WEBSITE PRIVACY POLICY

Last updated: January 2022

This privacy policy applies to the website at https://www.thbhotels.com.

Please read it carefully as it contains important information about how your personal details are processed and your rights pursuant to the regulations in force in this area.

We reserve the right to update our privacy policy at any time on the grounds of corporate decisions or to comply with any possible changes in legislation or case law. If you have any queries or require clarification regarding our privacy policy or your rights, you may contact us via any of the channels stipulated below.

You are hereby stating that the details you provide us with now or in the future, are correct and accurate and undertake to inform us of any modifications thereto. In the event that you provide personal details of third parties, you undertake to obtain their prior consent and to inform them of the contents of this policy.

As a general rule, the fields on our form that are marked as compulsory, must be duly completed in order to enable us to process your requests.

1. Who is responsible for processing your data? The details of the controller responsible for the personal details collected on this website are given below:

Controller: TURISMO Y HOTELES DE BALEARES, S.L.
Tax ID Code: C.I.F: B-57189110
Postal address: Vía Alemania 14, 6º, 07458 Can Picafort, Balearic Islands (Spain)
Tel: + 34 971 850033
email: [email protected]

When you make a booking at one of our hotels, the controller of the corresponding data shall be the entity detailed above. The identification details of these entities are given below:

HOTEL GRAN PLAYA S.L.U. (Hotel THB Gran Playa)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. B07011372

[email protected]

SIBU S.A (Hotel THB Gran Bahía)
Registered Office Address: C/ Almirante Cervera, 1, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07036205

[email protected]

GUYA PLAYA S.A (Hotel THB Guya Playa)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07218159

[email protected]

HOTEL CALA LLITERAS S.A. (Hotel THB Cala Lliteras)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07034523

[email protected]

DOS PLAYAS S.L. (Hotel THB Dos Playas)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. B07025356

[email protected]

LHOTSE INVESTMENTS S.A. (Hotel THB Sa Coma Platja)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07408248

[email protected]

HOTEL FELIP 1890 S.L.U. (Hotel THB Felip)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. B57786360

[email protected]

HOTEL MARÍA ISABEL S.A. (Hotel THB María Isabel)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07024995

[email protected]

SES FONTANELLES S.A. (Hotel THB El Cid)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07020753

[email protected]

PROM. PUERTO DE ALCUDIA, S.L. (Hotel THB Bamboo Alcudia)
Registered Office Address: C/ Corcega, 302-4ª-2A, 08008 Barcelona (España)
N.I.F.  B07180391

[email protected]

LOS MOLINOS DE IBIZA S.A. (Hotel THB Los Molinos)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07010176

[email protected]

CAN GUSTI S.A. (Hotel THB Naeco Ibiza)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07163611

[email protected]

APARTHOTEL BAHIA S.L.U. (Hotel THB Ocean Beach)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. B57412132

[email protected]

INMOBILIARIA AGAR, S.A.U. (HOTEL THB San Fermín)
Registered Office Address: C/ San Fermin, 11, 29630, Benalmádena (España)
N.I.F. A-29015831

[email protected]

INVERSIONES FINANCIERAS PONENT S.A. (Hotel THB Flora)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. A07161508

[email protected]

HOTEL ROYAL PLAYA BLANCA S.L.U. (Hotel THB Royal)
Registered Office Address: Vía Alemania 14, 6º, 07458 Ca’n Picafort, Islas Baleares (España)
N.I.F. B57868085

[email protected]

INVERSIONES TURÍSTICAS PLAYA BLANCA S.L. (Hotel THB Tropical Island)
Registered Office Address: c/ Fragata, 2, 35510 Playa Blanca - Lanzarote (España)
N.I.F. B35660232

[email protected]

CTS HOTEL V, S.L. (Hotel THB Lanzarote Beach)
Registered Office Address: Pl. el Janubio, 2, 35508 Costa Teguise, Las Palmas
N.I.F. B- 72959950

[email protected]

For all queries regarding the protection of your personal data, you may write to the THB HOTELS Data Protection Officer at [email protected]

2 WHY WILL YOUR DATA BE PROCESSED AND ON WHAT LEGAL GROUNDS?

Your data shall be processed for the following purposes:

• Booking management and provision of the services requested
• Online check-ins
• Responding to queries and complaints
• Website security management and administration
• Call Centre
• Statistical and quality management purposes
• Consolidation of the chain’s customer data
• Business data analysis and management control
• Sending of non-personalised commercial information and distribution list management (segmentation)
• Creation of a commercial profile for the personalisation of the chain’s commercial communications and services

Personalisation of website advertising

Details of each of these purposes are given below.

2.1 Booking management and provision of the services requested. THB HOTELS shall process the data provided in requests for bookings or services in order to manage said bookings and provide the services requested.

Which data are processed for this purpose and how have they been obtained?

The data categories to be processed by THB HOTELS for these purposes affect the following categories:

• Identification data, ID Card/Passport, date of birth, contact data (telephone, email and address) of the person in whose name the booking is made;
• Data relating to the actual booking or request for services (hotel, stay dates, number and age of guests and the services requested);
• Data relating to means of payment;
• Goods and services transaction data.

These data are obtained either directly from you via the booking form, the requests you make in our online forms and via our call centre, or from third parties that have processed the booking or requested the service on your behalf, such as the travel agency you have used to book your stay.

Processing these data is necessary in order to manage your booking and execute the accommodation contract, the provision of the services requested or the application of pre-contractual measures in place at your own request.

Financial data and those relating to goods and services transactions shall be processed for accounting and administrative purposes as well as compliance with accounting and tax legislation.

Booking data are consolidated on THB HOTELS databases for the purposes of management control and business data analysis, the remittance of commercial communications and the creation of commercial profiles (+ info in the section entitled “Consolidation of the chain’s customer data).

