PRIVACY POLICY

Personal data is only collected on this website with the knowledge and information of users.

In this document we explain in detail who is going to process  your data, what it is going  to be used for and what rights you can exercise, among other points. If you want to have more information you can read this Privacy Policy, as well as the Legal Notice and the Cookies Policy.

1. RESPONSIBLE FOR TREATMENT. WHO IS GOING TO TREAT YOUR DATA?

Identity	Neptuno Costadeje S.L.U
Direction	Calle Cataluña 3, Costa Adeje, 38670, Adeje, Santa Cruz de Tenerife
E-mail	subdirector@neptunocostadeje.com

2. WHAT PERSONAL DATA DO WE PROCESS AND WHERE DOES IT COME FROM

Due to your relationship with us, we may process different categories of personal data, always depending on the service or product contracted with us. These data may be collected by any of the means that Neptuno Costadeje S.L.U. offers, both online and in person. The categories of data processed may be the following:

• Contact data.
• Identification character of natural persons: name and surnames, DNI/identification document, telephone, email, address, signature.
• Special category data.
• Bank data.

If you have booked your stay through a travel agency or online travel agency, it will communicate your data to Neptuno Costadeje S.L.U. for the management of your reservation and/or contracting. Travel agencies or online travel agencies may use your personal data for their own purposes, so we will be dealing with another Data Controller. You can obtain information about the processing of your data by these entities by going to the Privacy Policy section of the agency's website.

In any case, if a third part y has provided us with your data, we will treat it within the purposes set out in this Privacy Policy.

3. PURPOSE. WHAT IS YOUR PERSONAL DATA USED FOR?

Neptuno Costadeje S.L.U. informs you that it may process personal data for the purposes indicated below, to the extent that there is a legal basis for each treatment as explained below.

The main purposes for which your personal data will be used are the following:

Purpose	More information on data processing
Reservation management and contracted services	Management of your contracted reservation. Sending confirmation of reservation. Processing, if applicable, of the payment of the reservation and the preauthorizations. In the event that in free writing fields of the data collection forms or by request to the call center agent, the user provides data related to their health to manage specific services, Neptuno Costadeje S.L.U. understands that said data is communicated expressly and voluntarily by the user, since there is prior request for this information and they will only be processed to manage the user's request (for example, rooms adapted based on special needs Management of requests for modification or cancellation of requested reservations. Check-in Management of accommodation and other services such as SPA, bars and restaurants, nursery, etc.
Compliance with legal obligations	Compliance with accounting, legal, fiscal and administrative obligations. In particular, registration of travellers and notification to the State Security Forces and Corps in compliance with public safety regulations.
Check In	Formalise and manage the booking, make the payment in accordance with the booking and cancellation conditions, as well as for the possible services derived from your stay.
Contests, raffles and events	Management of your participation in contests, raffles and other activities in which you have requested to participate.
Call recording	Neptuno Costadeje S.L.U. will process the data relating to your voice when you hold telephone conversations with us, by recording the calls you make or receive from Neptuno Costadeje S.L.U.. In any case, when we proceed to the recording of the call that we maintain with you, we will previously inform you about it, through a locution at the beginning. Calls will be recorded for: To respond to your requests and analyse them in order to improve the responses offered and provide a more personalised service, thus guaranteeing the quality of service. To increase security and to have a means of accreditation of the services or products requested and/or contracted and those offered by us, being necessary for this purpose the recording of the calls.
Referral of surveys of quality	In order to evaluate the level of user satisfaction with the contracted products and/or services, Neptuno Costadeje S.L.U. will send quality surveys in order to obtain your opinion about them and thus be able to improve the provision of its services on an ongoing basis In order to be able to offer the user products and services that may be of interest.
Commercial communications (not expressly requested)	In order to be able to offer the user products and services that nay be of interest, they will be sent offers on products and services related to those already contracted or that they have contracted in the past with Neptuno Costadeje S.L.U.. You will be able to opt out of receiving these communications in each communication you receive.
Commercial communications Sendi	Commercial communications about offers not related to the contracted services and/ or products. Neptuno Costadeje S.L.U. may send you promotional offers on certain products that the user can enjoy at the hotel (eg, furniture in the reserved room, invitations to events, SPA, etc.). In the same way, Neptuno Costadeje S.L.U. may send information about activities related to tourism and leisure, such as cultural activities, excursions, sporting events, etc. that may or may not be offered in conjunction with our accommodation services.
Questions, requests or suggestions	Management of the query, request or suggestion transferred by the interested party.
Resume Submission	Include it in the currently open personnel selection processes or for future processes in which the candidate may fit, not being able to be used for other purposes.

In addition, by providing your data by any of the means provided, you guarantee the veracity of the data provided and undertake to communicate any changes that occur in them.

