PRIVACY POLICY

Your privacy is important to us.

PANORAM HOTELS SPAIN, S.L. (hereinafter collectively and interchangeably referred to as “PHM”, “we”, “our” or “us”), is a hotel management company.

At PHM, we value the privacy of all individuals, including visitors to our website, www.panoramhotels.com, and anyone who provides us with information through it. We process user data as part of our service provision. Please note that any modifications made to the original text only aim to improve clarity, conciseness, or formality without altering the core message. If the text contains quotes, they are repeated verbatim. PHM agrees to process your data in compliance with the applicable personal data protection regulations. PHM will comply with 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, as well as any other applicable regulations in force.

PHM informs its users of the processing of their data and the fundamental principles of personal data protection through its Privacy Policy. However, certain services on the website may have special conditions of use that prioritize personal data protection over this policy.

We urge all users to carefully read this Privacy Policy to learn about the rules and practices we have developed to protect personal data and to understand our relationships with third parties who may have access to such data.

The user is solely responsible for the information provided on the website. If PHM wishes to use it for purposes other than those referred to, we will inform you of these new purposes and request your consent, if necessary.

By using our website, you acknowledge that you have read and agreed to our Privacy Policy, Cookie Policy, and Legal Notice.

1.- Who is the data controller?

Datos de contacto del responsable del tratamiento: PANORAM HOTELS SPAIN, S.L., with CIF B-83902429., address at C/ Cervantes, number 19, Bajo Derecha, 28014 – Madrid (Spain) and contact e-mail address rgpd@panoramhotels.com

  1. What are the data protection rights of users?

Users have the following rights: the

right to request access to their personal data, the right to request rectification of inaccurate data or completion of incomplete data, the

right to request deletion of their data, the right to request limitation of data processing (in

which case, data will only be kept for the

exercise or defense of claims), and the right to object to data processing.

 PHM will cease processing personal data, except when such processing is necessary for legitimate reasons or for the exercise or defense of possible claims.

If the user wishes to have their data processed by another data controller, PHM will facilitate the transfer of their data to the new controller.

Additionally, users have the right not to be subject to a decision based solely on the automated processing of their personal data.

If you have given consent for a specific purpose, you may withdraw it at any time without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

To exercise their rights, users must send a written communication to PHM’s registered office or to the email address indicated in section 1 of this Privacy Policy. The communication must include a photocopy of their ID card or other equivalent identification document.

How can you file a complaint with the Spanish Data Protection Agency?

To access the models and forms mentioned in the previous point, visit the official website of the Spanish Data Protection Agency.

 If you believe that PHM is mishandling your personal data, you can file a complaint with PHM or the corresponding Control Authority. In Spain, please direct your complaint to the Spanish Data Protection Agency (Agencia Española de Protección de Datos).

In what cases do we collect personal data about you and what type of data do we collect?

The term ‘personal information’ refers to any information that can be used to identify you, such as your name, address, telephone number, or email address.

If you choose to provide us with your personal data, PHM may have access to the information contained in each form you fill out or the data you provide through the different email accounts that PHM makes available for contacting us.

Your data is processed when you interact with PHM and our representatives, participate in PHM-related activities, or provide personal data through the website. This includes registering on our website or using certain features without registering, such as participating in our interactive services.

  1. a) Personal data provided voluntarily by the user:

Name and surname
Email

Any information provided via email or online forms.

  1. b) Personal data that our website collects from your computer or electronic device:

Cookies, only for https://www.panoramhotels.com

For additional details regarding PHM’s use of cookies, please refer to our Cookie Policy.

How does PHM utilize users’ personal data?

PHM notifies applicable users that any personal data provided to us and collected will be identified in PHM’s Register of Processing Activities and used solely for the purpose of:

Respond to user queries or information requests.

Provide our services in compliance with the Legal Notice.

Use personal data only for purposes required or permitted by law or with user consent.

Why do we process personal data?

PHM may process your personal data for legitimate business purposes, with your consent, to comply with legal and regulatory obligations, or as necessary for the performance of a contract to which you are a party.

PHM processes personal data for the promotion and evaluation of its services.

– This task involves responding to requests for technical and operational information related to the services offered by PHM on the website.

Additionally, it requires identifying and contacting customers to manage and fulfill contracts.

We will manage our relationship through our website based on any documents accepted or signed by the user.

COMPLY WITH LEGAL AND REGULATORY OBLIGATIONS.

Any other applicable regulations must also be followed.

CONSENT:

The user must provide consent for the collection and processing of their personal data, such as their CV. TRANSPARENCY: If there is no local regulation,

it is important to be transparent about who will have access to the user’s personal data.

Depending on the purpose for which personal information is collected, certain individuals may have access to such information.

PHM personnel or their representatives, subject to applicable data protection laws, may share information with

regulatory authorities or other third parties in accordance with applicable laws.

Third parties, such as service providers who process information as a data processor under the instructions of PHM, may also receive information. Before sharing any information, reasonable steps will be taken to ensure compliance with applicable data protection laws.

