ADDITIONAL INFORMATION – BOOKINGS and BARCELÓ EXPERIENCES
I.- Who is responsible for the processing of your data?
The entity responsible for the processing of your data is Barceló Gestión Hotelera, S.L. (hereafter in respect to this document, “BGH” or “Barceló”), whose registered office is at c/ Josep Rover Motta, 27, 07006, Palma de Mallorca. If you have any query regarding the protection of your data, you can contact Grupo Barceló’s Data Protection Office by emailing dpo@barcelo.com.
II.- Why do we process your data, and on what legal basis?
BGH advises the customer that their data will be processed by Barceló for the following purposes:
- Administration of the booking and contracted services. When administering and formalising the purchase of products and services offered by BGH, two direct channels are available to the customer: the company website (Barcelo.com) and the call centre.In cases where the booking is made by telephone, BGH will record the call to enable the company to check and authenticate the customer’s booking. BGH will always inform the customer that the call is being recorded, so that the customer understands that continuing with the call implies his/her agreement to the call being recorded, and that a refusal to agree will make it impossible to proceed with the booking.
In order to administer the booking requested, Barceló will need to process personal details provided by the customer through data collection forms.
For the same purpose, BGH will send the customer’s data to the company that owns the hotel selected by the customer. This may involve an international transfer of data to a country that does not offer the same level of protection of personal data as the European Union. In accordance with the terms of data protection legislation, the international data transfer will be effected under the booking contract requested by the customer. The data provided to the said organisations will be limited to what is essential for the processing of the booking for the customer’s chosen hotel and it will be used exclusively for this purpose.
In addition, BGH will process the information necessary to carry out the customer’s requests for booking amendments or cancellations.
The customer may volunteer or provide information concerning his/her health in response to a specific request by the tour operator or call centre agent (to ascertain which specific services are required). In this case, Barceló understands that where there has been no prior request for this information, such information is communicated expressly and voluntarily by the customer. Such data therefore will only be used to provide the service requested by the customer (for example, guest rooms adapted for use by guests with specific needs).
Legal basis: This data processing is necessary for the delivery of the contract.
- Provision of Barceló Experiences services. When administering and formalising customer bookings for Experiences, BGH needs to process certain of the customer’s personal data, in order to begin the process of contracting the said Experience.Once the booking form has been filled in, BGH will contact the customer to ask for the information required for the provision of the service requested, depending on the nature of the particular Experience in which the customer is interested. BGH may request personal details relating to third parties who will accompany and/or participate alongside the customer booking the Experience. The customer guarantees that the information s/he provides in relation to third parties is accurate, that s/he has informed the third party that their details have been provided to BGH, and (if applicable) that s/he has obtained the consent of the third party for the processing of such data.
Within the framework of providing the contracted service, BGH will pass the personal details of the customer and of any participating third parties to the provider of the said Experience, in order that the provider can administer the service and process the personal data of the interested parties in accordance with its privacy policy.
The communication of such data by BGH, within the framework of the provision of Barceló Experiences, may involve an international transfer of data to a country that does not offer the same level of protection of personal data as the European Union. The said international transfer of data will be made both to the hotel responsible for administering the booking of the Experience and to the supplier of the service in relation to the Experience requested by the customer. Under the terms of data protection legislation, the international data transfer will be duly justified because it is necessary for the delivery of the booking contract signed by the customer. The data provided to the suppliers of the service requested by the customer will be limited to what is essential for the processing of the request, and it will be used by the said suppliers exclusively for this purpose.
Legal basis: This data processing is necessary for the delivery of the contract.
- The fulfilment of financial, legal, tax-related and administrative obligations.Legal basis: This data processing is necessary for the delivery of the contract.
- In respect of the sending of marketing communications which could be of interest to the customer through any medium with offers or promotions relating to products and/or services already contracted or contracted in the past with BHG, personal data may be processed for the creation of profiles based on internal sources (for example, browsing data recorded by cookies, historical data and/or statistical data). The results of this will enable the design and analysis of individually tailored products, by means of segmentation into different groups according to common patterns. Such profiles will only be used to send customers individually tailored communications about products and/or services offered by BGH.Legal basis: This data processing is necessary for the satisfaction of BGH’s legitimate interests. The customer may at any time oppose the processing of his/her data for this purpose by following the instructions set down in Section V.
- The sending of marketing communications about offers and/or promotions not related to the contracted products and/or services. BGH may send customers promotional offers about certain products at the hotel that may be of interest (for example, furniture in the reserved guest room, or Barceló Experiences). Furthermore, BGH may send customers information relating to tourist and leisure activities (such as cultural activities, excursions, sporting events, etc.) which may or may not be offered alongside our hotel accommodation services.Legal basis: This data processing will be undertaken only if BGH has the customer’s consent. The customer may withdraw his/her consent by following the instructions set down in Section V.