2.2. Online check-ins. Pursuant to the traveller monitoring laws in force, hotels are required to register data for all the guests they accommodate. This information is recorded on the arrival forms that guests are required to complete, and is consolidated in a traveller log-register that must be kept by the hotel and made available to the corresponding authorities. The data required on the arrival form are as follows: name and surname, sex, data of birth, nationality, type and number of ID document, date of issue of said document, arrival date and signature.  

The data provided on the online check-in form shall be sent to the destination hotel. The online check-in function will allow for the pre-completion of the arrival form in order to speed up the check-on process on your arrival at the hotel. Use of the online check-in service is optional and does not affect your arrival at the hotel. If you opt not to use this function, you must fill in the arrival form when you reach the hotel. 

The data necessary in order to pre-complete the arrival form are processed on the grounds of the consent given by the use of this function.  

2.3. Responding to queries and complaints. The data provided by the queries or complaints you send us shall be processed in order to deal with your requests and handle any possible complaints.

The processing of any possible medical data you have provided is covered by article 9.2. f) of the GDPR, as said processing is necessary for the formulation, execution or defence of complaints.

Should your complaint or query affect the services provided by third party suppliers, the affected suppliers shall be duly notified.

Likewise, depending on the nature of your complaint or query, the recipients of the data included therein may include, among others, public bodies or administrations, official organisations, court agents, judges and tribunals or insurance companies. 

Our website includes a virtual assistant function (Velma). If you begin a conversation with Velma, we will process the data you enter in the chatbot and your email in order to contact you regarding your request, query or complaint. This chatbot function is provided by the French company Quicktext SAS, located at 64, rue Jean Pierre Timbaud, Paris 75011, France. The data obtained via the virtual assistant shall not be processed for commercial purposes.

Processing these data is necessary for the execution of the accommodation contract, the application of pre-contractual measures in place at your own request or for defence in the event of customer complaints. 

2.4. Website security management and administration: We process browsing data (IP addresses or logs) for the purpose of website security management and administration. The grounds for this processing are based on our legitimate interest in guaranteeing the security of the website. This interest is expressly acknowledged in recital 49 of the GDPR. The assessment of said interest with regard to your rights and liberties has taken into consideration the fact the said processing corresponds to generalised security practices and does not pose any significant threat to the interested parties.

2.5. Call Centre: Calls made to our Call Centre and made by our agents shall be recorded for security and quality management purposes. If you do not wish your call to be recorded, you may inform the agent who is handling your call to this effect.

Recordings are deleted within a maximum of 365 days, except when they must be stored for longer in order to manage any possible incidents or complaints. The above is without prejudice to their storage for as long as necessary in order to attend to any possible liabilities arising from processing or the periods stipulated by the applicable legal provisions.

Access to the contents of the recordings is limited to Call Centre managers and those persons requiring said access in order to handle your complaint correctly, such as our legal department or our Data Protection Officer. 

The grounds for the recording of calls are based on our legitimate interest in being able to provide proof of the conversation held between our customers and agents, particularly in relation to the contracting of products and services and managing your complaints or grievances, and also in order to assess and manage the quality of our customer service.  

The assessment of said interest with regard to your rights and liberties is based on the following: processing corresponded to our customers’ reasonable expectations as this is a generalised practice; said recordings may also benefit the interested parties themselves, for instance in the event of a discrepancy regarding their bookings or complaints; they do not represent a significant threat to customers’ privacy given that they may oppose the processing thereof; and also the limited number of people that may access the recordings and the time limit for their conservation. 

2.6. Statistical and quality management purposes. In order to assess and manage the quality of the products and services, THB HOTELS draws up statistics based on aggregate data obtained from transaction details and website browsing data (IP address, pages visited or actions taken) + info available in our cookies policy.

This processing is based on our legitimate interest in assessing and managing the quality of our products and services.

The assessment of said interest with regard to your rights and liberties is based on the fact that the processing had a limited impact on the privacy of the interested parties as it corresponded to their reasonable expectations. Likewise, it did not pose any significant threats due to the fact that it was carried out using aggregate data and with the consent of the interested parties regarding the metrics performed with cookies.

QUALITY CONTROL. THB HOTELS intends to conduct opinion surveys, although they are not a compulsory requirement.

In order to assess the application of the chain’s standards by THB hotels and assess the quality of the products and services offered to its customers, THB HOTELS may conduct satisfaction or opinion services among the chain’s customers. Should you provide any data in the surveys that allow you to be identified, such as your name or room number, THB HOTELS shall inform the HOTEL so that you can be contacted in relation to the complaints or suggestions you have made. Likewise, THB HOTELS may also use the contact data you have provided in order to contact you for the same purpose. This processing is based on the legitimate interest of the HOTEL and THB HOTELS in assessing and managing the quality of the products and services offered by the chain and improving their customer service.

How has this interest been assessed in relation to your rights and liberties?

• In order to assess this interest in relation to your rights and liberties, the following points have been established:
• Processing is compatible with the reasonable expectations of the interested parties, as they are customers of THB chain hotels who, having presented a complaint or suggestion in relation to the service received, have provided their identification data of their own free will. Likewise, the data used to contact said customers have been provided by the interested parties themselves.
• The impact said processing has on the privacy of the interested parties is limited, as the object of the contact is restricted to resolving complaints or commenting on the suggestions made by the interested parties. The latter also benefit from this purpose given the improvement to the quality of the services and the standard of customer service.

2.7. Consolidation of the chain’s customer data. The booking data, together with those generated by your stays at THB chain hotels, are consolidated on databases that are the property of THB HOTELS.

Which data are consolidated?

The consolidated customer data categories are as follows:

• Identification data: name, surname, identification document (type, number, date of issue), country of residence, postal, sending or billing address, email, fax, mobile phone number;
• Personal characteristics data: sex, date and country of birth, nationality, family data (family status: children, children’s date of birth, over or under legal age, partner), language;
• Data related to your bookings (hotels, stay dates, number and age of guests, services included in the booking and items consumed during the stay (purchases, use of services, food and beverages consumed, use of facilities);
• Data provided in grievances and complaints;
• Goods and services transaction data;
• Economic, financial and insurance data (we know the value of the services contracted and the payment method selected)

These data are consolidated in THB HOTELS systems located in the European Union.

