Updated 24th of February 2022
We respect your right to privacy and will only process personal data you provide to us in accordance with the Regulation (UE) 2016/679 of European Parliament and Counsel (the “GDPR”), and other applicable Spanish privacy laws.
RESPONSIBLE FOR YOUR DATA
If you have any questions, comments or complaints about the use of your personal data, please contact our customer service department by e-mail at firstname.lastname@example.org or by telephone at +34 935 115 181.
PRINCIPLES FOR PROCESSING YOUR DATA
The following principles are applied by EAS and by any of its staff members who have access to personal data. Personal data will always be:
a) processed lawfully, fairly and in a transparent manner.
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
f) processed with integrity and confidentiality: in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
TYPES OF DATA PROCESSED
We collect and process the following categories of personal data:
- Personal data related to the provision of our services.
- Personal data related to staff or candidates.
Personal data related to newsletter subscriptions and commercial prospection.
Identity and Contact Data: including your name, address, telephone number, email, date of birth, marital status, passport number, employment history, educational and/or professional background, tax status, employee number, job title and function, and other personal data concerning your preferences relevant to our services;
Business Information: including information provided in the course of the contractual or client relationship between you or your organization and us, or otherwise voluntarily provided by you or your organization;
Financial and Payment Data: including your bank account details and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information.
Additional Data: In performing our service relationship, you may voluntarily provide us with information that is considered as sensitive data. That is information related to your racial or ethnic origin, religious beliefs, political opinions, trade union activities, physical or mental health, sexual life. For example, if you tell us on your application that you need accommodation with facilities for people with disabilities, or you tell us about any food intolerance
Data about other people: Please ensure you have permission first to disclose to us information about any person other than yourself, your employees or your suppliers, you must ensure that they understand how their information will be used by us or any of our suppliers.
PURPOSE OF THE DATA PROCESSED
- We may use your personal data only for the following purposes:
- Provide and manage accommodation services or other services or solutions, as instructed by you or your organization.
- Register you as a client.
- To administer and manage our relationship with you, including processing payments, accounting, auditing, billing and collection
- Compliance with our legal obligations.
- Process applications for work with us.
- Exercise or defend our legal rights, or to comply with court orders.
- Communicate with you to keep you up-to-date about our services, through newsletters, briefings, announcements, other information regarding events and initiatives; to contact you with marketing campaigns or other promotional activities. We will only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided the opportunity for you to opt out at any time.
LEGITIMATION FOR PROCESSING YOUR DATA
We may process your personal data in connection with any of the purposes set out above on the legal basis of one or more of the following grounds for lawfulness:
- Because it is necessary to perform the contract or to be able to comply with your instructions or those of your organization.
- Because our legitimate interests, or those of a third party recipient of your personal data, make processing necessary, provided that such interests do not override your interests or fundamental rights and freedoms.
- Because you have given your consent to us to process your personal data in this way.
- To comply with our legal obligations, as well as to keep records of our compliance processes or tax records.
We will not use your personal data to make automated decisions that affect or create profiles other than those described above.
You can exercise any of the rights recognized in the data protection regulations before us.
We undertake to respect and facilitate the exercise of these rights and, in particular, the rights of access, rectification, suspension, opposition, limitation of processing and portability of data. These rights may be exercised by sending a written request to EAS, C/Muntaner 320 principal 2, 08021 Barcelona, or sending an email to email@example.com together with proof of your identity, such as your ID card, passport or any other valid identification document.
In any case, we inform you that you may file a complaint with the Spanish Data Protection Agency for the protection of any of your rights.
SECURITY OF YOUR PERSONAL DATA
EAS undertakes to comply with its obligation to ensure security of the personal data, implementing all the technical and organizational measures, according to current data protection regulations, to safeguard such data from destruction, adequate loss, unauthorized access or disclosure.
We have also implemented a notification procedure in the event of any suspected personal data breach, addressed to the data subjects and also to the appropriate supervisory authority in Spain.
ACCURACY OF DATA
You shall, in any event, be responsible for the accuracy of the data provided and EAS shall reserve the right to exclude you if you have provided false and /or incomplete data, notwithstanding that may take the appropriate actions in accordance with applicable law
For example, if you change your telephone or email address or you wish to cancel any request you have made to us, or if you become aware we have any inaccurate personal data about you, please let us know by contacting us through any of the electronic means informed in this policy.
Disclosure of your personal data
EAS do not sell, trade, or otherwise transfer to outside parties your personal data. This does not include trusted outsourced suppliers who assist us in operating our website, conducting our business, or servicing you or your organization, so long as those parties agree to keep this information confidential and all legal requirements are met according to data protection regulations.
PERIOD FOR WHICH THE PERSONAL DATA IS STORED
We will keep your personal data for as long as the business relationship lasts or as long as necessary for the purposes of processing. In determining the appropriate storage period for personal data, we rely on the quantity, type 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 the applicable legal requirements.
In any event, if there is further processing of data for purposes other than those for which they were initially collected, we will inform you of all aspects relevant to this other purpose before proceeding with such further processing.
RIGHT TO WITHDRAW CONSENT
If you have provided your consent to the processing of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent please contact us or follow the opt-out links on any marketing communications sent to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Withdrawal of consent to receive marketing communications will not affect the processing of personal data for the provision of our services.