1- WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?
The data controller for your personal information and owner of the website http://smartroomscompany.com is SMART ROOMS COMPANY, S.L., registered in the Mercantile Registry of BARCELONA, Volume 43,188, Folio 213, Sheet B426216, Entry 1, with VAT number B-65786378, and address at Calle Trafalgar, 52, 1º 2ª, 08010 Barcelona (hereinafter referred to as Smart Rooms).
SMART ROOMS has implemented the necessary technical and organizational measures to comply with data protection regulations.
The contact details for SMART ROOMS regarding privacy and the protection of your personal data are:
2- WHAT TYPE OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSE?
1- Types of personal data we process:
For reasons of confidentiality, we will process the minimum amount of personal data from third parties, beyond what is voluntarily provided by the interested parties or what the law requires us to process in the case of reservations in our establishments. We may collect and process the following categories of personal data:
- Name, title, gender.
- Contact details and address, phone number if you make a reservation at any of our establishments by phone and provide it, your email address if you make a reservation from your email, or any data required by the booking engine to make a reservation. Data and date of your reservation, information about your stay and preferences, as well as credit card information. In the case of making an electronic reservation, the system may request a selfie to verify the authenticity of the provided documentation. Your image will only be used for these purposes and will only be retained for the strictly necessary time.
- En caso de que contrate nuestros servicios en cualquiera de nuestros establecimientos, cuantos datos adicionales nos facilite para la prestación de estos.
- In case you hire our services in any of our establishments, any additional data you provide for the provision of these services.
- For our employees, identification data, social security data, banking data, and any other necessary for the development of the employment relationship.
- Identification data of our suppliers and contact persons in case they are companies.
- We record your communications with us made via email or other means. When you make a phone call, our customer service may record your inquiries in our database.
- Information collected when you use our website and other digital media, if applicable. When you use our website, we may record your IP address, browser type, operating system, referring website, and browsing behavior.
- Information you choose to share with us. You may choose to share information with us, for example, by adding a comment on LinkedIn or Facebook.
2-Your personal data will only be used for the following purposes:
- Registering you in our database if you hire our services.
- Conducting the necessary commercial and administrative procedures with users of our website and our clients or potential clients.
- At SMART ROOMS, we process the information you provide to us in order to respond to the information request you send us, provide you with information about our services, manage our services, as well as comply with the legal obligations arising from these activities.
- Sending commercial advertising communications such as our newsletter by email, social networks, or any other electronic or physical means, in case you have expressly consented to receive such commercial communications electronically. If you have contracted our services, or are a client of any of our establishments, we may send you commercial information, updates, or news related to our services without requiring prior consent.
- Communicating with you to respond to your inquiries and process your complaints.
- Communicating with you to obtain your opinion on the quality of our services or the treatment received.
- Likewise, the data collected during your navigation is processed in order to provide access to the online content of the website, as well as to attend to user requests, keep a statistical record of visits (IP addresses, browser data, country, accessed page, etc.) for the purpose of enabling us to develop better services and products, optimize our offer, and provide a more effective customer service, and improve the design and content of our websites.
- The data of our clients, employees, and suppliers will be processed, within the contractual relationship that binds them to us, in compliance with the administrative, tax, accounting, and labor obligations that are necessary under current legislation.
- Objection or revocation. You can object to or revoke your consent to receive marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us at firstname.lastname@example.org. In accordance with the LSSICE, SMART ROOMS does not engage in SPAM practices, therefore, we do not send commercial emails without the necessary legitimacy. In any case, you will always have the possibility to withdraw your consent to receive our communications. We will not process your personal data for any other purpose than those described in this Policy, except by legal obligation or judicial requirement. Your personal data will not be subject to decisions based on automated processing that produce effects on you.
3- WHAT IS THE LEGAL BASIS THAT LEGITIMIZES THE PROCESSING OF YOUR DATA?
The legal basis that legitimizes the processing of your personal data is your express consent granted to carry out the purposes described above, which will be requested at the time you request information from us.
In the event of a commercial or employment relationship between you, whether as a client, supplier, or employee, respectively, and SMART ROOMS, the legal basis that will legitimize the processing of your personal data will be the execution of the contractual relationship that will have been generated.
In certain cases, we will need to process your data to comply with the legal obligations that apply to us.
- - Sending commercial and/or promotional communications corresponding to the response to your request for information by any means. The legal basis that will legitimize this processing is your express consent granted when you voluntarily make the request.
- - Sending any information, including commercial information about news, updates, etc., and all information related to our activities or services contracted by our clients. The legal basis legitimizing this processing is our legitimate interest within the established commercial relationship with you.
