1. WEBSITE RESPONSIBILITY
This website is the responsibility of Líbere Hospitality S.L., NIF B 95953683, a company whose registered office is located at C/Buenos Aires nº12, 48001 Bilbao, Bizkaia; registered in the Bizkaia Mercantile Registry, volume 5850, folio 72, page BI- 73271, entry number 1 (hereafter referred to as Líbere Hospitality S.L.).
2. RATIONALE
Líbere Hospitality S.L. respects the privacy rights of its users and recognises the importance of protecting the personal data which Líbere Hospitality S.L. gathers about them.
The objective of this document is to inform website users about the personal data processing carried out on this website.
3. PERSONAL DATA PROCESSED MERELY BY ACCESSING THIS WEBSITE3.1. What data is processed?
When a user simply accesses this website, Líbere Hospitality S.L. collects the IP address and other data related to the Internet connection and its origin.
The IP address is a code that identifies the user’s Internet connection and the time at which the access occurred.
Only the user’s Internet access provider can identify which subscriber was assigned an IP address at a specific time.
Our website server automatically records the user’s IP address along with the date and time of access.
3.2. What is this data used for?
This data is only used to manage the normal use of this website, and to perform statistical analyses on the use of our website.
3.3 Data recipients
Líbere Hospitality S.L. does not pass this information to any third party, unless obliged to do so by current legislation (for example, an official request in connection with a police investigation).
3.4. Lawful processing
The legal basis that legitimises our processing of the IP address is the technological need to enable website provision.
3.5. Data processing period
IP addresses will be stored for a period of one month.
4. A USER’S RIGHTS AND HOW TO EXERCISE THEM
The data protection regulations guarantee users the following rights:
- Right of access: This allows the user to know what data is available, where it was obtained, to whom it has been provided, and how it has been used and processed.
- Right to rectification: This allows the user to rectify any inaccurate or obsolete data.
- Right to deletion: This allows the user to have their data erased.
- Right to object: This allows the user to prevent their data being used for a specific purpose.
- Right to limit processing: This allows the user to restrict the processing of their data unless it must be stored for some later purpose.
- Right to data portability: This allows the user to obtain a copy of their data in an electronic format and, in certain circumstances, to request that their data be passed to another service provider. This only applies to computer processing carried out with the user’s consent or for the purposes of fulfilling a contract.
- Right to withdraw consent: Where applicable, this allows the user to withdraw any consent they originally gave for the processing of their data.
To grant these rights, it must be possible to identify the user who makes a request, and it must also be possible to link that user’s identity with the data processed by Líbere Hospitality S.L.
However, Líbere Hospitality S.L. cannot establish this link just from the data it gathers when a user merely accesses the website, unless the user can provide certain documentation that permits their identification (for example, a certificate from their Internet access provider, which indicates the IP address assigned to the user at a specific date and time).
Users can exercise their aforementioned data-protection rights in respect of Líbere Hospitality S.L., and also withdraw any current consent for processing, by writing to the address given above or email given below specifying the requested rights and providing proof of their identity.
Should users require further information regarding these matters or consider their rights to data protection to have been violated, they are advised to contact the Spanish Data Protection Agency (www.aepd.es).
5. OTHER PROCESSING OF PERSONAL DATA
5.1. Cookies and similar technologies
Líbere Hospitality S.L. uses cookies and other similar data storage and retrieval mechanisms on terminal equipment (hereafter referred to as cookies).
Cookies are files downloaded to the user’s browser that Líbere Hospitality S.L. can read later. This use of cookies facilitates various functionalities, such as, for example, recognizing a user who has previously accessed the website, and provides the capacity to analyse the use of this web service for the purposes of improvement.
However, it is not possible to discover a user’s identity from the cookies used by Líbere Hospitality S.L., unless the user provides additional data through other means and this data can be linked to the downloaded cookies.
For more information, see our Cookies Policy.
5.2. Website forms
Líbere Hospitality S.L. has various website forms that are used to collect personal data.
5.2.1. Reservation form
Líbere Hospitality S.L. will process the data gathered through the reservation form primarily for the purpose of managing your reservation, as well as to manage an appropriate business relationship and to handle your requests for information regarding your reservation.
- The legal basis that legitimises this processing: The need to execute the contractual relationship between the parties, and the legitimate interest of Líbere Hospitality S.L. in keeping you informed about your reservation.
- Storage period: The data will be processed for the time necessary to manage the reservation. Subsequently, it will be locked and stored for five years pending any potential liabilities that may arise from the processing.
- Recipients: At the time of managing the reservation, your personal data will be communicated to the entity that manages the payment gateway: The legal basis that legitimises this processing is the need to execute the contractual relationship between the parties involved. Likewise, when checking your reservation, we inform you that the data provided at that time will be passed on to the relevant law enforcement authorities so that Líbere Hospitality S.L. can comply with its legal obligations. Thus, it is our obligation to comply with the legal basis that legitimises this processing. On the other hand, in the event of requesting any of the services offered by Líbere through its website and during the booking process and managed by third parties, your data will be transferred to said third parties in order to carry out the provision of the contracted service. The legal basis that legitimises the processing is the need to execute the contractual relationship between the parties.
