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Privacy Notice

 

AMORIM LUXURY – SGPS, S.A. (hereinafter referred to as “AMORIM LUXURY") is committed to protecting the personal data of guests of JNCQUOI HOUSE.

Therefore, it has prepared this Notice, which reflects what personal data its collects from or receive from you and the ways it uses that information, in the context of JNCQUOI HOUSE, in compliance with the legal requirements applicable to privacy and data protection, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”), Law No. 58/2019 of 8 August, Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002, and Law No. 41/2004 of 18 August 2004.

 

Who is responsible for the processing of your personal data?

In accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR), the controller of personal data is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

For these purposes, and under the terms set out below, AMORIM LUXURY acts as the data controller responsible for the processing of your personal data in connection with the operation of JNCQUOI HOUSE. AMORIM LUXURY is the holding company of the Group, which comprises several other entities, such as Amorim Guedes de Sousa, S.A., Amorim Guedes de Sousa II, Lda., Amorim Guedes de Sousa III, Lda. e AP – Amorim Prime, Sociedade de Investimentos, Lda. AMORIM LUXURY, through the companies mentioned above, is responsible for the catering and hospitality industry JNCQUOI, in Portugal.

  • Entity name: AMORIM LUXURY – SGPS, S.A.
  • Sede: Avenida da Liberdade, n.º 224, 1.º, 1250-148 Lisboa;
  • Contacto telefónico: +351 213 145 397 (Head Office);
  • E-mail: privacy@amorimluxury.com;
  • Website: https://www.amorimluxury.com/en/.

 

How can you contact the Data Protection Officer?

The Data Protection Officer plays an important role in the processing of personal data, ensuring, among other matters, the verification and monitoring of the compliance of data processing activities with the applicable legislation, verifying compliance with this Data Protection Notice and establishing clear rules for the processing of personal data. The Data Protection Officer also ensures that all persons who entrust their personal data to AMORIM LUXURY are informed of how their personal data are processed by AMORIM LUXURY and of the rights available to them in this regard.

Accordingly, data subjects may, if they so wish, contact the Data Protection Officer regarding any matters relating to the processing of personal data using the following contact details: privacy@amorimluxury.com.

 

What principles are applicable to the processing of your personal data?

When processing personal data, AMORIM LUXURY acts in accordance with the following legal principles:

  • Principle of Lawfulness, Fairness and Transparency – personal data are processed lawfully, fairly and in a transparent manner;
  • Principle of Purpose Limitation – personal data are collected for specified, explicit and legitimate purposes and are not further processed in a manner that is incompatible with those purposes;
  • Principle of Data Minimisation – personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • Principle of Accuracy – personal data must be accurate and kept up to date. Inaccurate personal data will be rectified or erased;
  • Principle of Storage Limitation – personal data must be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which they are processed, without prejudice to the application of longer retention periods where required to comply with legal obligations;
  • Principle of Integrity and Confidentiality – personal data are processed securely through the implementation of appropriate and effective technical and organisational measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage;
  • Principle of Accountability – AMORIM LUXURY is responsible for complying with the principles set out above and must be able to demonstrate such compliance.

 

How is your personal data obtained?

Your personal data will be obtained and processed by AMORIM LUXURY through the following means:

  • When you contact AMORIM LUXURY directly, whether in person, by telephone, by e-mail, through a contact form available on any of its websites or through any other communication channel, including for the purpose of making a reservation, requesting services, communicating preferences, submitting complaints or responding to satisfaction surveys.
  • When personal data is provided by third parties acting on your behalf or in connection with your reservation or stay, including your employer, personal assistants, travel agents, concierge services, event organisers or other authorised representatives. Where personal data are obtained indirectly, the information required under article 14 GDPR shall be provided at the latest at the time of the first communication with you.
  • When you interact with JNCQUOI HOUSE through its digital concierge, chatbot or other automated communication tools made available through its website;
  • Through the collection of information through cookies stored on your devices. Cookies are small text files stored on the hard drive or in the memory of the device used to access the website. For further information on the use and purposes of cookies, please refer to AMORIM LUXURY’s Cookie Policy.

 

Which of your personal data can be obtained?

