Privacy policy

Version valid from 13/07/2021.

In general terms, this Privacy Policy (hereinafter, the “PRIVACY POLICY”) governs the collection and processing of the personal data that you provide to us as a user of the website, which can be accessed through the domain name www.sansebastianbiarritz.com/ (hereinafter, the “WEBSITE”), including the services that are available on the WEBSITE at any given time. Notwithstanding the specific provisions set forth in given sections, forms or services available on the WEBSITE, the purpose of the foregoing is to provide you with the relevant information and, where appropriate, obtain your consent.

The PRIVACY POLICY may be changed to accommodate any judicial and/or administrative legislative changes, and according to the products and services included in the WEBSITE at any given time, always taking into account your rights and interests..

In any event, we provide you with appropriate technical resources to allow you to access the PRIVACY POLICY in order to duly fulfil our duty of disclosure and comply with the applicable data protection regulations.

 

1. Who is the Controller of your data?

Your data will be jointly processed by the following entities, on the basis of the respective agreement between them (hereinafter, the “JOINT CONTROLLERS”):

2. How do we obtain your data?

The data that is processed by the JOINT CONTROLLERS has been obtained from you, through your browsing of the WEBSITE and/or through you sending a query email.

If the personal data provided belongs to a third party, you warrant that you have informed that third party of the PRIVACY POLICY and obtained their authorisation to provide their data to the JOINT CONTROLLERS, for the purposes set forth below.

3. What types of data do we process?

The data that is processed is that which is provided by you while browsing the WEBSITE, through the appropriate forms that we use to enter into contact with you and/or by email.

In particular, we process the following categories of data:

4. For what purpose do we process your data and on what lawful basis?

We process your data for the following purposes:

We remind you that, in cases where the basis of the processing is your consent, you may freely withdraw it at any time, at no cost, subject to the terms set forth in Section 7. below.

5. To whom do we disclose your data?

Excluding those cases where the JOINT CONTROLLERS are legally obliged to do so (e.g. Tax Authorities, Department of Justice or other public authorities), your data will not be disclosed to any third parties.

No international transfers of your data are anticipated.

6. How long do we retain your data?

Generally, the personal data will be retained for the time necessary to fulfil the purpose for which it was collected, as long as you do not withdraw your consent or request its erasure at an earlier juncture. It will also be retained for the additional time necessary to fulfil the legal obligations to which the JOINT CONTROLLERS are subject.

In any event, we inform you that the JOINT CONTROLLERS have established internal data cleansing policies aimed at controlling the retention periods for the personal data held by them, so that it can be erased when it is no longer necessary and/or appropriate for the purpose for which it was collected.

7. What are your rights?

The applicable data protection regulations grant you a set of rights related to your personal data, which you may exercise while it is being processed. Those rights are as follows:

Furthermore, when the basis for the processing in question is your consent, you have the right to withdraw it at any time; this will not affect the legality of the processing that was based on the consent given before it was withdrawn.

You may exercise these rights and/or withdraw your consent by sending a written request to each of the JOINT CONTROLLERS, by emailing the following email addresses:

Finally, we inform you that you may file a complaint with the competent Supervisory Authority (Spanish Data Protection Agency (AEPD) in Spain and the National Commission on Information Technology and Freedom (CNIL) in France), especially when you have not received satisfaction in the exercise of your rights. You can contact those Authorities through their websites: www.aepd.es and www.cnil.fr.

8. Security measures

The JOINT CONTROLLERS will process your data in a manner that is completely confidential at all times, always fulfilling their statutory duty of confidentiality in relation to it, in accordance with the provisions of the applicable data protection regulations. For such purpose, they will implement any technical and organisational measures that may be necessary to safeguard the security of your data and prevent any alteration, loss and processing thereof or unauthorised access thereto, taking into account the state of the art, the nature of the stored data and the risks to which it is exposed.

9. Cookie policy

Additionally, we inform you that a Cookie Policy has been established for the WEBSITE. This can be accessed on the following link.