- Passing customer data to companies that own hotels within the Barceló network. BGH may pass customer data to the company that owns a hotel under the Barceló brand for the administration of the booking so that the customer receives the best possible service. In this case, BGH will communicate the data to the hotel chosen by the interested party in order to tailor the customer’s hotel stay to his/her requirements.This communication may involve the sending of international data transfers to a hotel in a destination located outside the European Union. In all cases, customer data will only be passed with the customer’s express consent, and to the hotel selected by the customer to enable the destination hotel to offer a service tailored to the customer’s requirements.
Legal basis: This data processing will be undertaken only if BGH has the customer’s consent. The customer may withdraw his/her consent by following the instructions set down in Section V.
- Undertaking market research. In order to offer its guests more individually tailored services, BGH may create profiles based on data extracted from sales made to customers, or data relating to their holiday history, financial capacity and preferences in respect of holidays. The data used in the said profiles may have been obtained from information generated by the customer at the hotel in which s/he stayed, and/or from external sources (for example, the internet, social networks). This information is extremely useful to BGH, as it helps the company to offer customers products tailored to their preferences in accordance with their past use of services offered by hotels, in a way that could improve the customer’s experience, in terms of both the current booking and of future bookings.Barceló informs that in pursuit of its marketing objectives and of the continuous improvement of its products it uses Salesforce Inc., a supplier based in the United States, thereby effecting an international transfer of data relating to its customers. The said supplier abides by the Privacy Shield agreement, which regulates international transfers between data processing organisations located within the European Union, and those located in the United States. This ensures that the transfer is effected under the terms of the agreement and that the supplier will process the data in compliance with the rules stipulated in the said agreement.
Legal basis: This data processing will be undertaken only if BGH has the customer’s consent. The customer may withdraw his/her consent by following the instructions set down in Section V.
- Management of customer claims and complaints. In order to operate a centralised system for dealing with complaints and/or claims from customers in respect of contracted services in its hotels, BGH will receive the information regarding the complaint or claim generated at the hotel. This will enable BGH to process the said claim or complaint and to offer an appropriate solution to the customer (for example, by offering discounts or more favourable terms for future stays as compensation for damages that the customer may have suffered). BGH therefore requires access to the information generated by the customer at the hotel in order to properly deal with the claim or complaint submitted.In the event that the customer has incurred compensable damage, BGH will pass this information to its contracted insurance provider in order to address the damages suffered by the customer.
Legal basis: This data processing is necessary in order to address the claim submitted on behalf of the customer.
- Customer care services. BGH has a customer care service for dealing with customer and potential customer enquiries, both in relation to information provided prior to the booking contract and also in relation to queries that may arise regarding the booking once it has been made, or to services offered by the hotels.Legal basis: This data processing is necessary in order to address the enquiry submitted on behalf of the interested party.
- Online reputation monitoring. BGH may carry out checks on reviews submitted by customers to websites such as TripAdvisor and other similar sites, with a view to monitoring its online reputation; this also enables the company to make business decisions to ensure the continuous improvement of its services. BGH may contact customers who have described negative experiences with a view to suggesting possible solutions. BGH understands that this constitutes a legitimate interest for the purposes of improving its services and of protecting its brand.Legal basis: This data handling is based on BGH’s legitimate interest in monitoring its reputation on the internet and in being able to resolve complaints and claims addressed to websites such as those mentioned above. The customer has the right to oppose this processing of his/her personal data by following the instructions set down in Section V.
- Judicial or administrative procedures. BGH, in the face of legal or administrative procedures which may arise from the offer or the provision of services by Barceló, will process such information as proves necessary to present relevant allegations, to exercise its right of defence or to lodge any claims it considers appropriate in the light of the events which have occurred.Legal basis: This data processing is based on legal obligations laid down by the administrative regulations (mainly the Common Administrative Procedure Law), or arises from BGH’s need to exercise its rights to effective legal protection, both for its own legal defence and in relation to lodging any legal claim that it may consider appropriate, whether based on Civil Procedure Law or Criminal Procedure Law.
- Submission of quality surveys. In order to assess the level of customer satisfaction with the company’s products and/or services, BGH will send out quality surveys to obtain the opinions of customers about the said products and/or services, and thus undertake the necessary steps to improve them where required.
Legal basis: This data processing is based on BGH’s legitimate interest. The customer may at any time opt out of receiving this type of communication by following the instructions in Section V. - Management of system faults. BGH will process the customer data that may be necessary in order to deal with any reported incident or any problem that BGH detects by its own means. Such data processing will be undertaken for the purpose of resolving the problem and any further problems resulting from it. BGH understands that it holds a legitimate interest in protecting the security of its IT assets, and in resolving problems that put such security at risk or put at risk its ability to continue to provide the services it offers its customers.Legal basis: This data processing is necessary for the satisfaction of BGH’s legitimate interests. The customer may at any time oppose the processing of his/her data for this purpose by following the instructions set down in Section V.
