Privacy and Data Policy / Privacy Policy and Personal Data

PRIVACY POLICY

The Navigator Collection - Hotéis e Gestão Hoteleira, SA, with registered office at AV. Quinta da Fonte 13 EDF Q34 1 Paço d'Arcos, 2770-192, holder of tax identification number 518124428, is 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 current Personal Data Protection legislation, 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 how The Navigator Collection - Hotéis e Gestão Hoteleira, SA processes your data and your rights as a data subject. Any data you provide to The Navigator Collection - Hotéis e Gestão Hoteleira, SA will be understood as obtained, processed, and transmitted in strict observance and in full compliance with the requirements established in the GDPR and applicable legislation.

Data Controller and Data Protection Officer:

In accordance with the GDPR, The Navigator Collection - Hotéis e Gestão Hoteleira, SA acts as the Data Controller for your data. For any clarification regarding this Privacy Policy or the processing of your data, you may contact The Navigator Collection - Hotéis e Gestão Hoteleira, SA through:

The Navigator Collection - Hotels and Hotel Management, SA

Address: AV. Quinta da Fonte 13 EDF Q34 1 Paço d'Arcos, 2770-192

Email: reservations@thenavigatorcollection.com

Type of personal data, Purposes and Basis for Processing:

This policy covers the online and offline data collection activities of The Navigator Collection - Hotéis e Gestão Hoteleira, SA, including data collected through various channels such as brand websites, agencies, and events/fairs, as well as subcontractors in which The Navigator Collection - Hotéis e Gestão Hoteleira, SA participates.

The Navigator Collection - Hotels and Hotel Management, SA collects and processes your data for a number of purposes:

• Booking or purchasing stays at the various accommodations managed by The Navigator Collection - Hotéis e Gestão Hoteleira, SA: There is a set of data that must be collected so that The Navigator Collection - Hotéis e Gestão Hoteleira, SA can provide the requested service, namely sending the booking confirmation, as well as managing any other matters related to the booking or purchase of stays. The necessary data includes: identification document details, address, mobile phone or telephone number, email address, details regarding stay preferences, details relating to interests, special occasions and special requests, and whenever necessary, credit card details (collected for payment purposes), although other personal data may be collected that may be necessary or convenient for the provision or collection of services. The basis for collecting this data is the management of the contractual relationship and the legitimate interest of The Navigator Collection - Hotéis e Gestão Hoteleira, SA. The data is processed electronically, in certain cases in an automated way, including file processing or profiling, and within the scope of managing the pre-contractual, contractual or post-contractual relationship, in accordance with current national and EU regulations.

• Conducting Satisfaction Surveys: In order to assess your level of satisfaction with the services provided, The Navigator Collection - Hotéis e Gestão Hoteleira, SA may send you quality surveys, which may be conducted via email or through customer satisfaction assessment companies. Customers are not obliged to respond to these quality surveys, which aim to gather opinions about the stays provided, with the objective of improving/developing them. The basis for processing this data is the legitimate interest of The Navigator Collection - Hotéis e Gestão Hoteleira, SA in continuously improving the quality of its services.

• Management and administration: the data collected so that The Navigator Collection - Hotéis e Gestão Hoteleira, SA can fulfill its accounting/tax and legal and administrative obligations is typically the data included in the client's identification document. The basis for processing this data is compliance with a legal obligation and the legitimate interest of The Navigator Collection - Hotéis e Gestão Hoteleira, SA in managing the relationship with the client.

• Commercial and promotional communications: The Navigator Collection - Hotéis e Gestão Hoteleira, SA collects data such as name, telephone or mobile phone 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 "Exercise of your Rights". The basis for processing this data is the legitimate interest of The Navigator Collection - Hotéis e Gestão Hoteleira, SA or, when requested, your consent.

