PRIVACY POLICY
1. Introduction
At CREATIUM LIVING, SL, we are committed to the protection of privacy and the correct use of the personal data that we process and that you provide us, both online on this website and, where appropriate, any of its subdomains, microsites, such as offline
Please read this policy carefully and make sure that you understand and agree to it before providing us with your personal data. If you do not agree with it, do not use this website or its services or provide us with your data.
The fact of accessing this site, using any of its services or providing us with your data, whether online or offline, we will understand as a clear affirmative action by which you give us your consent (when necessary) to treat your data for the purposes indicated below.
2. Who is responsible for processing your data?
CREATIUM LIVING, SL
Postal address: C/ Eduardo Dato, Nº 37, Bajo Izquierda. 01005- (Vitoria-gasteiz) - Álava
Email: info@zuiasuites.com
Telephone: 638527168
3. How have we obtained your data?
3.1 Obtaining the interested person himself.
If you are a customer (current or potential), or user of our website, you have provided them, either offline or online, when requesting our services, or contacting us requesting information.
By providing us with your data, you guarantee that you are enabled to do so, and that the information is true, up-to-date, and that it does not violate any contractual restrictions or rights of third parties. You are responsible for keeping your data and your profile correct and up-to-date, declining all responsibility CREATIUM LIVING, SL in case of not doing so. you commit not to impersonate other Users using their registration data for the different services and/or contents of the Website.
3.2 Obtaining automatically when visiting our website:
When you visit our website or our social media profiles, we collect information through cookies and other tracking technologies and web analytics. This means that data is sent from your browser to our servers to optimize our services and improve your user experience. Such data may be automatically collected and stored by us or by third parties on our behalf. You can consult our cookie policy.
The categories of data that may include are: IP address of the user, the date and time of the visit, the URL of the site from which the user came, the pages visited on our website, information about the browser used (type and version browser, operating system, etc.).
3.3 Communication by a third party of the data of the interested party.
It is possible that your data has not been provided to us directly by you, but has been provided to us by a third party with whom we work, to whom you have previously provided that data. For example:
a) The websites with which we collaborate to make reservations and through which you have been able to provide your data. Currently (www.booking.com ; www.airb&b )
b) Parents, guardians or legal representatives in the case of minors under 14 years of age.
Whoever makes the reservation must inform us by traveler registration regulations of a series of personal data related to those other travelers who are going to stay with us. In these cases, the categories of data that we process may be: identification data (name and surname, NIF/CIF, gender, nationality, date of birth, signature) contact data (telephone, place of habitual residence, town, country) number of travelers and family relationship (in the event that any of them is a minor)
3.4 Communication of third party data:
With respect to the data of other people, you must respect their privacy, taking special care when communicating or publishing their personal data. Only its owner can authorize the processing of their personal data. The publication of data of third parties without their consent may violate, in addition to the regulations on data protection, those relating to the right to honour, privacy or the image of said third parties.
If you provide us with data from third parties, it is your responsibility to have their prior and express consent to use them, and it is your duty to inform them of the treatment that we are going to carry out with their data. By accepting this privacy policy, you expressly guarantee that you have the authorization for said contribution, exonerating us from any responsibility in the event of any claim by an interested person.
4. What types of data do we process?
The categories of data we process can be:
Obtained from the interested person: identification data (name and surname, NIF/CIF, gender, nationality, date of birth, signature, (selfie) image), contact data (telephone, postal address, email address, invoice address , place of habitual residence), commercial and economic data (information on the services requested, customer history, and those necessary for payment: bank, credit card...)
Obtained automatically when visiting our website: IP address of the user, the date and time of the visit, the URL of the site the user came from, the pages visited on our website, information about the browser used (type and browser version, operating system, etc.). Also data from online profiles (information on preferences and interests, browsing or purchasing habits, what commercial actions have been carried out or what information has been requested), to be able to send you personalized information or exclusive campaigns...
