Privacy Policy Hotel ILUNION Atrium

WEB PRIVACY POLICY

The following is the privacy policy (hereinafter, ""web privacy policy"" or ""policy"") applicable to the Web Platform https://www.ilunionhotels.com/ (hereinafter, ""the Platform""), under the ownership of ILUNION HOTELS (hereinafter, ""ILUNION HOTELS"" or ""we"" or ""us"").

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WON'T TAKE LONG. WE WOULD LIKE TO EXPLAIN TO YOU IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE TREAT AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THE SECURITY OF YOUR PERSONAL DATA IS FUNDAMENTAL TO ILUNION HOTELS AND WE TAKE ITS CORRECT PROTECTION VERY SERIOUSLY.

1. WHO DOES THIS POLICY ADDRESS AND APPLY TO?
This policy applies to all users of the platform, whether or not they are ILUNION HOTELS clients (hereinafter, indistinctly, ""the user"" or ""the users"") who are considered natural persons. By personal data, we are referring to any information about an identified or identifiable natural person..

2. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
ILUNION HOTELS is a business group, made up of the following companies which, in terms of the processing of your personal data, act under a joint responsibility:

COMPANY NAME	ADDRESS	CONTACT DETAILS
ILUNION HOTELS, S.A	C/Albacete, 3, Edificio Torre Ilunion, CP 28027 – Madrid	contactcenter@ilunionhotels.com
ILUNION TURISMO RESPONSABLE, S.L.
ILUNION HOTELS CATALUNYA, S.A.	C/ Ramón Turró 196-198 Barcelona, BARCELONA - 08005 CIF: ESA66283144
ILUNION HOTELAKEUSKADI, S.L.	Calle Pérez Galdós, 56 Bilbao, BILBAO - 48013 CIF: ESB65818387

3. WHO IS THE DATA PROTECTION OFFICER (DPO) FOR ILUNION HOTELS?
ILUNION HOTELS has appointed a DATA PROTECTION DELEGATE COMMITTEE who will jointly exercise the functions legally attributed to the Data Protection Officer with whom, should you so wish, you may contact regarding all matters relating to the processing of your personal data and for the exercise of your rights in accordance with the provisions of the GDPR, through the following contact details:

Email Contact: "">contactcenter@ilunionhotels.com

4. WHAT DATA PROCESSING DO WE CARRY OUT
The data you provide us with, and the processing we carry out, are many and varied, both through the website and the other contact channels we have available, as well as during your stay in our hotels:

