PRIVACY POLICY

PRIVACY POLICY

 

1- WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

 

The owner of the website  https://www.yurbbantrafalgar.com is SMART ROOMS COMPANY, S.L

 

The person responsible for the processing of your personal data in relation to the data you provide through our page and referring to your relationship with the Hotel Yurbban Trafalgar is the company SOGAMAN RESIDENCIAL, SLU, owner of the Hotel and which is registered in the Mercantile Registry. of BARCELONA to volume 41.290, page 54, sheet number B-379.951, 1st registration with CIF B-65120453 and address at Calle Trafalgar, 30, 08010 Barcelona (hereinafter Yurbban Trafalgar)

 

YURBBAN TRAFALGAR has taken the necessary technical and organizational measures to comply with data protection regulations.

The contact details of YURBBAN TRAFALGAR, in relation to privacy and the protection of your personal data are:

 

 

 

 

 

+34- 932 68 07 27

 

 

 

gdpr@smartroomscompany.com        

 

2- WHAT TYPE OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSE?

1- Types of personal data we process

For reasons of confidentiality, we collect the least amount of data possible from our clients, beyond what they provide us voluntarily or what the Law obliges us to collect and keep in the case of reservations made through reservation engines.

We may collect and process the following categories of personal data:

 

a. Name, title, gender.

 

b. Your contact details and address, the telephone number if you make a reservation at our establishment by phone and leave it to us, your email address if you make a reservation to us from your email or those data required by the booking engine to make a reservation. Information and date of your reservation, information about your stay and preferences, as well as your credit card information. In the case of making a reservation electronically, we may request a copy of your identification document to verify the veracity of your identity. Your image will only be used for these purposes and will only be kept for the time strictly necessary. Once you leave our establishment, the system will delete the copy of the identity document immediately.

 

c. In the case of our employees, identification data, social security data, bank data and all that are necessary for the development of the employment relationship.

d. Identification data of our suppliers of their contact persons in the case of being companies.

 

d. We record your communications with us by email or other means. When you make a telephone communication, our customer service may record your questions in our database.

e. Information collected when you use our website, and other digital media, if applicable.

 

When you use our website we may record your IP address, browser type, operating system, website of origin, and web browsing behavior.

F. Information related to social networks.

 

Depending on your social network settings we may receive information from your social network provider. For example, when you sign in with a social network account to use our services, we may receive your social network profile including contact details, interests and contacts. For more information on the personal data we receive from your social network provider and how to change your settings, please refer to your social network provider's website and privacy policy.

 

g. Information you choose to share with us.

 

You can choose to share information with us, for example, by adding a comment on LinkedIn, Facebook.

 

h. In the event that you connect to the TV that you can find in any of our rooms, we will request your ID so that your browsing history will be recorded.

 

i Images captured by our video surveillance cameras inside our establishment.

 

 

2- Your personal data will only be used for the following purposes:

a. Register you in our database if you make a reservation at our Hotel or hire our services.

b. Carry out the necessary commercial and administrative procedures with the users of our website and our clients or potential clients.

 

c. At YURBBAN we process the information you provide us with in order to respond to the request for information that you send us, provide you with information about our services, manage our reservations or services, as well as comply with the obligations arising from said activities.

 

d. Send commercial advertising communications such as our newsletter by email, social networks or any other electronic or physical means, in case you have expressly consented to the sending of said commercial communications electronically. In the event that you have contracted our services, we may send you commercial information, news or news related to our services without requiring your prior consent.

 

e. Communicate with you to answer your queries and process your complaints.

 

F. Communicate with you to obtain your opinion about the quality of our services or the treatment received.

 

g. Likewise, the data collected during your browsing is processed with the aim of providing access to the online content of the web, as well as responding to the requests of web users, keeping a record of visit statistics (IP addresses, data from the browser, country, page accessed, etc.) in order to make it easier for us to develop better services and products, optimize our offer and provide a more efficient customer service and improve the design and content of our websites.

 

h. The data of our clients and suppliers will be processed, within the contractual relationship that links them with us, in compliance with the administrative, fiscal, accounting and labor obligations that are necessary under current legislation and, where appropriate, in compliance of the citizen security law.

 

i. Comply with the legal obligations that correspond to us.In accordance with the LSSICE, YURBBAN TRAFALGAR does not carry out SPAM practices, therefore, it does not send commercial emails if it does not have the necessary legitimacy. In any case, you will always have the possibility to withdraw your consent to receive our communications.

