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1. PRIVACY POLICY - PROTECTION OF USERS' PERSONAL INFORMATION

PALLADIUM GESTIÓN S.L. is especially sensitive to the protection of personal data of the users of the services of the website and its customers. By means of this Privacy Policy (or Data Protection Policy) the owner of this site informs the USERS of the website about the uses to which the personal data collected are subjected, so that they can decide, freely and voluntarily, if they wish to provide the requested information.

PALLADIUM GESTIÓN S.L. reserves the right to modify this Policy in order to adapt it to new legislation, jurisprudential criteria, industry practices, or interests of the entity. Any modification will be announced with due notice, so that you are fully aware of its contents.

 

1.1 DATA CONTROLLER

The data controller is PALLADIUM GESTIÓN S.L. with address for these purposes at: Avenida Bartolomé Roselló, 18, 07800 Ibiza (Baleares).

 

1.2 DPD CONTACT INFORMATION

The contact details of the DPD designated by the data controller are as follows: dpo@palladiumhotelgroup.com

 

1.3 PURPOSES OF PROCESSING

The purposes of the collection and processing of personal data, through the various forms owned by the data controller made available to users, respond, depending on the specific case to:

  • Manage the registration in the "Palladium Pro" program, as well as manage the earning and redemption of Agent rewards within the framework of the "Palladium Pro" program and the "Palladium Rewards" program. To do so, you are invited to link your "Palladium Pro" account with "Palladium Rewards". If the user has not created an account, a Palladium Rewards account will be generated to redeem his or her points.
  • Manage your contact requests through the channels and/or forms provided for this purpose.
  • Information and, where appropriate, registration in sweepstakes organized or in which the data controller participates.
  • Know and share the opinion and experience of Palladium Pro Members through "Hotel Reviews".
  • Manage access to the E-Learning platform for courses related to Palladium.
  • Contact, through Sales, in order to provide you with exclusive commercial advantages.
  • Sending communications related to your account, including, but not limited to, gift card balances, notifications and anything else that keeps the cardholder informed of the status of his or her account.
  • Sending commercial communications by any means (including electronic) to inform you about news, events and about our products or services that may be of interest to you, unless you object to such treatment.
  • If you expressly consent, publish your status regarding the "Challenges and Rankings" on the websites, networks and digital media of the Palladium Hotel Group.

When you sign up for the Palladium Rewards Program, you can learn about the intended purposes by clicking on the link.

 

1.4 CONSERVATION PERIOD

The personal data provided will be kept for the corresponding period of time to comply with legal obligations or for the period of time that a judge or court may require them.

Consent-based data will be retained as long as you do not revoke consent or object to the processing.

Additionally, in order to improve your experience in future stays in our hotels, we will keep the data related to your visit history for a period of seven years, unless you inform us otherwise, in which case the legally established periods will be maintained and for the period that a judge or court may require them.

 

1.5 DATA BLOCKING

In accordance with Article 32 of the Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD), data controllers shall proceed to block the data when it proceeds to its rectification or deletion.

The blocking of the data consists of the identification and reservation of the data, adopting technical and organizational measures to prevent its processing, except for making the data available to the judges and courts, the Public Prosecutor's Office or the competent Public Administrations, in particular the data protection authorities, for the enforcement of possible liabilities arising from the processing and only for the period of limitation of the same.

 

1.6 STANDING

The data controller is entitled to the processing of personal data, based on:

In cases where it has been requested, based on the consent given by the data subject for one or more specific purposes as stated in Article 6.1. a) of the General Data Protection Regulation by completing the forms and checking the box provided for this purpose.

  • Based on the execution of a contract for the provision of services in accordance with the Terms and Conditions of the "Palladium Pro" Program, as stated in Article 6.1. b) of the General Data Protection Regulation.
  • Based on the legitimate interest of the entity, once the weighting of interests has been carried out, under the terms established in article 6.1 f) of the General Data Protection Regulation.
  • On the basis of compliance with a legal obligation imposed on the controller in accordance with Article 6.1.c) of the General Data Protection Regulation.

 

1.7 ORIGIN OF THE DATA

The personal data comes from the registration made by the Agent in the program or from the forms filled in by him/her made available by the data controller.

By linking your Palladium Rewards account to Palladium Pro, Palladium can collect information on the various programs and hotel stays.

 

1.8 DATA ACCURACY

On the other hand, in order that the data contained in our files, computer and/or paper, always correspond to reality, we will try to keep them updated. So that, for these purposes, the User must make the changes, directly, when so enabled or by communicating, by reliable means, to the corresponding area or department of the data controller.

 

1.9 ADDRESSEES

The personal data you provide to the data controller will not be disclosed or communicated to third parties, unless legally required. In particular, the data may be communicated to public authorities, in order to comply with the requirements of such authorities and the applicable regulations, where appropriate.

Palladium Gestión S.L. does not market, sell or carry out any similar activity with your personal data, it only processes your personal data for the indicated purposes and for the use of the data controller.

The controller has service providers with access to personal data (Data Processors). Among these service providers, you can find companies located outside the European Economic Area, so that international data transfers could be made, in any case, complying with appropriate safeguards in accordance with Articles 44 and following of the RGPD. For the realization of international transfers with suppliers of Palladium Gestión S.L. located in the USA, the standard contractual clauses of data protection adopted by the European Commission and other guarantees provided for in Chapter V of the RGPD are provided as a guarantee.

 

1.10 USER RIGHTS

However, the data subject of the personal data may in any case exercise the rights to which he/she is entitled, in accordance with the General Data Protection Regulation:

  • Right to request access to personal data relating to the data subject.
  • Right to request its rectification or suppression.
  • The right to request the limitation of your treatment.
  • Right to object to the processing.
  • Right to data portability.
  • To revoke, as the case may be, the consents granted.

The interested party may exercise such rights by means of a request in which he/she shall specify which of these rights he/she requests to be satisfied, sending a letter to the following address: Avenida Bartolomé Roselló, 18, 07800 Ibiza (Balearic Islands) or by e-mail to rgpd@palladiumhotelgroup.com. When there are doubts about your identity, you may be required to attach a copy of your ID card or equivalent identification document.

If you consider that your right to personal data protection has been violated, you may contact our Data Protection Officer at dpo@palladiumhotelgroup.com, or file a complaint with the Spanish Data Protection Agency (www.aepd.es).

You can obtain additional information about Data Protection in the Privacy Policy of Palladium Hotel Group, in this link.

Version: May 2024