In the context of its operations relating to JNCQUOI HOUSE, AMORIM LUXURY may collect and process the following categories of personal data: identification data, contact data, travel and business travel data, as well as data about transactions, prior interactions, payments, consumer preferences, complaints/feedback, and health.

 

Are special categories of personal data processed?

AMORIM LUXURY does not generally seek to collect or process special categories of personal data within the meaning of Article 9 GDPR, including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for the purpose of uniquely identifying an individual, or data concerning a person's sex life or sexual orientation.

However, in certain circumstances, and where necessary to provide services requested by the data subject, AMORIM LUXURY may collect and process limited health-related information, such as information concerning allergies, dietary requirements, accessibility requirements or other specific needs relevant to the provision of hospitality services.

Such information will only be processed where permitted under applicable data protection laws and subject to appropriate safeguards.

Data subjects are requested not to provide special categories of personal data that are not necessary for the purposes described in this Privacy Notice. Where such information is provided without being required for those purposes, AMORIM LUXURY may delete or otherwise cease processing the information in accordance with applicable data protection laws.

 

Are personal data relating to children processed?

The services provided by JNCQUOI HOUSE are not specifically directed at children. Nevertheless, AMORIM LUXURY may process personal data relating to minors where necessary in connection with reservations, stays, hospitality services or other services requested by parents, legal guardians or other authorised representatives.

Where personal data relating to minors is processed, AMORIM LUXURY will do so in accordance with applicable data protection laws and will implement appropriate safeguards to protect their rights and interests.

Parents, legal guardians and other authorised representatives should ensure that any personal data relating to minors provided to AMORIM LUXURY is accurate and limited to what is necessary for the relevant purpose.

 

How can you help ensure the accuracy of your personal data?

AMORIM LUXURY takes reasonable steps to ensure that the personal data it processes is accurate and, where necessary, kept up to date.

Data subjects are responsible for ensuring that the personal data provided to AMORIM LUXURY is accurate, complete and up to date and for informing AMORIM LUXURY of any changes to such information.

Where personal data relating to another individual is provided, the person providing the information must ensure that they are authorised to do so and, where required, that the relevant individual has been informed of the processing of their personal data.

AMORIM LUXURY may request updates or corrections where it becomes aware that personal data may be inaccurate, incomplete or outdated.

 

To which purposes and on what basis can your personal data be used?

 

AMORIM LUXURY may process the aforementioned data for the following purposes and on the following legal bases:

  • Reservations: to receive, process and confirm accommodation reservations, including the management of amendments, cancellations and pre-arrival requests, on the basis of pre-contractual steps taken at the request of the data subject, pursuant to Article 6(1)(b) GDPR;
  • Stay management: to manage check-in and check-out procedures, verify identity, allocate accommodation, manage stays and provide hospitality services, on the basis of the performance of a contract, pursuant to Article 6(1)(b) GDPR;
  • Payments and invoicing: to process payments, issue invoices, maintain transaction records and manage related administrative and financial procedures, on the basis of the performance of a contract, pursuant to Article 6(1)(b) GDPR, and compliance with legal obligations relating to accounting, taxation and record-keeping, pursuant to Article 6(1)(c) GDPR;
  • Additional services: to provide additional services requested by guests, including transportation, concierge, butler and other hospitality-related services, on the basis of the performance of a contract, pursuant to Article 6(1)(b) GDPR;
  • Guest profiles: to create and maintain guest profiles, including the recording of preferences, interests, previous interactions, service requirements and stay history, in order to personalise the guest experience and improve service delivery, on the basis of the legitimate interests pursued by AMORIM LUXURY in providing a personalised and high-quality hospitality experience, pursuant to Article 6(1)(f) GDPR;
  • Health-related requirements: to record and process dietary requirements, allergies, accessibility needs and other health-related information necessary to accommodate guests’ requests and preferences, on the basis of the explicit consent of the data subject, pursuant to Articles 6(1)(a) and 9(2)(a) GDPR;
  • Satisfaction surveys: to send satisfaction surveys, analyse feedback and assess service quality in order to improve products, services and the guest experience, on the basis of the legitimate interests pursued by AMORIM LUXURY in monitoring and improving its services, pursuant to Article 6(1)(f) GDPR;
  • Complaints and requests: to receive, investigate and respond to complaints, requests, incidents and other communications, on the basis of the legitimate interests pursued by AMORIM LUXURY in managing customer relations and safeguarding its rights, pursuant to Article 6(1)(f) GDPR, and compliance with legal obligations where applicable, pursuant to Article 6(1)(c) GDPR;
  • Legal claims and security: to establish, exercise or defend legal claims and protect the rights, property, safety and security of AMORIM LUXURY, its guests and staff, on the basis of the legitimate interests pursued by AMORIM LUXURY, pursuant to Article 6(1)(f) GDPR.