The purpose of this consolidation is to create a customer register for the chain, standardise formats and information coding and to allow for the centralised management of operational processes that are common to all hotels, such as communicating traveller arrivals to the corresponding authorities, when so required by the legislation in force.

This consolidation is based on the legitimate interest stipulated in recital 48 of the GDPR of passing on customers’ personal data within a business group for internal administrative purposes.

How has this interest been assessed in relation to your rights and liberties?

In order to assess this interest in relation to your rights and liberties, the following points have been established:

• Processing is compatible with the reasonable expectations of the interested parties, as they are customers of THB chain hotels and the processing takes place within the framework of their relations with the aforementioned chain.
• The impact of processing on the privacy of the interested parties is limited, in view of the intended purpose, the limited period of data storage and the adoption of technical and organisational measures to prevent the use of said data for commercial purposes, including the creation of profiles, without the consent of the interested parties. (+ info on data storage time periods is available in the section “How long are your data kept for?”).

The consolidated data are also used for the purposes given below:

BUSINESS DATA ANALYSIS AND MANAGEMENT CONTROL

THB HOTELS processes the information obtained from the chain’s consolidated customer data in order to draw up reports and analyse business data for business intelligence and management control purposes. These analyses and reports offer results in the form of aggregate data and are used to draw up statistics and forecasts that will facilitate the taking of corporate decisions, optimise processes, measure the performance of the tourism products offered by the group and determine commercial strategies.

This processing is based on THB HOTELS’ legitimate interest in obtaining a consolidated vision of its business in order to adopt business decisions and for internal group administrative purposes.

How has this interest been assessed in relation to your rights and liberties?

In order to assess this interest in relation to your rights and liberties, the following points have been established:

• Recital 48 of the GDPR acknowledges the legitimate interest in passing on customers’ personal data within a business group for internal administrative purposes.
• Processing is compatible with the reasonable expectations of the interested parties, as they are customers of the chain and processing takes place within the framework of their relations with the aforementioned chain.
• The impact of processing on the privacy of the interested parties is limited, due to the adoption of technical and organisational measures intended to prevent the identification of individuals and the creation of profiles without the consent of the interested parties.

2.8 Sending of non-personalised commercial information and distribution list management (segmentation)

THB HOTELS processes the identification and contact data provided by the chain’s customers, together with data relating to their customer status and language in order to send non-personalised commercial information regarding the tourism products and services offered by the chain and to manage its distribution lists.

Consolidation of this information for this purpose is based on THB HOTELS’ legitimate interest in creating and exploiting a commercial database of the chain’s customers for direct marketing purposes.

How has this interest been assessed in relation to your rights and liberties?

In order to assess this interest in relation to your rights and liberties, the following points have been established:

• Recital 47 of the GDPR states that processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest. Recital 48 of the GDPR acknowledges that there may be a legitimate interest in passing on customers’ personal data within a business group for internal administrative purposes.
• Processing is compatible with the reasonable expectations of the interested parties, as they are customers of the chain and a contractual relationship exists prior to the sending of commercial information that refers to the chain’s own tourism products or services.
• The impact on the privacy of the interested parties is limited, due to the limited amount of data affected and the possibility of opposing processing both when obtaining the data and in the commercial communications themselves.

The sending of the chain’s commercial communications by electronic means is based on article 21.2 of Law 34/2002 of 11th July on information society services and electronic commerce which transposes directive 2002/58/EC (directive on privacy and electronic communications) in Spain.

You may at any time request your erasure from the chain’s distribution list via the link included for this purpose in our communications or by sending an email to; [email protected]

In order to manage its distribution lists, THB HOTELS classifies the recipients of its communications in accordance with their status as chain customers and language. This processing is based on THB HOTELS’ legitimate interest in segmenting the recipients of its communications.

How has this interest been assessed in relation to your rights and liberties?

In order to assess this interest in relation to your rights and liberties, the following points have been established:

• Processing is compatible with the reasonable expectations of the interested parties, as it is accessory to the sending of commercial communications and allows the recipients thereof to receive them in a format and with contents adapted to their language and market.
• The processing does not pose a significant threat to the privacy of the interested parties, as it consists of a simple classification based on objective criteria that do not allow the inference of new information regarding the interested parties, due to the adoption of technical and organisational measures that prevent the creation of commercial profiles, forecasts or individual behavioural analyses of the data corresponding to the chain’s customers, unless the interested parties have authorised the processing of their data for this purpose. Moreover, the interested parties retain control over their information as they are entitled to oppose the reception of commercial communications at any time.

BOOKING DATA RECOVERY: If you wish, you may request we recover your booking search information and send it to you by email if you have not completed the process. In this case, we will use technical cookies to obtain your email and the information relating to your search. Further information regarding this is available in our cookies policy. These data are processed for this purpose only. The grounds for processing these data are based on your consent. Not giving or withdrawing this consent does not condition access to the website or the provision of the services requested.

2.9 Creation of a commercial profile for the personalisation of the chain’s commercial communications and services

The creation of a commercial profile and the personalisation of our services and communications are based on the consent you are asked to provide. Withdrawal of your consent does not condition the provision of any services you may have contracted.

If you have authorised the personalisation of the chain’s services and communications, THB HOTELS will access the data generated by your stay at the hotel for their inclusion in a commercial profile.

Which data are included in my profile?

The profile drawn up by THB HOTELS will consolidated the following data generated by your bookings and stays at the chain’s hotels:

• Identification and contact data: name, surname, country of residence, postal address, email, fax, mobile phone number;
• Personal characteristics data: sex, date and country of birth, nationality, family data (family status: children, children’s date of birth, partner), language;
• Goods and services transaction data: data related to your booking (hotels, stay dates, number and age of guests, services included in the booking) and items consumed during the stay (purchases, use of services, food and beverages consumed, use of facilities);
• Preferences expressed during the stay (e.g. if you have requested a special type of pillow)
• Data provided in any complaints or grievances made;

Medical data or other special category data such as religion or beliefs, or payment method data (e.g. bank cards) you may have provided for the purpose of your stay will never be included in your profile.

