Abama Hotels’s Privacy Policy in Tenerife

ABAMA HOTELS WEBSITE DATA PROTECTION POLICY

I. Who is responsible for the processing of your data?

The person responsible for the treatment of your data is Tropical Hoteles, S.A. (hereinafter the "Hotel"), with address at Calle María Zambrano 4, 38.687 Guía de Isora, in Santa Cruz de Tenerife. CIF: A38009767. For any questions regarding data protection, please contact the data protection officer, via email dpd@tropical-hoteles.com.

II. With what purpose and legitimacy do we treat your data?

The customer is informed that their data will be processed by the Hotel, with the following purposes:

1.-Management of the reservation and contracted services In order to manage and formalize the purchase of products and provision of services offered by the Hotel, the customer has two direct channels for this:

Electronically through the website www.abamahotels.com or by telephone by contacting the Hotel directly (call center). In the event that the contracting is made by telephone, the Hotel will proceed to record the call, with the purpose of accrediting and verifying the contracting made by the client. The Hotel will always inform of the recording of the call, understanding the client that the continuation with the call, implies its conformity with such recording and taking into account that the non-conformity, will imply the impossibility to manage the reservation request that the client intends to make.

To manage the reservation requested by the customer, the Hotel must process the personal data provided by the customer through the data collection forms, which the Hotel has for this purpose.

Similarly, the Hotel will process the information necessary to manage requests for modification or cancellation of reservations requested by the customer.

Likewise, in order to provide the client/user with the services requested, by the different means indicated in the previous paragraphs, the Hotel, depending on the service requested, is obliged to communicate your personal data to the company of the Tropical Hotels Group in charge of the same. Our Group includes different companies within the complex, and each one establishes its services to customers who have made a reservation. The different companies of the Group that provide their services in the complex are indicated in point 11.

Legitimation. This treatment is necessary for the execution of the contract and for the correct provision of the contracted services. In the event that in freely drafted fields or by express request to the Tour Operator or the Hotel staff, the client provides data relating to their health to manage specific services, the Hotel understands that such data are communicated voluntarily by the client, since there is no prior request for this information, and will only be processed to manage the client's request (for example, rooms adapted to special needs). It is considered that, by providing such personal data, the customer consents to the use of such data for this purpose.

2. Fulfillment of accounting, legal, fiscal and administrative obligations. This treatment is necessary for the execution of the contract.

3. Sending commercial communications by any means, with offers related to products and / or services offered by the Hotel, which may be attractive to the customer.

Personal data may be processed for profiling, based on internal sources (e.g. data generated in the Hotel, historical data and statistics), whose results allow the preparation and analysis of personalized products and/or services, through segmentation into different groups in relation to common patterns. Such profiling will be used only to send you personalized communications, about products and / or services affected by the Hotel.

Legitimation. This treatment will only be carried out with the express consent of the customer. At any time, the customer may revoke their consent for their data to be processed for this purpose, following the instructions set out in section V.

4. Management of registration in newsletters for sending, by electronic means, information about offers and promotions on products and services offered by the Hotel.

When the client registers in the newsletter, through the section provided for this purpose on the page www.abamahotels.com, the Hotel may send commercial communications about the products and services offered by the Hotel, as well as events organized by it.

Legitimation. With regard to the sending of commercial communications by the Hotel about products and / or services offered by the Hotel, it is understood that by subscribing to the newsletter, the customer gives his consent for this purpose, by checking the corresponding validation box. On the other hand, with regard to the sending of commercial communications about products and / or services offered by entities other than the Hotel, you must have the consent of the client.

5. Management of customer complaints.
In order to manage in a centralized way those claims that the client interposes in relation to the contracted services, the Hotel will receive the information related to the client's claim, in order to process the claim and to be able to offer an adequate solution to the client, being able to offer discounts or more beneficial conditions in subsequent stays to compensate for the damages suffered. In this way, the Hotel needs access to the information generated by the customer, to adequately address the claim filed.

Where appropriate, if the claim is due to compensable damages suffered by the customer, the Hotel will communicate this information to the insurance company contracted by the Hotel, in order to manage the loss suffered by the customer.

Legitimation. This treatment is necessary to meet the claim generated by the customer. It is considered that, by providing such personal data, the customer consents to the use of the same for this purpose.

6. Customer service. The Hotel has a customer service, for the resolution of requests generated by customers or potential customers, in relation to both the provision of information prior to booking, such as questions that may arise about the reservation made, or the services offered at the Hotel.

Legitimation: This treatment is necessary to meet the request made by the customer or potential customer. It is considered that, by providing such personal data, the customer or potential customer consents to the use of such data for this purpose.

7. Judicial or administrative proceedings. The Hotel, before possible judicial or administrative proceedings that may arise as a result of services offered or provided by the Hotel, will treat that information necessary to present the appropriate allegations, exercise their right of defense or file those claims it deems appropriate depending on the facts occurred.

Legitimation. This treatment is based on legal obligations, marked by administrative rules (mainly, the Law of Common Administrative Procedure), or is necessary for the Hotel to exercise its legitimate right to effective judicial protection, both in its right of defense, as in the filing of legal claims it deems appropriate, based on the Civil Procedure Act or the Criminal Procedure Act.

