The privacy policy ("web privacy policy" or "policy") governing the Web Platform https://www.ilunionhotels.com/ ("the Platform"), owned by ILUNION HOTELS ("ILUNION HOTELS" or "we" or "us"), is detailed below

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WON'T TAKE LONG. WE WANT TO PROVIDE YOU WITH A SIMPLE, CLEAR AND TRANSPARENT EXPLANATION OF HOW WE PROCESS AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THE SECURITY OF YOUR PERSONAL DATA ARE FUNDAMENTAL TO ILUNION HOTELS AND WE TAKE ADEQUATE PROTECTION VERY SERIOUSLY.

1. WHO DOES THIS POLICY APPLY TO?

This policy is applicable to all platform users, whether or not they are ILUNION HOTELS clients (indistinctly, "the user" or "the users"), who are considered natural persons. By personal data, we mean any information about an identified or identifiable natural person.

 

2. WHO IS THE DATA CONTROLLER FOR YOUR PERSONAL DATA?

 

ILUNION HOTELS is a business group made up of the following companies, which are jointly responsible for processing your personal data:

 

NAME	ADDRESS	CONTACT DETAILS
ILUNION HOTELS, S.A.	C/Albacete, 3, Edificio Torre Ilunion, 28027 – Madrid	dpd@ilunion.com
ILUNION TURISMO RESPONSABLE, S.L.
ILUNION HOTELS CATALUNYA, S.A.	C/ Ramón Turró 196-198 Barcelona, BARCELONA - 08005 TAX ID: ESA66283144
ILUNION HOTELAK EUSKADI, S.L.	Calle Pérez Galdós, 56 Bilbao, BILBAO - 48013 TAX ID: ESB65818387

 

3. WHO IS THE ILUNION HOTELS DATA PROTECTION OFFICER (DPO)?

ILUNION HOTELS has appointed a DATA PROTECTION OFFICER COMMITTEE (DPO) that users may contact regarding all matters relating to the processing of their data, as well as any dispute that may arise in this regard, in accordance with the provisions of the GDPR. You can contact our DPO by:
Email address:  dpd@ilunion.com

4. HOW DO WE PROCESS YOUR DATA?

You provide us with diverse data through the website and the other contact channels available, as well as during your stay in our hotels, and we process them for various purposes:

