At Hotelbeds Group, we are concerned about your privacy. This policy describes what, why and how we collect and use your personal data, how we protect it and how you can get in touch with us.
More to the point, this policy regulates the processing of data carried out by Hotelbeds Group, S.L.U. (hereinafter, “Hotelbeds”), a legally constituted Spanish company which operates as a wholesale-retail travel agency, based in Palma de Mallorca (Spain), Cami de Son Fangos No. 100, Complejo Mirall Balear, Tower A, 5th floor, 6A-7A, 07007, with license number C.I. BAL-429, tax identification code No. B-28916765 and registered in the Mercantile Register of Palma de Mallorca on 28 March 1984, page PM-38224, volume 1825, sheet 217., as the controller of your data and a company of Hotelbeds Group, through this website (hereinafter, the “Website”).
This policy covers the processing of personal data of (i) clients and/or potential clients, (ii) suppliers and/or potential suppliers and (iii) candidates who wish to be future employees who access or transmit information through the Website. Therefore, this policy provides information regarding the processing of data with respect to the different categories of data subjects previously indicated.
If you are a user that does not fit into any of the categories listed above, please refrain from contacting or providing your personal data to Hotelbeds. In any case, you are informed that, if you contact Hotelbeds outside of the aforementioned cases, your data will be automatically deleted.
1. What are the purposes and lawful basis of the processing of your data carried out by Hotelbeds?
The data that Hotelbeds requests or may request from you is necessary for the purposes described in this policy and failure to provide it may lead Hotelbeds to be unable to contact you or manage your requests.
Hotelbeds reserves the right not to respond or process requests that do not include all the data that is requested.
By providing Hotelbeds with your data, you guarantee the veracity of the same and accept that Hotelbeds may periodically request the review and update of personal data that you keep.
1.1. In the event that you are a client or potential client of Hotelbeds
On this Website, you can find information that may be useful in order to learn about the services offered by Hotelbeds. In this sense, Hotelbeds will only request you and, therefore, will process the necessary data to provide you with the services you contracted or to be able to initiate and maintain a commercial and/or contractual relationship with you.
More to the point, the purposes for which your data may be processed by Hotelbeds and the lawful basis for that processing is as follows:
1.2. In the event that you are a provider or potential provider of Hotelbeds
On this Website, you can find information that may be useful in order to be informed of the activity of Hotelbeds. For this purpose, if you are or represent a supplier or a possible supplier of Hotelbeds and decide to contact Hotelbeds, the data that will be processed will be the necessary to initiate and maintain a contractual relationship with you, in case of that is an individual entrepreneur, or with the company that you represent.
More to the point, the purposes for which your data may be processed Hotelbeds and the lawful basis for that processing is as follows:
1.3. In the event that you are a candidate to be an employee of Hotelbeds and contact Hotelbeds through this Website
Through this Website, you can contact Hotelbeds in case you wish to submit your CV to participate in the selection processes that could be eventually carried out to incorporate new personnel to the company. For this purpose, Hotelbeds will request and, therefore, process the necessary data to manage your possible participation in selection processes, as well as to keep you informed of the possible selection processes in which you could fit in the future.
More to the point, the purposes for which your data may be processed Hotelbeds and the lawful basis for that processing is as follows:
1.4. Data processing coupled with mere navigation through the Website
In order to improve our services, to provide you with more relevant content and to analyze how visitors use this Website, we may use technologies, such as cookies or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies. Nevertheless, when said technologies are personally identifiable, Hotelbeds will process your personal data based on our legitimate interest of providing you with the best service on the Website and in the evaluation, improvement and simplification of the performance of our Website.
2. Who are the third parties to which your personal data may be shared?
The personal data that you provide to Hotelbeds may be communicated to the following categories of recipients:
- Third parties to which Hotelbeds is obliged to transmit information, such as public authorities, in order to comply with the requirements of said authorities and the applicable regulations, as the case may be.
- Companies that are part of the Hotelbeds Group, with the purpose of being able to properly manage and optimize your contractual relationship as a result of the centralization of administrative and computer processes existing within the Hotelbeds Group (whose relation you may consult on our webpage [indicate webpage]).
In addition, we inform you that the Hotelbeds Group can count on companies outside the European Union. In those cases, Hotelbeds, as a company of Hotelbeds Group, requires that these companies comply with the measures designed to protect personal data established in a binding contract, except in cases where the European Commission has determined that the country where said companies are located provide for an adequate level of protection of personal data. In this regard, Hotelbeds cooperates with Salesforce, acting the later as a data processor of Hotelbeds. Said processing activities might entail an international transfer of data to the USA. The transfer of data to Salesforce is subject to appropriate safeguards. More to the point, Salesforce is certified under the EU-U.S. Privacy Shield Framework.
