Privacy Policy

Your privacy is our concern

THE HOTELS NETWORK, S.L.P (hereinafter known as “THN”, “we”, “our” or “us”, is a technology company specialised in offering services to hotels and hotel chains to boost their online reservations.

We believe that personal privacy is important, both for visitors to our website https://www.thehotelsnetwork.com/es/ (hereinafter, the “website”) and any other relevant persons who share information with us through our website, whose data are processed by THN as part of its service provision (hereinafter jointly and severally known as, “you” or the “user” and in plural “users”). Therefore, THN undertakes the processing of your data in accordance with the applicable personal data protection legislation in force at the time. Specifically, THN will comply with the provisions established in: Organic Law 15/1999, of 13 December on the protection of personal data and Royal Decree 1720/2007, of 21 December, by which the implementing Regulation was approved of the said Organic Law, in addition to the LEGISLATION (EU) 2016/678 OF THE EUROPEAN PARLIAMENT AND COUNCIL of 27 April 2016 on the protection of physical persons regarding the treatment of personal data and the free circulation of the data, and by which was derogated Directive 95/46/CE and any other applicable associated regulations in force at any given time."

Pursuant to the above, THN hereby states its Privacy Policy with the aim of informing its users about the treatment of their data, in addition to the basic principles of protecting personal data that apply. However, certain services that are provided or that may be provided in the future on the website may contain specific conditions of use with provisions on the protection of personal data, which may prevail over this Privacy Policy.

Consequently, we urge all our users to read this Privacy Policy carefully in order to learn about the standards and practices that we have devised to protect personal data and to understand better our partnerships with third parties who might have access to your data.

In any event, the user is the sole person responsible for the information provided on the website and if in future THN wanted to use the information for different purposes to the above, we will inform you of these purposes and ask for your consent, if necessary.

To use our website, you acknowledge that you have read and accepted this Privacy Policy, our Cookies Policy and our Legal Notice.

1. Who is responsible for the treatment?

Contact details of the data processing administrator: THE HOTELS NETWORK, S.L., with Tax ID No. B-65542714 with registered offices on Avda. Diagonal, 439, 3º-1ª, 08036 Barcelona and email contract address privacy@thehotelsnetwork.com being the email of the DPO (Data Protection Officer) of THN.

2.- What are the data protection rights of the users?

The users may claim the following rights:

  • Right to request access to their personal data: you can ask THN for access to your data, which if we are responsible for its processing, will be possible.
  • Right to request a rectification of the data if incorrect, or to add to the data if incomplete.
  • Right to request the deletion of the data.
  • Right to request a limitation on its processing: in this case we will only retain the data for making or defending claims.
  • Right to object to processing: THN will stop processing personal data, except to continue its processing for legitimate reasons or for making or defending claims.
  • Right to transfer the data: in the event that the user wishes to have their data processed by another party, THN will facilitate the transfer of their data to the new party.
  • Right to not be subject to decisions based solely on an automated processing of their personal data.

If you have given your consent for a specific purpose, you may withdraw your consent whenever you want, without this affecting the legality of treatment based on the previous consent before its withdrawal.

In whichever case, at the time the user exercises their right of deletion, all personal data linked to your account, as well as the information and content included in your profile will be deleted. In addition, if the user exercises the right to delete data necessary for THN to provide services from the website, THN will be obliged to end its relationship with the user, and will proceed to deactivate the account, with the user having no right of complaint.

To exercise their rights, the users must send a written communication to THN’s company office or to the email address stated in section 1 of this Privacy Policy, including in both cases a photocopy of your national identity card or equivalent identity document.

3. How to make a claim at the Agencia Española de Protección de Datos (Spanish Data Protection Agency)?

You can use the templates and forms concerning the rights referred to in the previous points addressing them to the official page of the Spanish Data Protection Agency (http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/ejercicio_derechos/index-ides-idphp.php).

Claims lodged before the Supervisory Authority: If you consider that THN is manipulating your personal data inappropriately, you can direct your complaint to the DPO of THN or the relevant Supervisory Authority. In Spain the claim must be addressed to the Agencia Española de Protección de Datos.

4. In what ways do we collect your personal data and what sort of data is it?

For the purpose of this Privacy Policy, “personal data” means any information that identifies you or is able to be used to identify you, such as for example your name, address, telephone number or email address.

If you decide to provide us with your personal data, THN may use the data included in any of the forms that you complete or the data that you submit to us via the various email accounts that THN puts at your disposal to contact us.

This data is processed when you interact with THN and our representatives; when you participate or request that you be considered to participate in activities related with THN, such as provision of services or online surveys about our services; when you respond to any of our employment offers, when you interact with the website when requesting that you submit personal data, as described in this Privacy Policy and Cookies Policy; by registering on our website or using certain functions without registering, such as using our interactive services.

For more information on THN’s use of cookies, consult our Cookies Policy.

5. How do we use personal data of users?

THN communicates to those users to whom it applies, that the personal data that they provide to us and we store shall be identified in the Register of Processing Activities belonging to THN, which is used for the purpose of:

  • Answering enquiries and information requests that the users may make;
  • To provide users, at their request, with a demo of our services;
  • To provide our services, in accordance with the Legal Notice and Terms and Conditions, if applicable, that are established between THN and each of the users;
  • Respond to a candidate’s application for a job vacancy.
  • The use or provision of services, if applicable before registration of the user, in accordance with the general conditions of Use of the Website and the specific conditions of certain services;
  • To personalise and improve the tools and functions of the Website, and to ensure the technical functioning of the site;
  • If the user has checked the appropriate box to opt in, to keep them informed by sending them notifications/newsletters by email and/or other electronic means, the content of which will mainly be about our services, activities, projects, updates and new features of the website.
  • To use it for any other purpose required or permitted by the applicable legislation or by you having given consent.

