THE HOTELS NETWORK, S.L.P (hereinafter collectively and individually referred to as "THN", "us", "our" and "we"), is a technology company specialised in offering services to hotels and hotel chains to boost their online bookings.
We consider privacy to be paramount, both for visitors of our website https://www.thehotelsnetwork.com/en (hereinafter, the “website”) and for anyone else that may be affected by information provided to us through our website, whose data are processed by THN as part of the provision of service (hereinafter and jointly “you” and the “user”, and the plural “you” and the “users”). In this regard, THN undertakes to process your data in compliance with the applicable and in-force data protection legislation at all times. More specifically, THN shall comply with the premises established in 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, also known as the General Data Protection Regulation, repealing Directive 95/46/EC (GDPR), and Spanish Organic Law 3/2018 of 5 December on the protection of personal data and the guarantee of digital rights (LOPDGDD).
In any case, the user is solely responsible for the information that they provide us with via the website and, if THN wished to use it in the future for purposes other than those referred to, we will inform you of these new purposes and request your consent, if required.
1. Who is the data controller?
Contact details of the data controller THE HOTELS NETWORK, S.L., with tax identification number B-65542714, with registered address at Avda. Diagonal, 439, 3º-1ª, 08036 Barcelona, Spain, and contact email address firstname.lastname@example.org, corresponding to the data protection officer (DPO) of THN.
2. What data protection rights do users have?
Users may request the following rights:
- Right to access your personal data: you may ask THN whether or not we are processing your data, and if so, you can request access to them.
- Right to rectify your data if it is inaccurate, or to complete it if it is incomplete.
- Right to erase your data.
- Right to restrict the processing of your data: in this case, we will only store your data in order to exercise or defend legal claims.
- Right to object to the processing of your data: THN shall stop processing personal data unless we must continue processing them for a legitimate reason or for exercising or defending possible legal claims.
- Right to data portability: in the event that the user wishes that their data be processed by another data controller, THN shall transfer your data to the new data controller.
- Right to not be subject to a decision based solely on the automated processing of your data.
If you have granted consent for your data to be processed for a specific purpose, you may withdraw this consent at any moment without prejudice to the legality of the processing based on the consent given before its withdrawal.
In any case, when the user exercises their right to erasure, all personal data linked to their account, as well as all information and content embedded in their profile, shall be deleted. Likewise, in the event that the user exercises their right to erasure on the data that are necessary in order for THN to continue providing the services of their website, THN shall be obliged to terminate their relationship with the user, proceeding to de-register the user without the user being entitled to make any claim against them.
3. How can you file a claim to the Spanish Data Protection Agency (AEPD)?
4. In which cases do we collect your personal data and what type of data are they?
If you decide to provide us with your personal data, THN may use any of the data that you enter in any of the forms that you complete or data that you provide us with via the different THN email accounts that are available for you to use to contact us.
Personal data that our website obtains from your computer or electronic device:
Cookies, only for https://www.thehotelsnetwork.com/en/
5. How do we use users’ personal data?
THN informs applicable users that the personal data that they provide us with and that we collect shall be identified in the Record of Processing Activities owned by THN, and shall be used:
- To respond to consultations or information requests that may be made by users;
- To provide users, upon request, with a demonstration of our services;
- To provide our services in compliance with the Legal Notice and the Terms and Conditions, if applicable, that have been established between THN and each user;
- To respond to applications to job offers;
- For the use or provision of services, in the event that the user has previously registered on the website, in compliance with the General Conditions for Use of the website and the specific conditions of each service;
- To personalise and improve the website’s tools and features in order to guarantee its correct technical functioning;
- In the event that the user has selected the corresponding box, to keep them informed through sending notifications or newsletters via email and/or other electronic means, the content of which shall mainly be regarding our services, activities, projects, updates and new features of the website;
- To use them for any other purpose that may be demanded or allowed by applicable legislation or for the purpose for which you have granted your consent.
6. Why do we process your personal data?
THN may process your data for any of the following legal bases: (A) legitimate commercial purposes; (B) when you have given your consent; (C) when it is necessary in order to comply with the legal and regulatory obligations of THN and (D) for any reason necessary to comply with a contract of which you are a party.