Remember that, when we ask you to fill in your personal data to give you access to some functionality or service, we will mark some fields as mandatory, since they are data that we need to be able to provide you with the service in question. Please note that if you decide not to provide us with such data, you may not be able to enjoy those services or features or send us your request.

4. LEGITIMATION. WHY DO WE USE YOUR PERSONAL DATA?

The GDPR and the LOPD establish that a person's information (his or her "personal data") may only be processed if one of the legitimate bases expressly provided for in those regulations is met. More specifically, and in this regard, Article 6 of the GDPR establishes a closed list of the legitimate bases that may exist to justify and legitimise the processing of personal data:

• Consent;
• Contractual relationship;
• Vital interests of the data subject or of other persons;
• Compliance with a legal obligation for the controller;
• Public interest or exercise of public powers;
• Overriding legitimate interest of the controller or of third parties to whom the data are disclosed.

Neptuno Costadeje S.L.U. will carry out processing of your data, in some cases, under the legitimate interest provided for in Article 6.1.f) of the GDPR, insofar as it considers that it does not prejudice the right of customers to the protection of their personal data. This provision authorises processing operations which are - necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.

On such treatment, you have the right to:

• Obtain more information on what this -legitimate interest- consists of.
• To know how Neptuno Costadeje S.L.U. has come to the conclusion that they do not harm the protection of your personal data.
• Or directly to object to them. You may do so through the channels set out in section 7 - RIGHTS YOU MAY EXERCISE -, indicating the specific processing to which you object and the grounds on which your request is based.

Of all the processing carried out on the basis of legitimate interest, Neptuno Costadeje S.L.U. has carried out what is known as a "balancing test". This is an internal analysis to confirm that the legitimate interest of Neptuno Costadeje S.L.U. does not harm the interests of its customers in the protection of their personal data. You can obtain information about the relevant test by sending a request to the e-mail address subdirector@neptunocostadeje.com.

Having said this, Neptuno Costadeje S.L.U. will process your data for the purposes and in accordance with the legitimate bases detailed below.

PURPOSE	LEGITIMATION
Reservation management and services execution.	Contracted contractual
Compliance with legal obligations	Contract execution, compliance with legal obligation. Compliance with legal obligations (among others: Ley Orgánica 4/2015, de 30 de marzo, de 30 de marzo, de Protección de la Seguridad Ciudadana, art. 25.1.)
Check In	Execution of reservation contract and its consent
Contests, sweepstakes and events.	Your consent.
Call recording	Legitimate interest of Neptuno Costadeje S.L.U. Neptuno Costadeje S.L.U. has carried out a - weighing test -, from which it concludes that this legitimate interest does not harm your privacy, taking into account that: You will be informed prior to the recording of the calls, so that you can interrupt the call at any time before the recording begins, and raise your query or contract through other means (e.g. email or in person at our premises). The aim is to be able to have evidence of the conversation and to assess the care we have given you, whether you are satisfied with it, and how we can improve this care in the future.
Referral of surveys of quality.	Legitimate interest Of Neptuno Costadeje S.L.U..
Commercial communications (not expressly requested)	Legitimate interest.
Commercial communications.	Your consent.
Questions, requests or suggestions	If you send us a query, request or suggestion without being registered with Neptuno Costadeje S.L.U., we will use the data provided to respond to the query based on your consent and your legitimate interest. When a registered user makes us a query, request or suggestion, we use their data to respond based on the execution of the contract. In case of submitting a request to exercise the rights explained in point 7. RIGHTS YOU MAY EXERCISE, we will use your data based on a legal obligation.
Resume Submission	Execution of pre-contractual measures or the intention to conclude a contract at the request of the applicant.

5. CONSERVATION OF YOUR DATA. HOW LONG WILL WE KEEP THEM?

The personal data provided will be processed and kept for the time necessary to fulfill the purpose for which they are collected. Once this period has ended, we will keep your data duly stored and protected so that it can be made available to the competent Public Administrations, Judges and Courts or the Public Prosecutors Office during the limitation period for actions that may arise from the relationship maintained with the user and/or or during the legally established storage periods. Once the possible actions of each case have expired, Neptuno Costadeje S.L.U. will proceed to delete the personal data.

In the event that the legitimacy for the processing of your data is based on your consent, Neptuno Costadeje S.L.U. will keep your information as long as the user does not withdraw the consent first given.