In the event that the user submits their CV to SMART ROOMS, through the "talent" section of our website or through any other electronic means, we inform you that the provided data will be processed to make you participate in any selection processes that may exist, carrying out an analysis of the applicant's profile with the aim of selecting the best candidate for the vacant position in the Company. We inform you that we will only accept your CV if you send it to us electronically, so CVs submitted or delivered on paper will not be accepted. In the event of any changes in the data, we ask you to notify us in writing as soon as possible in order to keep your data duly updated.
We inform you that your CV and the data it contains will be kept for a maximum period of one year, after which the data will be deleted, ensuring complete confidentiality both in the processing and in its subsequent destruction. In this regard, after the aforementioned period and if you wish to continue participating in SMART ROOMS' selection processes, please send us your updated CV again.
However, if you are hired by SMART ROOMS, your CV will be kept, along with the rest of your employment record, for as long as your contractual relationship with the Company is maintained.
4- DATA RETENTION PERIOD: How long will your data be retained?
The personal data you provide to us will be kept for the time necessary to manage the information you request, as well as to provide our services or fulfil any contract generated between SMART ROOMS and third parties. In the case that we have your identifying data in our database for sending commercial information, they will be kept as long as the necessary legal basis that legitimizes their retention and use is maintained. You may cancel your data at any time in order not to receive commercial information.
Once the data have served the purposes for which they were collected, they will be permanently deleted. However, we will retain your data longer if necessary to fulfil legal obligations. Likewise, it may be necessary to keep them for the time necessary for the prescription of legal responsibilities that may arise.
The data you provide us to initiate a selection process will be kept for a maximum period of one year. Subsequently, if you have not joined SMART ROOMS or are not within a selection process, they will be deleted, and we will not keep a copy.
The personal data of our employees will be kept for the duration of their employment relationship with SMART ROOMS and, subsequently, for the periods provided for by law.
5- TO WHOM WILL YOUR DATA BE DISCLOSED?
Within our organization, your personal data will be processed by duly authorized personnel, and, if necessary or practical to fulfil the purposes indicated above, they may be processed by third parties.
The categories of recipients to whom your personal data may be disclosed are as follows:
- Third parties appointed data processors, such as IT providers, consultants, advisers, and other companies that provide auxiliary services.
- Social network providers.
- Public entities and organizations, solely for the purpose of complying with the legal obligations that correspond, including the communication of the data of guests staying in our establishments in compliance with current public safety regulations.
- Other providers to whom, if applicable, your personal data may be transferred, such as financial institutions, fraud detection service providers, etc.
- When necessary for operational reasons, with companies belonging to the SMART ROOMS CORPORATION to which Smart Rooms Company, SL belongs or to the SOGAMAN GROUP.
In any case, all of the aforementioned third parties will have previously signed the corresponding confidentiality commitment, following our instructions in accordance with current personal data protection regulations, will be subject to the duty of professional secrecy, or will act in compliance with a legal obligation.
The information you provide to us through this website will be hosted on SMART ROOMS' servers.
6.- YOUR RIGHTS WHEN PROVIDING US WITH YOUR DATA:
If you wish to exercise the rights granted by data protection regulations, please send an email to the following address: email@example.com, indicating the right you wish to exercise in the subject line, and attach a copy of your national ID card or passport.
The rights recognized by current regulations that you may exercise, if applicable, are:
Right of Access to Data:
You have the right to request whether SMART ROOMS is processing your personal data and, if so, to provide you with the following information:
- - The purposes of the processing.
- - The categories of data concerned.
- - The retention period or criteria for data retention.
Right to Rectification of Data:
You will have the right to request that SMART ROOMS rectify your data when it is inaccurate or incomplete through an additional rectification statement.
Right to Erasure of Data:
The data subject shall have the right to request SMART ROOMS to erase their data when:
- - The processing is unlawful.
- - The data subject has withdrawn their consent.
- - They are no longer necessary for the purposes for which they were collected or processed.
- - The data subject has exercised the right to object, and there are no overriding legitimate grounds for the processing.
- - The data must be erased to comply with a legal obligation of SMART ROOMS.
The data subject will not have the right to request SMART ROOMS to erase their data when the processing is necessary:
- - For exercising the right to freedom of expression and information.
- - To comply with a legal obligation of SMART ROOMS.
- - For the establishment, exercise, or defence of legal claims.
- - For reasons of public interest based on current legislation for public health, historical, statistical, or scientific research purposes.
