Privacy Policy

1. Data Controller

In compliance 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 (General Data Protection Regulation, hereinafter referred to as “GDPR”) and Organic Law 3/2018 of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter referred to as “LOPDGDD”), we inform you of the following:

The Data Controller of the personal data is:

REQUENA Y MARTINEZ S. A, C. I. F. A04002416 Dirección. C/ Plácido Langle, 08, 1º 04001 Almería Tel. 950 23 25 44 Email. torreluz@torreluz.com

2. Collected Data

We collect and process your personal information in general to manage the relationship we have with you. This personal data includes:

Customer Data

Identifying information: name, ID number (DNI/NIF/NIE/Passport), address (postal or electronic), phone number (landline or mobile), signature, photographs, videos.
Personal characteristics: date and place of birth, gender, age, nationality.
Cookies, IP address when visiting the website.

Potential Customer Data

Identifying information: name, ID number (DNI/NIF/NIE/Passport), address (postal or electronic), phone number (mobile).
Cookies, IP address when visiting the website.

Employee Data

Identifying information: name, ID number (DNI/NIF/NIE/Passport), address (postal or electronic), phone number (landline or mobile), signature, digital signature, social security account number, photographs.
Personal characteristics: marital status, date and place of birth, gender, nationality.
Academic data: education, qualifications, level of education.
Professional data: work experience, seniority, salary.
Banking data: bank account number.

Curriculum Data

Identifying information: name, ID number (DNI/NIF/NIE/Passport), address (postal or electronic), phone number (mobile), signature, photographs.
Personal characteristics: marital status, date and place of birth, gender, nationality.
Academic data: education, qualifications, level of education.
Professional data: work experience.
Cookies, IP address when visiting the website.

Video Surveillance

Identifying information: management of images.

Origin. The data comes from the interested party themselves.

3. How do we collect your information?

We collect your personal information through different means, and you will always be informed at the time of collection through informative clauses about the data controller, the purpose and legal basis of the processing, the recipients of the data and the retention period of your information, as well as how you can exercise your rights under data protection laws.

As a result of the purpose of the service we provide, of which you will have been duly informed and, where appropriate, consent will have been requested for one or more specific purposes.

REQUENA Y MARTÍNEZ S.A uses social networks, such as Facebook, Twitter, as another way to reach you. The information collected through the messages and communications you post may contain personal information that is available online and accessible to the public. These social networks have their own privacy policies explaining how they use, share your information and manage advertising, so REQUENA Y MARTÍNEZ S.A recommends that you consult them before using them to confirm that you agree with the way your information is collected, processed, and shared.

When you contact us by phone to make a reservation and contract various services

Through our website, we collect personal information when you sign up for our Torreluz Friends club, when you make a reservation and contract various services, when you request to receive commercial information, when you request to ask us a question, as well as related to your browsing through the use of cookies. To clearly and precisely understand the cookies we use, their purposes, and how you can configure or disable them, please refer to our Cookie Policy.

In addition, our facilities have a video surveillance system whose function is to ensure the safety of people and property, so your image may be recorded simply by accessing them.

4. User Responsibility

By providing us with your data through electronic channels, the user guarantees that they are over 14 years old and that the data provided to REQUENA Y MARTÍNEZ S.A is true, accurate, complete, and up-to-date. For these purposes, the user confirms that they are responsible for the truthfulness of the communicated data and that they will keep this information up-to-date so that it reflects their real situation at all times, being responsible for any false or inaccurate data they may provide, as well as for any direct or indirect damages caused.

5. Purpose of the Processing

The collection and processing of user’s personal data respond, depending on the specific case, to:

Customer Data

Management of reservation and contracted services data, as well as activities related to the commercial relationship.
Manage, where applicable, the registration process of the Customer on the Online Booking Platform.
Conducting checks to detect fraudulent activities.
Sending commercial communications associated with their registration.
Managing preferences associated with the Torreluz friends registration.
Management of social media platforms owned or associated with www.torreluz.com.
Statistical analysis and profiling based on browsing or interests in order to improve the service.
Contact, resolving incidents, managing inquiries related to the service, or any other similar situation related to the services offered by REQUENA Y MARTÍNEZ S. A.

Potential Customer Data

Management of data in relation to potential customers, as well as activities derived from the commercial relationship.
Management of social media platforms owned or associated with www.torreluz.com.
With the aim of providing the requested service.
Statistical analysis and profiling based on browsing or interests in order to improve the service.
Contact, resolving incidents, managing inquiries related to the service, or any other similar situation related to the services offered by REQUENA Y MARTÍNEZ S. A.

Employee Data

Management of data in the employment relationship with employees.

Curriculum Data

Human resources, staff selection.
Statistical analysis and profiling based on browsing or interests in order to improve the service.
Management of social media platforms owned or associated with www.torreluz.com.

Video Surveillance

Management of images to ensure the security of property, facilities, and individuals.

6. Retention Period

The data will be kept for as long as necessary to fulfill the purpose for which they were collected, for the years necessary to comply with legal obligations, and to determine any possible liabilities that may arise. They will be blocked and, if necessary, limited, and made available to the competent authorities.