Communicated by a third party: identification data (name and surname, NIF/CIF, gender, nationality, date of birth), contact data (telephone, postal address, email address, invoice or delivery address, place of habitual residence) family relationship in the case of minors
Regarding data with special protection: We do not treat special categories of data
5. Why do we treat your data and with what legitimacy?
The data that you provide us, as well as all that generated during the development of the relationship that we maintain with you, can be processed for different purposes and with different legitimations.
Summary table of purposes and their legal basis
PURPOSE
Maintain contact and communication, manage the contractual and/or pre-contractual relationship.
to manage the requests you make to us online, and to contact you.
Send potential customers, through electronic communications, information about our activities, and/or services similar to those requested
Installation of non-technical cookies
Transfers derived from regulations that is applicable to us (TRAVELLER REGISTRY DATA)
Send current clients, through electronic communications, information about our activities, and/or services similar to those requested
Installation of technical cookies
Carrying out opinion/satisfaction surveys
In the case of users of our website, or sender or recipient of an email: to manage those made online, and to contact you
Security and video surveillance of our facilities
LEGAL BASE
contractual relationship or application of pre-contractual measures at the request of the interested party (art. 6.1. b RGPD)
Consent
Compliance with regulations or legal obligation: Regulations of the Department of the Interior of the Basque Government on passenger registration.
Legitimate Interest
Public interest
When the legitimacy is based on consent, you can withdraw that consent at any time by sending us an e-mail to that effect to info@zuiasuites.com. Said withdrawal does not condition the processing of your data for the rest of the purposes described.
If the indicated treatment of your data is based on our legitimate interest, we consider that it is proportionate and has a minimal impact on your privacy, but your interests, rights or freedoms will always prevail over our legitimate interest, so that, if you do not want us to we treat your data for these purposes, please send us an e-mail in this regard to info@zuiasuites.com and we will do so.
The provision of the requested data is mandatory as it is essential to formalize and/or maintain the contractual or pre-contractual relationship and comply with the legal obligations derived from it; if you do not provide them, we will not be able to provide the service derived from said relationship.
6. How long will we keep your data?
We will keep the personal data that you provide us while the contractual, pre-contractual or commercial relationship is maintained and, once these have ended, as long as the interested party does not request its deletion. Even if the deletion is requested, we can keep them for the necessary time and limiting their treatment, only to:
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Comply with the legal/contractual obligations to which we are subject,
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and/or during the legal periods provided for the prescription of any liability on our part,
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and/or the exercise or defense of claims derived from the relationship maintained with the interested person.
In coordination with the above criteria, the deletion of personal data, whether in computer records or on paper, may be carried out, at the discretion of the organization, based on logistical needs and/or storage space that make it advisable to delete information or documentation.
7. To which recipients can we communicate your data?
We inform you that the data you provide us may be communicated to third parties for the fulfillment of purposes directly related to legitimate functions of assignor and assignee such as:
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To banking entities and/or providers of means of payment: for the management of collections and payments.
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To the entities or organizations to which there is a legal obligation to communicate data: for example, to the Tax Administration, to the Department of the Interior of the Basque Government.
8. International Data Transfers
At CREATIUM LIVING, SL, we will ensure that personal data is always processed and located in the European economic area. However, in certain circumstances, we may make international data transfers, for example, if it is necessary for the conclusion or execution of a contract, in the interest of the interested party, between CREATIUM LIVING, SL and another natural or legal person; or in the event that it is necessary for the execution of a contract between the interested party and CREATIUM LIVING, SL, for example when using service providers located outside the European Union, which may have access to personal data, for the provision of auxiliary services to our activity (hosting, housing, SaaS, remote backups, computer support or maintenance services, email managers, sending emails and email marketing, file transfer, etc...) or for the execution of pre-contractual measures adopted at the request of the interested party.
