accessed by other entities within the DHM group when necessary for service continuity.

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Other third parties

The data may be disclosed to third parties when required by law or public authorities.

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D. STORAGE PERIODS

The data is kept only for the time necessary for the purposes described.

When required by law (tax and accounting), the data is kept for 10 years.

Marketing data: until consent is withdrawn.
Opinion polls: for as long as necessary or until consent is withdrawn.
Call recordings: 90 days.
Video surveillance: 30 days.

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E. TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES

The DHM Group treats data with absolute confidentiality and adopts appropriate technical and organizational measures to protect personal data.

Measures such as the following are applied:

Regular audits;
Employee training;
Pseudonymization and encryption;
Security and resilience systems;
Data recovery mechanisms.

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F. INTERNATIONAL DATA TRANSFERS

The data is not transferred outside the European Union. Should it be transferred, compliance with applicable legislation will be guaranteed.

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G. FINAL PART

G.1. CHANGES TO THE PRIVACY POLICY

The DHM Group reserves the right to change this Privacy Policy at any time. The date of the last update will always be indicated. Significant changes will be communicated to users.

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G.2. APPLICABLE LAW AND JURISDICTION

Any dispute will be submitted exclusively to the courts of the Lisbon district.

See our Privacy and Personal Data Policy on the footer menu