DATA PRIVACY POLICY

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the “Online Offering”). With regard to the terminology used, e.g. “Processing” or “Responsible” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible
Finca Las Colinas
Los Arejos 97
Apdo. de correos 217
30880 Aguilas (Murcia)
España
info@finca-las-colinas.com

Managing Owner: Thomas Richard Jörger / NIE: Y5421805-F

Imprint: https://finca-las-colinas.com/impressum

Data Protection Officer: Thomas R. Jörger, thomas@finca-las-colinas.com, +34 682 766 099

Types of processed data
– Inventory data (e.g., names, addresses).
– contact information (e.g., e-mail, phone numbers).
– content data (e.g., text input, photographs, videos).
– usage data (e.g., websites visited, interest in content, access times).
– meta / communication data (e.g., device information, IP addresses).

Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons collectively as “users”).

Purpose of processing
– Provision of the online offer, its functions and contents
– Answering contact requests and communicating with users
– Safety measures
– Reach Measurement / Marketing

Used terms
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

“Processing” means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term covers a wide range and covers practically every handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data Data should not be assigned to an identified or identifiable natural person.

“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, to analyze or predict personal preferences, interests, reliability, behavior, location or change of location of this natural person.

‘Responsible person’ means the natural or legal person, public authority, body or body which, alone or in concert with others, decides on the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, body or body that processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.

Safety measures

We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and disconnection. In addition, we have established procedures that ensure the enjoyment of data subject rights, the deletion of data and the reaction to data threats, provided that we ourselves have the sovereignty over the databases. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 DSGVO).

Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant access to the data, this is done only on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) DSGVO), you have consented to a legal obligation or on the basis of our legitimate interests (e.g. the use of agents, webhosters, etc.).

Insofar as we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR.

Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of concerned persons
You have the right to ask for confirmation as to whether you are processing the data in question and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted without delay, or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other responsible persons.

You have acc. to Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.

Withdrawal
You have the right to consent according to. Art. 7 para. 3 DSGVO with effect for the future

Right to object
You may at any time object to the future processing of your data in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right to object to direct mail
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart are stored in an online shop or a login status. “Persistent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status of a website will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person responsible for providing the online offer (otherwise, if only their cookies are called “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their machine, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ will be explained. Furthermore, the storage of cookies by means of their shutdown in the settings of the browser can be achieved. Please note that not all features of this online offer may be used.

Deletion of data
The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legally permitted purposes, its processing will be restricted. That the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons. Our retention periods comply with the legal requirements in Spain.

Booking process
We process our clients’ data as part of the booking process in our online presence to enable them to select and book the selected accommodation and services, as well as their payment and execution.

The processed data includes inventory data, communication data, contract data, payment data and those affected by the processing belong to our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the course of operating our online presence, billing and customer service. Here we use session cookies for storing the booking content.

Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary to fulfill the contract.

As part of the use of our online services, we store the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after their expiration and taxable storage obligation).

External payment service providers
We use Paypal as an external payment service provider (privacy policy at https://www.paypal.com/en/webapps/mpp/ua/privacy-full), through whose platform users and we can make payment transactions.

As part of the fulfillment of contracts, we set the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Incidentally, we use external payment service providers on the basis of our legitimate interests. Art. 6 para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.

The data processed by PayPal includes inventory data, such as the name and the address, bank data, e.g. Account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, summary and recipient-related information. The information is required to complete the transactions. However, the data entered will only be processed and stored by PayPal. That We do not receive any account or credit card information, but only information with confirmation or negative disclosure of the payment. Under certain circumstances, the data will be transmitted by PayPal to credit bureaus. This transmission aims at the identity and credit check. For this we refer to the terms and privacy policy of PayPal.

For the payment transactions, the terms and conditions and the privacy notices of the respective payment service providers, which are available within the respective websites, or transactional applications apply. We also refer to these for further information and assertion of rights of revocation, information and other data subjects.

Comments and posts
If users leave comments or other contributions, their IP addresses based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO be stored for 7 days. This is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we may be sued for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, in accordance with our legitimate interests. Art. 6 para. 1 lit. f. DSGVO to process the information of users for the purpose of spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for the duration of their use and to use cookies to avoid multiple votes.

The data provided in the comments and contributions are stored by us permanently until the users object.

Contact
When contacting us (via contact form, e-mail, telephone or via social media), the details of the user to process the contact request is being recorded in accordance with. Art. 6 para. 1 lit. b) DSGVO. The information provided by the users can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization.

We delete the requests, if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.

Newsletter – Mail Chimp
The newsletters are distributed using MailChimp, a mailing service platform owned by Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA. The privacy policy of the shipping service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The service provider is based on our legitimate interests according to. Art. 6 para. 1 lit. f DSGVO and on basis of a contract processing agreement acc. Art. 28 (3) sentence 1 DSGVO.

The service provider may retrieve the data of the recipients in pseudonymous form, without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of distribution and the presentation of newsletters or for statistical purposes. However, the service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.

Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mail delivery, security and technical maintenance services we use to operate this online service. For this we use a service provider from Switzerland. Switzerland is taking over or has already adopted the EU Data Protection Act.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of contract processing contract).

Collection of access data and log files
We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data include the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.

Google AdWords and conversion measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 (1) lit. DSGVO) , USA, (“Google”).

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use Google’s online marketing method “AdWords” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) to show them to users who have a suspected interest in the ads. This allows us to better target advertisements for and within our online offering so that we only present ads to users that potentially match their interests. If a user e.g. Showing ads for products he was looking for on other online offers is called remarketing. For these purposes, upon access to our and other websites where the Google Advertising Network is active, Google will immediately execute a code from Google and become so-called (re) marketing tags (invisible graphics or code, also as ” Web beacons “) incorporated into the website. With their help, the user is provided with an individual cookie on the device. a small file is saved (instead of cookies, comparable technologies can be used). In this file is noted which web pages the user visited, for what content he is interested and what offers the user has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer.

Furthermore, we receive an individual “conversion cookie”. The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear about the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive information that personally identifies users.

The data of the users are pseudonym processed in the context of the Google advertising network. That Google stores and processes e.g. not the name or e-mail address of the users but processes the relevant data cookie-related within pseudonymous user profiles. That from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.

For more information about Google’s data usage, hiring and opt-out options, please read Google’s Privacy Policy (https://policies.google.com/technologies/ads) and Google’s Ads Ads Settings (https: // adssettings.google.com/authenticated).

Online presence in social media
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.

Unless otherwise stated in our Privacy Policy, we process users’ data as long as they communicate with us within social networks and platforms, e.g. write posts on our online presence or send us messages.

Integration of services and contents of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services, such as to include videos or fonts (collectively referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic, on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, time of visit, and other information regarding the use of our online offer.

Google Maps
We include maps from the Google Maps service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, users’ IP addresses and location data, but these are not collected without their consent (usually as part of the settings of their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

30880 Águilas, 17 February 2019


PLEASE NOTE: THE ABOVE IS NOT AN AUTHORIZED LEGAL TRANSLATION OF THE Data Privacy Policy. THE GERMAN VERSION IS THE ONLY LEGAL BINDING DOCUMENT.