These entities may be different and vary over time, but we will try to choose entities, either belonging to countries that have a level of protection equivalent to that of Europe in terms of data protection, or that have adequate guarantees to reach that level, or they will be made on the basis of any of the exceptions provided for in the RGPD.
9. Social networks and instant messaging applications.
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Use of WhatsApp instant messaging
In the event that we make an instant messaging App available to you to speed up communication with you, use it responsibly, read its privacy policy and configure it according to your preferences before sending information with personal data by said means.
Although this type of instant messaging applications can be useful in certain circumstances, we remind you that the information you publish on the Internet is accessible to many people, known or unknown, so there is a risk to your privacy and that of others.
We recommend that you do not provide personal, private and/or intimate information or information that you want to keep confidential by this means, as there are safer ways to do so. We cannot be held responsible for the operation and availability of the service since it is not provided by us but by third parties unrelated to us.
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Use of social networks
Users have the opportunity to join the pages or groups that the organization has in different social networks. They must take into account that, unless the organization requests their data directly (for example, to answer queries in a private environment), their data will belong to the corresponding Social Network. Therefore, users are recommended to carefully read the terms and conditions of use and the privacy policies of the corresponding Social Network, as well as make sure to configure their preferences regarding the processing of their data.
Characteristics of Social Networks incorporated in our website:
Our Services may include certain Social Media features and widgets, such as "Facebook Connect" connectors, "Like" button, "Share It" button, or other common social media interactive mini-programs. We are not responsible for the correct operation of these.
Rules of use of social networks:
Keep in mind that, if you decide to participate, publish or share content through our official page on a social network, said content will be public , and it will be your sole responsibility that said content complies with legal regulations.
You can prevent your personal data from appearing associated with said participation, configuring your privacy, or pseudonymizing your data (eg: using a "Nick" or "alias").
We remind you that, with respect to the data of other people, you must respect their privacy, taking special care when communicating or publishing their personal data. Only its owner can authorize the processing of their personal data.
The user may only publish on this page, or on our official page on social networks, personal data, photographs and information or other content whose ownership and property belong to him or for which he has the authorization of third parties. If you provide us with or publish data from third parties, it is your responsibility to have their prior and express consent to use, communicate and publish them, and it is your responsibility to inform them of the processing of their data by us or its publication by you. The publication of data of third parties without their consent may infringe, in addition to the regulations on data protection, that relating to the right to honor, privacy or the image of said third parties.
In any case, we will be able to eliminate both from this website and from our pages on social networks, any content published by the user when we detect that it has violated current legislation, and what is indicated in this privacy policy.
Social Networks are not hosted directly on our Services. Your interactions with them are governed by their policies and not ours. Read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, your rights and about your privacy settings.
10. What are your rights when you provide us with your data?
You can, when appropriate, exercise your rights of access, rectification, deletion, limitation and opposition to your treatment, as well as other rights, at the postal or electronic mail address indicated at the beginning of this privacy policy; in both cases by written and signed request attaching a copy of the DNI or passport or other valid document that identifies you. In case of modification of your data, you must notify it at the same address, declining this entity all responsibility in case of not doing so.
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Right of access: You can ask us what personal data we are treating, including requesting a copy of them.
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Right of rectification: You can request the rectification of inaccurate personal data or that we complete those that are incomplete, including by means of an additional statement.
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Right of deletion (right to be forgotten): You can request the deletion of your personal data when: they are not necessary for the purposes for which they were collected, you withdraw your consent, there has been an illicit treatment of them or due to compliance with a legal obligation .
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Right to limitation of treatment: You can request us to limit the treatment of your data, in which case we will only keep them for the exercise or defense of claims.
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Right of opposition: You can oppose the processing of your data if said processing is based on the legitimate interest of the data controller or is for advertising purposes.
Once any of the above requests have been received, we will respond within the legally established deadlines. You can claim before the Spanish Data Protection Agency. If you want more information about the rights you can exercise and to request model forms for exercising rights, you can visit the website of the Spanish Agency for Data Protection, www.aepd.es