8. Management of system incidents. The Hotel will treat the necessary information of its clients to manage any reported incident, or that the Hotel detects by its own means. Such data processing will only be carried out in order to solve the incident and solve those problems arising from it. The Hotel understands that it has a legitimate interest in preventing the security of its IT assets, as well as to solve incidents that jeopardize such security or the continuity of the services offered to its customers.

Legitimacy. This treatment is necessary for the satisfaction of legitimate interests of the Hotel. At any time, the customer may object to their data being processed for this purpose, following the instructions marked in section V.

9. Carrying out controls for the detection of fraudulent activities.
In order to control and monitor actions that may constitute fraud in present or future hires, the Hotel informs that it carries out an analysis of the transactions that are made in order to identify and analyze in more detail those that it detects as suspicious of being fraudulent, during the hiring period, preparing, where appropriate, temporary limited hiring exclusion lists.

Legitimation. This treatment is based on the legitimate interest of the Hotel, since it carries out a control and follow-up of all the operations carried out by its clients, for the detection of possible fraudulent conducts in the transactions that are carried out during the contracting process. The customer may object to the processing of data, following the instructions set out in section V.

10. Treatment of data relating to access to the Wifi network provided by the Hotel.
This treatment will be carried out in accordance with the privacy policy accepted by the customer, in the use of Wi-Fi services offered by the Hotel.

Legitimation. This treatment is necessary in order to manage the client's access to the Wifi service provided by the Hotel. It is considered that, by providing such personal data, the customer expressly consents to the use of the same for this purpose.

11. Companies of the Tropical Hotels Group that provide services within the complex.
The aforementioned companies provide different services within the Abama Terraces complex, with the aim of satisfying the requests of its clients and users.

Tropical Hoteles, S.A., Abama Gestión de Servicios, S.L., Abama Fase IV, S.L., Gestión de Hoteles y Servicios Turísticos, S.L., Tropical Residencial Canaria, S.L., Abama Terraces, S.L., Abama Residencial Turística, S.L., Abama golf y Tenis, S.L.
Legitimacy. This processing is necessary in order to provide the customer/user with all the services he/she may have requested. It is considered that by providing such personal data, you authorize in turn, that they can be communicated to the Group company that has to provide the requested service.

Without such authorization it would be unfeasible to provide the contracted services. At any time the customer/user may object to their data being processed for this purpose, following the instructions set out in section V.

III. How long will we keep your data?

The personal data to which we have access will be processed for as long as the contractual relationship or the purpose for which they were collected is maintained. After that, the Hotel will keep the personal data once the contractual relationship is terminated, or when they are no longer relevant for the purposes for which they were collected, duly blocked to be made available to the competent Public Administrations, Judges and Courts or the Public Prosecutor's Office, during the period of limitation of the actions that could be derived from the relationship maintained with the client, and/or the legally established periods of conservation. If the client has not revoked his consent to receive commercial communications, the Hotel may process his personal data, as described in section V, and may unsubscribe from receiving such commercial communications through the means provided for that purpose, in such communications.

IV. To whom will we communicate your data?

The Hotel may communicate the data:

- If it has the customer's consent to Abama Terraces, S.L., so that it can send commercial communications.
- Insurance brokerage and insurance company of the Hotel, in case the customer suffers a compensable damage.
- Competent Public Bodies, Judges and Courts.
- To the companies of the Tropical Hotels Group, which within the complex provide any of the services requested by the client/user.
- Apart from the above data communications, the Hotel has the collaboration of some third parties, service providers who have access to the personal data of customers, and who process the aforementioned data in the name and on behalf of the Hotel, as a result of their provision of services. Specifically, the Hotel will contract the provision of services by third party service providers that carry out their activity, by way of example and without limitation, in the following sectors: legal advice, multidisciplinary professional services companies, technology service providers, and IT service providers. With all the above mentioned companies, the Hotel has the respective data processing contracts, as data processors.

V. What are your rights when you provide us with your data?

The customer may exercise, if desired, the rights of access, rectification, correction and deletion of data, as well as to request to limit the processing of personal data, to request the portability of their data, as well as not to be subject to individualized decisions, or to revoke their consent, through the following means:

- By sending a written request to the postal address: Calle María Zambrano 4, 38.687 Guía de Isora, in Santa Cruz de Tenerife.
- By sending a request to the e-mail address dpd@tropical-hoteles.com.
The customer may, in relation to those treatments that are based on obtaining their consent, withdraw it, through the procedure detailed in the preceding paragraph. Likewise, the customer may object to those treatments based on the legitimate interest of the Hotel.

VI. What are your rights when you provide us with your data?

The personal data that the Hotel treats, are the personal data collected through:

- Our website: www.abamahotels.com
- Tour Operators that collaborate with the Hotel.
- Third parties outside the Hotel.
- Directly by the user/client.

VII. Before which authority can exercise their claims?

The client may file a claim before the Spanish Data Protection Agency, in relation to the response they have received from the Hotel, when attending to their rights.
In any case, the client is informed that the claims related to the processing of their personal data will be processed by the Data Protection Officer of the Hotel, and the client may send them to the addresses indicated in section V.