 

We will not process your personal data for any other purpose than those described in this Policy, except by legal obligation or judicial requirement.

 

Your personal data will not be the object of decisions based on automated treatments that produce effects on you.

 

 

3- WHAT IS THE LEGAL BASIS THAT LEGITIMATES THE PROCESSING OF YOUR DATA?

 

The legal basis that legitimizes the processing of your personal data is your express consent granted to carry out the purposes described above, which will be requested at the time you request information from us.

In the event of a commercial relationship between you, either as a customer or as a supplier, and YURBBAN TRAFALGAR, the legal basis that will legitimize the processing of your personal data will be the execution of the contractual relationship that will have been generated.

Comply with the legal obligations that correspond to us.

Sometimes the processing of your personal data will be legitimized by our own legitimate interest.

The legal basis that legitimizes the treatment of the images recorded by our video surveillance cameras is our legitimate interest in maintaining the security of our facilities.

If you do not provide us with your personal data or if you do not accept our privacy policy, YURBBAN TRAFALGAR will not process your personal data, but it may also make it impossible for us to send you information, or, in your case, that we provide our services.

 

Commercial information.

 

Any communication sent will be incorporated into the information systems of YURBBAN TRAFALGAR.

In the event that you provide us with your personal data and accept this privacy policy, we inform you that YURBBAN TRAFALGAR may carry out the following activities and/or actions, unless otherwise indicated:

 

- The sending of commercial and/or promotional communications corresponding to the answer to your request for information by any means. The legal basis that will legitimize this treatment is your express consent granted when you voluntarily make the request.

 

- The sending of any information, including commercial information on news, news, etc. and all information related to our activities or the services contracted by our clients. The legal basis that legitimizes this treatment is our legitimate interest within the commercial relationship established with you.

 

Objection or revocation. You can object or withdraw your consent to receive marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us via gdpr@smartroomscompany.com  

CVs

In the event that the user sends his CV to YURBBAN, we inform him that the data provided will be processed to make him a participant in the selection processes that may exist, carrying out an analysis of the applicant's profile in order to select the best candidate. for the vacant place in YURBBAN. We inform you that we will only accept your CV if you send it to us electronically, so that CVs sent or delivered on paper will not be accepted. In the event of any change in the data, please notify us in writing as soon as possible, in order to keep your data duly updated.

We inform you that your CV and the data it contains will be kept for a maximum period of one year, after which the data will be deleted, guaranteeing total confidentiality both in the treatment and in its subsequent destruction. In this sense, once the aforementioned period has elapsed and, if you wish to continue participating in the YURBBAN selection processes, please send us your updated CV again.

However, if you are hired by YURBBAN, your CV will be kept, together with the rest of your employment file, while your contractual relationship with the corresponding Company that hired you is maintained.

4- CONSERVATION PERIOD How long will we keep your data?

The personal data that you provide us will be kept for the time necessary to manage the information you request, as well as to manage your reservations or the provision of our services or the fulfillment of any contract that is generated between YURBBAN TRAFALGAR and third parties.

 

In the event that we have your identification data in our database for the sending of commercial information, they will be kept as long as the necessary legal basis that legitimizes their conservation and use is maintained. You may cancel your data at any time in order not to receive commercial information.

 

The images recorded by our video surveillance cameras will be kept for 30 days, unless at the request of the police or judicial authority they must be kept for a longer time. In these cases they will be kept properly blocked.

 

Once the data has met the needs for which it was collected, we will permanently delete it. However, we will keep your data for longer in case it is necessary to comply with legal obligations. Likewise, it may be necessary to keep them for the time necessary for the prescription of the legal responsibilities that are generated.

 

The data you provide us to start a selection process will be kept for a maximum period of one year. Subsequently, if you have not joined YURBBAN TRAFALGAR or are not in a selection process, they will be eliminated and we will not keep a copy.

 

The personal data of our workers will be kept for the duration of their employment relationship with YURBBAN TRAFALGAR and, subsequently, during the legally established periods.

 

5- TO WHICH RECIPIENTS WILL YOUR DATA BE COMMUNICATED?

 

Within our organization your personal data will be processed by duly authorized personnel, and, if necessary or practical to comply with the purposes indicated above, they may be processed by third parties.

