Privacy Policy

IMPORTANT: This Privacy Policy aims to inform all individuals who access and browse the Website about the data processing carried out by Empordà Golf Club, S.A. through it. The User must carefully read this Privacy Policy, as it may undergo modifications, which once published on the Website, will be applicable to the User.

Last updated: July 2020

Data Controller

Who is the data controller?

EMPORDÀ GOLF CLUB, S.A. (“EGC”)

Address: Carretera Palafrugell a Torroella de Montgrí (C-31 Km. 345), 17257 Gualta, Girona

Tax ID: A17233164

Phone: 972760450

Email: hotel@hotelterraverda.com

Origin and Categories of Data

What data will we process?

Please note that it is necessary for you to provide us with certain Personal Data to ensure the proper functioning of the Website and the services you may request through it. By providing us with your data, you guarantee the truthfulness and/or accuracy of the same. We warn you that you will be responsible for any false or inaccurate statements made, as well as for any damages caused as a result thereof to EGC.

The categories of data we may process are as follows: identifying data (name and surname, date of birth, gender, age, image, nationality data, ID card, passport and/or driver's license); contact details (email and/or telephone); data related to your credit card; and browsing data.

In addition to the data collected in the Website's forms, we may collect and process other personal data that may be generated during its use, such as offers and sections viewed, visit time, time spent on the Website, connection location, etc. Please note that all this data is very important to us because it allows us to configure the content and design of the Website and our services according to the preferences of our users. This data will be processed anonymously or aggregated for analytical or statistical purposes applied to EGC's business.

Likewise, in the event that you contract our services through a third-party operator or online travel agency not related to EGC, such entities will send us your personal data for the purpose of managing and processing the requested services.

Before making a reservation through such third parties, please read and review the privacy policies and web conditions of such entities, which will be applicable to you. EGC assumes no responsibility for the content and, in particular, for the data processing carried out by such third parties, over which EGC has no decision-making power for these purposes.

Will we process specially protected data?

No, we will not process data of special categories such as health data, ethnic or racial origin, religious beliefs, political opinions, etc.

Purpose and Legitimation of Processing

For what purposes and on what legal basis will we process your data?

Purpose: Service Provision

Provide services requested through the Website, such as processing and managing the requested reservation (both at our Hotel and/or golf course); offer our complementary services (restaurant, events and meetings, pool & spa, parking, etc.); provide access to the Wi-Fi network; offer applicable promotions at all times, if any.

Legal basis: Need to offer and provide the services requested through the Website.

Purpose: Responding to Information Requests

Address and resolve the questions or requests you make through our Website

Legal basis: Execution of the contractual relationship with you, or the adoption of pre-contractual measures if you are not a customer.

Purpose: Web Navigation

Manage and improve the operation of the Website through the analysis of statistical navigation data.

Legal basis: Express consent, where applicable.

Purpose: Marketing

Send you commercial information, even by electronic means, about EGC's products and/or services. Likewise, depending on your preferences, this information may include sending our Newsletter, with alerts of our exclusive promotions, alerts of competitions and/or golf tournaments organized at our facilities and news about our services, activities and/or events. You may unsubscribe at any time if you do not wish to continue receiving such communications, as will be indicated to you when you make a reservation, check-in at our hotel, or in the respective commercial communications.

We may also create profiles for the purpose of offering our users content and information tailored to their tastes and preferences.

Legal basis: Legitimate interest in informing our customers of products and services even by electronic means as provided for in art. 21 LSSI, as well as, if you are not a customer, when you have given us your consent to do so.

Will we make decisions based solely on automated processing, including profiling, with the data you provide us?

No, we will not make individual decisions based solely on automated processing that produce legal effects on you or significantly affect you in a similar way.

How long will we keep your data?

We will keep your personal data for as long as our pre-contractual or contractual relationship is in force for its proper management, and even after it has ended, to send you information - including commercial information - of interest to you, provided that it is appropriate, relevant, and limited to what is necessary for the purposes for which we process your personal data. The foregoing shall apply unless you exercise your right to erasure.

Once the processing of your data is no longer appropriate, relevant, and limited to what is necessary for the purposes for which they are processed, we will keep your data properly blocked and only to address potential liabilities, as required by applicable law.

Finally, we inform you that we will take all reasonable measures to ensure that your data is rectified or deleted when inaccurate.

Recipients

Will we disclose your data to third parties?

Yes, we will disclose your data to the following categories of third parties based on the reasons we explain:

Security Forces and Bodies: In the event that you stay at our hotel, we will be required to complete a registration book with your identifying and contact details, which we will make available to the members of the Security Forces and Bodies on a daily basis, all in accordance with applicable regulations on public security.

Others: We will share your personal data with other third parties if required to do so by a law, by an administrative or judicial authority, or for the public interest or order.

Providers: Your personal data will be accessible to those EGC providers who need such access to provide us with their services, such as IT or hosting providers. These third parties will act as our data processors, so we will have signed with them the corresponding data processing agreement to ensure that your personal data is processed in accordance with applicable law and the confidentiality and integrity thereof are respected.

International Transfers

Will your personal data be transferred to third countries or international organizations?

As is common nowadays, many IT providers have their servers outside the European Economic Area (EEA). In our case, some of our providers may be located outside the EEA. Therefore, and only when strictly necessary to operate the Website and/or provide you with the services you request, we will make international transfers as part of the provision of services by our providers. In any case, we inform you that with all these providers we will sign whatever documents are necessary to ensure that they offer adequate guarantees for such international transfers.

Rights

What rights do you have regarding the processing of your personal data?

We inform you that you have the following rights:

Access: You have the right to access your data to know what personal data concerning you we are processing.

Rectification or Erasure: In certain circumstances, you have the right to rectify any inaccurate personal data concerning you that we are processing or even to request its erasure.

Restriction: In certain circumstances, you have the right to request the restriction of the processing of your data, in which case we inform you that we will only keep them for the exercise or defense of claims.

Portability: In certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit them to another controller.

Objection: In certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data, in which case, we would stop processing them except for compelling legitimate reasons or for the exercise or defense of possible claims.

How can you exercise your rights?

You can exercise your rights at any time by contacting EGC through the following email info@hotelempordagolf.com or by postal mail Carretera Palafrugell a Torroella de Montgrí (C-31 Km. 345), 17257 Gualta, Girona, indicating in both cases, “Privacy Rights” as the subject. In order to verify your identity, we may require you to send us certain additional information or documentation such as a copy of your ID card.

The exercise of these rights is free of charge. However, please note that a fee may be charged when requests are unfounded, excessive, or repetitive.

Do you have the right to withdraw your consent?

Yes, you can withdraw your consent for the processing of your data for one, several, or all of the purposes indicated above that are based on consent for their processing at any time. Please note that, in such case, this may alter or even lead to the termination of the provision of services in your favor.

Do you have the right to lodge a complaint?

Yes, you can lodge a complaint at any time with the competent supervisory authority, which in our case is the Spanish Data Protection Agency (www.aepd.es).

In any case, before initiating any complaint, we kindly ask you to contact us via email info@hotelempordagolf.com in order to try to resolve any discrepancies or controversies amicably. We are confident that we can resolve your concerns diligently and efficiently.

Within what timeframe will we respond to you?

We will respond to your requests as soon as possible and, in any case, within one month. If this is not the case, please accept our apologies and contact us again so that we can assist you and rectify any possible technical error that may have prevented us from responding to you within the deadline.