Líbere Hospitality S.L. informs you that, unless you have objected to this on the reservation form by ticking the appropriate box, your data will be processed in order to send you commercial communications about services, products, news, events and/or promotions offered by the hospitality and tourism sector of Líbere Hospitality S.L., which we believe may be of interest to you.
- The legal basis that legitimises this processing: The legitimate interest of Líbere Hospitality S.L. derived from the existing business relationship between the parties involved.
- Storage period: The data will be processed indefinitely, unless and until you request your right to deletion or your right to objection.
There is further information about commercial communications in the “THE SENDING OF COMMERCIAL COMMUNICATIONS“ section of this Privacy Policy.
You may exercise your data protection rights, as described in the rights section “A USER’S RIGHTS AND HOW TO EXERCISE THEM“ of this Privacy Policy, at any time.
5.2.2. Contact form and information request
Líbere Hospitality S.L. will process your data provided via our various contact and information request forms, in order to meet your contact requests.
- The legal basis that legitimises this processing: The user’s consent, which is expressed at the time of sending their contact request.
- Storage period: The data will be processed for the period of time necessary to resolve the user’s contact request. Subsequently, this data will be locked and stored for three years pending any potential liabilities that may arise from the processing.
You may withdraw any consent previously given, and also exercise your rights in terms of data protection, at any time, as indicated in the rights section of this Privacy Policy: “WHAT RIGHTS DOES THE USER HAVE AND HOW TO EXERCISE THEM“.
6. ONLINE CHECK-IN
Libere Hospitality S.L. will process the data provided with the main purpose of managing your check-in, as well as the legal obligation of Líbere Hospitality S.L. to prove their identity and online guest registration, for which it will be necessary to collect their image and identity verification through an official document, such as an ID.
The legal basis that legitimizes this treatment is the need to execute the contractual relationship between the parties and the obligation of Líbere Hospitality S.L. to prove their identity and register guests.
At the time of managing the check-in, your personal data will be communicated to the entity that manages the payment gateway. The legal basis that legitimizes the treatment is the need to execute the contractual relationship between the parties. Likewise, we inform you that the data provided at that time will be communicated to the Security Forces and Bodies in order to comply with the legal obligations of Líbere Hospitality S.L. The legal basis that legitimizes the treatment is said compliance.
The data will be processed during the validity of the contractual relationship and, subsequently, during the legally necessary period, in order to attend to the possible responsibilities derived from said relationship. The information corresponding to the verification of your identity through your image will be eliminated when validating the document provided.
At any time you can exercise your rights regarding data protection, as indicated in the rights section “A USER’S RIGHTS AND HOW TO EXERCISE THEM” of this Privacy Policy.
7. THE SENDING OF COMMERCIAL COMMUNICATIONS
Líbere Hospitality S.L. informs the User that commercial communications, requested by the User or, if the User has not opposed their receipt by marking the corresponding checkboxes in the forms, sent by email will be sent using the Customer.io tool, managed by the company Peaberry Software, Inc. located in the USA. Therefore, your data may be transferred outside the European Economic Area. However, we inform you that these entities provide adequate data protection guarantees through their adherence to the EU-US Data Privacy Shield Framework, which is declared as providing an adequate level of protection by the European Commission, or by signing the Standard Contractual Clauses approved by the European Commission. The data will be processed for this purpose indefinitely until you decide to unsubscribe from these communications by exercising your right of deletion or objection.
In each communication, the User may object to receiving this type of information through the contact method provided to process their unsubscribe request.
The legal basis that legitimizes this processing is the consent granted by you through the marking of the corresponding checkbox.
At any time, you may exercise your rights of access, rectification, deletion, objection, limitation, or portability through postal mail to the address provided or by emailing privacy@liberehospitality.com, proving your identity and identifying yourself as a registered user of the website and specifying your request. If you believe that your data protection rights have been violated, you can file a complaint with the Spanish Data Protection Agency (www.aepd.es).
8. TELEPHONE CALL RECORDING
Líbere Hospitality S.L. informs the User that telephone calls will be recorded and the data provided by the User will be processed for the purpose of evaluating the quality and ensuring proper management of the service, as well as in cases where a reservation is desired and to confirm the reservation made via telephone.
The legal basis for this processing is the legitimate interest of Líbere Hospitality in evaluating the quality of the service provided, and in the case of service contracting, the legal obligation to confirm the contracting.
The recordings will be kept for the legally necessary period, with the purpose of addressing any potential liabilities arising from the relationship.
9. MORE INFORMATION
If the user has any further questions about the data collected under our Privacy Policy, they can send an email to: