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Privacy Policy

1- WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The person responsible for the processing of your personal data and owner of the website https://www.umasuites.com is SMART ROOMS COMPANY, SL registered in the Commercial Register of BARCELONA in volume 43,188, folio 213, page B426216, 1st entry with CIF B-65786378 and address at Trafalgar Street, 52, 1 º 2 ª, 08010 Barcelona, (hereinafter UMASUITES).

UMASUITES is a brand owned by SMART ROOMS COMPANY, SL through which it manages its own tourist establishments or those of third parties with the brands UmaHouse or Uma Suites.

SMART ROOMS has taken the necessary technical and organizational measures to comply with data protection regulations.

The contact details of SMART ROOMS, in relation to privacy and protection of your personal data are:

+34- 93 160 03 03
gdpr@smartroomscompany.com

 

2- WHAT KIND OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSE?

1-Types of personal data we process
For confidentiality reasons we collect as little data as possible from our customers, beyond the data they voluntarily provide us with or those that we are required by law to collect and keep in case of reservations made through the booking engines.

We may collect and process the following categories of personal data:

a. Name, title, gender.

b. Your contact details and address, telephone number if you make a booking by telephone and leave them with us, your email address if you make a booking to us from your email or those details required by the booking engine to make a booking. Details and date of your reservation, information about your stay and preferences, as well as your credit card details. Credit card information. In the case of making a reservation electronically, the system may request a selfie to verify the veracity of the documentation provided. Your image will only be used for these purposes and will only be kept for the time strictly necessary.

c. In the case of our employees, identification data, social security data, bank details and all data necessary for the development of the employment relationship.

d. Identification data of our suppliers and their contact persons in the case of companies.

e. Images captured by our video surveillance cameras installed in our establishments.

f. In case you send us your data via email because you are the owner of a building or a tourist apartment that you want us to manage, we will process the data necessary to evaluate the proposal and the corresponding procedures and formalities.

f. We record your communications with us by e-mail or other means. When you make a telephone communication, our customer service may record your questions in our database.

g. 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, website of origin and web browsing behavior.

2- Your personal data will only be used for the following purposes:

a. Register you in our database if you make a reservation, in case you provide them to us or make the reservation through a booking engine.

b. To carry out the necessary commercial and administrative procedures with the users of our website and our customers or potential customers.

c. At SMART ROOMS we process the information you provide in order to respond to the request for information you send us, provide you with information about our services, internally and externally manage your reservations or the provision of our services, as well as the purchases we make from our suppliers, and to comply with the legal obligations arising from such activities.

d. Communicate with you to answer your queries and handle your complaints or obtain your opinion about the quality of our accommodations, our services or the treatment received.

e. Send commercial advertising communications by email, social networks, or any other electronic means, if you have expressly consented to the sending of such commercial communications by electronic means. In case you are a recurring customer, we may send you commercial information, news or news related to our services without requiring prior consent. You may revoke your consent to receive marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us at gdpr@smartroomscompany.com.

f. To record the images captured by our video surveillance cameras installed in our establishments for security reasons. These images may be transferred to the police or judicial authorities at their request.

g. Likewise, the data that may be collected during your browsing will be processed in order to provide access to the online content of the website, as well as to meet the requests of web users, keep a record of statistical visits (IP addresses, browser data, country, page accessed, etc.) in order to help us develop better services and products, optimize our offer and provide a more effective customer service and improve the design and content of our websites.

h. The data of our customers and suppliers will be processed, within the contractual relationship that binds them to us, in compliance with administrative, tax, accounting and, where appropriate, in compliance with the law of public safety.

In accordance with the LSSICE, we inform you that SMART ROOMS does not engage in SPAM practices, therefore, does not send commercial mailings by e-mail if it does not have 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 purpose other than those described in this Policy, except by legal obligation or court order.

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 given to carry out the purposes described above, which will be requested at the time you request information from us. 

If a business relationship between you, whether as a customer, supplier, or employee and SMART ROOMS, the legal basis that will legitimize the processing of your personal data will be the execution of the contractual relationship generated, as well as, where appropriate, compliance with the corresponding legal obligations.

The legal basis that legitimizes the processing of images recorded by our video surveillance cameras is our legitimate interest in maintaining the security of our facilities.

Curriculum Vitae

If the user sends his/her CV to SMART ROOMS, through the "talent" section of our website or, through any other electronic means "we inform you that the data provided will be processed to make him/her participate in the selection processes that may exist, carrying out an analysis of the applicant's profile to select the best candidate for the vacant place in the Company. We inform you that we will only accept your CV if you send it to us electronically, so that CVs sent or delivered on paper will not be accepted. In case of any change in the data, please inform us in writing as soon as possible, to keep your data 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, guaranteeing total respect for confidentiality both in the processing and in its subsequent destruction. In this sense, after the aforementioned period and if you wish to continue participating in the selection processes of SMART ROOMS, please send us your updated curriculum again.