 

For how long is your personal data stored?

AMORIM LUXURY retains your personal data for as long as necessary to fulfil the purposes for which it was collected and processed, unless a longer retention period is required or permitted by law.

The retention period applicable to each category of personal data is determined on a case-by-case basis, taking into account the following factors:

  • The nature of the data;
  • The purposes for which the personal data was collected and is processed;
  • The duration of the contractual or commercial relationship with the data subject;
  • Applicable legal, regulatory, tax, accounting and reporting obligations;
  • Statutory limitation periods applicable to potential legal claims;
  • The need to establish, exercise or defend legal rights;
  • Business and operational requirements, including the maintenance of guest records and service history where appropriate.

Once the applicable retention period has expired, personal data will be deleted, anonymised or securely destroyed, unless further retention is required by law.

 

Is your personal data shared within the Amorim Luxury Group?

As established above, AMORIM LUXURY acts as the controller responsible for the processing of your personal data.

However, due to the integrated nature of the AMORIM LUXURY Group’s operations, your personal data may be shared with other companies of the Group, where necessary, to provide the products or services requested by you or to ensure a seamless customer experience.

For example, when you request a reservation at a JNCQUOI restaurant, the personal data necessary to arrange and manage that reservation may be shared with the relevant AMORIM LUXURY Group company operating that restaurant.

 

Is your personal data transferred to service providers?

To support the operation of JNCQUOI HOUSE and the provision of its products and services, AMORIM LUXURY engages carefully selected third-party service providers.

Where these service providers process personal data on behalf of AMORIM LUXURY, they act as data processors and may only process personal data in accordance with AMORIM LUXURY instructions and applicable data protection laws.

AMORIM LUXURY implements appropriate contractual, technical and organisational measures to ensure that personal data remains protected and secure. In accordance with Article 28 GDPR, each data processor is bound by a written data processing agreement governing the processing of personal data.

 

Will your personal data be disclosed to other recipients?

In certain circumstances, AMORIM LUXURY may be required to disclose personal data to third parties acting as independent controllers, particularly where such disclosure is required by law or is necessary for the establishment, exercise or defence of legal claims.

Depending on the circumstances, personal data may be disclosed to:

  • Banks and payment institutions, for the purpose of processing payments and managing financial transactions relating to services provided by JNCQUOI HOUSE;
  • Tax and customs authorities, including the Portuguese Tax and Customs Authority, for the purpose of complying with applicable tax, accounting and reporting obligations;
  • Courts, law enforcement authorities, regulatory bodies and other public authorities, where disclosure is required by law, judicial order or administrative request, or where necessary for the establishment, exercise or defence of legal claims;
  • Professional advisers, including lawyers, auditors and external consultants, where necessary to obtain professional advice or protect AMORIM LUXURY’s legitimate interests.

 

Is the provision of your personal data mandatory?

In certain circumstances, the provision of personal data is necessary for AMORIM LUXURY to enter into or perform a contract, provide the products and services requested, comply with its legal obligations, or otherwise pursue the purposes described in this Privacy Notice.

Where the provision of personal data is mandatory, failure to provide the requested information may prevent AMORIM LUXURY from processing a reservation, completing a check-in, providing the requested products or services, responding to a request, or otherwise establishing or maintaining a relationship with the data subject.

Where the provision of personal data is optional, this will be clearly indicated at the time of collection.

 

What security measures are applied to protect your personal data?

AMORIM LUXURY implements appropriate technical and organisational measures designed to ensure a level of security appropriate to the risks associated with the processing of personal data.

