Privacy Policy/

1. PRELIMINARY

In accordance with the provisions of Organic Personal Data Protection Act 15/1999, of 13 December 1999 (hereinafter, the Data Protection Act), and of Royal Decree 1720/2007, of 21 December 2007, approving the Regulation in development of the Data Protection Act (hereinafter, the Data Protection Regulation), MANAGEMENT HOTELERO PIÑERO, S.L. (hereinafter, MHP) wishes to inform Users of the Website www.grupo-pinero.com (hereinafter, the Website) of the policy regarding the processing and protection of the personal data of those persons who voluntarily identify themselves for use by any medium and form of contact with MHP or any other service present on the Website that would involve the communication of their personal data to MHP, such as services requiring prior registration or the contact form.

MHP informs the User of the Website that this privacy and personal data protection policy contains all aspects connected with the processing of personal data conducted by MHP as the corresponding data controller, by means of the MHP Website. The User fully and expressly accepts this policy merely by communicating his/her personal data to MHP through the use of any service on this Website, or by communicating his/her personal data by any form of contact using the resources posted on this Website. Should this policy be replaced by another, in whole or in part, said new policy will be deemed to be accepted in the exact same manner as here indicated. It is nonetheless the responsibility of the User of the Website to access this privacy and personal data protection policy periodically in order to ascertain the content of the processing of personal data communicated to MHP.

The User is informed that any processing of personal data will be subject to the scope of application of the legislation in force in Spain regarding data protection, as established by the Data Protection Act and the supplementary and developmental regulations thereof.

To this end, personal data shall be understood as any information concerning natural persons who are or could be identified, including an eEmail address and/or IP address, if they unequivocally identify the parties concerned, while a User is any natural person who is or could be identified and who communicates his/her personal data to MHP through the use of any service of the Website of said entity.

A User accessing the MHP Website is not obliged to provide personal data in order to use the Website, and as a result any communication of data for such purposes will be performed because the User has voluntarily decided to browse or make personalised use of the services. As a result, any form of personalised communication conducted by a User with MHP via any medium entails or involves free, unequivocal, specific, informed and express consent being given for the processing of his/her personal data by MHP. In processing such data, in accordance with Organic Personal Data Protection Act 15/1999, of 13 December 1999, the User is informed that his/her personal data, as freely and voluntarily provided by means of the contact eEmail address indicated on the Website (contact@grupo-pinero.com), will be stored in a filing system the controller of which is MANAGEMENT HOTELERO PIÑERO, S.L., for the purpose of administering and, where applicable, fulfilling any requests and calls for information received. The parties concerned may exercise their rights of access, rectification, cancellation and objection by sending a written request to said entity, together with a copy of their identity document, to Plaza Mediterráneo, 5, 07014 Palma de Majorca, Balearic Islands, indicating the specific right exercised, as set out in subsection 7 of these policies.

MHP could nonetheless, in particular and without being confined thereto, provide personal data request forms and/or other systems to obtain information, allowing queries, comments or suggestions to be submitted, or to request information from MHP.

Personal information will be used only for limited purposes, of which the User will be informed in advance in each specific case, on an unequivocal basis and prior to consent, gathering and processing of the User's data. In this regard, the User is informed that any information that might, where applicable, be published in connection with personal data processing by MHP prior to the gathering of data, by means of the information texts accompanying forms or services on the Website, will take priority over the wording of these policies.

MHP does not request or require the processing of Users' sensitive information, this being understood in accordance with the terms of Articles 7 and 8 of the Data Protection Act: data connected with race or ethnic origin, religious beliefs, criminal record, physical or mental health or sexual orientation. Should MHP require sensitive information, express consent will be requested from the user to gather and use this information, informing the user unequivocally in advance of the purpose for which said information is gathered and processed. If for any reason, without this having been requested by MHP, such information is voluntarily communicated by the User to said entity, said communication will constitute the existence of a declaration of express consent by the User as regards the processing of his/her data by MHP.

2. IDENTIFICATION OF THE COMPANY NAME OF THE DATA CONTROLLER.

MHP informs the User of the Website of the existence of various personal data filing systems and processing operations the controller of which is MANAGEMENT HOTELERO PIÑERO, S.L., of Tax Identification Number B-57211732 and registered office at Plaza Mediterráneo, 5, 07014 Palma de Majorca, Balearic Islands, registered in the Companies Register of Palma de Majorca, Volume 1988, Page 183, Sheet PM-4412, in which personal data that the User might for any reason communicate to MHP are gathered and stored.

3. INFORMATION AND CONSENT.

If the User does not maintain any legal relationship with MHP, he/she must bear in mind, and is informed, that the sending of an eEmail to MHP, to the eEmail addresses posted on the Website, and communication by the User to MHP of any personal data via any medium, entails or involves free, unequivocal, specific, informed and express consent for the processing of his/her personal data by MHP.