CHANNEL	PURPOSES OF PROCESSING ADDITIONAL INFORMATION	DATA CATEGORIES	LEGAL BASIS	STORAGE PERIOD
WEB	Browsing the web Allowing you to access the information and content available on the website. We recommend that you consult the documents of the Spanish Data Protection Agency (AEPD) on how Users can minimise the privacy risks derived from Internet browsing and information on technological security. In addition, if you access our website, please be aware 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, and that you can configure your preferences at any time in relation to the processing of your personal data for these purposes.	Web browsing data (data on your web browsing supported by cookies, web pages you visit, connection time, etc.).	Your consent, particularly in the case of accepting or authorising the use of cookies that so require, in accordance with the provisions of our Cookies Policy (ex art. 6.1 a) of the RGPD). Depending on the case, the satisfaction of your own or third parties' legitimate interests associated with the proper technical usability, management, maintenance, development and evolution of the website, tools, network and associated information systems (ex art. 6.1 f) of the RGPD) will also apply.	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 the data associated with your browsing profile, in relation to the analytical cookies that you have accepted, you should refer to the section relating to their temporality (see Cookies Policy).
	Handling your requests or requests relating to queries, incidents or bookings. For this purpose, a contact form is available in the “Contact” section of the platform.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address). • Personal data processed as a result of the consultation.	Your consent.	For the time strictly necessary to solve or attend to the requests.
	Sending commercial information. We will process your data in order to offer you, by any means of communication, including e-mail, SMS, MMS, or equivalent, commercial information about our products and services.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address).	Your Consent.	Your personal data will be processed for this purpose for as long as you do not object to such processing.
	Managing the booking of your accommodation in our hotels. In order to make a reservation for your stay in our hotels, we will need to process certain personal data, as without this information, we would not be able to process the reservation and the payment of the same.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address). • Personal data provided on a voluntary basis (postcode, address, time of arrival). • Personal identification data (name and surname, NIF - Individual Identification Number)). • Bank details (cardholder, card number, expiry date, and CVV).	Enforcement of the terms and conditions of service, as well as the obligation to comply with regulations.	During the time strictly necessary to manage your reservation, as well as during the prescription periods of any legal actions that may be required by the applicable regulations.
LOYALTY	Managing your registration access on LOYALTY In order to provide you with the associated benefits, we will need to have the personal data requested through the registration forms provided.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address). • Personal data provided voluntarily (postal code, address, city, date of birth).	Your consent.	Until the moment in which you request cancellation, as well as during the periods of limitation of the legal actions that may be required by the applicable regulations.
	Sending commercial information. We will process your data in order to offer you, by any means of communication, including e-mail, SMS, MMS, or equivalent, commercial information about our products and services.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address).	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 LSSICE (Law on Information Society Services and Electronic Commerce).	Your personal data will be processed for this purpose until you withdraw your consent.
	Commercial profiling. In order to carry out commercial activities and provide you with the services that best suit your profile, we will use your data obtained from the management of our services, as well as the preferences, hobbies and needs that you have indicated. We also inform you that no automated decisions will be taken on the basis of 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.) will be processed.).	Your consent. Depending on the case, the satisfaction of the legitimate interest, associated with the targeting of users' interests (ex art. 6.1 f) of the GDPR), will also apply.	Your personal data will be processed for this purpose for as long as you do not object to such processing.
	Registering preferences on sensitive data. 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) of the GDPR.
TELEPHONE	Handling your requests or requests relating to queries, incidents or reservations, and analysis of the quality of our services. The contact telephone number is available for this purpose: 902.42.42.42.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address). • Personal data processed as a result of the consultation. • Data derived from recording the call	Your consent. In order to analyse the quality of our services, we will record the call in accordance with our legitimate interest.	For the time strictly necessary to solve or attend to the requests.
WHATSAPP	Handling your requests or requests relating to queries, incidents or bookings. For this purpose, a WhatsApp contact number is available: +34 667 17 15 20.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address). • Personal data processed as a result of the consultation.	Your consent.	For the time strictly necessary to solve or attend to the requests.
RECEPTION	Registering your accommodation in our hotels. In order to register your stay in our hotels, we will need to process certain mandatory personal data, as without this information, we would not be able to process the reservation and the payment of the same.	• Personal identification data (name and surname). • Personal contact details (telephone or mobile number, e-mail address). • Personal data provided on a voluntary basis (postcode, address, time of arrival).	Enforcement of the terms and conditions of service, as well as the obligation to comply with regulations.	During the time strictly necessary to manage your reservation, as well as during the prescription periods of any legal actions that may be required by the applicable regulations.

Where the legitimate basis for processing your personal data is your consent, we would like to remind you that you have the right to withdraw your consent at any time simply and free of charge by writing to us at protecciondatos@ilunion.com.

Regarding the storage period, in general, when the personal data are no longer necessary for the purposes for which they were collected, and whenever applicable, they will be blocked, remaining available only to the competent authorities for the possible purging of legal responsibilities during the processing thereof, always in accordance with the applicable regulations, and may not be used for purposes other than those for which they were collected. Once the corresponding legal deadlines have elapsed in the event of blocking, your data will be deleted in accordance with the applicable regulations, and may also, if applicable, 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 entity responsible for the processing is the owner of the hotel, who can be identified using the video-surveillance information signs located in the hotel where you are staying (hereinafter, “‘ILUNION HOTELS”). Your personal data will be processed for the purposes of video surveillance and for the safety and security of persons, goods and facilities, by means of camera or video camera systems, fixed or mobile, capable of capturing and recording images, in order to check the state of facilities or goods, 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 the date of collection, except when they have to be kept in order to prove that acts have been committed against the integrity of persons, goods or facilities, in which case they may be made available to the competent authority.

