SUMMARY OF PRIVACY POLICY |
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RESPONSIBLE |
Identity: Ultimate Leisure Club INC.
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PURPOSE |
- Provision of frequent flyer club membership services.
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LEGITIMATION |
Contractual relationship, user consent and legitimate interest. |
TRANSFER OF DATA |
Companies of the Sirenis group to which ULC belongs, tourist service exchange companies and/or selected providers for the provision of services contracted with ULC. |
TRANSFER OF DATA |
Until the interested party withdraws their consent. |
RIGHTS |
Of access or knowledge, rectification, deletion and opposition or opt-out, limitation of the treatment and portability of the data. |
Visiting the website does not imply that the user registers or that he or she must provide personal data. In the event that data is requested, the website will inform you about this privacy policy.
In compliance with Regulation EU 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data ( RGPD ) and with the California Consumer Privacy Act of 2018 ( CCPA ); Ultimate Leisure Club informs website users of its Privacy Policy, so that they freely and voluntarily if they wish to provide the personal data that is required in any contact form or email.
When you want to contact us you can fill out a contact form where you will be informed about the mandatory nature of providing some data, or through other communication channels and social networks; mandatory data will be indicated by an asterisk [*] or an exclamation mark [!].
1. Who is responsible for processing your data?
Ultimate Leisure Club INC. (hereinafter, ULC), with Tax Identification Number in Panama (NIT): 155670967-2-2018 dv 70 and registered office at International Business Park, Building 3835, Floor 4, Suite 402 (Panama Pacific), Panama City, Panama is a company that belongs to the Sirenis group ( https://www.sirenishotels.com ).
The personal data that you provide us supposes an express consent, to be treated and incorporated into a file that is the responsibility of Ultimate Leisure Club INC. and MATUR S.L. with Spanish Tax Identification Code (CIF): B-07029465, with address at C/ Des Cubells, 32 Complejo Vila Parc, 07800 Ibiza (Illes Balears), Spain.
If you have any questions regarding data protection, you can contact the Data Protection Officer (DPO) of the Sirenis Group via email dpo@ultimateleisureclub.com , or by writing, indicating DATA PROTECTION, to the address: International Business Park, Building 3835, Floor 4, Suite 402 (Panama Pacific), Panama City.
2. For what purpose do we process your personal data?
Our website, in addition to informing about the advantages and privileges of the Ultimate Leisure Club, as a vacation or frequent flyer club of the Sirenis group; It is mainly aimed at ULC partner members, being an instrument to inform and manage their reservations.
To access ULC services you must be part of the ULC membership. In the event that it is necessary to provide any data to respond to requests for information or consultation, to keep you up to date on our advantages or to provide the services contracted by you; The sending of the forms is an express consent to the treatment of the personal data that you provide us for:
3. What is the legitimacy for the treatment of your data?
The legal basis of ULC for the treatment of your data is:
The sending of contact forms are positive and unequivocal actions of consent for the processing of data, to the extent that it is necessary for the fulfillment of the purposes set forth above.
4. To which recipients will your data be communicated?
ULC is a company that belongs to MATUR S.L., parent company of the Sirenis group ( https://www. sirenishotels.com ), so ULC may share and/or transmit your information and personal data to its affiliated or subsidiary companies (Sirenis group companies), tourist service exchange companies and/or selected providers for the provision of services contracted with ULC.
ULC uses the WhatsApp Business instant messaging service to contact member partners for the sole purpose of informing and remembering the reservations made. WhatsApp Business guarantees privacy, encrypting shared information from end to end. Both the data used for the reminders and the content of the messages will not be transferred to any third party. For more information, see the WhatsApp Business Privacy Policy.
We may also disclose your information to respond to or respond to court orders or other legal proceedings; to establish or exercise our rights; to defend ourselves against legal claims; or as otherwise required under applicable law.
Except as provided above, ULC will not transfer your personal data to unauthorized third parties without your prior consent, except to comply with legal requirements. In any case, you will be notified when your personal information is to be shared with third parties, and you will have the opportunity to opt out of having your information shared.
5. How long will we keep your data?
ULC will keep and process your personal data from your consent, while the commercial and contractual relationship is maintained, until you request its cancellation.
In any case, the data will be kept, at least, during the years necessary to comply with the legal obligations of ULC.
6. What information do we collect?
The data that ULC collects is all the information that you enter on the website or that you provide us in any way. This information may mainly include:
It is the responsibility of the user to provide all the real data that is required as mandatory for the use and enjoyment of the web. The data and information provided will be assumed as true, truthful and current, being the responsibility of the user to modify and/or update said information at all times; Otherwise, it will be understood that the data has not been modified and that it is accurate and current.
If you have provided us with personal data of a third party, such as in the referral program to commercially contact friends of ULC members, or companions in travel reservations, you must, prior to their inclusion, have informed them and requested their consent. of the extremes exposed here.
We remind you that the boxes marked with the symbol [*] or [!] are mandatory, and filling them out implies full and unconditional acceptance of this privacy policy.
7. What are your rights?
Anyone has the right to obtain confirmation as to whether or not ULC is processing personal data that concerns them.
Interested persons have the right to access or know their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes that were collected.
In certain circumstances, the interested parties may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims.
In certain circumstances and for reasons related to their particular situation, the interested parties may oppose (opt-out) the processing of their data. In the case of marketing or direct electronic communications, shipments will offer an automatic system to reject the receipt of future commercial communications; all this without retroactive effects on the previous treatment or transfer of data to third parties, and without prejudice to the obligations and legal consequences that derive from it.
Users may exercise their right to data portability, in which case the information they provided will be delivered in a structured, commonly used and machine-readable format to be transmitted to another data controller.
Although ULC does not make automated decisions, we inform you that you still have the right not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects or affects you, unless it is necessary for the execution of a contract, is permitted by law or you have given your explicit consent.
ULC does not sell any information of its customers or users in the traditional legal sense (transaction with economic value), although any type of exchange of information may be considered a sale under some privacy regulations. Likewise, and at all times, users may choose not to sell their personal data in the event that it were to proceed to do so.
You may exercise these rights by writing to the address: dpo@ultimateleisureclub.com.
The exercise of these rights is free, unless manifestly unfounded or excessive requests are made, in which case the interested party may be required to assume the cost of processing the request.
Likewise, and at all times, users may exercise their right not to be discriminated against for exercising their privacy rights. In the event that you consider that your rights have been violated with regard to the protection of your personal data, especially when you have not obtained satisfaction in the exercise of your rights, you can file your complaint with the competent national supervisory authorities on privacy and consumer rights. For any clarification, contact our Data Protection Delegate.
8. How do we protect your information?
At ULC we want you to feel safe using the website when browsing and making your travel reservations, so we are committed to safeguarding and treating the information we collect with the utmost confidentiality, forcing ourselves not to communicate it to unauthorized third parties. without your consent, not even for storage. This obligation will continue even after the end of business relations with you; all in accordance with current regulations.
Although no website can guarantee absolute security, at ULC we have implemented the international security standards of an administrative, technical and material nature, necessary to guarantee the security of the personal data that is processed, and prevent its alteration. , loss or unauthorized treatment, as well as the risks of varying probability and severity to which they are exposed and that the treatment entails for the rights and freedoms of natural persons.
9. Did we update our Privacy Policy?
ULC reserves the right to make changes or updates to this Privacy Policy at any time, in response to new legislation or jurisprudence, internal policies, new requirements for the provision or offering of our services or products.
These modifications will be available in any of the following media: