PRIVACY POLICY

Who is the Data Controller for the processing of the personal data?

In accordance with current legislation, the interested party is informed that the data provided will be processed by MINOR HOTELS EUROPE & AMERICAS, S.A. and MINOR HOTEL GROUP LIMITED (hereinafter, the entities) as joint controller for the processing of commercial communications for which their data is collected. The contact details of the entities are as follows:

MINOR HOTELS EUROPE & AMERICAS

- Tax Identification Number: A-28027944

- Registered office: Calle Santa Engracia 120, 7ª, 28003, Madrid

- Email: dpo@nh-hotels.com

MINOR HOTEL GROUP

- Tax Identification Number: 0105531001613

- Registered office: 88 The Parq Building, 12th Fl. Ratchadaphisek Road, Klongtoey Subdistrict, Klongtoey District, Bangkok Metropolis 10110, Thailand.

- Email: privacy.corporate@minor.com

1. Purposes of processing

The Personal Data provided by Data Subject will be used for the following purposes:

- Sending commercial communications via email or equivalent electronic means of communication about offers and services of both entities, unless you indicate otherwise by opposing the processing of your data.

- Personalisation of the services offered, through the analysis of your profile and tastes.

You may withdraw your consent at any time. However, if the data subject withdraws his or her consent or objects to the processing of his or her data, this will not affect the lawfulness of the processing previously carried out.

2. Lawful bases

The legitimate bases for the processing of your data are as follows:

- The consent of the data subject, for the sending of commercial communications about offers and services of both entities.

- The legitimate interest for the personalisation of the services offered by means of the analysis of your profile and tastes. This processing also contributes to improving the quality of the services provided to users. Although for the analysis of opinions, responses will be collected on an individual basis, their analysis will be carried out in a general way, by means of statistics, without identifying specific users. Users shall communicate their opposition to being contacted for this purpose.

3. What personal data will the entities process?

The entities will process the requested data by processing the following categories of personal data:

- Identification data: name, surname, first name,

- Contact data: e-mail address.

In addition, in order to analyse the performance of our services, the data derived from the data subject and contracting of our products and services will be used.

4. How long do we store your personal data?

The data collected for the sending of commercial communications will be kept until the data subject withdraws his/her consent to the sending of commercial communications, or objects to the same through the means made available by the entities to the data subject, in each of the commercial communications that may be sent. Subsequently, if necessary, the Parties shall keep the information blocked for the legally established periods.

5. Security of data

The entities have implemented the necessary technical and organisational measures to ensure the security of your Personal Data and prevent its alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.

6. To which recipients will personal data be communicated?

Entities shall not disclose data to third parties.

7. Processing of third party data

In the event that the Data subject provides, at any time, data of third parties, he/she declares to have their consent and undertakes to transfer the information contained in this clause to them, as well as to inform the entities of any change or update regarding the same.

8. International data transfers.

We inform you that your data will be transferred to third countries as MINOR HOTEL GROUP LIMITED are located outside the European Economic Area. The aforementioned transfer will be made as a result of the joint controller agreement between MINOR HOTEL GROUP LIMITED and MHEA for sending information and commercial communications that the same agreement is intended. In this regard, we inform you that this will be regulated by standard contractual clauses previously authorised by the Spanish Data Protection Agency.

9. Data subject responsability

The data subject:

- Guarantees that he/she is over 18 years of age and that the data he/she provides belong to him/her and that they are true, exact, complete and up to date. To this effect, the data subject is responsible for the ownership and veracity of all the data he/she communicates and will keep the information provided suitably updated, so that it corresponds to his/her real situation.

- He/she will be responsible for any false or inaccurate information that he/she provides with his/her consent and for any damages, direct or indirect, that this may cause to the entities or third parties.

10. What Rights do Data Subject have?

Data Subject have the right to:

- Revoke consents given.

- Access their personal data.

- Rectify inaccurate or incomplete data.

- Request the deletion of their data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

- Obtain from the entities the limitation of the processing of the data when any of the conditions provided for in the data protection regulations are met.

- Request the portability of their data.

- To oppose the processing of their data.

- File a complaint before the Competent Authority, when the interested party considers that the entities have violated the rights that are recognised by the applicable data protection regulations.

You can contact the entities by sending an e-mail to dataprotectiongroup@nh-hotels.com or privacy.corporate@minor.com

In addition, you shall lodge a complaint with the competent data protection authorities in the countries of the Data Controllers mentioned above if you consider that your rights have been infringed.

Last update: September 2023

© MINOR HOTEL GROUP LIMITED and MINOR HOTELS EUROPE & AMERICAS, S.A. All rights reserved.