Privacy and Data Policy

PRIVACY POLICY

MA TRAVEL LTD - BRANCH IN PORTUGAL, with registered office at Avenida do Forte, 4 – Parque Suécia, Edf. Suécia V, Floor 0 – 2794-038 Carnaxide, holder of corporate identification number 980 564 808 and its Group Companies are committed to protecting the privacy of your personal data (hereinafter “data”) and, therefore, undertakes to process and ensure the security of such data in accordance with the Personal Data Protection legislation in force, and, in particular, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation – “GDPR”. This Privacy Policy aims to inform you of how MA TRAVEL LTD – BRANCH IN PORTUGAL processes your data and your rights as a data subject. Any data you provide to MA TRAVEL LTD-SUCURSAL EM PORTUGAL will be understood as obtained, processed and transmitted in strict compliance with and in full compliance with the requirements established in the GDPR and current legislation.

Data Controller and Data Protection Officer :

In accordance with the provisions of the GDPR, MA TRAVEL LTD-SUCURSAL EM PORTUGAL acts as the entity responsible for the processing of your data. For any clarification related to this Privacy Policy or the processing of your data, you may contact MA TRAVEL LTD-SUCURSAL EM PORTUGAL through:

MA TRAVEL LTD – PORTUGAL BRANCH

Address : Quinta da Fonte, 13 Quinta da Fonte Street – Q34-Forum Building – 2770-192 Paço de Arcos

Email : res.pelicanalvor@thenavigatorcollection.com

Type of personal data, Purposes and Basis for Processing :

This policy covers the online and offline data collection activities of MA TRAVEL LTD – SUCURSAL EM PORTUGAL, including data that it collects through various channels, such as brand websites, agencies and events/fairs as well as subcontracted entities in which MA TRAVEL LTD – SUCURSAL EM PORTUGAL participates.

MA TRAVEL LTD – BRANCH IN PORTUGAL collects and processes your data for a number of purposes :

• Booking or purchasing stays at the various accommodations managed by MA TRAVEL LTD : There is a set of data that must be collected so that MA TRAVEL LTD – SUCURSAL EM PORTUGAL can provide the requested service, namely sending the booking confirmation, as well as to manage any other matters related to the booking or purchase of stays. The necessary data are: identification document data, address, mobile phone or telephone number, email address, data relating to stay preferences, data relating to interests, special occasions and special requests, and, where necessary, credit card details (collected for payment purposes), although other personal data that may be necessary or convenient for the provision or billing of the service may be collected. The basis for collecting this data is the management of the contractual relationship and the legitimate interest of MA TRAVEL LTD – SUCURSAL EM PORTUGAL. The data is processed electronically, in certain cases automatically, including the processing of files or the definition of profiles and within the scope of the management of the pre-contractual, contractual or post-contractual relationship, in accordance with the national and community standards in force.

• Carrying out satisfaction surveys : in order to assess your level of satisfaction with the services provided, MA TRAVEL LTD – SUCURSAL EM PORTUGAL may send you quality surveys that may be sent by email or through customer satisfaction assessment companies. Customers are not obliged to respond to these quality surveys, which aim to collect opinions about the stays provided, with the aim of improving/developing them. The basis for processing this data is the legitimate interest of MA TRAVEL LTD – SUCURSAL EM PORTUGAL in continually improving the quality of its services.

• Management and administration : the data collected so that MA TRAVEL LTD – SUCURSAL EM PORTUGAL can comply with its accounting/tax and legal and administrative obligations are typically the data entered in the customer’s identification document. The basis for processing this data is compliance with a legal obligation and the legitimate interest of MA TRAVEL LTD – SUCURSAL EM PORTUGAL in managing the relationship with the customer.

• Commercial and promotional communications : MA TRAVEL LTD – SUCURSAL EM PORTUGAL collects data such as name, telephone or mobile number and email address, in order to provide you with information about services that may be of interest to you (for example, marketing communications or campaigns and promotions), collecting your consent when necessary. At any time, you may object to the processing of your data for these purposes, as stipulated in the paragraph below “Exercising your Rights”. The basis for the processing of this data is the legitimate interest of MA TRAVEL LTD – SUCURSAL EM PORTUGAL or, when requested, your consent.

Under the terms of the duty of information to which MATRAVEL LTD – SUCURSAL EM PORTUGAL is obliged, the categories of subcontractors to which the personal data of website users and MATRAVEL LTD – SUCURSAL EM PORTUGAL customers are communicated are presented below:

Transfer of personal data:

As part of a reservation and/or purchase, MA TRAVEL LTD – SUCURSAL EM PORTUGAL may provide the following data:

I. To government authorities (e.g. immigration, border control, public safety and security entities and combating terrorism).

II. In the context of merger, acquisition and/or incorporation processes in which it is involved, when such transfer is necessary within the scope of the legitimate interests of MA TRAVEL LTD – SUCURSAL EM PORTUGAL or of third parties to whom the data is communicated. The processing of personal data may also be carried out by service providers, who act on behalf of MA TRAVEL LTD – SUCURSAL EM PORTUGAL, namely marketing and digital and social media agencies, accounting management services, auditors and lawyers, external entities that provide us with technological services, such as providers of IT platforms, hosting services, maintenance and support of our databases, etc.

Minors' data:

Data relating to minors is collected and processed with the consent of their parents or legal guardian. With regard to this data, the parents or legal guardian may exercise the rights granted to data subjects by the GDPR.

