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PALLADIUM REWARDS PRIVACY POLICY
PALLADIUM GESTIÓN S.L.U. is particularly conscious of its duty to protect the personal data of users of the website’s services and of its customers. With this Privacy Policy (or Data Protection Policy), the owner of this site hereby informs website USERS about how the personal data collected are used so that they can freely decide whether to provide the requested information.
PALLADIUM GESTIÓN S.L.U. reserves the right to amend this Policy in line with new legislation, criteria of case law, industry practice, or the company's interest. Any change thereto will be announced with due notice to ensure you have a thorough understanding of its content.
1 DATA CONTROLLER
PALLADIUM GESTIÓN S.L.U. is the data controller, and its address for this purpose is: Avenida Bartolomé Roselló, 18, 07800 Ibiza, Balearic Islands, Spain.
2 DATA PROTECTION OFFICER CONTACT DETAILS
The contact information for the data protection officer appointed by the data controller is: dpo@palladiumhotelgroup.com
3 PURPOSES OF DATA PROCESSING
The purpose of collecting and processing personal data through the forms owned by the data controller and made available to the Users is, depending on the specific case, to:
- - Manage registration in the “Palladium Rewards” program, and administer user points earned and spent in that program.
- - Manage bookings made through the "Palladium Rewards” program website at any of our hotels.
- - Take into account the information and preferences you have indicated in your “Palladium Rewards” profile, as well as the products and services you have booked and enjoyed, in order to offer you products and services that may be of interest to you, based on statistical data compiled by us.
- - Manage your contact requests made through the channels and/or forms available for that purpose.
- - Provide information and, when applicable, register in prize draws organized by or in which the data controller participates.
- - Gain knowledge of our customers’ opinions through satisfaction and quality surveys.
- - Send communications related to your account including points balance, card category or level, notifications, and anything else that keeps the member informed about the status of their account.
- - Send marketing communications by any means (including electronic) to inform you of any news or events and about any products or services that might be of interest to you, unless you oppose this type of processing.
- - Manage the transfer of Rewards points to a friend or another loyalty program.
4 DATA STORAGE PERIOD
In order to comply with legal obligations, any personal data provided will be kept during the corresponding period or during such period as may be required by a judge or a court.
Consent-based data shall be stored as long as you do not withdraw your consent or object to their processing.
Additionally, to improve your experience during future stays at our hotels, we will store the data related to your visit history for seven years unless you tell us otherwise, in which case the periods established by law and for the period of time during which they may be required by a judge or court will be observed.
5 DATA BLOCKING
In accordance with article 32 of Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (hereinafter LOPDGDD as per its acronym in Spanish), data controllers will proceed to block data when they must be amended or erased.
The blocking of data consists of identifying and restricting such data, by implementing technical and organizational measures, in order to prevent their processing, except where the data are made available to judges and courts, the Public Prosecutor’s Office, or the competent Public Authorities, in particular data protection authorities, for the purpose of establishing potential liabilities arising from the processing, and solely for the duration of the applicable limitation period.
6 LEGITIMATE GROUNDS
The data controller may lawfully process personal data:
- - When this has been requested and consent has been granted by the data subject for one or more specific purposes as specified in article 6.1 a) of the General Data Protection Regulation by filling out the forms and checking the box provided for this purpose.
- - When processing is necessary for the execution of a contract for the provision of services in accordance with the Terms and Conditions of the “Palladium Rewards” program as specified in article 6.1. b) of the General Data Protection Regulation.
- - On the grounds of legitimate interest, pursuant to article 6.1. f) of the General Data Protection Regulation.
7 DATA SOURCE
Personal data are obtained from the User's registration in the “Palladium Rewards” program, the booking made by the data subject, or the forms provided by the data controller which the data subject has filled out.
8 DATA ACCURACY
We will endeavor to keep all data held on file up-to-date to ensure their accuracy. For this purpose, Users may make changes themselves when this option is enabled or communicate them officially in writing to the data controller's corresponding area or department.
9 RECIPIENTS
The personal data that you provide to the data controller may be reported to the following recipient categories:
- - Third parties the Company is required to convey information to, such as public authorities, to comply with those authorities’ requirements and the legislation applicable in that case.
- - Companies that own the hotels to be able to make the booking. The lawful basis in this case would be the execution of a contract or pre-contractual measures (art. 6.1.b. GDPR). • In cases where registration in the "Palladium Rewards” program is done through a personalized link provided by a program member, that member will be able to see the full name of the people who have registered with the program using this link so that they can verify the list of “friends” who have accepted the invitation and those for whom the referring user has received points.
- - Organizations that have joined the Program under a participation agreement (Partners), where Rewards points are transferred to another loyalty program. In such an event, only the Palladium Rewards membership number will be communicated to the party responsible for running the loyalty program to which the Rewards points are transferred. The lawful basis for this disclosure of personal data is the data subject’s consent, as provided when completing the form and confirming the points transfer.
PALLADIUM GESTIÓN S.L.U. does not market, sell, or undertake any similar activity with your personal data. It limits itself to processing your personal data for the purposes indicated and for the data controller’s use.
The data controller has service providers with access to personal data (processing managers). Some of the service providers may reside outside the European Economic Area; therefore, international data transfers may occur, although they would comply with the appropriate guarantees in accordance with Chapter V of the GDPR. For international transfers with suppliers of PALLADIUM GESTIÓN S.L.U. located in the US, data protection clauses such as those adopted by the European Commission are provided by way of a guarantee.
10. RIGHTS OF INTERESTED PARTIES
The data subject may exercise their rights in accordance with the General Data Protection Regulation. These rights are as follows:
- - Right to request access to the data subject’s personal data • Right to request the rectification of inaccurate or incomplete data
- - Right to request their erasure
- - Right to request the restriction of processing
- - Right to object to processing
- - Right to data portability
- - Right to withdraw any consent given
The data subject may exercise these rights by submitting a request specifying which right is to be exercised, sending this written request to the Data Controller at the following address: Avenida Bartolomé Roselló, 18, 07800 Ibiza, Balearic Islands, Spain, or by email to rgpd@palladiumhotelgroup.com. When there are doubts about the subject’s identity, they might be asked to provide a copy of their National ID card or equivalent document.
Furthermore, if you believe that your right to personal data protection has been violated, you may contact our Data Protection Officer at dpo@palladiumhotelgroup.com, or a complaint with the Spanish Data Protection Agency (www.aepd.es).