In addition, your profile will be enriched with the data obtained as a result of your participation in profiles or with the profiles and analytics obtained from the observation of your website browsing through the use of cookies and similar technologies.

THB HOTELS will use this profile for the following purposes:

• To personalise the services provided by the chain’s hotels, such as congratulating you on your birthday or taking into account the preferences you have expressed during your stay.

What does this personalisation imply?

The hotels in the chain that you contact or contract services with will consult your profile data in order to personalise their handling of your request and personalise this service. Personalisation is carried out in accordance with the chain standards, as defined by THB HOTELS. Consultation of your profile only occurs when you contact and interact with the chain’s hotels and is carried out by connecting to THB HOTELS’ customer relations management (CRM) tool located in the European Union. Your data are not included on the systems of the chain’s hotels that consult your profile. The chain has adopted technical and organisational measures to guarantee the necessary degree of protection for the personal data processed, which include, but are not limited to, secure connections, strict controls on access to profile data and the introduction of regulations regarding the persons authorised to access this information. You may contact our Data Protection Officer if you require further details of these guarantees.

• To tailor offers to your consumer profile, for instance, in order to determine the times of year that you have stayed or usually stay at our establishments, or the type of product you may be interested in, based on your past bookings or actions on the website (e.g. products designed for family holidays if you have travelled with family members, or stays related to products you have consulted on our website but have not booked). This profile is also used to make special offers based on your booking frequency, the products contracted and the amount spent.

Although no automated individual decisions are taken that have legal implications for our customers or have a significant impact on them based on this profile, you are hereby informed of your right to oppose the adoption of such decisions, pursuant to the provisions of article 22 of Regulation (EU) 2016/679.

Dataflows and processing are based on the consent you have given. However, said consent does not condition the provision of the services contracted. You may revoke your consent at any time by sending an email to [email protected]

2.10. Personalisation of website advertising.

If you have authorised the use of advertising cookies, we will process the information generated by your browsing (IP address, pages visited and actions on the website) to analyse your activity on the website and create a commercial profile in order to personalise our advertising content.

Processing is based on your consent for the installation of this type of cookies, which you may revoke at any time on the website settings panel or by modifying your privacy options on your web browser or hardware. Further information about the use of cookies and similar technologies is available in our cookies policy.

3 WHO ARE YOUR DATA PASSED ON TO?

Your data shall only be passed between THB Group companies under the circumstances described in the previous sections, or passed on to third parties for legal reasons, with your prior consent or when necessary in order to provide you with the services you have requested. Specifically:

We will provide the destination hotel with your booking data. Passing on these data is necessary in order to execute the booking or to apply pre-contractual measures in place at the request of the interested parties.

The HOTEL shall pass on guest arrival information to the corresponding authorities when so required by health, security or traveller control regulations in force in the territory where it is located.

Should your booking include accessory services provided by third party suppliers or should your requests affect this type of services, the personal data necessary for processing said booking/availability request shall be passed on to the corresponding suppliers for this purpose only. Likewise, and when necessary for their resolution, we shall pass on your complaints to the affected service suppliers. Furthermore, depending on the nature of your complaint, the recipients of the data therein may include, among others, public bodies or administrations, official organisations, court agents, judges and tribunals or insurance companies. These communications are necessary either for the provision of the services contracted or the application of pre-contractual measures in place at your own request, or for the formulation, exercise or defence of complaints.

If you have given your consent, we will pass on your identification and contact data (name, surname, email and the dates booked for your stay) to our collaborator on Ibiza: Ice Mountain Ibiza S.L., (hereinafter O Beach Ibiza), with registered business address at Camí des Molí, 12-14 - 07820 Sant Antoni de Portmany, Ibiza, Balearic Islands, Spain, in order to send you commercial information about its activities and services. The grounds for this communication are the consent you were asked to give on the booking form. Not giving or withdrawing your consent does not condition the execution of your booking at our hotels or the provision of the services contracted. You may unsubscribe to the processing of your data for commercial purposes at any time by sending an email to [email protected]. Further details of this data processing is available on the supplier’s privacy policy website: https://www.obeachibiza.com/es/politica-de-privacidad/

4 HOW LONG ARE YOUR DATA KEPT FOR?

As a general rule, we will keep your data for the duration of your relationship with the destination hotel and THB HOTELS, and in all cases, for the periods stipulated in the applicable legal provisions and for as long as necessary in order to respond to any possible liabilities arising from the processing thereof. Your data will be disposed of when they are no longer necessary or pertinent to the purposes for which they were collected.

Specifically:

We shall keep economic data and those relating to goods and service transactions generated by your stay for the period required by accounting and tax legislation in force.

Pursuant to the legislation in force, the destination hotel shall keep the guest log-register for the periods stipulated in said regulations and for at least 5 years.

Any medical data customers may have given the hotel in order to attend to their special needs shall be disposed of daily in the case of non-residents and at the end of their stay in the case of residents.

The conversations held in the website chatbot shall be kept for as long as necessary in order to handle your request, query or complaint and shall be disposed of within a maximum period of one year.  

Customer data consolidated in the central hotel management tool (PMS) shall be kept for 5 years.

The data processed by THB HOTELS for commercial purposes, including the commercial profiles, shall be kept until their processing is opposed or a request is made for their erasure. The formats documenting your consent for the processing of your data for these purposes, such as signed forms, electronic form logs and check-in sheets, shall be kept for the duration of the processing and for the applicable time limits.

The data processed by THB HOTELS for business data analysis and management control purposes shall be kept for an unlimited period of time.

The expiry dates of the cookies used on this website are specified in our cookies policy.

5 YOUR RIGHTS

You are entitled to obtain confirmation as to whether we are processing your personal data or not, and, where appropriate, access said data. You may likewise request the rectification of any incorrect data or the completion of incomplete data. You may also request their erasure when, amongst other reasons, the data are no longer necessary for the purposes they were collected.