These measures are established following an assessment of the risks that processing activities may pose to the rights and freedoms of individuals. Based on this assessment, AMORIM LUXURY adopts and maintains safeguards aimed at preventing accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

Such measures include, where appropriate, access controls, confidentiality obligations, information security procedures, staff awareness measures, and other safeguards designed to protect personal data throughout its lifecycle

In addition, AMORIM LUXURY ensures that employees, service providers and other persons authorised to access personal data are subject to appropriate confidentiality obligations and process personal data only where necessary for the performance of their duties.

AMORIM LUXURY regularly reviews and updates its security measures to ensure their continued effectiveness and appropriateness in light of technological developments, evolving security risks and applicable legal requirements.

 

What rights do you have as a data subject?

Under applicable data protection laws, data subjects have several rights in relation to the processing of their personal data. To exercise any of these rights, data subjects may contact AMORIM LUXURY using the contact details set out above.

  • Right to withdraw consent: where processing is based on consent, to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal;
  • Right of access: to obtain confirmation as to whether personal data is being processed and, where that is the case, to access such data and obtain information regarding the processing;
  • Right to rectification: to request the correction of inaccurate personal data and the completion of incomplete personal data;
  • Right to erasure: to request the deletion of personal data in the circumstances provided for by law;
  • Right to restriction of processing: to request that the processing of personal data be restricted in certain circumstances;
  • Right to data portability: to receive the personal data provided in a structured, commonly used and machine-readable format and, where technically feasible, to have such data transmitted to another controller;
  • Right to object: to object, at any time, on grounds relating to the data subject’s particular situation, to processing based on legitimate interests and to processing for direct marketing purposes;
  • Right not to be subject to automated decision-making: to request not to be subject to a decision based solely on automated processing, including profiling, where such decision produces legal effects or similarly significantly affects the individual;
  • Right to lodge a complaint with the competent supervisory authority: if a data subject considers that the processing of personal data infringes applicable data protection laws, a complaint may be lodged with the competent supervisory authority. In Portugal, the competent supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD), with the following contact details: address: Av. D. Carlos I, 134 - 1.º, 1200-651 Lisbon, Portugal; tel.: +351 213928400; fax: +351 213976832; e-mail: geral@cnpd.pt; website: www.cnpd.pt.

 

Does this Privacy Notice apply to third-party websites?

The websites and digital platforms operated by AMORIM LUXURY may contain links to third-party websites, applications or online services.

AMORIM LUXURY does not control and is not responsible for the privacy practices, content or operation of such third-party websites or services. Any access to, or use of, those websites is subject to the privacy notices, terms and conditions and other policies made available by the relevant third party.

AMORIM LUXURY therefore recommends that individuals carefully review the privacy notice and terms of use applicable to any third-party website, application or service before providing personal data or otherwise interacting with it.

 

How do social media platforms process personal data?

AMORIM LUXURY maintain a presence on various social media platforms, including LinkedIn, Facebook, Instagram, to communicate with customers, prospective customers and other individuals interested in JNCQUOI HOUSE.

When you interact with AMORIM LUXURY through these platforms, your personal data may be processed as well by the relevant social media provider. AMORIM LUXURY has limited control over how personal data is collected and processed by these platforms, which operate under their own privacy policies and terms of use.

Social media platform providers are responsible for their own processing activities, including the operation of their platforms, the management of user accounts, the use of cookies and tracking technologies, and any transfers of personal data that may occur in connection with their services.

Depending on the platform and the nature of the interaction, personal data may be transferred to and stored in countries outside the European Economic Area ("EEA"). Where this occurs, the relevant platform provider is responsible for implementing any safeguards required under applicable data protection laws.

AMORIM LUXURY recommends that individuals carefully review the privacy notices of the social media platforms they use.

 

How will changes to this Privacy Notice be communicated?

AMORIM LUXURY may update or amend this Privacy Notice from time to time to reflect changes in its processing activities, legal obligations, business operations or applicable data protection requirements.

Any updates to this Privacy Notice will be made available through the relevant communication channels used by AMORIM LUXURY, including its websites where appropriate.

Data subjects are encouraged to review this Privacy Notice periodically to remain informed about how their personal data is processed and protected.

 

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