If you wish to join our team and apply for one of our job positions, the data provided in your resume will become part of our job bank and will be kept for the duration of the selection process and for a maximum of 2 years or until you exercise your right to deletion.

If at any time we have collected your data to address you as a potential customer of our services or to respond to a quote request made by you, such data will be kept for a maximum of 2 years from collection. They will be deleted after this period if no contractual relationship has been formalized or when requested by you.

In any case, and as a general rule, we will keep your personal information as long as there is a contractual relationship that binds us or until you exercise your right to deletion and/or limitation of processing. In such cases, the information will be blocked without being used beyond its preservation, as long as it may be necessary for the exercise or defense of claims or there may be some type of liability that needs to be addressed.

7. Legitimación

REQUENA Y MARTÍNEZ S. A is legitimized to process personal data for one or more specific purposes as established by the GDPR:

Article 6.1.a) GDPR, the data subject has given consent to the processing of their personal data for one or more specific purposes.

Unambiguous consent based on preferences and purposes.
Based on the consent given by the data subject through the signing or acceptance of the relevant forms. If you are a user of our website, by ticking the box on the contact form, you authorize us to send you the necessary communications to respond to the query or information request raised.

Article 6.1.b) GDPR, the processing is necessary for the performance of a contract to which the data subject is party or for the application of pre-contractual measures requested by them.

Article 6.1.c) GDPR, the processing is necessary for compliance with a legal obligation applicable to the data controller.

Article 6.1.f) GDPR, legitimate interests pursued by the data controller to ensure the security of property, facilities, and individuals.

Article 6.1.f) GDPR, legitimate interest to address inquiries and claims raised by users and to manage the collection of amounts owed, as well as sending commercial communications.

8. Data Accuracy

All information provided by the user through the Portal’s services must be truthful. For this purpose, the user guarantees the authenticity of all data communicated as a result of completing the forms necessary for the subscription of the Services. Likewise, it will be the responsibility of the user to keep all the information provided to REQUENA Y MARTÍNEZ S. A permanently updated so that it responds, at all times, to the real situation of the user. In any case, the user will be solely responsible for false or inaccurate statements made and for any damages caused to REQUENA Y MARTÍNEZ S. A.

9. Recipients

In case it is necessary due to an incident recorded by our security cameras, your images could be communicated to the State Security Forces and Corps, in accordance with the law.

The personal data of clients will be transferred to Police Departments for the control of the entry register of travelers, as well as in cases where there is a legal obligation.

They will only be transferred in cases necessary for the development, control, and fulfillment of the expressed purpose(s), in cases provided by law.

There are no international transfers of your data to countries outside the European Economic Area (EEA).

Likewise, your personal information will be available to Public Administrations, Courts, and Tribunals, to address possible liabilities arising from the processing.

10. User Rights

We inform you that you can exercise your rights of access (to request access to personal data and certain information about the processing, purposes, category of data processed, and recipients, among other aspects), rectification (rectification of inaccurate data), deletion (deletion of data when, among other reasons, they are no longer necessary for the purposes for which they were collected), opposition (right to object to the processing of your data, at any time, for reasons related to your particular situation), limitation of processing (limitation of your personal data, being processed only for the exercise or defense of claims), revocation of consent (revoke the consent given at any time), and data portability (receive personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller without hindrance from the data controller to whom they were provided, in the legal cases provided for this purpose) accompanying a copy of your ID or equivalent identification document to C/ Plácido Langle, 08, 1º 04001 Almería. If you have not obtained satisfaction in the exercise of your rights, you have the right to file a complaint with the Spanish Data Protection Agency, whose contact details are as follows: C/ Jorge Juan, 6 – 28001 Madrid Telephone: 901 10 00 99/ 912 66 35 17.

11. Security Measures

Finally, it is reported that REQUENA Y MARTÍNEZ S. A will adopt in its information system reasonably reliable and effective physical, technical, and organizational measures, in compliance with the principle of proactive responsibility, in order to guarantee the security and confidentiality of stored data, thus preventing its alteration, loss, treatment, or unauthorized access and theft.

In addition, all personnel with access to personal data have been trained and are aware of their obligations regarding the processing of their personal data.

In the contracts we sign with our suppliers, we include clauses requiring them to maintain the duty of secrecy regarding personal data to which they have had access by virtue of the assignment, as well as to implement the necessary technical and organizational security measures to guarantee the permanent confidentiality, integrity, availability, and resilience of the systems and services for the processing of personal data.

All these security measures are periodically reviewed to ensure their adequacy and effectiveness. However, absolute security cannot be guaranteed, and there is no security system that is impenetrable, so in the event that any information subject to processing and under our control is compromised as a result of a security breach, we will take appropriate measures to investigate the incident, notify the Control Authority, and, if necessary, those users who may have been affected to take appropriate measures.

It is reported that the website www.torreluz.com is not adhered to any code of conduct, either its own or others. In the future, this adhesion may be modified by the will of REQUENA Y MARTÍNEZ S. A without any express written communication to its users.

This Privacy Policy may be modified scrupulously in response to possible legislative changes that occur, as well as to the guidelines issued by the Spanish Data Protection Agency.