Under certain circumstances, you may request the restricted processing of your data. In this case, we shall only process the affected data in order to lodge, apply or defend complaints or in order to protect the rights of others. In certain cases, and for reasons related to your particular circumstances, you may also oppose the processing of your data. In this case, we shall cease to process your data, except for overriding legitimate reasons that prevail over your interests or rights and liberties, or in order to lodge, execute or defend complaints.

Furthermore, and under certain conditions, you may request the portability of your data for transfer to another data controller.

You may revoke the consent you have granted for certain purposes, without affecting the legality of any processing based on the consent given prior to revocation.

You may, at any time, revoke your consent or oppose the processing of your data for direct marketing purposes, including the creation of commercial profiles. In this case, we shall cease to process your personal information for these purposes. You are likewise entitled to oppose the adoption of automated individual decisions that have legal implications for you or similarly have a significant impact on you, when this right concurs in accordance with the provisions of article 22 of Regulation (EU) 2016/679.

In order to cease receiving commercial communications from the group, you may use the link provided to this effect in our communications or write to the following email address: [email protected]

In order to request the erasure of your commercial profile, you may write to the following email address: [email protected]

You may likewise lodge a complaint before a data protection authority. You may consult the list and contact details of the European data protection agencies on the European Commission website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. 

To exercise your rights, you must send us a request by post or email to the addressed included in the section “Who is the controller of your data?”

Further information regarding your rights and how to exercise them is available on the Spanish Data Protection Agency website (https://www.aepd.es).

PRIVACY POLICY FOR SALES AND COMMERCIAL INFORMATION

This privacy policy applies to our sales and commercial information.   

Please read it carefully as it contains important information regarding the processing of your personal details and your rights pursuant to the corresponding regulation currently in force.  

We reserve the right to update our privacy policy at any time in accordance with corporate decisions, as well as to comply with any possible changes in legislation or legal precedents. If you have any queries or require clarification regarding our privacy policy or your rights, you may contact us via any of the channels indicated below.   

1. Who is responsible for processing your details? 

The data controller responsible for processing your details is TURISMO Y HOTELES DE BALEARES, S.L., holder of Spanish Tax ID No.  (CIF) B-57189110 and with registered business address at Vía Alemania 14, 6º C.P. 07458 Can Picafort, Balearic Islands, Spain. 
You may contact the Data Protection Controller at [email protected]

2.    What type of personal details do we collect? 

The details used to draw up sales and commercial profiles are obtained from the following sources:  

- The forms you fill in and the requests you make.
- Profiles and analytics obtained from users’ website browsing, regardless of whether they are registered or not. This may involve the use of browser tracking (more information is available in our cookies policy).    
- The products and services you acquire.

Essentially, the data we process can be classified in the following categories:  

- ID and contact details.
- Data of a personal nature such as gender, date and country of birth, nationality and language.  
- Financial and transaction data. 
- Details of your contact history with us. 
- Details relating to customer preferences and profiles, as well as sales and commercial tracking data.   
- Consolidated data generated by users’ website browsing habits, such as the IP address used to access the website, weblogs, the pages visited or actions carried out on the website. In order to do this, we use cookies and similar technologies that may involve tracking your browsing habits.  
- Geolocation data. 
- Card details, required to pay for or guarantee bookings, as well as to pay for stays or associated services.  
- Details of your social media profile and data generated by your use of social media that you have opted to share with us, such as other contact details, photographs, likes and comments.  

3. Why do we create profiles and what do we process these details for? 

We use the details obtained from sales profiles to enable us to learn more about and better understand our customers and users in order to enhance their experience, based on the analysis and improvements to the standard of the service we provide as well as its personalisation.

We also use them to send personalised sales communications to the electronic media you provide and to draw up statistics, surveys and improve the quality of our products and services. 

User browsing details are passed on in order to monitor the pages visited and tailor the campaigns to meet users’ needs. The information that is passed on is anonymous and does not contain any information that can identify users.

4.  Who can we pass on your details to? 

We will only pass on your details when required to do so by law.  

Organisations operating the hotels managed by TURISMO Y HOTELES DE BALEARES S.L., solely for internal administrative purposes and/or for the purposes stated above.   

Suppliers of TURISMO Y HOTELES DE BALEARES S.L. or companies operating the hotels, when necessary in order to comply correctly with the legal obligations and/or purposes stated above.  

Partners and companies collaborating with TURISMO Y HOTELES DE BALEARES S.L. in order to comply with the purposes stated above, and/or when so authorised, in order to send sales communications. 

5. Legal grounds for data processing

The creation of sales profiles, personalisation of our services and sending personalised sales offers and communications are based on your consent, although withdrawal of said consent shall not condition the provision of the services hired.  

The legal grounds for sending non-personalised sales and commercial information such as newsletters, as well as for drawing up quality surveys and statistics are our legitimate interests in assessing and promoting our services.  

6. How long we will keep your data for? 

The profiles and data processed for sales and commercial purposes will remain active until such a time that the interested parties revoke their consent or request their elimination and, in all cases, for the periods contemplated in the applicable legal provisions and for the time necessary to address all possible liabilities arising from their processing. The formats used as proof of consent for the processing of your data for these purposes, including but not limited to, signed forms and electronic signing logs, shall be conserved throughout the processing period and for the applicable prescription periods.   

7. Your rights

You are entitled to obtain information as to whether or not we are processing your personal details and should this be the case, obtain access to them. You may likewise request the rectification of your details if they are incorrect, or their completion should they be incomplete.

Furthermore, you may request their elimination when, amongst other reasons, the data are no longer necessary for their intended purpose.  

Under certain circumstances, you may request the limited processing of your details. This means that we will only process the details necessary in order to formulate, exercise or defend any claims or complaints made, or with a view to protecting the rights of others.  
In certain conditions, and for reasons related to your personal situation, you may also oppose the processing of your details. Should this occur, we will cease to process your data, except in the event of legitimate and overriding reasons that prevail over your interests, rights and liberties, or for the formulation, exercise and defence of claims and complaints.   

