I. PRIVACY AND DATA PROTECTION POLICY
In compliance with the provisions of current legislation, Vilanova Apartments (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 natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
Royal Decree 1720/2007, of 21 December, approving the Regulation 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 party responsible for the processing of the personal data
The party responsible for the processing of the personal data collected at Vilanova Apartments is: Vilanova Apartments SL, holder of Tax Identification Number: B65611162 and registered in: Rgistro mercantil de Barcelona with the following registry details: Tomo 42.739, Folio 210, sheet number B-411.391, whose representative is: Vilanova Apartments (hereinafter, Data Controller). Its contact details are as follows:
Address: Rambla Salvador Samá 18A
Contact telephone number: 637250157
Contact email: email@example.com
Register of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Vilanova Apartments, through the forms provided on its pages will be included and processed in our file in order to facilitate, expedite and fulfill the commitments established between Vilanova Apartments and the User or the maintenance of the relationship established in the forms filled in by the User, or to respond to a request or query from the User. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a register of processing activities is kept which 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 shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:
Principle of lawfulness, fairness, and transparency: the consent of the User shall be required at all times following fully transparent information on the purposes for which the personal data is collected.
Purpose limitation principle: personal data will be collected for specified, explicit, and legitimate purposes.
Principle of data minimization: personal data collected will be only that which is strictly necessary for relation to the purposes for which they are processed.
Accuracy principle: personal data must be accurate and always up to date.
Principle of limitation of the storage period: personal data shall only be kept in a form that allows the identification of the User for the time necessary for the purposes for which they are processed.
Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.
Principle of proactive accountability: the Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by Vilanova Apartments are both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.
Special categories of personal data are understood to be data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data relating to health or data relating to the sex life or sexual orientation of a natural person.
For the processing of special categories of personal data, the explicit consent of the User for one or more specific purposes shall, in any case, be required.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Vilanova Apartments undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User will have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent shall not condition the use of the Website.
On those occasions when the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed in the event that the completion of any of them is compulsory because they are essential for the correct development of the operation carried out.
Purposes of the processing for which the personal data is used
The personal data is collected and managed by Vilanova Apartments in order to facilitate, expedite and fulfil the commitments established between the Website and the User or to maintain the relationship established in the forms that the latter fills in or to respond to a request or query.
Likewise, the data may be used for commercial, personalisation, operational and statistical purposes, and activities inherent to the corporate purpose of Vilanova Apartments, as well as for the extraction and storage of data and marketing studies to adapt the Content offered to the User, and to improve the quality, operation and browsing 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 to which the information collected will be put.
Retention periods of personal data
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: 48 months, or until the User requests their deletion.
At the time the personal data is obtained, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.
Recipients of personal data
The User's personal data will be shared with the following recipients or categories of recipients:
-ENTORNODIGITAL. Carrer Josep Estivill, 11-13 08027 Barcelona (Spain) -ICNEA TECNOLOGÍA SL. Carrer de Mandri, 38, 08022 Barcelona -Google -Google Analytics
In the event that the Controller intends to transfer personal data to a third country or international organisation, the User will be informed at the time the personal data are obtained about the third country or international organisation to which the data are intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.
Personal data of minors
In compliance with the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of 5 December, 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 Vilanova Apartments. In the case of a minor under 14 years of age, the consent of the 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
Vilanova Apartments undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent 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 is transmitted securely and confidentially, as the transmission of data between the server and the User, and in return, is fully encrypted or encoded.
However, due to the fact that Vilanova Apartments cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to entail a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.
Personal data shall be treated as confidential by the Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any person to whom it makes the information accessible.
Rights derived from the processing of personal data
The User has over Vilanova Apartments and may, therefore, exercise the following rights recognised in the RGPD and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights against the Data Controller:
Right of access: this is the User's right to obtain confirmation as to whether or not Vilanova Apartments is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Vilanova Apartments has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned for said data.
Right of rectification: This is the User's right to have their personal data amended if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
Right of erasure ("the right to be forgotten"): This is the User's right, unless otherwise provided for by law, to obtain the erasure of his or her personal data when they 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 objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under the age of 14. In addition to erasure, the Controller shall, taking into account the technology available and the cost of its implementation, take reasonable steps to inform controllers who are processing the personal data of the data subject's request for erasure of any link to those personal data.
Right to restriction of processing: This is the User's right to restrict the processing of his or her personal data. The User has the right to obtain the restriction of processing where the User contests the accuracy of his or her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and where the User has objected to the processing.
Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format and to transmit it to another controller. Where technically feasible, the Controller shall 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 cease the processing thereof by Vilanova Apartments.
Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualised decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.
Therefore, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD-http://vilanovaapartments.com", specifying:
Name, surname(s) of the User, and copy of ID card. In cases where representation is permitted, it will also be necessary to identify the person representing the User by the same means, as well as the document accrediting the representation. The photocopy of the DNI may be substituted by any other legally valid means that accredits identity.
Request with the specific reasons for the request or information to which access is sought.
Address for notification purposes.
Date and signature of the applicant.
Any document that accredits the request being made.
This application and any other attached documents may be sent to the following address and/or e-mail address:
Postal address: Rambla Salvador Samá 18A
Links to third party websites
The Website may include hyperlinks or links that allow access to third-party websites other than Vilanova Apartments, and which are therefore not operated by Vilanova Apartments. The owners of these 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 in which his or her personal data is being processed, he or she shall have the right 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).