Types of Personal Data:
The ‘Personal Data’ refers to any information relating to an identified or identifiable individual such as:
- Name, Gender, Nationality, Mailing address, Date of birth
- Passport and visa information or other identification information
- Contact information including contact number, e-mail address, or other social medias available (wechat, viber, facebook, instagram)
- Guest stay information, including diverse preferences (pertaining to accommodation, service preference, facilities, amenities, ages of children or any other aspects of services used), health restrictions, and other personal identifying information
- Credit card or debit card details and account details
- Information or feedback provided regarding marketing preferences, in surveys, promotional offers, and those third parties
Collection of Data:
Guest may provide us personal information as follows:
- By making a reservation
- By staying or visiting the resorts managed by The Small Maldives Island Co or by using its services
- By providing it to us in communications regarding service delivery
- By signing up in TSMIC loyalty program, Maldives Aficionado
- By downloading mobile application
- By communication through website chat
- By providing the information to us by participating in a marketing initiative.
Below you may find the type of information collected for each condition:
Making a Reservation
When making a reservation, collection of information is necessary to process guest requests. This information includes name, gender, nationality, date of birth, contact information such as email address and phone number, credit card or debit card details, bank account details, and other preferences relative to making the reservation request. It may also include guest preferences regarding service delivery. In other circumstances, wherein TSMIC resorts has special offers with qualifying criteria, further information may be required such as nationality, date of birth or Maldives Aficionado membership ID.
TSMIC and its resorts offer packages which involve third parties wherein personal information will be shared with that third party to the extent necessary in providing service and processing the request.
Staying or visiting TSMIC resorts and use of its services
Guests are required to present identity card (passport) when visiting or staying in any of the resorts managed by TSMIC. This will include information such as name, passport number and expiration date, nationality, mailing address and birthdate. Guests are also requested to check all information initially collected when making the reservation through a Registration Form. This form will also indicate their consent if they would like subscribe of unsubscribe in all marketing communications.
Communications regarding service delivery
Transactional emails such as pre-arrival forms and surveys are used as a communication with the guests to provide us information regarding guest preferences pertaining to accommodation, service preference, facilities, amenities, ages of children or any other aspects of services used. It may also include health restrictions and other personal identifying information. This information is recorded to enhance guest satisfaction and service delivery.
Maldives Aficionado loyalty programme
All guests of TSMIC and its resorts - Amilla Fushi and Finolhu, are welcome to be part of the Maldives Aficionado loyalty programme. Membership is voluntary. By choosing to enroll, members agree to share additional personal information for us to deliver a more personalised and quality service, as well as receive marketing communications, promotions and exclusive offers.
Mobile application is created to offer utmost convenience to the guest. It contains latest updates and general information about Maldives Aficionado, TSMIC and its resorts – Amilla Fushi and Finolhu. By downloading the application, no information is collected otherwise provided upon registration with name and email address.
Each resort of TSMIC features a chat in the website so that the guest can communicate directly with regards to any concerns and inquiries. Given this feature, the web chat will require the name of the guest and the email address. Further information may be required based on the guest query for us to be able to provide service and process the request.
If guests do not want to accept cookies, they can block them by adjusting the settings on the internet browser, however, guests may not be able to use all the features of the website
Use of Personal Data:
Personal information is used in order to fulfill the commitment to:
- Providing the services we offer
- Increasing the convenience for guest present and future stays
- Keep guests informed about new products and services or upcoming promotions and exclusive offers which we believe may be of guest interest
If guests do not wish to have the Personal Data processed for any of these Purposes then they will have the opportunity to indicate this when they indicate the consent and unsubscribe on all communications.
Data Subject Consent:
Loyalty Program: Maldives Aficionado membership is voluntary. By signing up, members agree to share personal information and receive marketing communications, promotions and exclusive offers.
For information collected when making reservation, visiting or staying in one of the resorts of TSMIC, guest has an option if he/she would like to subscribe to our communications or not, at the time of the data collection.
If guest do not wish to receive offers or email communications, guest can unsubscribe by sending an email to email@example.com using the subject line “Unsubscribe”, so indicating your request with sufficient information so that we can appropriately act on the request. All marketing communication of this type will also contain instructions for unsubscribing.
Disclosure of Personal Data:
The Small Maldives Island Co manages the island resort Amilla Fushi. Sharing the data across the property is essential in providing the same quality of service for the guest, and for the same purpose described above.
Where a third party processes the Personal Information on behalf of the TSMIC then such processing will be governed by a contract agreement. When applicable, this agreement will impose to the data processor all obligations set up by Article 28 of GDPR.
TSMIC will not disclose the guest personal data to outside third parties which are not associated with TSMIC. Circumstances where we might make disclosure:
- Contracted Partners/Travel Agents, Service Providers and Suppliers
- Consumer Insights
- Credit Authorisation
- Legal Requirements
OPERA system is sitting behind the firewall, only selected staff and third-party interfaces (such as Travel Click) can access guest profile via their specific credentials or through encrypted format.
Guests create User ID and Password to access personal data information in the Maldives Aficionado loyalty programme, whereby guests are entitled to make changes to any personal data relating to the profile held in database. Inside TSMIC, only selected staff and contractors have access to the server via their Password.
All reservation information is not accessible from outside TSMIC, hence, User ID and Password is not required for all the guests, otherwise, booked via website. Only selected TSMIC staff and contractors have access to the server via their Password.
Data Subject Rights:
The guest has the right to request from TSMIC the access, rectification or erasure of his/her personal data or restriction of processing and to object to processing as well as the right to data portability. Those rights can be exercised by sending an email to firstname.lastname@example.org.
The guest has also the right to lodge a complaint with a supervisory authority.
Personal Data are kept during 3 years after the end the commercial relationship between TSMIC and the data subject if the data is a client, of 3 years after the last active contact if the data subject is a prospect.
*Please note: This policy is subject to change without prior notice.