Notwithstanding the above, you may at any time revoke your consent and oppose the processing of your data for direct marketing purposes, including the drawing up of sales and commercial profiles. In this case we shall cease to process your personal details for the aforementioned purposes. Withdrawal of consent will not affect the lawfulness of the data processing, pursuant to the prior consent granted thereto.  

Likewise, and under certain circumstances, you may request the portability of your data for their transfer to another processing controller.  

You are likewise entitled to present a complaint before the Spanish Data Protection Agency or any other competent controlling authority.  

In order to exercise your rights, you must send us a request to this effect, enclosing a copy of your National Identity Document or other valid documented form of identification by conventional post or email to the addresses included in the section entitled ‘Who is responsible for processing your details?’

In order to revoke your consent to receive our sales and commercial information, you may simply unsubscribe via the link included for this purpose in our newsletters, or by sending an email to [email protected]

Further details of your rights and how to exercise them are available on the Spanish Data Protection Agency website at https://www.aepd.es.

Last updated: May 2018

CURRICULUMS PRIVACY POLICY

Please read this privacy policy carefully as it contains important information about how your personal details are processed and your rights pursuant to the regulations in force in this area.  If you have any queries or require clarification regarding our privacy policy or your rights, you may contact us via any of the channels stipulated below.  You are hereby stating that the details you provide us with now or in the future, are correct and accurate and undertake to inform us of any modifications thereto. In the event that you provide personal details of third parties, you undertake to obtain their prior consent and to inform them of the contents of this policy.

Who is responsible for processing your data? The details of the controller responsible for the personal details collected on this website are given below:  

Controller: TURISMO Y HOTELES DE BALEARES, S.L. (THB Hotels)

Postal address: Vía Alemania 14, 6º, 07458 Can Picafort

Tel / Fax: + 34 971 85 00 33 / +34 971 85 14 24

email: [email protected]

What do we process your details for?          Your details will be processed in order to manage and monitor our staff selection procedures.  

How did we collect your details? We have had access to your curriculum vitae, either directly from you or the jobs website you have registered with in order to take part in our selection procedures.  

How long we will keep your details for? We will keep your CV for up to one year following its latest update. If you wish to continue taking part in our selection procedures, you must therefore provide us with an updated version of your CV. Notwithstanding the above, we shall keep your details for the period stipulated in the applicable legal provisions and for as long as necessary in order to respond to any liabilities arising from the processing thereof.               

We can we pass on your details to? We shall not pass on your details, except unless so required by law or with your prior consent.  

Legal grounds for processing. The legal grounds for processing your details are your wish to be included in our staff selection procedures and our legitimate interest in the management thereof.  

What are your rights?

You are entitled to obtain confirmation as to whether we are processing your personal details or not, and to access said details.

Likewise, you may request that your details be corrected in the event that they are inaccurate or completed should they prove to be incomplete. You may also request their erasure when, amongst other reasons, the details are no longer required for the purposes they were collected. 

Under certain circumstances, you may request the restricted processing of your details. In this case, we will only process the affected details in order to formulate, exercise or defend claims or with a view to protecting the rights of others.

Under certain conditions and for reasons related to your personal situation, you may also oppose the processing of your details. In this case, we shall cease to process your details, except for overriding and legitimate reasons that prevail over your interests, rights and liberties, or in order to formulate, exercise or defend claims. 

You may revoke your consent given for certain purposes, although this shall not affect the lawfulness of processing based on consent prior to withdrawal thereof, and lodge a complaint before the Spanish Data Protection Agency. We hereby inform you that the EU General Data Protection Regulation likewise acknowledges your right to data portability. 

To exercise your rights you must send us a request to this effect, attaching a copy of your national ID document or other valid form of identification, to the postal or email addresses specified in the section entitled “Who is responsible for processing your details?” 

Further information about your rights and how to exercise them are available for consultation on the Spanish Data Protection Agency website at

https://www.aepd.es

CUSTOMER AND GUEST PRIVACY POLICY

Last modified: June 2018

This privacy policy applies to data processed at THB HOTELS. Please read it carefully as it contains important information about the processing of your personal details and your rights as recognised in the legislation in force in this area. This policy is posted at https://www.thbhotels.com/en/privacy-policy and is also available for consultation at the hotel reception, where you may also request a copy for you to keep.

As a general rule, all fields marked compulsory on our forms must be completed before we can process your requests.

1. Who is the data controller? The data controllers for customer and guest details are as follows:

The company operating the hotel you are staying at (hereinafter the HOTEL), whose identification and contact details are available at the hotel Reception and on the https://www.thbhotels.com/en/privacy-policy and THB HOTELS (TURISMO Y HOTELES DE BALEARES S.L.); the respective responsibilities of the HOTEL and THB HOTELS (TURISMO Y HOTELES DE BALEARES S.L.) are detailed below:

The HOTEL is responsible for processing activities resulting from hotel operations, including, but not limited to, the hotel’s administrative and accounting procedures; handling bookings, stays and the provision of the services hired, as well as customer service and guest complaints.

THB HOTELS is liable for processing activities that affect the THB brand and hotel management for the chain, including, but not limited to the following:

• Setting and monitoring the standards applied by the chain’s hotels and corporate management controls;
• Monitoring and improving quality standards at chain level;
• Commercial and sales use of data corresponding to users and customers of the Group’s brands, such as sending sales information.

2.  What kind of personal details do we collect? The data we process are obtained from the following sources:

• The forms you fill in and the requests you make, such as bookings or requests for services;
• The information provided in order to hire our services;
• The information generated by your stay and the provision of the aforementioned services.

All these data are provided either directly by you or by third parties placing requests on your behalf, such as the travel agencies that have booked your stay.

