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PRIVACY POLICY | (AM RESORTS EUROPE)

Last updated: February 27th, 2019

Except as otherwise noted in this Privacy Policy, AMResorts Europe is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”)), which means that we decide how and why the information you provide to us is processed. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law.
We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Information we may collect
We may Process the following categories of Personal Information about you:
• Personal details: your name; username or log in details; password;.
• Demographic information: gender; age/date of birth; nationality; salutation;.
• Contact details: postal address; telephone and/or mobile number; email address;.
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
We may also collect:
• Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
• Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
• Non-precise information about the approximate physical location (for example, at the city or postal code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
• Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device but is different than a hardware serial number.
• Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
• Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
• Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
• Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
• Device type, settings and software used.
• Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
• Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
• Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third-party website.
• Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
• Mobile analytics to understand the functionality of our mobile applications and software on your phone.

Sensitive Personal Information
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual preference, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business except where we are explicitly given consent to support the booking process.
Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

How we Collect Information
We may collect Personal Information about you from the following sources
• Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
• Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
• Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
• Content and advertising information: If you choose to interact with any third-party content or advertising on the Services or Channels, we may receive Personal Information about you from the relevant third party.
• Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.

Purposes for Which We May Process Your Information
The purposes for which we may Process Personal Information, subject to applicable law, include:
• Accounts and Personalization: providing personalization for Services from company’s name or its partners including (i) management of your account, (ii) posting of your personal reviews, testimonials or comments, (iii) offering of contests, as well as chat areas, forums and communities, and (iv) customer support and relationship management.
• Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
• Surveys: engaging with you for the purposes of obtaining your views on our Services.
• Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you.
• Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using Personal Information to serve you advertisements on the Services and Channels.
• User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
• Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular third-party merchant’s site to offer coupons and other offers that are relevant to your shopping experience; offering of coupons via SMS messages if a mobile phone number is provided.
• Marketing to Customers: We may market to current and prospective customers who have indicated an interest in doing business with, or have previously conducted business with, in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising.
• IT Administration: compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
• Security: Cyber-security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
• Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that the user is in violation of our Terms and conditions or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security company’s name, any of our users or the public, or to respond to an emergency.
• Administrative: Budget planning, commercial information, invoicing, tax declaration.

Video Surveillance
We have CCTV systems in our facilities that might record you while you are using them, the purpose to record activity only in public areas is to provide security to our customers, employees and to provide evidence to legal institutions when they require it by official means.
All the public areas that are being recorded by our CCTV Systems can be identified by a signboard, by using our facilities you agree to be recorded.

Automatic Decision-Making
AM Resorts Europe does not use automatic decision-making process. If in the future, we start using that technology to process your information we will notify you previously and inform you about your rights.

Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above.
• Internal Third Parties: Other companies in the ALG Group.
• External Third Parties:
 Suppliers of accommodation and travel services based within or outside the EEA acting as processors or controllers who provide the services that make up any booking of travel services that you make with us;
 Service providers acting as processors based within and outside the EEA who provide IT and system administration services;
 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within and outside the EEA who provide consultancy, banking, legal, insurance and accounting services;
 Regulatory and governmental bodies and other authorities acting as processors or joint controllers based in within and outside the EEA who require reporting of processing activities in certain circumstances.
• Specific third parties: Such as Elavon Financial Services DAC, based in UK, who provides a credit card merchant service, and Trisept Solutions LLC, the technology provider behind the Website’s booking platform, and based in the United States.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers of Information
Because of the international nature of our business, we may need to transfer your Personal Information within the ALG group of companies, and to third parties, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
In accordance with the above, we may send your Personal Information to the following countries where Apple Leisure Group has operations and partnership with services providers:
• United States of America
• Mexico
• Dominican Republic
• Panama
• Curacao
• Jamaica
• Costa Rica
• Spain
• St Martin
• Netherlands
• United Kingdom
We have implemented appropriate technical security measures in order to protect Personal Information during International transfers, in compliance with applicable laws.
Where you have made a reservation for accommodation or travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.

For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. Contact details can be found at the bottom of this Privacy Policy.
Data Security
• We have implemented appropriate technical and organizational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Transport Layer Security (TLS) 1.1 or higher to transfer certain Personal Information to provide protection. However, we are not responsible for any breach of security or for the actions of any third parties.
• Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.
Data Accuracy
We take every reasonable step to ensure that your Personal Information that we Process is accurate and up to date. When you inform us that your Personal Information is inaccurate we will correct or erase it.
Know Your Rights
In accordance with GDPR a person living in the EU has the right to request
• a copy of what information we collected from you
• to update/rectify your personal information
• deletion of your personal information
• we stop certain types of processing with your information
• an electronic copy of your data that will be provided in a format that a machine will be able to read
Keep in mind that your information is important to provide you with products and services. Deletion or restriction of certain data may prevent us from providing the services you requested. You also have the right to file a complaint with the EU Data Protection Authorities.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Data Minimization
We take every reasonable step to ensure that your personal information collected and processed is limited to what we need to provide you services, or access to the services, described in this Privacy Policy.
Data Retention
We take every reasonable step to ensure that your Personal Information is only Processed and stored for the minimum period necessary for business and legal requirements. We will only use your data for the reasons you provided it to us, and for legal reporting purposes.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By legal and tax purposes we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Cookies/Automated Collection of Information and Third-Party Policies
Company´s name currently uses "cookies" on our site. Our cookies tag each visitor's browser with a random, unique number. The cookie simply assigns a number and does not disclose any personal information about the person using the browser. By noting where these uniquely numbered browsers go on our site, we can study traffic patterns and site usage, and improve our site to better fit our customers' needs.
We may connect information collected automatically with information we already have about you in order to identify you as an AM Resorts Europe guest, including from third parties (for example, Google Analytics) to whom you have given permission for this purpose. This allows us to provide you with a personalized experience regardless of how you interact with us online, in store, mobile, etc.
We and our service providers, and third parties you have given permission to, may use cookies, web beacons and other technologies to receive and store certain types of information whenever you interact with us through your computer or mobile device. This information, which includes, but is not limited to: the pages you visit on our site, which web address you came from, the type of browser/device/hardware you are using, purchase information and checkout processes, search terms, and IP-based geographic location, helps us recognize you, customize your website experience and make our marketing messages more relevant. This includes AM Resorts Europe content presented on another website or mobile application, for example, AM Resorts Europe emails. These technologies also enable us to provide features such as storage of items in your cart. We also use Flash cookies for fraud prevention purposes.
For more detailed information our Cookie Policy can be found here

Cookies, Tracking & Interest-Based Advertising
The help function of your browser should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued or to not receive cookies at any time. If you set your device to not receive at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of our features (i.e. you will be able to browse the site but will not be able to make a purchase).

Contact Details
You may contact us at the addresses set out below or by emailing rgpd@aluahotels.com
Attention:
Gremi Cirurgians i Barbers, 48, 2°E, 07009, Palma de Mallorca
Phone Number: 971465611
You may also find information about how to contact each Hotel here