Information about the use of Cookies:

When accessing the MATRAVEL website, you must accept or reject the Cookies Policy. These Cookies will only be installed with your express consent, except in cases where consent is necessary for the functioning of the Site.

Period for which personal data will be retained:

The data is kept by MA TRAVEL LTD – SUCURSAL EM PORTUGAL for the period strictly necessary to fulfill the purposes mentioned above, except when there are retention obligations imposed by applicable legislation, or legitimate interest, which require the retention of personal data for a longer period. Personal data collected for the purpose of sending communications about campaigns and promotions are kept for a period of 2 years.

Personal Data Security Measures:

MA TRAVEL LTD – SUCURSAL EM PORTUGAL uses appropriate security measures to protect your data, including technical and organizational measures to protect data against abusive or unlawful processing and against accidental loss, damage or destruction. Data is processed by employees of MA TRAVEL LTD – SUCURSAL EM PORTUGAL or by authorized service providers, accessing only the data strictly necessary, depending on the specific purposes for which the data was collected.

Exercising your Rights:

As the data subject, you may exercise the following rights, within the legally established limits:

i. Access to personal data [When submitting a request for access, you will be provided with access to and details of the personal data processed by MA TRAVEL LTD – SUCURSAL EM PORTUGAL.]

ii . Rectification of personal data [If your personal data is incomplete or incorrect, you may request that it be corrected.]

iii . Right to be forgotten [When exercising your right to be forgotten, MA TRAVEL LTD – SUCURSAL EM PORTUGAL will, if applicable, erase your personal data.]

iv . Portability of personal data [When requesting the portability of your personal data, you will receive, in a machine-readable format, the personal data you have provided and which are processed based on your consent or in the execution of a contract.]

v. Objection to the processing of personal data [For reasons relating to your particular situation, you have the right to object to the processing of your personal data by MA TRAVEL LTD – SUCURSAL EM PORTUGAL carried out on the basis of legitimate interest or in relation to direct marketing.]

vi. Revocation of consent for processing [If you revoke your consent, MA TRAVEL LTD – SUCURSAL EM PORTUGAL will remove your consent for the activity you specify].

The exercise of these rights depends on a written request (including a copy of a document proving the client's identity and mentioning the right or rights that he/she wishes to exercise), to be sent by one of the following means:

Address : MA TRAVEL LTD – BRANCH IN PORTUGAL - Quinta da Fonte, 13 Quinta da Fonte Street – Building Q34-Forum – 2770-192 Paço de Arcos

Email : res.pelicanalvor@thenavigatorcollection.com

In person : at our office, by filling out a specific form. After sending the request with the necessary information, MA TRAVEL LTD – SUCURSAL EM PORTUGAL will respond within one to two months, taking into account the complexity and number of requests.

Once the request has been sent with the necessary information, MA TRAVEL LTD – SUCURSAL EM PORTUGAL will respond within one to two months, taking into account the complexity and number of requests.

Supervisory Authority : National Data Protection Commission – CNPD at www.cnpd.pt.

Information about the use of Cookies:

When accessing the MATRAVEL website, you must accept or reject the Cookies Policy. These Cookies will only be installed with your express consent, except in cases where consent is necessary for the functioning of the Site.

Changes to the Privacy Policy:

MA TRAVEL LTD – SUCROSAL EM PORTUGAL reserves the right to, at any time, make changes or updates to this Privacy Policy, and such changes will be duly updated on our platforms and websites. Please check back regularly to see any updates or changes to this policy.

Privacy and Personal Data Policy - applicable to Users of this Hospitality Business when making a reservation

Data Controller (we): The Hospitality Business which will provide to you, the user, the requested service. Our identification and contact details are available on the website you used to make your reservation / to pose your questions to us. They will also appear on our invoice which we'll send to you.

Data Compliance Officer: Not applicable to Data Controllers' activities.

User: You, who filled-in the reservation form or any other documentation related to it.

Purpose: The purpose of processing the data provided through this form is to manage the reservations made by you, user and/or to answer to the questions / requests you posed.

Legal basis:
- Either the need to perform our contract with you, user / the need to take steps at your request prior to entering into a contract.
- Or the consent of you, the user, by ticking in the box of acceptance of the Terms and Conditions of which this Privacy and Personal Data Policy is an integral part.

Duration: We will store the data provided by you, the user, during the time necessary for the management of the reservation you made, as well as of the accommodation services you requested. Once the management is finished, your data will be kept for six (6) months. If you consent to receive marketing and/or commercial information, your data will be stored until you revoke your consent.

Processor: We engage our partner Guestcentric Group (www.guestcentric.com ) for carrying out the reservations engine of our business. Guestcentric acts under our authority and we have signed a contract with Guestcentric Group for the provision of their services. We have instructed Guestcentric Group in written as per how the processing should be done.

Data subjects different from the users: Where you, user, provide us with personal data pertaining to a different data subject from yourself, you are responsible for such acts as well as for obtaining the respective consent of such data subjects for the provisioning of their data.

Transfer of Data: We shall not transfer personal data to a third country outside the EEA (European Economic Area).

Data Subject Rights: Data Subjects can exercise their rights of access, rectification, cancellation and opposition by sending an email or through the postal service to the contact details on our reservation website and on our invoices.

Supervisory Authority: If a data subject considers their rights affected, they can also appeal to the competent supervisory authority of the Member State concerned. More info at: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en