For Enotel Hotels & Resorts, the privacy and security of the personal data of guests, investors, Enotel Club customers and other partners are aspects that are of crucial importance for the company.
This policy applies to all systems, people and processes that make up the Enotel Hotels & Resorts information system. The commitment to the security of personal data was assumed by the Management of Enotel Hotels & Resorts and extends to all employees of the organization. Enotel Hotels & Resorts promotes information security and protection in the processing of personal data stored by the institution and collected through traditional tour operators and agencies and online operators (OTA) and online reservation centers (incorporated on the website https://www.enotel.com/).
In the processing of personal data, we respect your privacy, we reiterate our commitment to implementing measures for compliance, in particular, to ensure:
- a lawful treatment, supported by a legal basis, legitimate interest or consent of the data subject
- that processing is limited to the purpose for which the data were made available
- that there are mechanisms to obtain accuracy and completeness of the data made available
- the minimization of the required data, requesting only those suitable for the purpose
- limitation in data storage, according to the defined retention periods
- the implementation of measures for the integrity and confidentiality of information
Enotel Hotels & Resorts is defining procedures for the company's compliance with the principles described above and requirements of the new Regulation for the Protection of Personal Data (RGPD), for existing information systems and to carry out a prior impact assessment and implementation of privacy measures in new data processing to be carried out in the future.
To learn more about how we collect, use, share and protect the personal data we collect, please consult the following sections of this Privacy Policy.
1. Enotel Hotels & Resorts
Enotel Hotels & Resorts is a hotel group with a presence in Madeira Island, Portugal and Brazil that is dedicated to guest accommodation and related services, such as catering, wellness and leisure.
The person responsible for the processing of personal data at Enotel Hotels & Resorts is Enotel - Management, S.A, headquartered in 29 Simplício dos Passos Gouveia Street, 9004-576 Funchal, legal person nº 511062060.
2. Categories of Personal Data processed by Enotel Hotels & Resorts
In order to perform its duties and provide personalized service during the stay, Enotel Hotels & Resorts deals with the following categories of personal data:
- Identification data (e.g., name, passport number, customer number)
- Demographic data (e.g., gender, date of birth, nationality, and country of residence)
- Contact data (e.g., address, mobile phone, email and profiles on social networks)
- Sensitive data, at the customer's option (e.g., dietary restrictions, personal preferences, family information, health history)
- Financial data (e.g. Credit Card)
- Holiday and household data (e.g., family composition, travel preferences and frequency and other holiday history information)
- Electronic identification data (e.g. Enotel Club user ID, IP address used to identify a device via the Internet)
- Personal data made public by the data subject, (e.g., content created and shared publicly with Enotel on third-party social networks or by uploading to one of our websites, applications and other online and offline services, including Facebook, Instagram, Linkedin and the similar.)
3. Purposes, grounds for processing and retention periods for personal data
3.1. Customers and Guests
In pursuing its duties, by contractual relationship, legal obligation and / or legitimate interest, Enotel Hotels & Resorts may treat Your personal data for the purposes described in the table below.
