Privacy and data protection policy

Your trust is important to us and we are committed to protecting the privacy and security of your personal information. The information that is shared with us helps us provide a great experience with Arenal Suites. We have a privacy team committed to protecting all personal information we collect and helping to ensure that personal information is handled correctly throughout the world. Thank you for using Arenal Suites!

Respecting the provisions of current legislation, Arenal Suites undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

This Privacy Policy describes the way in which we collect, use, process and disclose your personal information, along with your access data to the Arenal Suites Platform and Payment Services and their use thereof. This Privacy Policy describes our practices to protect privacy with respect to all websites, platforms and services that link to it. Please read the privacy policy on the corresponding site.

Laws that incorporate this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it respects the following standards:

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

• Organic Law 15/1999, of December 13, on the Protection of Personal Data (LOPD).

• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data.

Responsible for the processing of personal data collected at www.arenalsuites.com is: INVERSIONES SUAPO S.A. provided with NIF: A-86924875, who holds the ownership of the ARENAL SUITES brand (hereinafter Arenal Suites).

Address:
C / ARENAL, 8 PLANT 3 28013, MADRID (SPAIN)
Contact phone: 91 1212441
Contact email: info@arenalsuites.com

Registration of Personal Data

The personal data collected by Arenal Suites, through the forms extended on its pages, will be entered in an automated file under the responsibility of Inversiones Suapo SA, which undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to facilitate, expedite and fulfill the commitments established between Arenal Suites and the User or the maintenance of the relationship established in the forms that it completes, or to meet a request or query thereof.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set forth in Article 5 of the GDPR:

• Principle of legality, loyalty and transparency: the consent of the User will be required at all times prior completely transparent information of the purposes for which personal data is collected.

• Principle of limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes.

• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.

• Principle of accuracy: personal data must be accurate and always updated.

• Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of their treatment.

• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.

• Principle of proactive responsibility: Arenal Suites of the treatment will be responsible for ensuring that the above principles are met.

Data you provide us.

Information needed to use the Arenal Suites Platform.

We request and collect the following personal information about you when using the Arenal Suites Platform. This information is necessary for the correct execution of the contract between you and us and allows us to fulfill our legal obligations. Without that information, we may not be able to provide all requested services.

• Account information. When registering to have an Arenal Suites Account, we require certain information such as your first name, last name, email address and date of birth.

• Profile Information. To use certain functions of the Arenal Suites Platform (such as booking), we may ask for additional information, which may include your address, telephone number and a profile picture.

• Identity Verification. Information To help create and maintain a trustworthy environment, we may collect information to verify your identity (such as photographs of your identification document issued by the Government, passport, national identity document or driving license, to the extent permitted. applicable law) or other authentication data.

• Payment information. To use certain functions of the Arenal Suites Platform (such as booking), we may ask you for some financial information (such as your bank account or credit card information) in order to process payments (via Stripe).

• Communications with Arenal Suites and other Members. By contacting Arenal Suites or using the Arenal Suites Platform to communicate with other Members, we collect information about these communications and any data you choose to provide.

Information you voluntarily provide.

You can provide us with additional personal data to obtain a better user experience when using the Arenal Suites Platform. This additional information will be processed based on our legitimate interest or, where appropriate, with your consent.

• Additional profile information. You may provide additional information as part of your Arenal Suites profile (such as your gender, preferred language (s), city and personal description). Some of this information, as indicated in your Account settings, is part of your public profile page and will be publicly visible.

• Calendar contact information. You can choose to import contacts from your calendar or specify the information of your contacts manually in order to access certain functions of the Arenal Suites Platform, such as encouraging them to use Arenal Suites.

• Other information. You can choose to provide us with information by filling out any form, doing a search, updating or adding information to your Arenal Suites Account, answering surveys, posting in community forums, participating in promotions, communicating with our customer service team, sharing your Experience with us or use other features of the Arenal Suites Platform.

Information necessary for the use of Payment Services.