CHANNEL	PROCESSING PURPOSESADDITIONAL INFORMATION	DATA CATEGORIES	LEGAL BASIS	STORAGE PERIOD
WEB	Browsing the website Allowing you access to the information and content provided therein. We suggest you consult the documents of the Spanish Data Protection Agency (AEPD) on recommendations to Users to minimise the privacy risks derived from Internet browsing and information on technological security. Additionally, if you go to our website, we inform you that we will process your browsing data for analytical, advertising and statistical purposes, provided that you have accepted the corresponding cookies in accordance with the Cookies Policy. You can configure your preferences in relation to the processing of your personal data for these purposes at any time.	Web browsing data (data on your web browsing supported by cookies, web pages you visit, connection time, etc.).	Your consent, specifically, if you accept or authorise the use of cookies when required, in accordance with the provisions of our Cookies Policy (ex Art. 6.1 a) GDPR). Depending on the case, meeting our own or a third-party legitimate interest associated with the adequate technical usability, management, maintenance, development and evolution of the website, tools, network and associated information systems will also apply (ex Art. 6.1 f) GDPR).	Your data will be kept for the essential and necessary time to enable you to browse and use our website and its contents correctly. With regard to data associated with your browsing profile as related to the analytical cookies that you have accepted, you should pay attention to the section relating to their duration (see Cookies Policy).
	To handle your requests relating to queries, incidents or bookings. A contact form is available in the "Contact" section of the platform for this purpose.	• Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email). • Personal data processed as a result of the query.	Your consent.	For the time strictly necessary to solve or handle them.
	Sending commercial information. We will process your data in order to offer you information about our products and services by any means of communication, including email, SMS, MMS, or equivalent.	• Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email).	Your consent.	Your personal data will be processed for this purpose for as long as you do not object.
	Managing your booking for accommodation at our hotels. We will need to process certain personal data in order to book your stay at our hotels; without them, we will not be able to process the booking and payment.	Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email). • Personal data provided voluntarily (postcode, address, arrival time). • Personal identification data (name and surname, tax ID). • Bank details (card holder, card number, card expiry month/year and CVV).	Enforcing the terms and conditions of service, as well as the obligation to comply with regulations.	During the time strictly necessary to manage your booking, as well as during the statute of limitation periods for any legal actions that may be required by applicable regulations.
LOYALTY	Managing your registered access to LOYALTY We will need to know the personal data requested on the registration forms provided in order to provide you with the associated benefits.	• Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email). • Personal data provided voluntarily (postcode, address, city, date of birth).	Your consent.	Until you request cancellation, as well as during the statute of limitation periods for any legal actions that may be required by applicable regulations.
	Sending commercial information. We will process your data in order to offer you information about our products and services by any means of communication, including email, SMS, MMS, or equivalent.	Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email).	Your consent, as well as our legitimate interest when you have already been a guest at one of our hotels since the information we are going to provide you with in these communications is about our hotels and our services in accordance with the Spanish Information Society Services and Electronic Commerce Act (LSSICE).	Your personal data will be processed for this purpose as long as you do not object.
	Commercial profiling. We will use your data obtained from managing our services, as well as the tastes, hobbies and needs you have informed us of, in order to carry out commercial actions and provide you with the services that best suit your profile. Please also note that no automated decisions will be made on based on this profile.	Data associated with the user profile (services or products contracted; level of satisfaction with the services or products contracted by the user, etc.) are processed.	Your consent. Depending on the case, meeting the legitimate interest associated with segmenting user interests will also apply (ex Art. 6.1 f) GDPR).	Your personal data will be processed for this purpose for as long as you do not object.
	Recording sensitive data preferences. To be able to record and store sensitive information to help improve your customer experience.	Sensitive data (health)	Your explicit consent in accordance with Art. 9.2.a) GDPR.
TELEPHONE	To handle your requests relating to queries, incidents or bookings, and to analyse the quality of our services. A contact telephone number is available for this purpose: +34 902.42.42.42.	Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email). • Personal data processed as a result of the query. • Data from call recordings	Your consent. We will record calls in accordance with our legitimate interest to analyse the quality of our services.	For the time strictly necessary to solve or handle them.
WHATSAPP	To handle your requests relating to queries, incidents or bookings. A WhatsApp contact is available for this purpose: +34 667 17 15 20.	Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email). • Personal data processed as a result of the query.	Your consent.	For the time strictly necessary to solve or handle them.
RECEPTION	Recording you accommodation at our hotels. We will need to process certain personal data in order to record your stay at our hotels; without them, we will not be able to process the booking and payment.	• Personal identification data (name and surname). • Personal contact details (personal telephone or mobile phone, email). • Personal data provided voluntarily (postcode, address, arrival time). • Personal identification data (name and surname, tax ID). • Bank details (card holder, card number, card expiry month/year and CVV).	Enforcing the terms and conditions of service, as well as the obligation to comply with regulations.	During the time strictly necessary to manage your booking, as well as during the statute of limitation periods for any legal actions that may be required by applicable regulations.

When the legitimate basis for processing your personal data is your consent, please remember that you have the right to revoke your consent at any time, simply and free of charge, by writing to us at protecciondatos@ilunion.com.

With regard to the storage period, when personal data are no longer necessary for the purposes for which they were collected and whenever applicable, they will generally be blocked and will only be available to competent authorities for any legal responsibilities arising during their processing, always in accordance with applicable regulations; they may not be used for other purposes. In the case of blocked data, once the corresponding legal deadlines have elapsed, your data will be deleted in accordance with applicable regulations and, if applicable, they may also be securely anonymised by ILUNION HOTELS (anonymised/non-personal data).

5. VIDEO SURVEILLANCE

In relation to the processing carried out through the video surveillance systems installed in our hotels, we inform you that the data controller responsible for the processing will be the owner of the hotel, which will be identified on the video surveillance information signs located in the hotel where you are staying ("ILUNION HOTELS"). Your personal data will be processed for the purposes of video surveillance and security of persons, assets and facilities, using fixed or mobile camera or video camera systems capable of capturing and recording images, in order to check the status of facilities or assets, control access to the building, car parks and garages. The basis for this processing is public interest.

Your data will be deleted within a maximum period of one (1) month from their collection except when they must be kept to accredit acts against the integrity of persons, assets or facilities, in which case, they may be made available to the competent authority.