 

The categories of recipients to whom your personal data may be communicated are the following:

 

a. Appointed third party processors, such as IT providers, consultants and advisers and other companies providing ancillary services.

b. Social network providers.

c. Public Entities and Organizations, exclusively for the purpose of complying with the corresponding legal obligations.

d. Other providers to whom, where appropriate, your personal data may be transferred, such as financial institutions, fraud detection service providers, etc.

e. When necessary for operational reasons, with SMART ROOMS CORPORATION and its group of companies, or the SOGAMAN GROUP, companies with which we share administration and direction.

F. Third Party Websites. Our websites may link to third party websites. If you follow these links, you will leave our website or mobile applications. This privacy policy does not apply to third party websites. YURBBAN TRAFALGAR declines any responsibility for the use of third parties of your personal data. The use of these websites is done under his own responsibility.

 

In any case, all the aforementioned third parties will have previously signed the corresponding confidentiality agreement following our instructions in accordance with current personal data protection regulations, will be subject to the duty of professional secrecy or will act in compliance with a legal obligation. .

 

The information that you provide us both through this website will be hosted on YURBBAN TRAFALGAR servers.

 

6.- WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

 

 

If you wish to exercise the rights that the data protection regulations grant you, please send us an email to the following address gdpr@smartroomscompany.com, putting the right you wish to exercise in the subject line and attaching a copy of your national identity document or passport.

 

The Rights that the current regulations recognize and that, where appropriate, you can exercise are:

 

Right of Access to data:

 

You have the right for YURBBAN TRAFALGAR to notify you whether or not your personal data is being processed, and if the processing is confirmed, it will allow your access by providing you with the following information:

-The purposes of the treatment.

-The categories of data in question.

-The term or criteria for data conservation.

Right to rectify data:

 

You will have the right for YURBBAN TRAFALGAR to rectify your data when they are inaccurate or incomplete by means of an additional rectifying statement.

 

Right of Deletion of the data:

 

The interested party will have the right for YURBBAN TRAFALGAR to delete their data, when:

-The processing is unlawful.

-The interested party has withdrawn their consent.

-They are no longer necessary in relation to the purposes for which they were collected or processed.

-The interested party has exercised the right of opposition and other legitimate reasons for the treatment do not prevail.

-The data must be deleted to comply with a legal obligation of YURBBAN TRAFALGAR.

 

The interested party will not have the right for YURBBAN TRAFALGAR to delete their data when the treatment is necessary:

-To exercise the right to freedom of expression and information.

-To comply with a legal obligation of YURBBAN TRAFALGAR.

-For the formulation, exercise or defense of claims.

-For public interest based on current legislation for reasons of public health or for purposes of historical, statistical or scientific research.

 

Data Portability Right:

 

You have the right for YURBBAN TRAFALGAR to transmit your data to another data controller or to the same interested party, through a structured format of habitual use and mechanical reading, when the treatment is carried out by automated means and is based on:

-The consent of the interested party for specific purposes.

-The execution of a contract or pre-contract with the interested party.

 

The right to data portability will not apply when:

-The transmission is technically impossible.

-May negatively affect the rights and freedoms of third parties.

-The treatment has a mission of public interest based on current legislation.

 

Right to Limit Treatment:

 

The interested party will have the right to oppose the processing of your data by YURBBAN TRAFALGAR for reasons related to your particular situation, when the processing is based on:

  -Direct marketing.

-Elaboration of profiles.

-Legitimate interest of the person in charge or third parties, provided that the interests or rights and freedoms of the interested party do not prevail, especially if he is a child.

-Historical, statistical or scientific research, unless the treatment is necessary for reasons of public interest.

 

Even if the interested party opposes the processing of your data, YURBBAN TRAFALGAR may continue to process them as long as their legitimate interest prevails over the interests or rights and freedoms of the interested party in a legal proceeding that justifies it.

YURBBAN TRAFALGAR must inform the interested party of the right to oppose the processing of your data in an explicit, clear and separate way from any other information, at the time of the first communication.

 

Opposition right:

 

It is the right not to carry out the treatment of these or to cease it when your consent for the treatment is not necessary, due to the concurrence of a legitimate and well-founded reason, referring to your specific personal situation, that justifies it. , and provided that a Law does not provide otherwise.

 

Right not to be subject to profiling:

 

The interested party shall have the right not to be subject to profiling whose purpose is to make individual decisions based on automated data processing and aimed at evaluating, analyzing or predicting the following personal aspects:

 

-Professional performance.

-Economic situation.

-Health.

-Preferences or personal interests.

-Reliability.

-Behavior.

-Location or movements of the person.

 

When profiling is based solely on automated processing:

 

-The interested party shall have the right to be informed if the decision that may be taken may produce legal effects that significantly affect him.

 

-The interested party will have the right to obtain human intervention by YURBBAN TRAFALGAR, to express their point of view and to challenge the decision, if the treatment has been

authorized by:

-The explicit consent of the interested party.

 

-A contract between YURBBAN TRAFALGAR and the interested party.

 

It will not apply to the right not to be subject to profiling when the decision that can be taken as a result of this is authorized by:

 

-The explicit consent of the interested party.

-A contract between YURBBAN TRAFALGAR and the interested party

.

-Un tratamiento fundamentado en la legislación vigente.

 

7- CLAIM BEFORE THE CONTROL AUTHORITY:

 

In the event that you consider that YURBBAN TRAFALGAR has violated any of your rights protected by the personal data protection regulations or that it has violated any obligation regarding the protection of Personal Data, you have the right to file a claim with the control authority. competent authority that in Spain is the Spanish Data Protection Agency located at Calle Jorge Juan, 6. 28001 – Madrid.

Tel. 901 100 099 - 912 663 517

 

You can also file an electronic claim through the electronic office that is available on your website https://www.aepd.es  

 

8-LEGISLACIÓN Y JURISDICCIÓN

 

This privacy policy is governed in each and every one of its extremes by 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 to the processing of personal data and the free movement of such data.

 

It is also governed by Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights. Likewise, our website is governed by Law 34/2002, of July 11, on services of the information society and electronic commerce.

 

The Users of this Website are subject to Spanish legislation and jurisdiction to which they expressly submit, with the Courts and Tribunals of BARCELONA being competent to resolve all disputes arising from or related to its use.

 

 

9- ADDITIONAL INFORMATION

 

-SOCIAL NETWORKS (PRIVACY POLICY)

 

We inform you that YURBBAN TRAFALGAR may have a presence on social networks. The treatment of the data that is carried out of the people who become followers in the social networks (and/or carry out any link or connection action through the social networks) of the official pages of YURBBAN TRAFALGAR will be governed by this section, as well as those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and previously accepted by the user.

YURBBAN TRAFALGAR will process your data for the purpose of correctly managing your presence on the social network, informing you of the provider's activities, products or services, as well as for any other purpose that the regulations of Social Networks allow.

 

The publication of content is prohibited:

- That they are allegedly illegal by national, community or international regulations or that they carry out allegedly illegal activities or contravene the principles of good faith.

 

- That violate the fundamental rights of people, lack of courtesy in the network, annoy or may generate negative opinions in our users or third parties and in general whatever the content that YURBBAN TRAFALGAR deems inappropriate.

 

- And in general that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of private life, consumer protection and intellectual and industrial property rights.

 

Likewise, YURBBAN TRAFALGAR reserves the right to withdraw, without prior notice from the website or the corporate social network, those contents that are considered inappropriate.

The communications sent through social networks will be incorporated into a file owned by YURBBAN TRAFALGAR, being able to send you information of interest.

 

You can access more information, as well as consult the companies that are part of our group, in this privacy policy.

 

In any case, if you send personal information through the social network, YURBBAN TRAFALGAR. will be exempt from liability in relation to the security measures applicable to this platform, and the user should, in case he wants to know them, consult the corresponding particular conditions of the network in question.

 

SECURITY MEASURES:

 

The data you provide us will be treated confidentially. YURBBAN TRAFALGAR has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the treatment of the data and to avoid its alteration, loss, theft, treatment or unauthorized access, according to the state of the technology and nature of the data stored. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in current regulations.

 

SSL CERTIFICATE (SECURE SOCKETS LAYER)

 

The SSL CERTIFICATE provides authentication, privacy and security of information between YURBBAN TRAFALGAR and the user. YURBBAN TRAFALGAR has a security certificate that is used to make secure connections and is established using preset keys, encoding and decoding all data sent until the connection is closed.

 

LANGUAGE

 

The language applicable to this Privacy Policy is Spanish. Therefore, in case there is any contradiction in any of the versions provided in other languages, the Spanish version will prevail.

 

10-UPDATE

 

This Privacy Policy was last updated in January 2023 but may be updated at any time. We recommend that you consult it each time you access our page in case it has been altered.