However, if you are hired by SMART ROOMS, your CV will be kept, together with the rest of your employment file for as long as your contractual relationship with the Company is maintained.

 

4- CONSERVATION PERIOD How long will we keep your data?

The personal data you provide will be kept for the time necessary to manage the information you request from us, as well as to manage the reservations made by our customers or for the fulfillment of any contract generated between SMART ROOMS and third parties.

The images recorded by our video surveillance cameras will be kept for 30 days, unless required by the police or judicial authorities to be kept for a longer period of time. In these cases they will be duly blocked.

Once the data have fulfilled the needs for which they were collected, we will delete them definitively. However, we will keep your data for a longer period of time if this is necessary to comply with legal obligations. Likewise, it may be necessary to keep them for the time necessary for the prescription of the legal responsibilities that are generated.

The data you provide us to initiate a recruitment process in SMART ROOMS will be kept for a maximum period of one year. Afterwards, if you have not joined SMART ROOMS and you are not part of 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, thereafter, for the periods provided by law.

 

5- TO WHICH RECIPIENTS YOUR DATA WILL BE COMMUNICATED?

 

Within our organization, your personal data will be processed by duly authorized personnel, and, if necessary or practical to fulfill the purposes stated above, may be processed by third parties.
The categories of recipients to whom your personal data may be communicated are as follows:

a. When necessary for operational reasons, with the companies Smart Rooms Company, S.L. and The Net Revenue, S.L. or GRUPO SOGAMAN (such as Sogaman, S.L.; Sogaman Residencial, S.L.U.; Sogaman T26, S.L.U. Sogaman Rambla, SLU, Sogaman Palma, S.L.U.) with which we share management.

b. Third parties appointed as processors, such as IT providers, consultants and advisors and other companies that provide ancillary services.

c. Public entities and bodies, exclusively for complying with the corresponding legal obligations, including the Police to whom the identity of the persons staying in our establishments will be communicated, in compliance with the current regulations on public safety.

d. Other providers to whom, if applicable, your personal data may be transferred to financial institutions, fraud detection service providers, if applicable, etc.

e. Video surveillance management company.

In any case, all the aforementioned third parties will have previously signed the corresponding confidentiality commitment following our instructions in accordance with the 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 both through this website will be hosted on the servers of SMART ROOMS.

 

6.- WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

If you wish to exercise the rights that the data protection regulations grant you, please send us an e-mail to the following address gdpr@smartroomscompany.com putting in the subject the right you wish to exercise and attaching a copy of your national identity card or passport.

The rights that the current legislation recognizes and that, if applicable, you can exercise are:

Right of Access to data:
You are entitled to be informed by SMART ROOMS whether your personal data is being processed and, if the processing is confirmed, it will enable your access by providing you with the following information:
-The purposes of the processing.
-The categories of data being processed.
-The period or criteria for data retention.

The right to rectify the data:
You will have the right to have SMART ROOMS rectify your data when they are inaccurate or incomplete by means of an additional rectifying statement.

Right to Deletion of Data:
- The data subject shall have the right to have SMART ROOMS delete his/her data, when:
- The processing is unlawful.
- The data subject has withdrawn his/her consent.
- They are no longer necessary in relation to the purposes for which they were collected or processed.
- The data subject has exercised the right to object and no other legitimate grounds for the processing prevail.
- The data must be deleted in order to comply with a legal obligation of SMART ROOMS.

The data subject shall not have the right to have SMART ROOMS delete his or her data when the processing is necessary:
-To exercise the right to freedom of expression and information.
-To comply with a legal obligation of SMART ROOMS.
-For the formulation, exercise or defense of claims.
-For public interest based on current legislation for reasons of public health or for historical, statistical or scientific research purposes.

Right to data portability:
You have the right for SMART ROOMS to transmit your data to another data controller or to the same data subject, by means of a structured format of habitual use and mechanical reading, when the processing is carried out by automated means and is based on:
-The data subject's consent for specific purposes.
The performance of a contract or pre-contract with the data subject.

The right to data portability shall not apply when:
-It is technically impossible to transmit.
-It may adversely affect the rights and freedoms of third parties.
-The processing has a public interest mission based on current legislation.

Right to restrict the processing:
The data subject shall have the right to object to the processing of his/her data carried out by SMART ROOMS for reasons related to his/her particular situation, when the processing is based on:
-Direct marketing.
-Profiling.
-Legitimate interest of the controller or third parties, provided that the interests or the rights and freedoms of the data subject, especially if he/she is a child, do not prevail.
-Historical, statistical or scientific research, unless the processing is necessary for reasons of public interest.