The user, if so required, and where there are documents requesting data, may only complete the forms on this Website by providing MHP with precise and current data corresponding to his/her own identity, and therefore may not use the data of third parties.

4. IDENTIFICATION OF THE RECIPIENTS TO WHICH MHP PLANS TO TRANSFER OR COMMUNICATE DATA.

MHP has plans to transfer or communicate data only as required in accordance with Article 11.2(c) of the Data Protection Act in order to fulfil its obligations regarding Public Authorities in those cases where so required in accordance with the legislation in force in this regard from time to time, and likewise, where applicable, with regard to other bodies such as Judges, the Ministry of Public Prosecution, Courts, the Accounts Tribunal or Public Ombudsman.

Data may be communicated to companies of Grupo Piñero or other third-party entities that own property rights over content accessible via the Site, in order to maintain control over the exploitation of content.

Likewise, MHP informs the User that, in the event that it is required to transfer data to other third parties, it will first inform the User on an express, precise and unequivocal basis of the recipients of the information, the purpose for which the data will be used, and the nature of the data transferred, or as applicable, where so established by the Data Protection Act, will first request unequivocal, specific and informed consent from the User. The User must for these purposes take particular care with the information that he/she might provide via the personal data gathering forms posted on the Website.

5. SECURITY MEASURES ADOPTED WITH REGARD TO PERSONAL DATA PROCESSING

MHP informs the User that, in accordance with the provisions of the Data Protection Act and the Data Protection Regulation, it has adopted the necessary technical and organisational measures to guarantee the security of the personal data, and avoid any alteration, loss, processing or access without authorisation, in accordance with the technological state of the art, the nature of the data stored, and the risks to which they are exposed, whether through human action or the physical or natural environment, and will only record personal data in filing systems that fulfil the conditions established in the aforementioned Regulation with regard to their integrity and security, and those of data processing centres, premises, equipment, systems and programs. MHP likewise guarantees to the User compliance with the duty of professional secrecy as regards the Users' personal data, and the duty to maintain them.

6. UPDATING OF DATA

The User is the only source of information for his/her personal data, and MHP therefore requests, in order to keep its data current and up-to-date at all times, in accordance with the principles of the Data Protection Act, that the User send notice to the address indicated for rights of access, rectification, cancellation and objection to be exercised, as regards any change to the data.

7. EXERCISE OF RIGHTS OF OBJECTION, ACCESS, RECTIFICATION AND CANCELLATION REGARDING DATA PROTECTION

MHP informs the User of the possibility of exercising his/her rights of access, rectification, cancellation and objection by sending a written request to MANAGEMENT HOTELERO PIÑERO, S.L., of Tax Identification Number B-57211732, of registered office at Plaza Mediterráneo, 5, 07014 Palma de Majorca, Balearic Islands, or any that might replace this, of which the General Data Protection Register will be informed. To this end, the party concerned should send written notice to MHP, indicating the request or the right exercised, together with a copy of both sides of his/her national identity document or a legally valid identity accreditation document.

This right may only be exercised on a purely personal basis, and the party concerned may therefore exercise said rights in person by providing accreditation of his/her identity; by means of a legal representative, in which case accreditation of said status will be required; and/or by a voluntary representative expressly designated to exercise said right.

In cases of representation, the identity of the individual represented must be clearly accredited by submitting a copy of his/her national identity document or equivalent document, and the powers of representation granted by said individual.

In all cases the notification sent to MHP must expressly indicate the request or the right being exercised.

8. EXERCISE OF RIGHTS OF REVOCATION AND OBJECTION TO THE RECEIPT OF ELECTRONIC COMMERCIAL COMMUNICATIONS REGARDING ELECTRONIC COMMERCE

Those users who have authorised the sending of commercial communications by eEmail and/or have requested that MHP send this type of communication, are informed that, pursuant to Articles 21 and 22 of the Information Society and Electronic Commerce Services Act, the User is entitled to object to the processing of his/her data for promotional purposes for the receipt of commercial communications, and enjoys the right to revoke the consent given for this purpose at any time, simply by notifying MHP of said decision.

To this end, the User may inform MHP of his/her objection and/or the revocation of the consent granted by sending an eEmail to the address baja@grupo-pinero.com

9. UPDATING OF THE POLICIES

MHP may occasionally update this privacy and personal data protection policy for its Website. The User must nonetheless bear in mind that the processing of his/her data will, where communication of data to MHP occurs, be governed by the established standards in force at the time when the personal data were provided to MHP.

The user will in all cases be responsible for periodically accessing the published privacy and personal data protection policies of MHP, in order to be familiar at all times with the latest version.