Policy on Privacy

PRIVACY POLICY

 

1. Controller

 

The Controller responsible for the processing of the personal data provided by you through www.hipartners.com (the “Website”) is Hotel Investment Partners, S.A., having its registered offices in Edificio Planeta, Avenida Diagonal 662-664, 2nd Fl., 08034 Barcelona, email address info@hipartners.com (hereinafter “HIP” or the “Company”).

 

HIP has appointed a Data Protection Officer (DPO) who can be contacted at the following email address: dpo@hipartners.com.

 

2. Purposes of processing and lawful bases for processing

 

HIP processes the personal data provided by you for the following purposes:

 

  • to manage relations with customers and potential customers and with any interested party who contacts HIP; the lawful basis for this processing is the existence of a contractual or pre-contractual relationship or the legitimate interest of HIP in responding to queries when the aforementioned bases do not prove applicable.

 

  • receiving and evaluating CVs of candidates for positions of employment, and the management of the internal data base of candidates and, if vacancies are found that fit candidates’ profiles, contacting them; the lawful basis for the inclusion of candidates’ data in HIP’s job bank is the data subjects’ consent and the application of pre-contractual measures in the phases of the selection process prior to hiring.

 

  • to send you information on our products or services, including by electronic means; the lawful basis for this processing is your prior consent give by checking the corresponding box or, as the case may be, and so long as you do not object to it, HIP’s legitimate interest in sending you said information since there is a prior commercial relationship with you.

 

  • HIP may process your personal data with a view to attending to and investigating reports received through the Whistleblower’s Channel. You can access the privacy policy of HIP’s Whistleblower’s Channel through this link.

 

  • HIP also uses its own and third parties’ cookies to ascertain and analyse the use of its website and to adapt and improve its content. You can obtain more information on the use that HIP makes of cookies, and how to accept, reject or configure them by means of the buttons provided in HIP’s Cookies Policy through this link.

 

HIP does not take any automated decisions that might affect you based on the personal information that it processes.

 

3. Recipients and international transfers of data

 

The personal data provided may be communicated to other companies in the HIP group for internal administrative purposes or, when necessary, to comply with the contractual relations existing with the data subject, for example in the case of hotels forming part of the group. When necessary, HIP or the corresponding group company or companies will give you more information on the processing of your data.

 

Apart from this, HIP has service providers that act as Processors and help us with the internal management of the company, both in the operation of the business and in its administration. HIP has signed the corresponding agreements with them regulating the processing of personal data in accordance with data protection legislation. In certain situations HIP may also provide services to other group companies, acting in such cases as Processor.

 

In the event that HIP has to transfer your data outside the European Economic Area, it will make sure that such transfers are made with adequate safeguards to ensure an appropriate level of security as regards data protection. These safeguards may include, without imitation, the existence of an Adequacy Decision of the European Commission (EC), the adoption of standard contractual clauses also approved by the EC, or the application of any other mechanism recognised by current data protection legislation.

 

Lastly, when there is a legal obligation, it is possible that we might have to communicate your data to third parties such as courts and tribunals, State security forces or bodies and public prosecutors as well as consultancy and legal advisory firms for the formulation, exercise or defence of claims.

 

4. Retention times

 

HIPwill retain your personal data for as long as it needs them to fulfil the purpose for which they were collected.

 

In any case, any personal data you provide through the spontaneous application process will be kept in our database for a period of one year, with the possibility of that retention period’s being renewed subject to your consent.

 

Once the purposes have been fulfilled, HIP will retain the personal data duly blocked to the extent that liabilities may derive for HIP or any of its group companies or when so required by applicable legislation.

 

5. Rights of data subjects

 

In accordance with the legal obligations established in the applicable data protection legislation and in the terms provided therein, you can exercise your rights of access, rectification, erasure, restriction, objection and portability by sending an email to dpo@hipartners.com, or sending a letter to the postal address: Edificio Planeta, Avenida Diagonal 662-664, 2nd Fl., 08034 Barcelona.

If you have given your consent to anything, you can similarly withdraw this consent freely and at any time, without its producing any adverse consequences for you.

 

In any case, you have the right to file a claim or complaint regarding HIP’s processing with the Spanish Data Protection Agency.