| Purpose of treatment | Data Category | Legal basis | Shelf life |
|---|---|---|---|
|
Reservation management; Invoicing; Management of collections and credit recovery; Promoting a stay that suits the interests and safety of guests. |
Identification Data Contact Details Financial Data Sensitive Data |
Pre-contractual arrangements, performance of a contract and post-contractual due diligence arising from the provision of the service. |
For individual bookings – 3 (three) months. In group bookings – 4 (four) months The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with. |
|
Personalized intervention in SPA treatments |
Identification Data Contact Details Sensitive data |
Pre-contractual due diligence, execution of a contract and post-contractual due diligence resulting from the provision of the service. |
3 (three) months. The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with. |
|
Compliance with legal obligations, namely with the authorities, among others, of supervision, tax and fiscal, judicial and police. |
Identification Data Contact Details Financial data |
Legal obligation. For the declaration, exercise, or defense of rights in legal proceedings. |
The legal term is applicable at any time for each legal and legal obligation to be fulfilled. Until the expiry of the statute of limitations or expiry for the exercise of rights. |
|
Security of people and goods through the video surveillance system |
Identification Data |
Legitimate interest |
30 (thirty) days after image capture. The period may be longer if there is a legal process or legal obligation to comply with. |
|
Customer segmentation and direct marketing for the dissemination and sending of promotional offers Enotel Hotels & Resorts |
Identification Data Contact details Financial data |
Legitimate interest in the development and growth of the data controller's activity and the provision of promotional offers to customers. |
Permanent conservation, unless objected by the data subject. |
|
Event organization and management |
Identification Data Contact details |
Pre-contractual due diligence, execution of a contract and post-contractual due diligence resulting from the provision of the service. |
While the contract runs. The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with. |
|
For commercial, marketing purposes and contacts related to commercial or marketing campaigns. |
Identification Data Contact details |
Explicit consent |
Until revocation of consent by the data subject. |
|
Preservation of your personal preferences, to guarantee a personalized welcome for future stays: |
Identification Data Contact details Sensitive data |
Explicit consent |
Until revocation of consent by the data subject. |
The processing of personal data of children under 13 is only carried out with the consent of parents or
guardians for parental ownership.
3.2. Enotel Club customers
If you are an Enotel Club customer, in addition to the treatments defined in the previous section, we use your data to administer the Enotel Club Customer loyalty program, to personalize and improve your experience with all our services, to communicate news, promotional and transactional materials of the various services offered by Enotel Club and to personalize advertisements and content delivered to you online, by email, mobile phone and also through the website, APP for mobile devices and via communication with the Customer Relationship Center.
In the pursuit of its attributions, through a contractual relationship, legal obligation and/or legitimate interest, Enotel Hotels & Resorts may process Your personal data for the purposes described in the table below.
| Purpose of treatment | Data Category | Legal basis | Shelf life |
|---|---|---|---|
|
Sending exclusive promotional offers to Enotel Club customers |
Identification Data Contact details |
Legitimate interest in developing and growing the activity of the controller and making promotional offers available to members |
Permanent conservation, unless objected by the data subject. |
|
Contract management,billing and promotion of a stay suited to the interests and safety of Enotel Club customers |
Identification Data Contact details Financial data Sensitive data |
Pre-contractual due diligence, execution of a contract and post-contractual due diligence resulting from the provision of the service |
While the contract runs. The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with. |
|
Organization and management of events or sweepstakes Enotel Club |
Identification Data Contact details |
Pre-contractual due diligence, execution of a contract and post-contractual due diligence resulting from the provision of the service |
While the contract runs. The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with. |
The processing of personal data of minors under the age of 13 is only carried out with the consent of the parents or guardians of parental ownership.
4. Sources of Personal Data
We process your Personal Data through the following sources:
- Enotel Hotels & Resorts Websites: All of our websites may be used to collect personal data. This includes both the website that we operate directly through our domains and IP addresses and websites or pages that we establish on third-party services.
- Social Networks: We process the personal data shared with Enotel Hotels & Resorts through social networks such as Facebook, Instagram, Linkedin, Youtube and other third parties that offer this type of service.
- Electronic mail and instant messaging systems: Services used to maintain electronic communications between the data subject and Enotel, including those made available directly by us, or third-party services such as WhatsApp, Telegram, SMS (short message service) and the like.
- Enotel Hotels & Resorts Mobile Applications: Mobile applications are provided directly by Enotel and its platforms or through third-party services such as Google or Apple.
- Customer service and sales center: Communications are made with the guest/customer through our call and sales centers.
- Ads, advertisements and online forms: Interactions with any type of Enotel advertisements, advertisements and online forms.
- Paper records: Completed paper records distributed during events and other interactions with Enotel;
- Data received from third parties: Including, but not limited to, social networks and third-party websites such as Facebook, Instagram, Linkedin, and the like, data aggregator services, Enotel partners, public sources and data received during the acquisition of others. companies.