We will not sell or disclose any information or personal data that you have provided on our website, which can identify you directly or indirectly, to third parties.

Where are your personal data processed?

We will not carry out transfers of personal data outside the European Economic Area (EEA). Notwithstanding the above, in the event that such transfers are made, PHM will do so in compliance with applicable data protection laws. Regardless of where your personal data is collected or processed, PHM ensures and guarantees that service providers maintain appropriate administrative, technical, and physical security measures to protect information about you.

How do we protect your personal data?

PHM maintains the levels of data protection security required by Royal Decree 1720/2007, of December 21, which approves the Regulation for the Development of the Organic Law on Personal Data Protection and other related legislation in force at all times, and has established all technical means at its disposal to prevent loss, misuse, alteration, unauthorized access, and theft of the data that the user provides through the website.

In any case, we have implemented measures that we consider appropriate to protect your information, both internally and externally, against loss, misuse, unauthorized access, disclosure, alteration, and destruction, and to ensure the integrity of the data we collect. PHM will take appropriate technical and organizational measures, both when designing the data processing system and at the time of processing itself, to preserve security and prevent unauthorized processing. However, despite the diligent implementation of such measures, the user should be aware that security measures on the Internet are not impregnable.

Third parties will only process your personal data according to our instructions and when they have agreed to treat the information confidentially and keep it secure.

How long will we retain your personal data?

PHM processes your personal data for the period necessary to fulfill the purposes established in this Privacy Policy, as well as to retain your personal information in compliance with the provisions of relevant laws and regulations.

The criteria we follow for this are determined by:

– The purpose of the data collected and compliance with that purpose.

– The reasons why the data is collected; e.g., in case of consent, you may revoke it at any time.

– Mandatory storage periods according to contractual and regulatory requirements.

Please note that in some cases, PHM is obliged to retain certain data about you.

Confidentiality

Professionals working at PHM who have any involvement in services provided to the user are committed to not disclose or use the accessed information. The information provided by the user will, in any case, be considered confidential and cannot be used for purposes other than those related to the management associated with their requests and services contracted from PHM, if applicable. In this sense, we undertake not to disclose or reveal information about the user’s intentions, the reasons for the requested advice, or the duration of their relationship with us.

Social networks

PHM is present on some of the main social networks on the Internet and acts as the data controller concerning the data published by PHM on these platforms.

PHM will process the data on each social network according to the rules established by each social network. Therefore, unless stated otherwise by PHM, we may inform our followers on the corresponding social network about our activities, events, and other related topics, including follower care, through the channels provided by the social network.

PHM will not extract personal data from social networks unless the user expressly consents.

Special category of personal data

We will not collect or process any particularly sensitive personal data or data included in the special category of personal data of users unless explicitly provided by them. The special categories of personal data refer to information related to race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the exclusive purpose of identifying a natural person, data concerning health, sex life, or sexual orientation.

Policy on child use

This website is not designed for or directed to children under eighteen (18) years of age without parental or legal guardian authorization. In this regard, we do not deliberately collect information from such individuals. However, if parents or legal representatives believe that their children have sent us personal data without their consent, please contact us by writing to rgpd@panoramhotels.com.

Direct marketing

We will not use users’ personal data for direct marketing purposes without their explicit prior consent.

If at any time you decide to stop receiving commercial or promotional information from PHM, you can, free of charge and without providing a justification, unsubscribe from direct marketing campaigns and object to the future processing of your personal data for such purposes by sending an email to rgpd@panoramhotels.com or by clicking the “opt-out” (unsubscribe) link in the subject of the email. You can also use the unsubscribe procedure provided in any promotional message you receive from PHM.

Please note that even if you decide not to subscribe or unsubscribe from promotional emails or newsletters, we may still need to contact you regarding important non-commercial information, such as problem-solving, error detection and prevention, or generally to comply with the website’s Legal Notice.

Automated decision making

We will not use automated decision-making processes, including profiling unless you have explicitly authorized us to do so. In that case, we will inform you about the logic used in the decision, as well as the significance and anticipated consequences of such processing for you.

Links to other websites

PHM’s websites contain links to other websites that we consider potentially useful and informative for you. However, please note that we do not endorse or recommend the content or services of such websites, nor are we responsible for their privacy policies. We recommend that you consider and read the privacy policies of all the sites you visit. Remember that what is stated in this Privacy Policy only applies to the data collected and/or processed by PHM.

Modifications and integrity of our Privacy Policy

We will only use your personal data as established in the Privacy Policy in force at the time we collect your personal data. PHM reserves the right to modify this Privacy Policy at any time by publishing such modifications on our website, so we recommend that you visit it whenever you access the Privacy Policy. If at any time we decide to use personal data differently from what was stated at the time of collection, we will inform you via email, provided we have it. At that time, you will be given the option to authorize other uses or disclosures of the personal data you have provided to us before the modification of our Privacy Policy.

In the event that any clause of this Privacy Policy is annulled or deemed void, the rest of the conditions will not be affected, maintaining their full validity and effect, in accordance with the current regulations applicable at all times.