The Person Responsible for the Treatment of Payment Data needs to collect the following data necessary for the proper execution of the contract entered into with you and for compliance with the applicable legislation (such as regulations for the prevention of money laundering). Without this information, you will not be able to use the Payment Services:

• Payment information. When using the Payment Services, the Person Responsible for the Treatment of Payment Data will require certain financial data (such as your bank account or credit card information) to process payments and comply with applicable legislation.

Information that we collect automatically from your use of the Arenal Suites Platform and Payment Services.

When you use the Arenal Suites Platform and Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the correct execution of the contract between you and us, for the fulfillment of our legal obligations and given our legitimate interest in being able to provide and improve the functions of the Arenal Suites Platform and Payment Services.

• Geographic location data. By using certain features of the Arenal Suites Platform, we may collect information about your precise or approximate location from data such as your IP address or the GPS of your mobile device to offer you a better user experience. Most phones allow you to control or disable the use of location services for applications in the device settings menu. Arenal Suites may also collect this information when you are not using the application if location services are activated in the settings menu or in the permissions of your device.

• Usage Information. We collect information about the interactions you have with the Arenal Suites Platform, such as the pages or other content you view, the searches for Ads you make, the reservations you have made and other actions carried out on the Arenal Suites Platform .

• Registration data and information about your device. We automatically collect registration and device information each time you access and use the Arenal Suites Platform, even if you have not created an Arenal Suites Account or accessed it. This information includes, among other information, details about how you have used the Arenal Suites Platform (including if you clicked on links to third-party applications), IP address, dates and times of access, hardware and software information, information of device, information of device events, unique identifiers, data on blockages, data on cookies and the pages you have viewed or with which you interacted before or after using the Arenal Suites Platform.

• Cookies and similar technologies. We use cookies and other similar technologies when you use our platform, use our mobile application or participate in our online advertisements or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs and mobile identifiers. In most cases, the information we collect using cookies and other tools is only used in an unidentifiable way without reference to personal information. For example, we may use the information we collect to better understand website traffic patterns and to optimize the experience of our website. In some cases, we associate the information we collect through the use of cookies and other technologies with your personal information. Our business partners can also use these tracking technologies on the Arenal Suites platform or hire others to track their behavior on our behalf.

• Pixels and SDK. Third parties, including Facebook and Twitter, may use cookies, web beacons and other storage technologies to collect or receive information from our websites and other Internet sites and use that information to provide measurement services and advertisements of interest. In the case of applications, third parties, including Facebook and Twitter, may collect or receive information from your application and other applications and use it to provide measurement services and advertisements of interest. Users can choose not to participate in the collection and use of information for ad targeting by updating the configuration of their Facebook account ads and contacting info@arenalsuites.com by providing a description of their request and the validation information For more information about our use of these technologies, see our Cookies Policy.

• Do not track signals. You can disable the use of cookies through the browser settings.

• Transactional Information Stripe collects information regarding its payment transactions made through the Arenal Suites Platform, including the payment instrument used, the date and time, the payment amount, the expiration date of the payment instrument and the postal code of billing, email address, IBAN code, your address and other transactional data. These data are necessary for the correct execution of the contract between you and us and for the provision of Payment Services.

Data of minors.

Our websites and applications are not directed to children under 16 and we do not collect any personal information directly from those under 16. If you believe that we are treating a minor's personal information inappropriately, we will take it very seriously and urge you to contact us using the information provided in the “Contact” section below.

Examples of personal information we collect on our website:

• The Internet IP address you use to connect to the Internet with your computer or other device;

• Username, email address and password of your account;

• Information about your computer, device and your Internet connection such as the application of the device or the version and type of your browser, the types and versions of your browser connection, the operating system or time zone settings;

• The location of your device or computer;

• Telephone numbers used to call our customer service.

• We may also use device identifiers, cookies and other technologies in devices, applications and our web pages to collect browsing data, use or other technical information for fraud prevention purposes. For more information on this point, see Cookies Policy.

• In no case, special categories of personal data are treated within the meaning of Article 9 of the GDPR.

How we collect the information.

