Politique de confidentialité
1. Responsible
In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, General Data Protection Regulation (hereinafter, GDPR) and the Organic Law on the Protection of Personal Data and guarantee of digital rights 3/2018, of December 5, we inform you of the following.
The Data Controller of personal data is;
REQUENA Y MARTINEZ S. A, VAT number A04002416 Address. C/ Plácido Langle, 08, 1º 04001 Almería Tel. 950 23 25 44 Email. torreluz@torreluz.com
2. Data collected
We collect and process your personal information in general to manage the relationship we have with you. This personal data includes:
Customer data
- Identifying data: name and surname, ID card / 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.
Prospective customer data
- Identifying data: name and surname, ID card / NIE / Passport, address (postal or electronic), phone number (mobile).
- Cookies, IP address when visiting the website.
Employee data
- Identifying data: name and surname, ID card / 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 studies.
- Professional data: work experience, seniority, salary.
- Banking data: bank account number.
Curriculum data
- Identifying data: name and surname, ID card / 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 studies.
- Professional data: work experience.
- Cookies, IP address when visiting the website.
Video surveillance
- Identifying data: management of images.
- Source. The data comes from the interested party.
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 regarding data protection.
Derived from the purpose of the service we provide, of which you will have been duly informed, and in some cases, consent will have been requested for one or more specific purposes.
REQUENA Y MARTÍNEZ S. A uses social networks, such as: Facebook, Twitter, this is 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 that explain 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 how your information is collected, processed, and shared.
When you contact us by phone to make a reservation and hire various services
Through our website, we collect personal information when you sign up for our Torreluz friends club, when you make a reservation and hire various services, when you request to receive commercial information, when you request to make a query, as well as information related to your browsing through the use of cookies. To know clearly and precisely the cookies we use, their purposes, and how you can configure or disable them, please refer to our Cookie Policy.
Additionally, 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’s 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. To this end, the user confirms that they are responsible for the truthfulness of the communicated data and that they will keep this information updated so that it reflects their real situation, being responsible for any false and inaccurate data they may provide, as well as for the direct or indirect damages that may arise.
5. Purpose of the processing
The collection and processing of the user’s personal data respond, depending on the specific case, to:
Customer data
- Management of reservation and contracted services data, as well as the management resulting from the business relationship.
- Manage, if applicable, the Client’s registration process on the Online Reservation Platform.
- Perform checks to detect fraudulent activities.
- Sending commercial communications associated with your registration.
- Manage preferences associated with Torreluz friends registration.
- Management of social platforms owned or associated with www.torreluz.com
- Statistical analysis and profiles based on navigation or interests in order to improve the service.
- Contact, resolve incidents, manage queries related to the service or any other similar situation in relation to the services offered by REQUENA Y MARTINEZ S. A.
Prospective customer data
- Management of data in the relationship with potential customers, as well as the management resulting from the business relationship.
- Management of social platforms owned or associated with www.torreluz.com
- In order to provide you with the requested service.
- Statistical analysis and profiles based on navigation or interests to improve the service.
- Contact, resolve incidents, manage queries related to the service or any other similar situation in relation to the services offered by REQUENA Y MARTINEZ S. A.
Employee data
- Management of data in the employment relationship with employees.
Curriculum data
- Human resources, staff selection.
- Statistical analysis and profiles based on navigation or interests in order to improve the service.
- Management of social platforms owned or associated with www.torreluz.com
Video surveillance
- Image management to ensure the security of property, facilities, and people.
6. Retention Period
The data will be kept for as long as necessary to fulfill the purpose for which it was collected, for the years required to fulfill legal obligations, and to determine any possible liabilities that may arise. Being blocked and, if applicable, limited, being able to be made available to the competent authorities.
If you want to join our staff 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 we have collected your data at any time to address you as a potential customer of our services or respond to a budget request made by you, such data will be kept for a maximum of 2 years, from the date of collection, and will be deleted after this period if no contractual relationship has been formalized or when you request it.
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 which case, the information will be blocked without further use beyond its retention, as long as it may be necessary for the exercise or defense of claims or if there may be some kind of responsibility that needs to be addressed.
7. Legitimacy
REQUENA Y MARTINEZ 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 for the processing of their personal data for one or more specific purposes.
- Unequivocal consent based on preferences and purposes.
- Based on the consent given by the data subject by signing or accepting 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 submitted.
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 at the request of this of pre-contractual measures.
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 interest of the data controller to ensure the security of property, facilities, and people.
Article 6.1.f) GDPR, legitimate interest to address the queries and claims that you raise and to manage the collection of outstanding amounts, as well as the sending of commercial communications.
8. Data Accuracy
All the information provided by the user through the Portal’s services must be true. To this end, the user guarantees the authenticity of all the data communicated as a result of completing the forms necessary for the subscription of the Services. Likewise, it will be the user’s responsibility to keep all the information provided to REQUENA Y MARTINEZ S. A constantly 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 the damages caused to REQUENA Y MARTINEZ S. A.
9. Recipients
If necessary due to an incident recorded by our security cameras, your images may be communicated to the State Security Forces and Bodies, in accordance with the provisions of the Law.
Customer personal data will be transferred to Police Stations for the control of the entry parts logbook, 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 the cases provided for by law.
There are no international transfers of your data to countries outside the European Economic Area (EEA).
Furthermore, your personal information will be available to Public Administrations, Judges, and Courts, to handle any 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, categories of data processed, and recipients, among other aspects), rectification (rectification of inaccurate data), deletion (deletion of data when, among other reasons, it is no longer necessary for the purposes for which it was collected), opposition (you have the 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, which will only be processed 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 transmit it to another data controller without hindrance from the data controller who provided it, in the legal cases provided for this purpose) accompanying a copy of your ID or equivalent identification document at C/ Plácido Langle, 08, 1º 04001 Almería. If you have not been satisfied in the exercise of your rights, you have the right to file a complaint with the Spanish Data Protection Agency, whose contact information is as follows: C/ Jorge Juan, 6 – 28001 Madrid Telephone numbers: 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 physical, technical, and organizational measures, reasonably reliable and effective, appropriate, complying with the principle of proactive responsibility, in order to ensure the security and confidentiality of the stored data, thus preventing its alteration, loss, processing, unauthorized access, and theft of this data.
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 that require them to maintain the duty of confidentiality regarding the personal data to which they have had access as a result of the assignment, as well as to implement the necessary technical and organizational security measures to ensure permanent confidentiality, integrity, availability, and resilience of the systems and services for the processing of personal data.
All these security measures are reviewed periodically to ensure their adequacy and effectiveness. However, absolute security cannot be guaranteed, and there is no security system that is impervious, so in the event that any information subject to processing and under our control is compromised due to a security breach, we will take appropriate measures to investigate the incident, notify the Supervisory Authority, and, where appropriate, those users who may have been affected so that they can take appropriate measures.
It is reported that the website www.torreluz.com is not affiliated with any code of conduct, whether its own or external. In the future, this affiliation may be modified at the express will of REQUENA Y MARTÍNEZ S. A without the need for express written communication with its users.
This Privacy Policy may be modified scrupulously in response to both possible legislative changes and the guidelines issued by the Spanish Data Protection Agency.