Recordis Hotels

Website Privacy Policy

Privacy policy that governs the data collected and processed through the Website

DETAILED INFORMATION WEBSITE PRIVACY POLICY

Index

  • 1. Objective of the Privacy Policy
  • 2. Definitions
  • 3. Identity of the Data Controller
  • 4. Applicable Laws and Regulations
  • 5. Principles applicable to the processing of personal data
  • 6. Data Processing Activities Performed
  • 7. Necessary and Updated Information
  • 8. Personal Data of Minors
  • 9. Technical and Organizational Security Measures
  • 10. Rights of Data Subjects
  • 11. Complaints before the Supervisory Authority
  • 12. Acceptance and Changes to the Privacy Policy

1.- OBJECTIVE OF THE PRIVACY POLICY

The purpose of this “Privacy and Data Protection Policy” is to publicize the conditions that govern the collection and processing of personal data by HOTEL SIRENAS SEGOVIA S.L., making the utmost effort to ensure the fundamental rights, honor, and freedoms of the people whose personal data are processed, in compliance with the current regulations and laws that regulate the Protection of Personal Data according to the European Union and the Spanish Member State, and, specifically, those expressed in the “Processing Activities” section of this Privacy Policy.

Therefore, in this Privacy and Data Protection Policy, users of the Website https://www.recordishotels.com are informed of all the details of interest to them regarding how these processes are carried out, for what purposes, what other entities may have access to their data, and what the users’ rights are.

2.- DEFINITIONS

«Personal data»: Any information relating to an identified or identifiable natural person (‘the Website user’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

«Processing»: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

«Restriction of processing»: The marking of stored personal data with the aim of limiting their processing in the future.

«Profiling»: Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

«Pseudonymisation»: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

«Filing system»: Any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.

«Controller» or «data controller»: 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

«Processor» or «data processor»: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

«Recipient»: A natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

«Third party»: A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

«Consent of the data subject»: Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

«Personal data breach»: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

«Genetic data»: Personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question.

«Biometric data»: Personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data.

«Data concerning health»: Personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.

«Main establishment»: a) As regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment; b) As regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if it has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation.

«Representative»: A natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27 of the GDPR, represents the controller or processor with regard to their respective obligations under this Regulation.

«Undertaking»: A natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity.

«Supervisory authority»: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR. In the case of Spain, it is the Spanish Data Protection Agency.

«Cross-border processing»: a) Processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or b) Processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.

«Information society service»: Any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.

3.- IDENTITY OF THE DATA CONTROLLER

The Data Controller is that natural or legal person, of a public or private nature, or administrative body, which alone or jointly with others determines the purposes and means of the processing of personal data; in the event that the purposes and means of the processing are determined by the Law of the European Union or of the Spanish Member State.

In the aspects expressed in this Privacy and Data Protection Policy, the identity and contact details of the Data Controllers are:


HOTEL SIRENAS SEGOVIA S.L. – NIF B40185290

  • CALLE JUAN BRAVO, 30. 40001, Segovia (Segovia), Spain
  • Email: enrique@recordishotels.com
  • Phone: 921 462 663

HOTEL INFANTA ISABEL S.L. – NIF: B40144693

  • CALLE ISABEL LA CATÓLICA, 1. 40001, SEGOVIA (Segovia), Spain
  • Email: infanta@recordishotels.com
  • Phone: 921 461 300

4.- APPLICABLE LAWS AND REGULATIONS

This Privacy and Data Protection Policy is developed based on the following data protection regulations and laws:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. Hereinafter GDPR.

Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights. Hereinafter LOPD/GDD.

Law 34/2002, of July 11, on Information Society Services and Electronic Commerce. Hereinafter LSSICE.