We may use, store and process personal information to:

• Provide, understand, improve and develop the Arenal Suites Platform.

• Create and maintain an environment of trust and confidence (eg to comply with our legal obligations and ensure compliance with the Arenal Suites Policies).

• Provide, customize, measure and improve our advertising and marketing.

• Provide, improve and develop the Arenal Suites Platform. We may use personal information to provide, improve and develop the Arenal Suites platform, for example:

  • Allow you to access the Arenal Suites Platform and use it.

  • Allow you to communicate with other Members.

  • Direct, protect, improve and optimize the Arenal Suites Platform and the experience of Arenal Suites, for example, through analysis and research.

  • Provide customer service.

  • Send you messages about the service or support, such as updates, security alerts and account notifications.

  • If you provide us with the information of your contacts, we can process this information: 1) to facilitate your invitations by recommendation; 2) to send your requests for references; 3) to carry out detection and prevention of fraudulent activities; 4) and for any purpose you authorize at the time of collection.

    We process this personal information for these purposes in view of our legitimate interest in improving the Arenal Suites Platform and the experience of our Members in it, and whenever necessary for the proper execution of the contract entered into with you.

• Create and maintain an environment of trust and with better security conditions. We may use personal information to create and maintain a trustworthy and more secure environment, such as:

  • Detect and prevent fraud, spam, insults, security incidents and other harmful acts.

  • Conduct safety investigations and risk assessments.

  • Verify or authenticate information or identifications that you have provided (eg, to verify your Accommodation address or compare the photo that identifies you with another photo you provide).

  • Check with databases and other sources of information, including criminal and police background checks, to the extent permitted by applicable law and subject to your consent, where appropriate.

  • Comply with our legal obligations.

  • Resolve any dispute arising with any of our Members and demand compliance with our contracts with third parties.

  • Demand compliance with our Terms of Service and other policies, and in relation to the preceding activities, we may analyze the interactions you make with the Arenal Suites Platform, your profile information and any other content that you submit to the Arenal Platform Suites, as well as information obtained from third parties. In certain cases, automated processes may restrict or suspend your access to the Arenal Suites Platform if such processes detect an activity that may pose a security or other risk to the Arenal Suites Platform, our community or third parties. If you dispute the decision based on the automated process, contact us as indicated in the “Contact” section below.

  We process this personal information for these purposes in view of our legitimate interest in protecting the Arenal Suites Platform, to assess the correct execution of the contract entered into with you and to comply with the applicable legislation.

• Provide, customize, measure and improve our advertising and marketing. We may use personal information to provide, customize, measure and improve our advertising and marketing and power, as follows:

  • Send you promotional messages, marketing content, advertising and other information that may interest you based on your preferences (including information regarding Arenal Suites or campaigns and partner services), as well as advertising through social communication platforms such as Facebook, Twitter or Google.

  • Customize, measure and improve our advertising.

  • Manage recommendation programs, prizes, surveys, sweepstakes, contests or other promotional activities or events sponsored or managed by Arenal Suites or by our Third Business Partners.

  • Outline your characteristics and preferences (from the information you provide us, your interactions with the Arenal Suites Platform, the information obtained from third parties and your search and reservation history) to send you promotional, marketing or advertising messages, as well as other information that we consider may be of interest.

  • Signing up for an email subscription will not affect the frequency of administrative emails we may send in relation to any Arenal Suites account. No fee is charged for sending promotional emails, but third-party data rates may apply. Please note that you may not be able to benefit from certain promotions if you do not have an Arenal Suites account, and invite you to relevant events and opportunities.

We will treat your personal information for the purposes set out in this section in view of our legitimate interest in conducting marketing activities to offer you products or services that may be of interest to you.

How the Responsible for the Processing of Payment Data uses the information collected.

We may use personal information as part of the Payment Services for, for example:

• Allow you to access the Payment Services and use them.

• To detect and prevent fraud, abuse, security incidents and other harmful activities.

• To carry out safety investigations and risk assessments.

• Make checks with databases and other sources of information.