The types of data we process can be typically classified as follows:

• Identification and contact details, ID cards or passports and signatures;
• Details of a personal nature, such as gender, date and country of birth, nationality, family status and language;
• Transactions and financial details;
• Details related to your booking and generated as a result of your stay;
• Details relating to customer profiles and preferences, as well as sales monitoring details;
•  Where appropriate, health details for the Miniclub service, including, but not limited to, any medicines that minors may be required to take.
• Hotels offering SPA treatments or Miniclub services for children may process the health details provided by customers in order to handle special needs, such as allergies or any medicines that must be taken.

3. Why do we process your details? The HOTEL will process your data in order to manage your bookings and stays, provide the services requested and comply with its legal obligations. With your consent, we will compile images of your experience with us that will then be posted on social media and published in hotel and corporate catalogues, as well as released to the written and online press.

THB HOTELS will process your data for hotel chain management purposes. This includes the analysis of business data and corporate information obtained from the consolidation of customer and guest data from the chain’s hotels, for the purpose of corporate management monitoring, statistical purposes, improvements to the group’s services and the sending of sales information by THB HOTELS and third party partners operating in the tourism sector. In order to improve our customers’ experience through actions such as the personalisation of our services or offers, we will draw up a commercial profile based on the information provided. No automated decisions will be taken on the basis of this profile.

For quality control purposes, THB HOTELS may carry out opinion surveys, although they are not a compulsory requirement.

5. Legal grounds for processing. The HOTEL’s legal grounds for processing your data are based on the execution of the accommodation or service contract and compliance with its legal obligations, in particular the applicable accounting, tax, tourist, safety and traveller inspection regulations.

The recording and dissemination of the entertainment and activities organised by the HOTEL featuring identifiable people are carried out with the consent of the interested parties.

Processing for hotel chain management purposes is based on THB HOTELS’ legitimate interest in processing consolidated data from the chain’s hotels for internal administrative and management control purposes, as well as in order to appraise and promote the Group’s services.

The grounds for sending by electronic means sales promotions and details of products and services offered by THB HOTELS and third party partners, as well as the creation of commercial profiles, loyalty actions and the personalisation of services are based on the consent requested, although the withdrawal of said consent shall not affect the provision of the contracted services.

6. How long will we keep your details for?  Customer and guest details shall be kept for the duration of their relationship with the HOTEL and THB HOTELS, and in all cases for the period stipulated in the applicable legal provisions and for as long as necessary in order to respond to any possible responsibilities resulting from the processing thereof. Your details shall be erased when they are no longer necessary or pertinent for the purposes for which they were collected.

The profiles and data processed for commercial and sales purposes shall remain active until you request their erasure. The formats containing your consent for the processing of your details for the purposes stated, such as signed forms and elogs of forms sent and check-in forms, etc., shall be conserved for the duration of the processing procedures and for the corresponding legally prescribed periods.

7. What are your rights? You are entitled to obtain confirmation as to whether we are processing your personal details or not, and, where appropriate, to access said details. Likewise, you may request that your details be corrected in the event that they are inaccurate or completed should they prove to be incomplete. You may also request their erasure when, amongst other reasons, the details are no longer required for the purposes they were collected.

Under certain circumstances, you may request the restricted processing of your details. In this case, we will only process the affected details in order to formulate, exercise or defend claims or to protect the rights of others.

Under certain circumstances and for reasons related to your personal situation, you may also oppose the processing of your details. In this case, we shall cease to process your details, except for overriding and legitimate reasons that prevail over your interests, rights and liberties, or in order to formulate, exercise or defend claims.

Notwithstanding the above, you may at any time revoke your consent and oppose the processing of your details for direct marketing purposes. In this case we shall cease to process your personal details for these purposes. Withdrawal of your consent shall not affect the lawfulness of processing based on the prior consent obtained.

Furthermore, and under certain circumstances, you may request the portability of your data for transfer to another data controller.

You are likewise entitled to lodge a complaint before the Spanish Data Protection Agency or any other competent control authority.

To exercise your rights you must send us a request to this effect, attaching a copy of your national ID document or other valid form of identification, to the postal or email addresses specified in the section entitled “Who is responsible for processing your details?”

To revoke your consent to receiving our sales and commercial information, simply send an email to [email protected]

Further information about your rights and how to exercise them is available for consultation on the Spanish Data Protection Agency website at http://www.aepd.es.

CALL CENTRE PRIVACY DETAILS

APP TERMS AND CONDITIONS OF USE

These terms and conditions of use are applicable to the Application (hereinafter the APP), which is the property of  TURISMO Y HOTELES DE BALEARES S.L. (hereinafter THB HOTELS).

By accessing this application, you become a USER, which, on access thereto, implies full and unreserved acceptance of these  terms and conditions of use, as well as the most recent version of the customer and guest privacy policy, without prejudice to the General Terms and Conditions of Contract applicable by THB HOTELS, in those cases where compliance therewith is compulsory.  

You are therefore advised to read these documents prior to using the functions offered by the APP,  as well as each time you access it, as we reserve the right to change, modify, add or eliminate part of these terms and conditions at any time.  

I. TERMS AND CONDITIONS OF USE

1. Introduction.

The APP provides users with information about the hotels managed under the THB HOTELS registered trademark. Depending on the hotel selected by the user, the information provided may include details about the hotel, sightseeing, leisure and gastronomy, as well as the services it offers, including the option of checking in directly via the APP. Prior registration is not required in order to access and use the APP functions. By accessing and using the APP, you are agreeing to comply with the terms and conditions stipulated below, and you are therefore advised to read this section carefully before you start browsing.   

2. Declarations.

The User declares that:

• he / she is of legal age and has full capacity to enter into a binding agreement;
• he/ she fully understands and comprehends these terms and conditions;
• the data he/she may provide whilst using the APP are complete and truthful.  

Users undertake to use this APP in a licit manner, pursuant to the provisions of these terms and conditions, and in such a manner that will not prove detrimental to the rights or interests of  THB HOTELS or third parties.

