Since Morgan-Jupiter II Management & Consultation Services, Unipessoal, LDA (“Morgan-Jupiter,” “we,” “us”, or “our”) set up, our approach has been anchored with a strong commitment to privacy, security, compliance and transparency. This approach is compliant with EU data protection requirements, including those set out in the General Data Protection Regulation (“GDPR”), which replaced the EU Data Protection Directive (also known as “Directive 95/46/EC“) and became enforceable on May 25, 2018. We are committed to protecting the information that you share with us, and explaining how we collect and process that information.
Personal Data We Collect
This Privacy Statement describes the privacy practices of the Morgan-Jupiter for data that we collect:
- through website(morganjupiterapartments.pt) operated by us from which you are accessing this Privacy Statement
- through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”)
- through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us
- when you visit or stay as a guest at one of our properties, offered on the third party reservation platforms, or through other offline interactions (collectively, “Property Visits and Offline Interactions”)
Collectively, we refer to the Websites, our Social Media Pages, as the “Online Services” and, together with the Property Visits and Offline Interactions, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.
Information you provide to us: we collect personal data (including where applicable sensitive personal data) you provide directly to us. This includes:
Date and place of birth
Nationality, passport, visa or other government-issued identification data
Important dates, such as birthdays, anniversaries and special occasions
Membership or loyalty program data
Credit and debit card number or other payment data
Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
In more limited circumstances, we also may collect:
Data about family members and companions, such as names and ages of children
Biometric data, such as digital images
Images and video and audio data via security cameras located in public areas, such as parking spot, office, in our properties;
Guest preferences, enquiries and comments and any other personalized data (“Personal Preferences”), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit
If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.
Your stay information, including the suite where you have stayed, date of arrival and departure, and special requests made.
your credit card, mobile payment and other payment details;
your reviews, feedback and opinions about our properties and services;
information collected through the use of closed circuit television systems and other security systems; and any other personal data you choose to provide to us.
Information Collected by Cookies and Other Tracking Technologies: we and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular and count visits. Web beacons are electronic images that may be used in our services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see our Cookies Policy.
Information We Collect From Other Sources: we may also obtain personal data from our hotels and from our third party service providers (such as information relating to the credit of guests) and from public sources and combine that with information we collect through our Site where we believe that it is necessary to help manage our relationship with you.
How We Use Your Personal Data
We may use your personal data for the purposes set out below.
For the performance of our agreement with you, in order to:
process, confirm, provide and charge for apartments’ arrangements and restaurant reservations and our goods and services;
fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organisers and your employer) and vendors (e.g. credit card companies, airline operators and other loyalty programmes);
provide you with access to the content on our Site, and respond to your enquiries and requests for information and services; and
administer, and disclose the winner of, contests and lucky draw competitions conducted by us or on our behalf.
For our legitimate commercial interests, in order to:
understand how our products and services impact you, provide you with a better, more personalised level of service, and further develop our products and services, including linking or combining with information we get from others to do so;
provide privileges, benefits and services to you, process applications for and administer membership programmes, verify and validate your ability to access and use certain products, services and information;
monitor your use of our Site and your bookings, and conduct analysis of the use of our Site in order to operate, evaluate and improve our Site and our services, understand your preferences, display customised content to you on our Site which may be of interest to you and troubleshoot any problems;
conduct market analysis, market research, customer satisfaction and quality assurance surveys to improve our apartments and services; and provide for the safety and security of guests.
To comply with legal obligations to which we are subject:
meet legal and regulatory requirements and administer general record keeping.
Use of information based on your consent:
facilitate direct marketing, promotional and customer management purposes, including sending you promotional communications (including without limitation emails and push notifications) or special offers if you have consented to receive the same. Please see section “Direct Marketing” below;
Disclosures of Your Personal Data
We may share your personal data:
between and among Morgan-Jupiter and a limited number of our operators as are relevant for the above purposes and to facilitate the operation of our business, but we shall only do so on a need to know basis;
with the operator of the suite you book, stay or visit for the above purposes;
with third-party payment processors, payment service providers, IT and marketing support service providers and other consultants, vendors and service providers who need access to such information to carry out work or provide services on our behalf or who help us to provide the Site to you;
with anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organisers and your employer) in order to fulfill contractual obligations;
with any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;
if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Morgan-Jupiter, our affiliates or others;
in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or any change of management of a hotel;
with our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
with any other party at your consent or at your direction; and otherwise as permitted or required by applicable laws and regulations.
We may also disclose aggregate or de-identified data that is not personally identifiable with third parties, including our commercial and strategic partners.
From time to time, we would like to use your name, email address, mobile phone number, and other relevant contact information to send you either via emails, SMS messages, telephone calls, push notifications, post, or social media (e.g. Instagram and Facebook) information that we think may be of interest to you, including about our apartments, products and services, news about our membership programmes (if you join our loyalty programme), satisfaction surveys, events, offers and promotions, but we can only do so with your consent.
We would also like to share (for gain) such data with the operator of the apartments, so that they may send you information, news updates, special events, offers and promotions as regards their products and services, including travel, transportation, retail, food and beverage, hotel accommodation, credit cards, financial and investment services, real estate, entertainment, publications, fashion and jewellery, leisure and sports, health and wellness, non-profit and charitable activities, telecommunications, social networking, media and public relations, but we will not use your personal data for direct marketing without your consent.
You may opt-out from receiving marketing communications at any time by following the unsubscribe instructions contained in the marketing communications or contacting Morgan-Jupiter. If you opt out of these communications, we may still send you non-promotional communications, such as those about your, unless we are prohibited from doing so by applicable laws.
Retention of Personal Data
Our Commitment to Data Security
We have in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss or use of your personal data and to keep your personal data confidential. These measures are subject to ongoing review and monitoring. To protect your personal data, we also require our third party service providers to take reasonable precautions to keep your personal data confidential and to prevent unauthorised or accidental access, processing, erasure, loss or use of personal data, and to act at all times in compliance with applicable data protection laws.
We cannot guarantee that our Site will function faultless and without any interruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.
If you are in the EU, our online services are not directed at children under the age of 13. If you believe we have collected information about a child under the age of 13, please contact us so that we may take appropriate steps to delete such information. If you are at least 13 but under the age of 16, please get the consent of your parent or legal guardian before giving us any personal data about yourself.
Third Party Sites
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below.
Your Rights and Contact Us
You are entitled to the following rights: right of access to the personal data we hold about you, right of rectification, right to erasure, right to restrict data processing, right to object against profiling and your personal right to data portability. Whenever reasonably possible and required, we will strive to grant these rights within one (1) month. You may also withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time, and you may in certain circumstances ask us to delete your personal data. However, we may not be able to continue providing services to you if you entirely withdraw your consent or ask us to delete your personal data entirely. To make these requests, or if you have any questions or complaints about how we handle your personal data, or would like us to update the data we maintain about you and your preferences, please contact our data protection officer by email [email protected], or by post at Rua Rodrigo da Fonseca 15, RC/F, 1250-189, Lisboa, Portugal.
We may change this Cookies Policy from time to time by posting the updated version of the policy on our Site. Please check this Site periodically to be informed of any changes.
If you have any questions about the cookies used on our website, please contact us at [email protected]
Last Updated: 11 Feb. 2020