A. GENERAL PART

A.1. The DHM Group

The Discovery Hotel Management Group, which includes DISCOVERY FUND HOTEL MANAGEMENT I, S.A (“Discovery FHMI”), headquartered at Largo Jean Monnet, 1 - 7º, 1269-068 Lisboa, Portugal, under the unique registration number and corporate entity 515312738, and a set of Hotel Units more specifically identified here: www.dhmportugal.com (collectively, the “DHM Group”), acts to ensure the protection of personal data of its Customers in the context of services provided through our Hotel Units and Users who visit our Websites. This includes information provided by the Customer and/or the User that allows the DHM Group to identify and/or contact them (“Personal Data”).

We have compiled the main points regarding the processing of personal data of our Customers and Users in this Privacy Policy, thereby ensuring that we provide the necessary information in a transparent, concise, and easily understandable manner to comply with the rules of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 on Data Protection (“GDPR”).

A.2. Entities of the DHM Group Responsible for the Processing of Personal Data

Stays at Hotel Units

As a rule, when a Customer 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 that provide services related to the stay at these same Hotel Units and determine how your 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 providing hotel services and associated services (restaurants, bars, use of health clubs or Spas), managing contacts with Customers, and billing and collection will be the Hotel Unit that provides these services.

The Personal Data collected and processed for these purposes consist of information related to name, gender, date of birth, telephone, mobile phone, email, 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 data processing carried out for the purposes of protecting people and property and security at the Hotel Units (through video surveillance systems).

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