Right to Data Portability:
You have the right to have SMART ROOMS transmit your data to another data controller or to yourself, in a structured, commonly used, and machine-readable format, where the processing is carried out by automated means and is based on:
- - Your consent for specific purposes.
- - The execution of a contract or pre-contract with the data subject.
The right to data portability will not apply when:
- - The transmission is technically impossible.
- - It may adversely affect the rights and freedoms of third parties.
- - The processing serves a purpose of public interest based on current legislation.
Right to Restriction of Processing:
The data subject shall have the right to object to the processing of their data carried out by SMART ROOMS for reasons related to their particular situation, when the processing is based on:
- - Direct marketing.
- - Profiling.
- - The legitimate interests pursued by the controller or third parties, provided that the interests or rights and freedoms of the data subject do not prevail, especially if the data subject is a child.
- - Historical, statistical, or scientific research, unless processing is necessary for reasons of public interest.
Even if the data subject objects to the processing of their data, SMART ROOMS may continue to process them as long as their legitimate interest outweighs the interests or rights and freedoms of the data subject in a justified legal procedure.
SMART ROOMS must explicitly inform the data subject of their right to object to the processing of their data, separate from any other information, at the time of the first communication.
Right to Object:
This is the right to prevent the processing or cease processing when consent is not required for the processing, due to the existence of a legitimate and well-founded reason related to your particular situation, unless a law provides otherwise.
Right not to be subject to automated decision-making:
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
When automated profiling is based solely on automated processing:
- - The data subject has the right to be informed if the decision that may be made could have legal effects that significantly affect them.
- - The data subject has the right to obtain human intervention from SMART ROOMS, to express their point of view and to challenge the decision if processing has been authorized by:
- - The explicit consent of the data subject.
- - A contract between SMART ROOMS and the data subject.
The right not to be subject to automated decision-making shall not apply when the decision that may be made as a result of this is authorized by:
- - The explicit consent of the data subject.
- - A contract between SMART ROOMS and the data subject.
- - Processing based on current legislation.
7. COMPLAINT TO THE SUPERVISORY AUTHORITY:
If you believe that SMART ROOMS has violated any of your rights protected by personal data protection regulations or that it has violated any obligation regarding the protection of personal data, you have the right to file a complaint with the competent supervisory authority, which in Spain is the Spanish Data Protection Agency located at Calle Jorge Juan, 6. 28001 - Madrid. Tel. 901 100 099 - 912 663 517
You can also file an electronic complaint through the electronic headquarters available on their website https://www.aepd.es.
8. LEGISLATION AND JURISDICTION
It is also governed by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights. Likewise, our website is governed by Law 34/2002, of July 11, on information society services and electronic commerce.
Users of this website are subject to Spanish legislation and jurisdiction, to which they expressly submit. The Courts and Tribunals of BARCELONA shall be competent for the resolution of all conflicts arising from or related to its use.
9. ADDITIONAL INFORMATION
We inform you that SMART ROOMS may have a presence on social media. The processing of data concerning individuals who become followers on social media (and/or perform any link or action of connection through social media) of SMART ROOMS's official pages will be governed by this section, as well as by those conditions of use, privacy policies, and access regulations belonging to the respective social media platform, which have been previously accepted by the user.
SMART ROOMS will process your data for the purposes of properly managing its presence on the social network, informing you of activities, products, or services of the provider, as well as for any other purpose that social media regulations allow.
The publication of content that is:
- - Presumably unlawful by national, community, or international regulations or that carries out activities that are presumably illegal or that contravene the principles of good faith.
- - That infringes on the fundamental rights of individuals, lacks courtesy in the network, bothers or may generate negative opinions in our users or third parties, and, in general, any content that SMART ROOMS considers inappropriate.
- - And, in general, that contravenes the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, protection of consumers, and intellectual and industrial property rights.
Likewise, SMART ROOMS reserves the right to remove, without prior notice from the website or corporate social network, any content considered inappropriate.
Communications sent through social media will be incorporated into a file owned by SMART ROOMS, and you may be sent information of interest.
In any case, if you send personal information through social media, SMART ROOMS will be exempt from liability in relation to the security measures applicable to this platform. If you want to know them, you should consult the corresponding particular conditions of the specific social network.
The data you provide us will be treated confidentially. SMART ROOMS has adopted all the necessary technical and organizational measures and all levels of protection necessary to guarantee the security of data processing and to prevent its alteration, loss, theft, processing, or unauthorized access, in accordance with the state of the technology and the nature of the stored data. Likewise, it is also guaranteed that the processing and recording in files, programs, systems, equipment, premises, and centres comply with the requirements and conditions of integrity and security established in current regulations.