• To comply with its legal obligations (such as money laundering prevention regulations).

• To apply the Payment Terms and other payment policies.

• Send you promotional, marketing, advertising and other information that may be of interest to you based on your preferences, as long as you have given your consent to do so. You will have the right to withdraw such consent at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.

The Person Responsible for the Processing of Payment Data processes this information in view of his legitimate interest in improving Payment Services and the experience of its users with them, and to the extent necessary for the proper execution of the contract entered into with you. , as well as to comply with applicable legislation.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Arenal Suites undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent will not condition the use of the Website.

In the occasions in which the User must or can provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.

Customer service: We consider that we have a legitimate interest to attend to the requests or queries that you raise through the various existing means of contact. We understand that the processing of this data is also beneficial for you as it allows us to properly assist you and resolve the questions raised. When you contact us, in particular, for the management of incidents related to the product purchased through the Platform, the treatment is necessary for the execution of the sales contract. When your query is related to the exercise of the rights on which we inform you below, or with claims related to our products or services, what legitimizes us to process your data is the fulfillment of legal obligations on our part.

Marketing: The legitimate basis for treating your data for marketing purposes is the consent you give. As an example, when you agree to receive personalized information through various means, when you authorize the sending of newsletters, or when you accept the legal bases to participate in a promotional action.

You can choose the promotional messages you wish to receive.

• You can limit the information you provide to Arenal Suites. Participation in promotions and marketing programs is voluntary.

• You can limit the communications that Arenal Suites sends you.

• To unsubscribe from marketing emails, just send an email to the address info@arenalsuites.com with the text "unsubscribe".

• To revoke the permissions you have given to send promotional text messages, type REVOKE in response to any message.

• Please note that even if you decide to unsubscribe from marketing communications, we may have to contact you to provide important information about your account transactions. For example, even if you unsubscribe from emails, we may send you activity confirmations or fraud alerts.

Development, fulfillment and execution of the contract: The processing of your data is necessary for the execution of the contract that links us with you. We understand that the processing of this data is positive for all parties involved when payment of a purchase occurs and in particular for you as it allows us to establish the appropriate measures in order to protect you against fraud attempts made by third parties.

Purposes of the treatment to which the personal data are destined

The personal data are collected and managed by Arenal Suites in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fill out or to attend a request or inquiry.

Likewise, the data may be used for a commercial, personalization and operational purpose, and activities of the corporate purpose of Arenal Suites, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well how to improve the quality, operation and navigation of the Website.

When the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Periods of retention of personal data

The personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only during the following period: 3 years, or until the User requests its deletion.

When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The personal data of the User will be shared with the following recipients or categories of recipients:

• Public Agencies, Tax Agency, Judges and Courts and, in general, competent Authorities, when Arenal Suites has a legal obligation to facilitate them.

• Google LLC, with address at 1600 Amphitheater Parkway, 94043, Mountain View (California), United States, which provides GSuite services, consisting of cloud computing and email services.

  You can check the privacy policy and other legal aspects of this company at the following link: https://www.google.com/intl/en/policies/privacy/

  Google participates and has certified its compliance with the framework of the agreement between the US. and the European Union called Privacy Shield, having undertaken to submit all personal information received from member countries of the European Union to the principles derived from the Privacy Shield.

  You can get more information about the Privacy Shield on the website of the US Department of Commerce: https://www.privacyshield.gov/welcome

  You can also check the accession of Google to the Privacy Shield in the following link: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

• Facebook Ireland, Ltd. domiciled at 4 Grand Canal Square Grand Canal Harbor Dublin 2, Ireland. You can consult the privacy policy and other legal aspects of said company in the following link: https://www.facebook.com/privacy/explanation. Facebook participates and has certified its compliance with the framework of the agreement between the US. and the European Union called Privacy Shield, having undertaken to submit all personal information received from member countries of the European Union to the principles derived from the Privacy Shield.