- The implementation of controls to detect fraudulent activity. BGH informs that for the purpose of regulating and monitoring any activities which may constitute fraud, whether in the present or in the future, the company carries out an analysis of the transactions executed in order to identify and analyse in greater detail any that arouse suspicions of fraudulent activity during the period during which the contract applies. Where appropriate, time-limited lists of customers excluded from entering into contracts with the company will be drawn up.
Legal basis: This data processing is based on the legitimate interest of BGH, as it undertakes regulation and monitoring of all transactions made by its customers in order to detect possible fraudulent activity arising during the contracting process. The customer may oppose the processing of his/her data by following the instructions set down in Section V.
- Data processing in respect of the MyBarceló application:
This data processing will be undertaken in accordance with the privacy policy accepted by the customer at the point of downloading the application.
- The processing of data relating to the Wi-Fi internet access provided by BGH:
This data processing will be undertaken in accordance with the privacy policy accepted by the customer at the point of first using the Wi-Fi services offered in the hotels.
III.- For how long will we store your data?
The personal data which can be accessed will be processed for the duration of the contractual relationship and/or for the purpose for which it was obtained. BGH will continue to store, duly blocked, the personal details after the end of the contractual relationship or after they cease to be required, so that they remain available to the relevant Public Authorities, the Courts of Law or the Public Prosecutor for the term of the statute of limitations for actions that may derive from the contractual relationship with the customer and/or for the periods prescribed by law. BGH will physically delete the data on the expiry of these periods.
Furthermore, if the customer has not refused to receive marketing communications, BGH may process the said customer’s personal data in accordance with the terms of the present information clause. The customer may opt out of receiving the said communications if s/he so wishes, by following the procedures described in Section V.
If the customer has indicated that BGH may keep his/her data for the future, BGH will store the information provided that the customer does not withdraw his/her consent.
IV.- To whom can we supply your data?
BGH can supply the data to:
- Other companies that own hotels within the Barceló network. This communication may involve the sending of an international data transfer. In each case, the customer will be notified by email about the company that owns the hotel which will receive his/her information. The said hotel will receive the information necessary to administer the booking and the information necessary to provide a tailored service (if the customer has given consent).
Apart from, and without prejudice to the above, the customer’s personal data may equally be provided to the hotel to enable it to administer requests of services in respect of Barceló Experiences. - Insurance brokerage and BGH’s insurance company in the event of the customer suffering compensable injury or damage.
- Relevant Public Authorities, Courts of Law and Tribunals.
- Apart from the above-mentioned instances when data may be passed on, BGH works in partnership with a number of third-party suppliers who have access to the personal details of the customers, and who process these details in the name and on behalf of BGH by virtue of their role as suppliers. In particular, BGH contracts the supply of its services through third-party suppliers who undertake their activity in sectors including, but not limited to, the following: providers of legal advice, multidisciplinary professional service providers, technological service providers, and IT service providers. BGH’s suppliers include Salesforce Inc, an organisation located in the United States, and a member of Privacy Shield.
V.- What are your rights when you provide your personal data to us?
Interested parties may exercise, as they wish, their rights to access, rectification and deletion of data. They may also request that the processing of their data be subject to a limitation; they may oppose it, request its portability, or request that it should not be the subject of individual automated decisions, by the following means:
- By means of a written application to the postal address shown above.
- By means of an email application to dpo@barcelo.com.
Where the data processing is based on the granting of the interested parties’ consent, interested parties may withdraw their consent by means of the procedure outlined in the paragraph above.
Interested parties may apply for the right of opposition to data processing which is based on BGH’s legitimate interest, and particularly to the receipt of marketing communications, the creation of marketing profiles and the receipt of surveys.
VI.- How have we obtained your data?
The personal data processed by BGH is the information gathered by means of:
- Our direct channels:
- Website (barcelo.com).
- Our call centre for direct telephone requests.
- Companies owning hotels under the Barceló brand.
VII.- To what authority should customers address complaints or claims?
Interested parties may submit a complaint or claim to the Spanish Data Protection Agency in respect of the response to their complaint received from the BGH in relation to their rights.
In all cases, customers are advised that all claims relating to the processing of personal data will be dealt with by Barceló Hotel Group’s Data Protection Office, located at c/ Josep Rover Motta, 27, 07006, Palma de Mallorca, or they can send an email to dpo@barcelo.com. In either case, this should be accompanied by a copy of the customer’s National Identification Document, Tax Identification Document or other official means of identification.