By way of an example, but under no circumstances limited or exclusive to, Users likewise undertake to abide by the following provisions:   

• Not to take part in activities that are illegal or contrary to public order or good faith;
• Not to attempt to access, modify, manipulate and, where appropriate, use other Users’ data;
• Not to use other Users’ data or any other information obtained from the APP for purposes other than the object thereof;
• Not to use data published on the APP in order to establish business contacts or send unsolicited communications (spam);  
• Not to disseminate, transmit or make available to other Users or third parties any type of information, elements or contents that constitute illicit or unfair advertising;
• Not to introduce or spread any false, deceitful, ambiguous or imprecise information or contents that may mislead the receivers thereof, or may alter other Users’ economic behaviour;   
• Not to publish content or carry out actions that constitute or imply the breach of the intellectual and industrial property rights of THB HOTELS or third parties;
• Not to attack the image of third parties;
• Not to disseminate contents or propaganda of a racist, xenophobic or pornographic nature or that constitute an incitement to terrorism or attack human rights;
• Not to damage the hardware and software systems of THB HOTELS, its suppliers or third parties;
• Not to introduce or disseminate online computer viruses or to use any other hardware or software systems that are susceptible of causing the aforementioned damage;
• Not to eliminate, alter, avoid or manipulate any security system or protection device installed on the APP.

Access to and use of the APP is free, has no cost and does not require User identification.  

Notwithstanding the above, if you opt to use the check-in function, you will be asked to provide the email you used to complete the booking and the booking reference we sent you in the booking confirmation email.  

The data used to access check-in are personal and confidential. Access to this function and the procedures carried out therein are the responsibility of the Users, who accept full liability for the actions carried out when using this function. Users undertake to notify THB HOTELS immediately of any unauthorised access or procedure carried out in reference to their booking.  

5. Liability waiver.

This APP  is supplied “as is” and use thereof is at the User’s own risk. Therefore, neither THB HOTELS, nor its administrators, employees, suppliers or collaborators shall be liable for damage of any type, direct or other, arising from the use of the APP. Specifically, THB HOTELS, is exempt, to the full extent provided by law, from all types of explicit or implicit guarantees.   

THB HOTELS does not guarantee the availability and accessibility of the APP, although it shall make all reasonable efforts in this sense. Interruptions may occasionally occur during the time required in order to carry out the corresponding maintenance operations.  

THB HOTELS shall not be liable for any damage caused by interferences, interruptions, telephone faults or outages that are not attributable to the aforementioned organisation. Likewise, it shall not be liable for delays or blockages in the use of the current electronic system due to failures or overloads in the data processing centre, telephone lines, Internet system or other electrical systems, or for any other alteration to Users’ software or hardware. Similarly, it does not guarantee the absence of viruses,  malwares, trojans or other elements that may affect Users’ IT systems, documents or files, and is therefore exempt from all liability for damage of any kind to Users for this reason.   

Likewise, THB HOTELS shall not be liable for the damage resulting from the illegitimate intromission of third parties that is beyond its control.  

Nor shall it be liable for the damage caused by the use or misuse of the APP contents, or for any consequences resulting from content errors, faults or omissions that may appear in the APP provided by the Users themselves or third parties. THB HOTELS accepts no liability whatsoever for those services that it does not provide directly.  

THB HOTELS accepts no liability whatsoever arising from third party content that is transmitted, hosted or can be accessed from the APP, as it is not required to check beforehand that such links comply with the legislation in force. Regarding the links or hyperlinks included on this APP that redirect to other Internet sites, Users hereby accept that THB HOTELS has no control of any kind over such sites and their contents.  

Under no circumstances shall THB HOTELS be liable for any of the contents included in any third party site link. Likewise, it does not guarantee the technical availability, quality, reliability, precision, scope, veracity, validity and legality of any materials or information included on any of the aforementioned hyperlinks or Internet sites.  

Moreover, the inclusion of these external connections shall not imply any form of association, merger or participation with the controllers or owners of the linked websites or services, or the recommendation or promotion thereof.

Those persons or organisations who, after obtaining due authorisation from  THB HOTELS, wish to create a link thereto, must guarantee access only to the website, not the reproduction of its contents and services.  

7. Personal data processing.

Details of the processing of Users’ data and how to exercise their rights to the access, elimination, limitation and rectification of their personal data, as well as their right to oppose their processing and portability, are available in the customer and guest privacy policy on the website homepage. Furthermore, this policy is attached to these terms and conditions for reference purposes.  

Without prejudice to the contents subject to third party intellectual rights, the intellectual property rights of the APP, the APP name, its source code, design, browsing structure and the elements contained therein (by way of an example: images, sound, audio, video, software or copy; brands or logos, colour combinations, structure and design, etc.), are the property of THB HOTELS, which holds full and exclusive exploitation rights over them, with particular reference to the rights to reproduce, distribute, publish and transform them, pursuant to the provisions of the Intellectual Property Law currently in force.   

It is strictly forbidden to reproduce, distribute and publish, including in disclosure mode, all or part of the contents of this APP for commercial purposes, in any format and by any technical means, without obtaining authorisation from THB HOTELS or, where appropriate, from third parties holding intellectual property rights or copyright over the affected content.  Notwithstanding the above, APP Users may view the APP elements and even print, copy and save them in the memory of their device or in any other physical format, provided that this is solely for their personal and private use. Users undertake to guarantee the integrity of the APP and to prevent all deformation, modification or alteration thereto that may negatively affect the legitimate interests of THB HOTELS or prove detrimental to its good name.  

Should one of the clauses included in these general terms and conditions be declared null and void, said provision shall only affect the particular provision or part thereof so declared. All other general terms and conditions shall still apply, and the aforementioned provision or part thereof shall be considered voided.  

Access to and use of the APP shall necessarily imply that you have expressly accepted each and every one of these terms and conditions of use.  

This APP shall be subject to Spanish legislation with the exception of its conflict of laws principles. All disputes that may arise as a result of its use or of the services associated thereto shall be subject to the competence and jurisdiction of the Courts and Tribunals of Palma de Mallorca, and Users expressly waive all other jurisdictions to which they may be entitled.    

Version 1.0 – January 2020