Apart from the above communications, Hotelbeds may also work with service providers that may have access to your personal data and that process the aforementioned data in the name and on behalf of Hotelbeds as a result of the provision of services. In this sense, Hotelbeds has entered into the corresponding data processing agreements with each of the suppliers that provide services to Hotelbeds, with the aim of guaranteeing that said suppliers will process your data in accordance with the rules laid down in current legislation and in compliance with Article 28 of the GDPR.
Specifically, the aforementioned service providers of Hotelbeds are included, by means of example but not limited to the following sectors: logistics, legal services, training services, medical services, maintenance, transport, technology and IT services.
Finally, should you wish, you may obtain a copy of the complete measures required by Hotelbeds to ensure compliance with applicable laws and regulations by contacting our Data Protection Officer by the contact details indicated below.
3. How does Hotelbeds protect your data?
Hotelbeds has appropriate policies and has put into place technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss or accidental destruction, damage, use and illegal or unauthorized disclosure.
At Hotelbeds, we will also take all reasonable precautions to ensure that our staff and employees who have access to your personal data have received adequate training.
In any case, please note that any transmission of data through the Internet is not completely secure and, as such, must be carried out at your own risk. Although we will do our best to protect your personal data, Hotelbeds cannot guarantee the security of the personal data transmitted through this Website.
4. For how long does Hotelbeds keep your data?
The retention period of your data will be determined according to the duration of your contractual relationship with Hotelbeds and the deadlines defined by law. In this sense, the criteria that Hotelbeds uses to set the terms of retention of your data have been determined in accordance with the requirements established in the applicable legislation, regulations and guidelines, as well as the operational requirements of Hotelbeds related to the correct management of the relationship with its customers.
In this sense, your data will be stored while you maintain any kind of commercial or contractual relationship with Hotelbeds. After said relationship ceases, your personal data will be erased at the time that all the necessary actions, and administrative managements, have been carried out in order to manage and give by conclude any obligation that may remain between you and Hotelbeds.
Notwithstanding the foregoing, your data will be stored, duly blocked, as long as responsibilities for the execution of our contractual or pre-contractual relationship may be derived, as well as for the fulfilment of other legal obligations in charge of Hotelbeds. On this matter, Hotelbeds guarantees that it will not process the data unless it is necessary for the formulation, exercise or defense of claims, or, when this is required in order to facilitate them to the Public Administration, Judges and Courts during the prescription period of their rights or legal obligations.
5. How can you exercise the rights over your personal data?
You may exercise your rights of access, rectification, erasure, objection, limitation and portability, as well as to withdrawal at any time the consents you have previously given us, by mail to Camí de Son Fangos, 100, Torre A, 5ª Planta, 3A-4A, 07007 Palma de Mallorca, Spain or by sending an email to firstname.lastname@example.org. Should you wish, you may also contact our Data Protection Officer as the contact details indicated below.
Furthermore, if appropriate, you can lodge a claim to the Spanish Data Protection Authority, especially if you consider that we have not adequately addressed your rights, by accessing www.aepd.es or at the address Calle Jorge Juan, 6, 28001, Madrid.
6. How can you contact us?
If you have questions or comments in relation to data protection matters, you may contact our Data Protection Officer, which contact details are as follows: email@example.com.
Last update: 11/06/2019
8.- Intellectual/industrial property and other rights
8.1 Website content
All the designs, brands, patents, names, images, logos, graphics, icons, applications and other website content are the property of HOTELBEDS, or where applicable HOTELBEDS has a licence for their use, and are under protection from industrial and property rights. Under no circumstances does access to the website imply a transfer of said rights by HOTELBEDS to the CLIENT, which may not make any commercial use of such content, or in any way alter, reproduce, distribute or publicly communicate said content without authorisation by HOTELBEDS.
The CLIENT recognises and agrees that, with the exception of the regulations herein provided, it shall acquire no right or interest with regard to the information or data to which it has access, and that HOTELBEDS shall continue to be the sole owner of the information and data, including but not limited to all patents, copyrights, brands, business secrets, commercial names, contracts, industrial designs and other property rights belonging to them, anywhere in the world.
All brands, copyrights, database rights and other intellectual and industrial property rights over the contents of the website (and its organisation and appearance), as well as the source codes, are the property of HOTELBEDS or its providers. Neither the CLIENT nor any other representative may copy, modify, alter, publish, publicly communicate, distribute, sell or transmit the contents of this website or its source code, either wholly or in part, without written authorisation from HOTELBEDS.