6. Why do we process your personal data?

THN can process your personal data based on any of the following legal grounds: (A) legitimate commercial ends; (B) when you have given consent; (C) when it is necessary to comply with legal and regulatory obligations of THN and (D) when it is necessary for the fulfilment of a contract to which you are a party.

7. Who can access your personal data?

Depending on the reasons why the personal data has been collected, the following persons can access, jointly and severally, the said information:

  • Authorised personnel of THN or its representatives acting in the name of THN, subject to the data protection laws that are applicable;
  • Regulatory authorities or other third parties in compliance with the applicable laws;
  • Third parties (service providers that process information as data processing contractors, as instructed by THN). However, only after carrying out due diligence to ensure that we could share the information in compliance with the applicable data protection laws.

We do not sell, nor divulge to third parties any information or personal data that you have submitted on our website and may identify you directly or indirectly.

8. Where is your personal data processed?

THN does not transfer personal data outside of the European Economic Area (EEA). If such transfers were to take place, THN would carry out the transfer in accordance with the applicable data protection laws. Regardless of the place where your personal data is collected and treated, THN supervises and ensures that the service providers maintain the appropriate administrative, technical and physical security measures to protect your information.

For more information on the the use of contract templates by THN, contact us on privacy@thehotelsnetwork.com.

10. For how long do we store personal data?

THN processes your personal data for the period necessary to comply with the purposes set out in the Privacy Policy, and to maintain your personal information in accordance with the provisions of the law and relevant regulations.

The criteria we follow is driven by:

  • The purpose of the collected data and achieving the stated aim.
  • The reasons why data is collected: e.g. for consent, you may revoke your consent at any moment.
  • Obligatory storage periods according to the contractual and legislative requirements.

In some cases THN is obliged to keep some data about you.

11. Confidentiality

The staff who work at THN and have any kind of involvement in the services provided to the user, are committed to not divulge or make use of the information they have access to. The information submitted by the user will always be treated as confidential, although it may be used for other purposes than those related to attending to your requests and THN’s contracted services, if applicable. Therefore, we commit ourselves to neither divulge nor disclose information about the intentions of the user, the reasons for the consultation requested or the duration of the relationship with the user.

12. Social networks

THN has a presence on some of the main social networks on the Internet, for which it acts as the responsible party for the treatment of data published by THN.

THN will treat the data on each social network according to the rules established for such treatment by each social network. Therefore, and unless otherwise stated by THN, we will be able to inform our followers on the respective social network about our activities, events and other related topics, of interest to the follower, via the channels provided by the social network.

THN will not extract personal data from the social networks, except where the user has given their express consent.

13. Special category of personal data

We will not collect nor process any personal data that is especially sensitive or included in the special category of user’s personal data, unless the users have provided them to us explicitly. The special category of personal data refers to information related to race or ethnic origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, membership of trade unions, genetic data, biometric data for the exclusive purpose of identifying a physical person, health data, sexual habits or orientation.

14. Policy on children

This website is not designed nor directed at children under sixteen (16) years, without the authorisation of their parents or legal guardian. Therefore, we will not knowingly collect information concerning children. However, if the parents or legal guardians consider that their children have submitted personal data, without their consent, they should write to us at privacy@thehotelsnetwork.com.

15. Direct marketing

We do not use user’s personal data for the purpose of direct marketing without your prior express consent.

If at any time you decide to stop receiving sales and promotional information from THN, you can, without charge and without needing to give a reason, opt out of direct marketing campaigns and prevent the future processing of your data for such purposes by sending us an email to privacy@thehotelsnetwork.com or by entering “opt-out” in the subject field of the email. You can also use the opt-out procedure provided in any promotional message received by THN.

However, please note that even though you decide not to subscribe to or opt out of promotional emails and newsletters we may continue to contact you regarding important information of a non commercial nature, such as solutions to problems, detection and prevention of errors or in general to comply with the Legal Notice and/or the Terms and Conditions of the website.

16. Automated decision making

We do not use automated decision making processes, including the creation of profiles (profiling), unless we have been explicitly authorised to do so. In this case, we would inform you about the rationale used in the decision, as well as the meaning and forseeable consequences of the processing procedure for you.

17. Links to other websites

On THN’s websites there are links to other websites that we consider to be potentially useful and informative for you. However, please note that we do not guarantee nor recommend the content or services of these websites; neither are we liable for their privacy policies. We recommend that you read and take into account the Privacy Policy of every site that you visit. Remember that what is stated in this Privacy Policy only covers the data which is collected and/or treated by THN.

18. Amendments and integrity of our Privacy Policy

We only use personal data in accordance with the Privacy Policy that is in is force at the time we collect your personal data. THN reserves the right to amend this Privacy Policy at any moment, publishing such amendments on our website, and therefore we recommend that you read it each time that you access the Website. If we decide at any time to use personal data differently to the way that was declared at the time it was obtained, it will be communicated by email, provided that we have your email address. At this time you will be given the option to authorise other uses or sharing of personal data than those you provided us with before the amendment to our Privacy Policy.

In the event that any clause of this Privacy Policy were annulled or considered void, the remaining conditions would not be affected, fully retaining their validity and their force, under the applicable legislation in force at any time.

Date of last update: May 2018

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