5. Purposes of data processing through the website https://www.enotel.com/
Enotel Hotels & Resorts makes available through the website https://www.enotel.com, for the convenience of its users, the possibility of interaction and online reservations.
| Purpose of treatment | Data Category | Foundation of legality | Retention Deadline |
|---|---|---|---|
|
Requests for information, suggestions, compliments, complaints or reservations through the “Contact Us” Form |
Identification Data Contact details |
Pre-contractual due diligence, execution of a contract and post-contractual due diligence resulting from the provision of the service |
Term strictly necessary for the execution of the order. The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with. |
|
Subscription to promotional offers, through an online form. |
Identification Data Contact details |
Explicit consent. |
Until revocation of consent by the data subject. |
|
Online reservations |
Identification Data Contact details Financial data |
Pre-contractual due diligence |
For individual bookings: 3 (three) months For group bookings: 4 (four) months The period may be longer to ensure rights or duties related to the contract or if there is a legal process or legal obligation to comply with |
6. Cookie Policy
To ensure normal operation and personalization, the site may use cookies.
On each site, a Cookies Policy will be presented, with the details of the cookies used on that site, namely:
- Types of cookies;
- Purpose of using cookies;
- The retention period of the collected data;
- How consent can be withdrawn.
For all cookies that require consent, the user's consent will be obtained in advance to apply the cookies.
The method for withdrawing consent from cookies by the user will be as easy as giving consent.
We use our own and third party cookies to optimize your visit and improve our services by customizing our content and advertising based on your location and analysis of your browsing habits. If you continue browsing without modifying your browser configuration, we consider that you accept its use.
Our website https://www.enotel.com/ uses cookies, they are small files stored on your computer that monitor activity while using our site, providing essential information to make your navigation simpler site. When stored on your computer, cookies allow you not to enter all data each time you use the site. This data allows us to customize the site to your preferences and to navigate according to your needs.
If you do not want cookies to be stored on your computer, you can, through your browser settings, oppose cookies on our site. To learn how to configure your browser settings to manage your cookies, browse the Help of the browser you are using. You may delete cookies already on your device at any time, but be aware that disabling cookies may restrict certain features that will prevent you from navigating to your preferences.
Various types of cookies are used, namely:
- "Necessary" Cookies - Without these cookies, the intended services cannot be provided. They do not identify you and are used to understand your interaction with the site, such as preferences and navigation flow.
- Performance cookies - They do not identify you and are intended to understand your behavior anonymously.
- Functional cookies - They keep your preferences regarding the use of the site, so you do not have to re-configure the site each time you visit it. It may collect data with your consent such as your encrypted email or identification.
- Advertising cookies - Target advertising based on the interests of each user and allow user identification through their browser or mobile device, limiting the amount of time they see the ad, helping to measure the effectiveness of advertising and the success of the website organization.
- Third party cookies - These measure the effectiveness of third party advertising and may contain personal data. Your email or identification can be shared anonymously, allowing your partner to target advertising accurately.
7. Transfer of personal data to other entities
In order for Enotel Hotels & Resorts to be able to fulfill its mandate and in order to provide you with quality service, you may have to disclose or give access to your personal data to other entities:
In such cases, Enotel Hotels & Resorts will only transmit your personal data to the following recipient categories:
- Entities and authorities to whom the personal data are to be reported under legal obligation (SEF and police)
- Tax Authority
- Entity responsible for the reservation center application of the website https://www.enotel.com/
- Other entities required for management and operation, namely: accounting, computer assistance, computer security, communications.
- Amazon Services to ensure the hosting and infrastructure of our websites and services, but which meet all the necessary requirements to ensure the safety of your data (ISO 27001 and PCI DSS).
- In case of reorganization, sale or merger we may transfer the information collected to the third parties involved.
- Companies of the Enotel Group, namely in Brazil, the international transfer of data for commercial and marketing purposes and contacts related to commercial campaigns.