They will not be passed on to third parties, unless required by law 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 HAPPENS IF YOU DO NOT PROVIDE US WITH YOUR DETAILS?
For the processing of personal data that we carry out in full compliance with our corporate purpose and objectives, we endeavour to request or apply only the minimum data that is essential for this purpose. This is in line with the principles included in the applicable regulations.
However, failure to provide your personal data may mean that you will be unable to: 1) browse our website correctly (disable technical cookies); 2) process your reservation or specific request (for example, due to the lack or insufficient filling in of the forms provided on the platform).
In any case, we kindly ask that the information and personal data you provide us with are adjusted and limited to what is requested through said 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 ANY THIRD PARTIES?
In general, we do not share your data with any third parties, nor do we sell or offer it to them. However, as a client of ILUNION HOTELS, your personal data may be shared with the entities that directly manage our hotels. Likewise, your data may be shared with our collaborating entities, in the manner and for the purposes described in the contracts signed with said entities. For the purposes indicated above, your personal data may be communicated, for example, with the entities that own the payment gateways. In any case, without detriment to the above, legally speaking we may transfer your data to:

Public Administrations in the cases provided for by Law.
State Security Forces and Authorities.
Courts and Tribunals.
It is also possible that certain third parties may have access to your personal information in the course of providing services to ILUNION HOTELS. For example, in the case of third-party cookies that are applied on the platform (see cookies policy).

ILUNION HOTELS has a number of data processors in charge of the processing of personal data under our control, allowing access to them, as trusted suppliers, and to the extent strictly necessary for the provision of the services contracted with them. These data processors operate under a service contract in accordance with the terms, conditions and guarantees contained in article 28 of the GDPR, with ILUNION HOTELS undertaking the corresponding controls, inspections and audits in this area to check that these data processors strictly comply with the contracts signed for this purpose and the applicable regulations.

8. DO WE TRANSFER YOUR PERSONAL DATA INTERNATIONALLY?
As a general rule, we do not plan to transfer your personal data internationally, and ILUNION HOTELS will adopt the necessary measures and guarantees in this area in accordance with current legislation on personal data protection. Nevertheless, in our cookies policy you will find information on the use of cookies by third parties who may transfer personal data internationally. You can consult the privacy information of third parties that serve cookies on this website, through our Cookies Policy.

9. WHAT RIGHTS DO YOU HAVE, 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 registered office of the company, or by e-mail to protecciondatos@ilunion.com, enclosing, if necessary to prove your identification, a copy of your national identity card or equivalent identification document (passport, NIE, 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, please visit www.aepd.es.
However, we recommend that before submitting any complaint or claim to the AEPD you contact us, and especially our DATA PROTECTION DELEGATE COMMITTEE (contactcenter@ilunionhotels.com) in order to analyse the specific situation and try, if necessary, to find an effective and amicable solution.

10. DO WE IMPLEMENT SECURITY AND PROTECTION MEASURES FOR YOUR PERSONAL DATA?

Taking into account the nature, scope, context and stated purposes of the processing, as well as the risks to your rights and freedoms which vary in likelihood and severity, ILUNION HOTELS applies (and will apply) appropriate technical and organisational measures to ensure the appropriate security and protection of your personal data, taking into account criteria for privacy by design and by default, as well as applying a system approach to concurrent risk which will be reviewed and updated by ILUNION HOTELS when necessary. The use of the 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 future legislative, doctrinal or jurisprudential developments that may be applicable, or for technical, operational, commercial, corporate or business reasons, and shall inform you in advance and with reasonable notice of any changes that may occur whenever possible. In any case, we recommend that, each time you access this platform, you read this policy in detail, as any modification will be published on this platform.