5.- PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

The personal data collected and processed through this Website will be treated in accordance with the following principles:

  • Principle of lawfulness, fairness, and transparency: All processing of personal data carried out through this Website will be lawful and fair, being completely clear to the user when the personal data concerning them are being collected, used, consulted, or processed. The information relating to the processing carried out will be transmitted in advance, easily accessible, and easy to understand, in simple and clear language.
  • Principle of purpose limitation: All data will be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Principle of data minimization: The data collected will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: The data will be accurate and, where necessary, kept up to date, taking all reasonable steps to ensure that personal data that are inaccurate with respect to the purposes for which they are processed are erased or rectified without delay.
  • Principle of storage limitation: The data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  • Principle of integrity and confidentiality: The data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
  • Principle of accountability: The entity owning the Website will be responsible for compliance with the principles set out in this section and will be able to demonstrate it.

6.- DATA PROCESSING ACTIVITIES

Below are the data processing activities carried out through the Website, specifying each of the following sections:

  • Activity: Name of the data processing activity
  • Purposes: Each of the uses and treatments that are made with the collected data
  • Legal basis: The legal basis that legitimizes the processing of the data
  • Data processed: Type of data processed
  • Source: Where the data is obtained from
  • Storage: Period during which the data is kept
  • Recipients: Third-party individuals or entities to whom the data is provided
  • International Transfers: Cross-border shipments of data outside the European Union

6.1 MAIN PROCESSING ACTIVITIES

These are data processing activities whose purposes are necessary and essential for the provision of services.

6.2 OPTIONAL PROCESSING ACTIVITIES (if the user has checked their acceptance)

These are personal data processing activities whose purposes are not essential for the provision of the service and that are only carried out if the user has given consent for these activities.

WEBSITE

6.2 OPTIONAL PROCESSING ACTIVITIES (if the user has checked their acceptance)

  • Legal bases: (Art. 6.1.a GDPR) Consent of the data subject
  • Purposes: E-commerce; Contact and commercial activities with clients; Management of potential clients and contacts; Management of web users; Management and response to inquiries received through the web contact form; Personnel selection; Newsletter subscription; Use of non-essential cookies; Processing of personal data from the use of a website
  • Categories of data and groups: Web contacts (Identifying data). E-commerce clients (Identifying data; Economic, financial and insurance data; Transactions of goods and services)
  • Data source: The data subject or their legal representative
  • Recipient categories: Not foreseen
  • International transfer: Not foreseen
  • Storage period: For a period of 1 year from the last confirmation of interest

7.- NECESSARY AND UPDATED INFORMATION

All fields marked with an asterisk (*) in the Website forms will be mandatory, such that the omission of any of them could lead to the impossibility of providing the requested services or information.

You must provide truthful information, so that the information provided is always up-to-date and contains no errors, you must communicate to the Data Controller as soon as possible, the modifications and rectifications of your personal data that occur through an email to the address: enrique@recordishotels.com.

Likewise, by clicking the “I accept” button (or equivalent) incorporated in the aforementioned forms, you declare that the information and data you have provided in them are accurate and true, as well as that you understand and accept this Privacy Policy.

8.- DATA OF MINORS

In compliance with the provisions of Article 8 of the GDPR and Article 7 of the LOPD/GDD, only those over 14 years of age may grant their consent for the processing of their personal data lawfully by HOTEL SIRENAS SEGOVIA S.L.

Therefore, children under 14 years of age may not use the services available through the Website without the prior authorization of their parents, guardians, or legal representatives, who will be solely responsible for all acts performed through the Website by the minors in their charge, including the completion of telematic forms with the personal data of said minors and the marking, where appropriate, of the boxes that accompany them.

9.- TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES

The Data Controller adopts the necessary organizational and technical measures to guarantee the security and privacy of your data, prevent its alteration, loss, treatment, or unauthorized access, depending on the state of technology, the nature of the stored data, and the risks to which they are exposed.

Among others, the following measures stand out:

  • Ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services.
  • Restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
  • Regularly test, assess, and evaluate the effectiveness of technical and organizational measures for ensuring the security of the processing. Pseudonymize and encrypt personal data, in the case of sensitive data.