Even if the data subject objects to the processing of his or her data, SMART ROOMS may continue to process them provided that its legitimate interest prevails over the interests or the rights and freedoms of the data subject in a legal proceeding that justifies it.

SMART ROOMS shall inform the data subject of the right to object to the processing of his/her data explicitly, clearly and separately from any other information, at the time of the first communication.

Right of opposition:
This is the right not to have their processing carried out or to cease processing when their consent to the processing is not necessary, due to the concurrence of a legitimate and well-founded reason, referring to their specific personal situation, which justifies it, and provided that a Law does not provide otherwise.

Right not to be subject to profiling:
The data subject shall have the right not to be subject to profiling whose purpose is to make individual decisions based on automated data processing and intended to evaluate, analyze or predict the following personal aspects:
-Professional performance.
-Economic situation.
-Health.
-Personal preferences or interests.
-Reliability.
-Behavior.
-Location or movements of the person.

When profiling is based solely on automated processing:
-The data subject shall have the right to be informed if the decision that may be taken is likely to produce legal effects significantly affecting him/her.
-The data subject shall have the right to obtain human intervention by SMART ROOMS, to express his or her point of view and to challenge the decision, if the processing has been authorized by means of:
-The data subject's explicit consent.
-A contract between SMART ROOMS and the data subject.
The right not to be subject to profiling does not apply when the decision that may be taken as a result of profiling is authorized by:
-The explicit consent of the data subject.
-A contract between SMART ROOMS and the data subject.
-A processing based on the legislation in force.

 

 

7-CLAIM BEFORE THE SUPERVISORY AUTHORITY:
In case you consider that SMART ROOMS has violated any of your rights protected by the personal data protection regulations or that SMART ROOMS has violated any obligation regarding the protection of Personal Data, you have the right to submit a complaint to 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

Likewise, you can file an electronic claim through the electronic headquarters available on its website https://www.aepd.es 

8-LEGISLATION AND JURISDICTION

This privacy policy is governed in each and every one of its ends by 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.

Likewise, it is governed by the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights. Likewise, our website is governed by Law 34/2002, of July 11, 2002, on information society services and electronic commerce.

Users of this website are subject to Spanish legislation and jurisdiction to which they expressly submit, being competent for the resolution of all disputes arising from or related to its use the Courts and Tribunals of BARCELONA.

9- ADDITIONAL INFORMATION

SOCIAL NETWORKS (PRIVACY POLICY)

We inform you that SMART ROOMS may have a presence in social networks. The processing of data carried out by the people who become followers in social networks (and/or perform any link or action of connection through social networks) of the official pages of SMART ROOMS shall be governed by this section, as well as by those conditions of use, privacy policies and access regulations belonging to the social network that applies in each case and previously accepted by the user.

SMART ROOMS will process your data for the purposes of properly managing your presence in the social network, informing you of activities, products or services of the provider, as well as for any other purpose that the regulations of the Social Networks allow.

The publication of content is prohibited:
- That are allegedly unlawful by national, community or international regulations or that perform allegedly unlawful activities or contravene the principles of good faith.
- That violate the fundamental rights of persons, lack of courtesy in the network, disturb 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 contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

Likewise, SMART ROOMS reserves the right to remove, without prior notice, from the website or the corporate social network any content deemed inappropriate.
Communications sent through social networks will be incorporated into a file owned by SMART ROOMS, which may send you information of interest.
You can access more information, as well as consult the companies that are part of our group, in this privacy policy.
In any case, if you send personal information through the social network, SMART ROOMS shall be exempt from liability in relation to the security measures applicable to this platform, and the user, if he/she wishes to know them, should consult the corresponding particular conditions of the network in question.



SECURITY MEASURES

The data you provide will be treated confidentially. SMART ROOMS has adopted all technical and organizational measures and all necessary levels of protection to ensure security in the processing of data and avoid its alteration, loss, theft, treatment or unauthorized access, according to the state of technology and nature of the data stored. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in the current regulations.

SSL CERTIFICATE (SECURE SOCKETS LAYER)

The SSL CERTIFICATE provides authentication, privacy and information security between SMART ROOMS and the user. SMART ROOMS has a security certificate that is used to make secure connections and is established using pre-established keys, encrypting and decrypting all data sent until the connection is closed.

LANGUAGE
The language applicable to this Privacy Policy is Spanish. Therefore, if any contradiction in any of the versions provided in other languages, the Spanish version shall prevail.

10-UPDATE

This Privacy Policy was last updated in December 2021, but may be updated at any time. We recommend that you check it each time you access our site for any changes.