Some of the legal deadlines that we must comply with are the following:

DATA	DEADLINES
Entrance art and booK registration	3 years
Accounting and tax documentation for comercial purposes	6 years
Accounting and tax documentation for tax purposes	4 years
Building access control	1 month
Video surveillance	1 month
Sending commercial communications	Until the withdrawal of your consent

6. TO WHOM DO WE COMMUNICATE YOUR DATA?

To fulfill the purposes indicated in this Privacy Policy, it is necessary that we give access to your personal data to entities that provide us with support in the services we offer, namely:

• Financial entities, business advice, transport, etc: companies necessary for the management of your reservation and stay.
• Collection management entities and insurers in order to carry out the claims against tour operators or clients as a result of the legitimate interest of Neptuno Costadeje S.L.U. in managing the collection of the services provided, as well as insuring the amounts pending payment.
• Third-party services, such as cloud-based services, payment processing technology services, services to carry out marketing initiatives, or services to conduct customer surveys on our behalf.
• Search engines

Apart from those indicated, Neptuno Costadeje S.L.U. will not transfer personal data to third parties, except by legal obligation. However, in the case of being transferred to a third party, the user will be previously informed requesting express consent for such transfer. The entity responsible for the database, as well as those who intervene in any phase of the treatment and/or the entities to whom it has been communicated -in any case, always with the corresponding authorization granted by the user-, are obliged to observe the professional secrecy and the adoption of the levels of protection and the necessary technical and organizational measures within its reach to guarantee the security of personal data, avoiding, as far as possible, unauthorized access, illicit modifications, theft and/or loss of data, in order to ensure the corresponding level of security of the files, according to the nature and sensitivity of the data provided by the users of this website.

In compliance with the LO 4/2015 on the protection of public safety Public Safety, the details of guests will be communicated to the police authorities.

7. RIGHTS YOU MAY EXERCISE

You can exercise any of the rights that we explain below, simply indicating the reason for your request and the right you want to exercise. In the event that we consider it necessary to be able to identify you, we may request a copy of a document proving your identity.

In general, you will always have the right to:

• Request access to your personal data, to know what data we have about you.
• Request rectification of your data: keep in mind that, by actively providing us with your personal data by any means, you guarantee that they are true and accurate and you agree to notify us of any changes or modifications to them.
• Request that we delete your data to the extent that they are no longer necessary for the purpose for which we need to treat them as we have informed you above, or that we no longer have the legitimacy to do so.
• Request that we restrict the processing of your data, which means that in certain cases you may ask us to temporarily suspend the processing of your data or to keep it longer than necessary when you may need it.
• Request the portability of your personal data. This means that you will have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, in order to be able to transmit it to another entity directly, whenever technically possible.
• Request the right to object to the processing of your data when the processing of your data is based on our legitimate interest.
• Request not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects on him or significantly affects him in a similar way.

You can request the exercise of right through the following means:

• Postal mail, sending your request or delivering it in person at: Calle Cataluña 3, Torviscas Centro, Costa Adeje, 38670, Adeje, Santa Cruz de Tenerife
• A través del correo electrónico: subdirector@neptunocostadeje.com

Neptuno Costadeje S.L.U. must answer the request within one month of receipt of the request. This period may be extended for another two months if necessary, taking into account the complexity and number of requests.

You have the right to withdraw the consent given at any time by sending an email to Subdirector. The withdrawal of consent will not affect the legality of the treatment carried out before the withdrawal of consent.

If you consider that your right to the protection of your personal data has been violated, you may file a claim with the Spanish Data Protection Agency, www.aepd.es.

8. WHAT HAPPENS IF YOU PROVIDE US WITH THIRD PARTY DATA OR IF A THIRD PARTY HAS PROVIDED US WITH DATA HIS?

There are occasions when you can provide data from third parties, for example, contact persons. If you provide us with Personal Data of third parties, you guarantee that you have informed them about the purposes and how we need to process your personal data.

If you have booked your stay through a travel agency or online travel agency, it will communicate your data to Neptuno Costadeje S.L.U. for the management of your reservation and/or contracting. Travel agencies or online travel agencies may use your personal data for their own purposes, so we will be dealing with another Data Controller. You can obtain information about the processing of your data by these entities by going to the Privacy Policy section of the agency's website.

In any case, if a third party has provided us with your data, we will treat it within the purposes set out in this Privacy Policy.

9. CHANGES TO THE PRIVACY POLICY

We may modify the information contained in this Privacy Policy when we deem it appropriate, in compliance, for example, with legislative or jurisprudential changes. In the event that we do so, we will notify you in different ways through the changes on the web, or we will even communicate it to your email address when the change in question is significant for your privacy, so that you can review the changes, assess them and, where appropriate, oppose or unsubscribe from any service or functionality.

10. ANY QUESTIONS ABOUT THIS POLICY OR YOUR RIGHTS?

If you have any doubts or questions about the privacy policy or about how to manage any personal data that you have provided us, you can contact subdirector@neptunocostadeje.com.