In accordance with the duty to provide information to which The Navigator Collection - Hotéis e Gestão Hoteleira, SA is bound, the categories of subcontractors to whom the personal data of website users and clients of The Navigator Collection - Hotéis e Gestão Hoteleira, SA are communicated are presented below:

Transfer of personal data:

In the context of a reservation and/or purchase, The Navigator Collection - Hotéis e Gestão Hoteleira, SA may provide the following data:

I. To government authorities (e.g., immigration, border control, public safety and security agencies, and counter-terrorism).

II. Within the scope 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 The Navigator Collection - Hotéis e Gestão Hoteleira, SA or third parties to whom the data is communicated. The processing of personal data may also be carried out by service providers acting on behalf of The Navigator Collection - Hotéis e Gestão Hoteleira, SA, namely marketing and digital and social media agencies, accounting management services, auditors and lawyers, external entities that provide us with technological services, such as IT platform providers, hosting services, maintenance and support of our databases, etc.

Data on minors:

Data from minors is collected and processed with the consent of their parents or legal guardian. Regarding this data, parents or legal guardians may exercise the rights granted to data subjects under the GDPR.

Information on the use of cookies:

When accessing the website of The Navigator Collection - Hotéis e Gestão Hoteleira, SA, you must accept or reject the Cookie Policy. These cookies will only be installed with your express consent, except in cases where consent is necessary for the operation of the Site.

Personal data retention period:

The data is retained by The Navigator Collection - Hotéis e Gestão Hoteleira, SA for the period strictly necessary to fulfill the aforementioned purposes, except when there are retention obligations imposed by applicable legislation, or legitimate interest, that require the maintenance of personal data for a longer period. Personal data collected for the purpose of sending communications about campaigns and promotions is retained for a period of 2 years.

Personal Data Security Measures:

The Navigator Collection - Hotéis e Gestão Hoteleira, SA uses appropriate security measures to protect your data, including technical and organizational measures to protect the data against abusive or unlawful processing and against accidental loss, damage or destruction. The data is processed by employees of The Navigator Collection - Hotéis e Gestão Hoteleira, SA 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 limits established by law:

i. Access to personal data [When submitting an access request, you will be provided with access to and details about the personal data processed by The Navigator Collection - Hotéis e Gestão Hoteleira, SA]

ii. Correction of personal data [If your personal data is incomplete or incorrect, you may request its correction.]

iii. Right to be forgotten [By exercising your right to be forgotten, The Navigator Collection - Hotéis e Gestão Hoteleira, SA will, if applicable, delete 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 that is processed based on your consent or the performance of a contract.]

v. Objection to the processing of personal data [For reasons related to your particular situation, you have the right to object to the processing of your personal data by The Navigator Collection - Hotéis e Gestão Hoteleira, SA based on legitimate interest or in relation to direct marketing.]

vi. Revocation of consent for processing [If you revoke your consent, The Navigator Collection - Hotéis e Gestão Hoteleira, SA will remove your consent for the activity you specify].

Exercising these rights requires a written request (including a copy of a document proving the client's identity and mentioning the right or rights they wish to exercise), to be sent via one of the following methods:

Mail: The Navigator Collection - Hotels and Hotel Management, SA - AV. Quinta da Fonte 13 EDF Q34 1 Paço d'Arcos, 2770-192

Email: reservations@thenavigatorcollection.com

In person: at our office, by filling out a specific form. After submitting the request with the necessary information, The Navigator Collection - Hotéis e Gestão Hoteleira, SA will respond within one to two months, taking into account the complexity and number of requests.

After the request with the necessary information is submitted, The Navigator Collection - Hotéis e Gestão Hoteleira, SA 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 on the use of cookies:

When accessing The Navigator Collection website, you must accept or reject the Cookie Policy. These cookies will only be installed with your explicit consent, except in cases where consent is necessary for the Site to function.

Changes to the Privacy Policy:

The Navigator Collection - Hotels and Hotel Management, SA reserves the right to modify or update this Privacy Policy at any time, and such changes will be duly updated on our platforms and websites. Please check regularly for 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