In the event of the CLIENT making inappropriate use of any brand belonging to HOTELBEDS, without the express authorisation of HOTELBEDS through the corresponding licence, the CLIENT shall be immediately denied access to the HOTELBEDS product, which shall not affect the right of HOTELBEDS to bring any legal action it deems fit in defence of its rights.
With the exception of the stipulations in the General Conditions, the CLIENT is prohibited from copying, reproducing, modifying, transmitting, selling, leasing, marketing or disclosing the contents (and/or any of their elements) provided and disclosed by HOTELBEDS.
The CLIENT recognises and accepts that merely revealing or accessing the information or data available on this website does not constitute an offer by HOTELBEDS for the sale or transfer of such elements.
8.4 Content waiver
The information on this website has been entered in good faith and with reasonable diligence. HOTELBEDS cannot guarantee that the content is completely free of defects or typographical errors, and as such HOTELBEDS accepts no liability whatsoever for any errors or omissions that may exist on this website. The information on accommodation and other services provided by HOTELBEDS is as accurate as possible derived from the information supplied by the various service providers. HOTELBEDS is not responsible for any inaccuracies in the information with regard to the actual service provided by the service providers.
The website may include links to third-party websites, which are provided solely for purposes of information. Any such websites are independent from HOTELBEDS, which shall not be held responsible for them or for any material that they may contain.
The service providers promoted on our website are independent entities and entrepreneurs and in no case are they agents, representatives or employees of HOTELBEDS. They provide their services in accordance with their Terms and Conditions, which may limit or exclude their liability with regard to the CLIENT or the CLIENT. HOTELBEDS and its affiliates are not liable for any action, omission, negligence or breach of contract by these independent entities and entrepreneurs, or for any damages or costs that may result from such circumstances. HOTELBEDS and its affiliates are not liable for any reimbursements in the event of overbookings, force majeure or any other cause beyond control of HOTELBEDS.
To the extent permitted by Law, HOTELBEDS excludes any implicit guarantee with regard to the veracity and accuracy of the information, services and materials contained in this website. Such information, services and materials are provided as they are by the service providers and subject to availability, with no guarantee of any kind.
The liability of HOTELBEDS will not under any circumstances exceed the amount paid by the CLIENT to HOTELBEDS for the specific services offered, regardless of whether said liability is the result of a breach of these Terms and Conditions, a breach of the agreement that these Terms and Conditions relate to, an action or omission that violates any legal or regulatory obligations, or any other cause.
Some of our websites and emails with HTML format may use markers and/or cookies to compile statistics regarding the usage of HOTELBEDS. One web marker is an image placed in the message to inform HOTELBEDS that said message has been viewed, with the sole purpose of compiling usage statistics.
If you are using this website this means that you accept and agree with the information provided herein, and therefore that you accept these Terms and Conditions.
Furthermore, it is the sole responsibility of the CLIENT to ensure that these Terms and Conditions are brought to the attention and obtain the acceptance of its end consumers, intermediaries and any other person or company involved that may affect or be affected by said Terms and Conditions. By facilitating any transaction carried out through this website, the CLIENT accepts that these Terms and Conditions apply to each and every transaction made.
14.- News bulletins
HOTELBEDS does not automatically subscribe users to our news bulletin. To receive it, you are given the option of subscribing. If you do subscribe, you can be informed by email of hotel news and offers. If you wish to unsubscribe from receiving our news bulletins, you can do so in the “News bulletins” section.
In the event that HOTELBEDS fails to apply any of the stipulations set out in the previous points, under no circumstance shall this be deemed to be a waiver of said stipulation.
16.- Regulatory references
All regulatory references made in these Terms and Conditions are understood to have been made in observance of the regulation indicated herein, of the regulation that it is replaced by or by whichever regulation is in force at any time.
17.- Legislation and privilege
These Terms and Conditions and any non-contractual obligations arising out of or in connection with it, shall be governed by the laws of Spain.
Without prejudice to the above, in case of judicial dispute, each party agrees that the governing law shall be the one of the domicile of the defendant.
Each party agrees that courts of the country of domicile of the defendant of the relevant action shall have exclusive jurisdiction to determine any dispute arising out of or in connection with this Agreement (including in relation to any non-contractual obligations). Any counterclaims shall be ignored in deciding who the defendant is. Where there are separate but related actions the courts with jurisdiction shall be decided by the first of such actions to be issued. Each party irrevocably waive any right that it may have to object to an action being brought in such courts, to claim that the action has been brought in an inconvenient forum, or to claim that such courts do not have jurisdiction.