  You can get more information about the Privacy Shield on the website of the US Department of Commerce: https://www.privacyshield.gov/welcome

• Apart from the previous data communications, Arenal Suites has the collaboration of some third party service providers that have access to your personal data and that treat the aforementioned data in the name and on behalf of Arenal Suites as a result of their provision of services. Some examples are:

  • Financial entities.

  • Technology service providers.

  • Tax advice to bill services.

Arenal Suites follows strict criteria for the selection of service providers in order to comply with their data protection obligations and undertakes to sign with them the corresponding data processing contract through which it will impose, among others, the following obligations: apply appropriate technical and organizational measures; treat personal data for the agreed purposes and only following the documented instructions of Arenal Suites; and delete or return the data to Arenal Suites once the provision of services ends.

In the event that Arenal Suites of the treatment intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the intention to transfer the data, as well as the existence or absence of a decision of adequacy of the Commission.

Secrecy and security of personal data

Arenal Suites undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in a way that guarantees the security of personal data and prevents the destruction, loss or accidental alteration or Illicit personal data transmitted, preserved or otherwise treated, or unauthorized communication or access to such data.

However, because Arenal Suites cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, Arenal Suites of the treatment undertakes to notify the User without undue delay when a violation occurs of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the GDPR, it is understood as a violation of the security of personal data any breach of security that causes the accidental, unlawful or unlawful destruction, loss or alteration of personal data transmitted, kept or otherwise treated, or unauthorized communication or access to such data.

The personal data will be treated as confidential by Arenal Suites of the treatment, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the information.

Rights derived from the processing of personal data

The User has about Arenal Suites and may, therefore, exercise the following rights recognized in the GDPR before the Data Controller:

• Right of access: It is the right of the User to obtain confirmation of whether or not Arenal Suites is treating their personal data and, if so, to obtain information about their specific personal data and the treatment that Arenal Suites has performed or performed, as well as, among other, of the available information on the origin of said data and the recipients of the communications made or planned of the same.

• Right of rectification: It is the right of the User to modify their personal data that prove to be inaccurate or, taking into account the purposes of the treatment, incomplete.

• Right of deletion ("the right to be forgotten"): It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or treated; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; personal data has been treated illegally; personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years old. In addition to deleting the data, Arenal Suites of the treatment, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the interested party's request to delete any link to that personal data

• Right to limit the processing: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when he challenges the accuracy of his personal data; the treatment is illegal; Arenal Suites of the treatment no longer needs personal data, but the User needs it to make claims; and when the User has opposed the treatment.

• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive dArenal Suites from processing their personal data in a structured format, for common use and mechanical reading, and to transmit them to another responsible of treatment Whenever technically possible, Arenal Suites of the treatment will directly transmit the data to that other person in charge.

• Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease the processing of them by Arenal Suites

• Right not to be the subject of a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless the current legislation establishes otherwise.

Thus, the User may exercise their rights through written communication addressed to the Data Controller with the reference "GDPR ARENAL SUITES",

• Name, surname of the User and copy of the ID. In cases where the representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the DNI may be substituted, by any other means valid in law that proves the identity.

• Request with the specific reasons for the request or information that you want to access.

• Address for the purpose of notifications.

• Date and signature of the applicant.

• Any document that accredits the request you make.

Links to third party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Arenal Suites, and therefore are not operated by Arenal Suites The owners of such websites will have their own data protection policies, being themselves , in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of the regulations in force in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Agency for Data Protection (http://www.agpd.es).

Acceptance and changes in this privacy policy

It is necessary that the User has read and is in accordance with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he accepts the processing of his personal data so that Arenal Suites of the treatment can proceed to it in the form, during the deadlines and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Arenal Suites reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will be explicitly notified to the User.

This Privacy Policy was updated on 06/05/2019 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to processing of personal data and the free circulation of this data (GDPR).

For the drafting of this privacy policy, Arenal Suites has contracted the services of RUBIO FUENTES JM SL, (legal consultant specializing in internet law, new technologies, e-commerce and data protection) with NIF B05506993 and registered office at Calle Isidoro of deer 10, entlo. Left CP: 30001 of Murcia.