They will not be transferred to third parties unless legally obliged to do so or, where appropriate, to State Security Forces and/or judges and courts. We will not transfer your data internationally.

You can exercise your rights as set out in the "WHAT ARE YOUR RIGHTS, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?" section of this Privacy Policy.

6. WHAT ARE THE CONSEQUENCES OF NOT PROVIDING YOUR DATA?

We endeavour to request or apply the minimum and essential data necessary for our personal data processing to fully implement our corporate purpose and objectives. This is in line with the principles contained in applicable regulations.

However, failure to provide your personal data may make it impossible for you to: 1) browse our website correctly (disable technical cookies); 2) process your booking or specific request (for example, due to the lack of or insufficient completion of the forms provided on the platform).

In any case, we kindly ask that the information and personal data you provide us with adapt and are limited to what is requested on those forms, and that they are accurate, updated and truthful, in order to be able to properly verify your identity and to be able to access the platform's services.

In this regard, users shall be fully responsible for the personal data and information they provide to ILUNION HOTELS within the framework of the platform and, where appropriate, for the services they require or contract.

7. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We generally do not share, sell or offer your data to third parties. However, as a client of ILUNION HOTELS, your personal data may be shared with the entities that directly manage our hotels. Furthermore, your data may be shared with collaborating entities, in the manner and for the purposes described in the contracts signed with them. For the purposes indicated above, your personal data may be communicated, for example, to entities that own payment gateways. In any case, without detriment to the above, legally speaking we may transfer your data to:

Public Authorities in the cases provided for in by Law.
State Security Forces and Corps.
Courts.

Certain third parties may also possibly access your personal information as part of the services they may provide to ILUNION HOTELS. For example, in the case of third-party cookies applied on the platform (see cookies policy).

ILUNION HOTELS has various data processors for the personal data it controls. As trusted suppliers, they are allowed access to the data to the extent strictly necessary to provide the services contracted with them. Such data processors operate under a service contract under the terms, conditions and guarantees contained in Article 28 GDPR. ILUNION HOTELS carries out the corresponding controls, inspections and audits to check that these data processors strictly comply with the contracts signed for this purpose and with applicable regulations

8. ARE YOUR PERSONAL DATA TRANSFERRED INTERNATIONALLY?

Please note that international personal data transferred are generally not foreseen and ILUNION HOTELS will adopt the necessary measures and guarantees in accordance with current personal data protection regulations. Notwithstanding the foregoing, in our cookies policy you will find information on the use of cookies by third parties who may make international personal data transfers. You can consult the privacy information of third parties with cookies on this website in our Cookies Policy.

 

9. WHAT ARE YOUR RIGHTS, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?

 

You may exercise your rights of access, rectification, deletion, portability, limitation of processing and opposition by sending a letter to the company's registered office, or by email to dpd@ilunion.com, enclosing, if necessary, a copy of your national identity card or equivalent identification document (passport, foreigner identity card, etc.).

We also inform you that if you do not consider that your personal rights have been duly addressed, you may file a complaint with the competent supervisory authority, in this case, the Spanish Data Protection Agency (AEPD). For more information visit www.aepd.es.

However, before filing any complaint or claim with the AEPD, we recommend that you contact us, especially our DATA PROTECTION OFFICER COMMITTEE ( dpd@ilunion.com), in order to analyse the specific situation and try to find an effective and amicable solution.

10. ARE SECURITY AND PROTECTION MEASURES IN PLACE FOR YOUR PERSONAL DATA?

Taking into account the nature, scope, context and stated purposes of processing, as well as the risks of varying likelihood and severity to your rights and freedoms, ILUNION HOTELS applies (and will apply) appropriate technical and organisational measures in order to ensure the appropriate security and protection of your personal data by meeting privacy by design and by default criteria, as well as applying a system to approach concurrent risks, which will be reviewed and updated by ILUNION HOTELS as necessary. The use of Hyper Text Transfer Protocol (HTTPS) on our platform is an enhanced guarantee for the security of your personal data.

11. VALIDITY AND MODIFICATION OF THE PRIVACY POLICY

ILUNION HOTELS reserves the right to modify this policy in order to adapt it to applicable future legislative, doctrinal or case law developments, or for technical, operational, commercial, corporate and business reasons, informing you beforehand and reasonably of the changes whenever possible. In any case, each time you access this platform, we recommend that you read this policy in detail as any modification will be published in the policy.