7. Who can access your personal data?
Depending on the purposes for which the personal information is collected, the following people may interchangeably access these data:
- Authorised THN staff or its representatives acting on behalf of THN, subject to applicable data protection legislation;
- Regulatory authorities or third parties, in compliance with applicable legislation;
- Third parties (service providers that process data as data controllers, following the instructions of THN). All of the aforementioned may only access your data once the necessary measures have been taken to ensure that we are able to share these data in compliance with applicable data protection legislation.
We shall not sell or disclose to third parties any personal information or data that you have provided us with via our website and that make it possible to identify you either directly or indirectly.
8. Where are your personal data processed?
THN shall not carry out any transfer of personal data outside the European Economic Area (EEA). In the event that such a transfer was to occur, THN would only do so in compliance with applicable data protection legislation. Regardless of the place where your personal data are collected or processed, THN ensures and guarantees that the service providers maintain suitable levels of administrative, technical and physical security in order to protect your information.
For more information on the use of contractual models by THN, please contact us by emailing email@example.com.
9. How do we protect your personal data?
In order to ensure the safety of information, THN applies various technical and organisational measures to guarantee the suitable level of security in compliance with applicable regulations. In any case, THN shall take suitable technical and organisational measures both when designing the data processing system and during the carrying out of the processing itself in order to preserve security and prevent unauthorised processing. However, despite the careful implementation of such measures, the user is informed that internet security measures are not impenetrable. THN is not responsible for the actions of third parties who access these data and information by violating these measures.
10. How long do we store your data for?
The criteria that we follow for this are determined by:
- The purpose of the data collected and the fulfilment of this purpose.
- The reasons that allow the data to be collected, e.g. when you have given consent, it may be withdrawn at any moment.
- Storage periods demanded by contractual and legislative requirements.
Please be aware that in some cases, THN is obliged to store certain pieces of your data.
The professionals who work at THN and who have intervened in any way in the provision of services to the user are bound to not disclose or use any of the information that they have accessed. The information provided by the user shall in all cases be considered confidential, without prejudice to it being used for purposes other than those related to managing your requests and the services contracted to THN, if applicable. Accordingly, we are bound to neither disclose nor reveal information on users’ intentions, the reasons for requesting advice or the duration of their relationship with THN.
12. Social networks
THN is present on some of the main social networks found on the internet and is the data controller of the data published therein by THN.
THN shall process the data on each social network in compliance with the rules established by each social network for this purpose. Therefore, until indicated otherwise by THN, we may inform our followers on the corresponding social network of our activities, events and other related topics, including providing followers with customer service via the channels provided by the social network for this purpose.
THN shall not extract any personal data from social networks unless the user gives their express consent.
13. Special category personal data
We shall not collect or process any personal data that is particularly sensitive or included in special categories of users’ personal data unless the users have explicitly provided us with this data. Special categories of personal data refer to information relating to race or ethnic origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, trade union membership, genetic data, biometric data where used for purposes of identifying a natural person, and data concerning health, a person's sex life or sexual orientation.
14. Policy on the use of children's data
This website is neither designed for nor intended for use by children under sixteen (16) years old without their parents’ or legal guardian’s authorisation. Accordingly, we do not deliberately collect information on these people. In any case, if the parents or legal guardians consider that their children have provided us with personal data without their consent, please let us know by emailing us at firstname.lastname@example.org.
15. Direct marketing
We shall not use users’ personal data for direct marketing purposes without your express prior consent.
If at any moment you decide that you wish to stop receiving commercial or promotional information from THN, you may unsubscribe, free of charge and without having to provide a justification, from our direct marketing campaigns and oppose the future processing of your personal data for these purposes by sending us an email to email@example.com or by pressing “opt-out” in the email. You may also use the procedure for unsubscribing found in any promotional message that you receive from THN.
Please bear in mind that, even if you decide to unsubscribe from or opt out of promotional emails or newsletters, we may still need to contact you regarding important information of a non-commercial nature, such as resolving problems, detecting and preventing errors or more generally in order to comply with the website’s Legal Notice and/or Terms and Conditions.
16. Automated decision-making
We shall not use automated decision-making processes, including profiling, unless you expressly authorise us to do so. In this case, we would notify you of the logic used in the decision, as well as of the meaning and expected consequences of the processing for you.
17. Links to other websites
Text updated in giugno 2019.