On the other hand, the Data Controller has decided to manage the information systems according to the following principles:

  • Principle of regulatory compliance: All information systems will comply with the applicable legal, regulatory, and sectoral regulations that affect information security, especially those related to the protection of personal data, security of systems, data, communications, and electronic services.
  • Principle of risk management: Risks will be minimized to acceptable levels, seeking a balance between security controls and the nature of the information. Security objectives must be established, reviewed, and consistent with information security aspects.
  • Principle of awareness and training: Training programs, sensitization, and awareness campaigns will be articulated for all users with access to information, in matters of information security.
  • Principle of proportionality: The implementation of controls that mitigate the security risks of the assets will be carried out seeking a balance between the security measures, the nature of the information, and the risk.
  • Principle of responsibility: All members of the Data Controller will be responsible for their conduct regarding information security, complying with the established rules and controls.
  • Principle of continuous improvement: The degree of effectiveness of the security controls implemented in the organization will be reviewed on a recurring basis to increase the capacity to adapt to the constant evolution of risk and the technological environment.

10.- RIGHTS OF DATA SUBJECTS

Current data protection regulations protect the user in a series of rights in relation to the use given to their data.

Each and every one of these rights is personal and non-transferable, that is, they can only be carried out by the data owner, after verification of their identity.

Below are the rights of the Website users:

  • Right of access: It is the right that the Website user has to obtain confirmation of whether or not the Data Controller is processing their personal data and, if so, obtain information about their specific personal data and the processing that the data controller has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned for them.
  • Right to rectification: It is the right that the Website user has to have their personal data that prove to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
  • Right to erasure: It is often known as the “right to be forgotten,” and it is the right that the Website user has, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, will adopt reasonable measures to inform other possible controllers who are processing the personal data of the data subject’s request for the deletion of any link to that personal data.
  • Right to restriction of processing: It is the right of the Website User to limit the processing of their personal data. The Website User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs them to make claims; and when the Website User has objected to the processing.
  • Right to data portability: In those cases where the processing is carried out by automated means, the Website User will have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other Controller.
  • Right to object: It is the right of the User not to have their personal data processed or to have the processing of them ceased by the Data Controller.
  • Right not to be subject to automated individual decision-making, including profiling: It is the right of the Website User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.
  • Right to withdraw consent: It is the right of the Website User to withdraw, at any time, the consent given for the processing of their data.

The Website user can exercise any of the aforementioned rights by contacting the Data Controller and after identifying the User using the following contact information:

  • Controller: HOTEL SIRENAS SEGOVIA S.L.
  • Address: CALLE JUAN BRAVO, 30. 40001, Segovia (Segovia), Spain
  • Phone: 921 462 663
  • E-mail: realsegovia@recordishotels.com
  • Website: https://www.recordishotels.com

The Website user can exercise any of the cited rights by addressing the Data Controller and after identification of the User using the following contact information:

  • Controller: HOTEL INFANTA ISABEL S.L.
  • Address: CALLE ISABEL LA CATÓLICA, 1. 40001, SEGOVIA (Segovia), Spain
  • Phone: 921 461 300
  • E-mail: infanta@recordishotels.com
  • Website: http://www.hotelinfantaisabel.com

11.- RIGHT TO LODGE A COMPLAINT WITH THE SUPERVISORY AUTHORITY

The user is informed of their right to file a complaint with the Spanish Data Protection Agency if they consider that a violation of data protection legislation has been committed with respect to the processing of their personal data. Contact information of the supervisory authority:

  • Spanish Data Protection Agency
  • Email: info@aepd.es
  • Phone: 912663517
  • Website: https://www.aepd.es
  • Address: C/. Jorge Juan, 6. 28001, Madrid (Madrid), Spain

12.- ACCEPTANCE AND CHANGES TO THE PRIVACY POLICY

It is necessary that the Website user has read and agrees with the data protection conditions contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed with it in the manner, deadlines, and for the indicated purposes.

The Data Controller reserves the right to modify this Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change from the Spanish Data Protection Agency. Changes or updates made to this Privacy Policy that affect the purposes, storage periods, data transfers to third parties, international data transfers, as well as any right of the Website User, will be explicitly communicated to the user.