I. PRIVACY AND DATA PROTECTION POLICY
In compliance with the provisions of current legislation, Apartamentos Centro Jardines (hereinafter also Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GPRD)
- Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
- Royal Decree 1720/2007, of 21 December, which approves the Regulations implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
- Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the person responsible for processing the personal data
The person responsible for the processing of the personal data collected at Apartamentos Centro Jardines is: Gestión Turística Madrileña 2015, SL, with NIF: B32462517 (from now on, the data controller). Their contact details are as follows:
Address and fiscal domicile: C/ Cardenal Quevedo 12 – 2B Madrid
Contact telephone number: +34 607 02 81 71
Contact email: email@example.com
Registration of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Apartamentos Centro Jardines, through the forms provided in its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Apartamentos Centro Jardines and the User or the maintenance of the relationship established in the forms that the User fills out, or to meet a request or consultation of the same. Likewise, in accordance with that envisaged in the RGPD and the LOPD-GDD, unless the exception envisaged in Article 30.5 of the RGPD is applicable, a register of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.
Principles applicable to the processing of personal data
The processing of the User’s personal data will be subject to the following principles contained in article 5 of the RGPD and in article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights:
- Principle of legality, loyalty and transparency: the User’s consent will be required at all times, after being informed in a completely transparent manner of the purposes for which the personal data are collected.
- Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
- Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
- Accuracy principle: personal data must be accurate and always updated.
- Principle of limitation of storage time: personal data will only be kept in such a way as to allow identification of the User for the time necessary for the purposes of processing.
- Principle of integrity and confidentiality: personal data will be processed in such a way as to guarantee their security and confidentiality.
- Principle of proactive responsibility: the data controller will be responsible for ensuring that the above principles are complied with.
Categories of personal data
The data categories dealt with in Apartamentos Centro Jardines are only identifying data. In no case are special categories of personal data processed within the meaning of article 9 of the RGPD.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Apartamentos Centro Jardines undertakes to obtain the express and verifiable consent of the User for the processing of his personal data for one or more specific purposes.
The User shall have the right to withdraw his/her consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent shall not condition the use of the Website.
On the occasions when the User must or may provide his or her data through forms to make enquiries, request information or for reasons related to the content of the Web Site, he or she will be informed if the completion of any of these forms is mandatory because they are essential for the correct development of the operation carried out.
Purposes of the treatment to which the personal data are destined
Personal data are collected and managed by Apartamentos Centro Jardines in order to facilitate, speed up and fulfil the commitments established between the Web Site and the User or the maintenance of the relationship established in the forms that the latter fills in or to deal with a request or query.
Likewise, the data may be used for the commercial purpose of personalisation, operations and statistics, and activities inherent in the corporate purpose of Apartamentos Centro Jardines, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.
At the time the personal data is obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used; in other words, the use or uses that will be made of the information collected.
Periods of retention of personal data
The personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: as long as the business relationship is maintained or you do not request its termination and during the period for which legal liability may arise for the services provided, or until the User requests their deletion.
At the time when the personal data are obtained, the User will be informed about the period of time during which the personal data will be kept or, when this is not possible, the criteria used to determine this period of time.
Recipients of personal data
The User’s personal data will not be shared with third parties.
In any case, at the time the personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.
Personal data of minors
In compliance with the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Apartamentos Centro Jardines. In the case of minors under 14 years of age, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.
Secrecy and security of personal data
Apartamentos Centro Jardines undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of the personal data and to avoid the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted in a secure and confidential manner, as the transmission of data between the server and the User, and in feedback, is fully encrypted or unencrypted.
However, since Apartamentos Centro Jardines cannot guarantee the inexpugnability of the Internet or the total absence of hackers or others who access personal data in a fraudulent manner, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. In accordance with the provisions of article 4 of the RGPD, a violation of the security of personal data is understood to be any violation of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.
The personal data will be treated as confidential by the data controller, who undertakes to inform of and to ensure by means of a legal or contractual obligation that such confidentiality is respected by his employees, associates, and any person to whom he makes the information accessible.
Rights arising from the processing of personal data
The User has over Apartamentos Centro Jardines and may, therefore, exercise against the Data Controller the following rights recognised in the RGPD and the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:
- Right of access: This is the right of the User to obtain confirmation of whether or not Apartamentos Centro Jardines is processing his personal data and, if so, to obtain information on his specific personal data and the processing that Apartamentos Centro Jardines has carried out or is carrying out, as well as, among other things, the information available on the origin of such data and the recipients of the communications made or planned.
- Right of rectification: This is the User’s right to have his personal data modified if they are found to be inaccurate or, taking into account the purposes of the processing, incomplete.
- Right of suppression (“the right to forget”): This is the right of the User, provided that the legislation in force does not stipulate otherwise, to obtain the deletion of his or her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other legal basis; the user opposes the processing and there is no other legitimate reason to continue it; the personal data has been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a person under 14 years of age. In addition to the deletion of the data, the data controller must, taking into account the available technology and the cost of its implementation, take reasonable steps to inform the data controllers who are processing the personal data of the data subject’s request for the deletion of any link to those personal data.
- Right to limit processing: This is the right of the User to limit the processing of his or her personal data. Users have the right to obtain limitation of processing when they contest the accuracy of their personal data; the processing is unlawful; the data controller no longer needs the personal data, but the user needs it to make a claim; and when the user has objected to the processing.
- Right to the portability of data: Where processing is carried out by automated means, the User shall have the right to receive from the Data Controller his personal data in a structured, commonly used and machine-readable format and to transmit them to another Data Controller. Wherever technically possible, the data controller will transmit the data directly to that other controller.
- Right to object: This is the user’s right not to have his or her personal data processed or to have it stopped by Apartamentos Centro Jardines.
- Right not to be subject to a decision based solely on the automated processing, including the creation of profiles: This is the right of the User not to be subject to an individualised decision based solely on the automated processing of his or her personal data, including the creation of profiles, unless otherwise provided for by law.
Users may therefore exercise their rights by writing to the Data Controller with the reference “RGPD-apartamentos-centrojardines.com/en”, specifying
- Name, surname(s) of the user and a copy of the ID card. In those cases in which representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other legally valid means of proof of identity.
- Request with the specific reasons for the request or information you wish to access.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that accredits the request made.
This application and any other attached documents may be sent to the following address and/or e-mail:
Postal address: C/ Cardenal Quevedo 12 – 2B Madrid
Links to third party websites
The Web Site may include hyperlinks or links that allow access to the web pages of third parties other than Apartamentos Centro Jardines, and which are therefore not operated by Apartamentos Centro Jardines. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way his or her personal data is being processed, he or she shall be entitled to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he or she has his or her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).