8. Rights of Data Subjects
Customers, as data subjects, enjoy the following rights:
8.1. Right of access
Whenever you request it, you can obtain information on what personal data about you are processed by Enotel Hotels & Resorts. You can also access your personal data, as well as obtain the following information:
- The purposes for which your personal data are processed
- The type of personal data that is processed
- The entities to whom your personal data may be communicated, including entities from the European Union or international organizations
- The period of retention of your data or, if this is not possible, the criteria for setting this period
- The rights you enjoy in relation to the processing of your personal data
- If personal data have not been obtained from you, information about the origin and type of data concerned
8.2. Right of rectification
Whenever you consider that your personal data (provided by you) is incomplete, you may request it to be completed, or you may request rectification if it is found to be incorrect. (e.g. address, tax ID, contacts, personal preferences).
8.3. Right to erasure
In certain circumstances the data holders may request the deletion of their personal data. Enotel Hotels & Resorts will advise whether or not this right can be met against existing retention obligations through legal enforcement or legitimate interest.
8.4. Right to limitation of treatment
The right to limitation of the processing of personal data allows you to ask the controller thereof which restricts the scope of access and processing of your personal data or to suspend the activities of treatment. May require limiting the processing of personal data in the following cases:
- if you dispute the accuracy of your personal data, for a period of time that allows Enotel Hotels & Resorts to verify its accuracy;
- if Enotel Hotels & Resorts no longer need personal data for processing purposes, but if such data are necessary for the purposes of declaring, exercising, or defending a right in a legal proceeding.
8.5. Right to portability
You may request the Enotel Hotels & Resorts to deliver, in a structured format, current use and automatic reading of personal data provided by you. You also have the right to ask Enotel Hotels & Resorts to transmit this data to another controller, provided that this is technically possible.
The right to portability applies only in the following cases:
- when treatment is based on explicit consent or performance of a contract
- when the treatment in question is carried out by automated means.
8.6. Right of opposition
You have the right to object to the processing of your personal data at any time for reasons relating to your particular situation, and when the processing is performed for purposes other than those for which the data were collected, but which are compatible with them.
In such cases, Enotel Hotels & Resorts will cease to process your personal data unless it has legitimate reasons for such processing and if it takes precedence over your interests.
The exercise of its right of opposition may entail the suspension or termination, in whole or in part, of the benefits associated with the purpose of processing the data concerned.
You can also oppose the processing of their data for direct marketing purposes.
8.7. Right to withdraw your consent
In case of data processing is based on your consent, you may cancel your consent at any time.
If you withdraw your consent, your personal data will no longer be processed unless there are other grounds, such as legal and regulatory obligations or the public interest of Enotel Hotels & Resorts, which justify such processing.
8.8. Right to present complaints to Enotel Hotels & Resorts or supervisory authority
The exercise of your rights is free of charge unless the request is manifestly unfounded or excessive and in such cases a reasonable fee may be charged for the associated costs.
The answer to your requests must be made within a maximum of 30 days, unless it is a particularly complex request, in which case the period may be longer.
Enotel Hotels & Resorts has appointed a Personal Data Protection Officer, in accordance with Articles 37, 38 and 39 of the General Data Protection Regulation. You can contact the Enotel Hotels & Resorts DPO and exercise your rights through the following channel:
- Email: by email to dpo@enotel.com
- Post Office: 29 Simplicio dos Passos Gouveia Street, 9004-576 Funchal – Madeira Island / Portugal.
If you wish to make a complaint regarding matters relating to the processing of your personal data you may do so with the National Data Protection Commission, the competent supervisory authority in Portugal www.cnpd.pt.
9. Changes to this policy
Enotel Hotels & Resorts may change this Privacy Policy at any time to reflect current privacy practices. When we make changes to this statement, we review the “update date” in the document footer. We encourage you to periodically read this Privacy Policy so that you know how Enotel Hotels & Resorts protects your information.