GENTEEL HOME APARTMENTS Group, in application of the General Data Protection Regulation (GDPR EU 2016/679) and the Organic Law on the Protection of Personal Data and Guarantee of Digital Rights (LO 3/2018), draws up the following policy which governs the different data processing activities carried out by this entity:
GENTEEL HOME APARTMENTS Group informs that the personal data collected through its website (www.genteel-home.com) are included in automated files owned by this entity, which have implemented the appropriate security measures to guarantee the accessibility, integrity and availability of the data stored therein.
| DATA CONTROLLER DETAILS |
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Company name: GENTEEL HOME APARTMENTS Group. The Group comprises the following companies: GENTEEL HOME GESTORA S.L. with N.I.F.: B-90437369 GETUPRÓ S.L. with N.I.F.: B-86110897 CONTRATACIONES HOSTELERAS S.L. with N.I.F.: B-90397563 INMOBILERT S.L. with N.I.F.: B-90314709 SIGHTSEE S.L. with N.I.F.: B-91974477 PERNOCTACIONES HOSTELERAS S.L. with N.I.F.: B-90397571 ALOJAMIENTOS GENTEEL-HOME S.L. with N.I.F.: B-90437351 |
| Registered address: Calle Muñoz Olivé nº1, Portal 1 - Planta 3, C.P.: 41001, Sevilla. |
| Email address: dpo@genteel-home.com |
What is the purpose for which your data is processed?
The general purpose for which GENTEEL HOME APARTMENTS Group obtains your data consists of the correct and appropriate management of its accommodations and the commercial relationship maintained with you.
For your better understanding, we specify below the specific purposes for which the data you provide is used, depending on the different personal data processing activities according to the reason for which you contact us through the website:
| DATA PROCESSING PURPOSES | |
| Processing Activity | Purpose for which the data is collected |
| Guest | Management of the guest’s accommodation, including offering extras depending on location. Luggage management service. Possible incidents that may arise during the stay. Invoicing of services. Handling suggestions and complaints. Communication management. |
| Owner | Management of the accommodations in each owner’s properties. Communication management. |
What is the legal basis that legitimises the processing of your data?
The legal basis for the processing activities carried out by GENTEEL HOME APARTMENTS Group is as follows
| LEGAL BASES | |
| Processing Activity | Legal basis allowing data processing |
| Guest | Consent. Contractual relationship. |
| Owner | Consent. Contractual relationship. |
How long do we retain your data?
Your data will be held by GENTEEL HOME APARTMENTS Group for the periods/criteria specified. Once this period has expired, we will proceed to delete and destroy all the data provided by you.
| DATA RETENTION | |
| Processing Activity | Period/Criterion |
| Guest | The data will be retained until the end of the stay in the accommodation and the conclusion of the commercial relationship, without prejudice to their retention for statistical purposes or to apply more favourable conditions for regular guests, applying the relevant security measures, unless the data subject expressly revokes consent, in which case they will be definitively deleted, or unless legal retention periods in accounting and tax matters require longer storage. |
| Owner | 6 years, from the end of the contractual relationship between the parties. |
The periods/criteria set out above will be complied with without prejudice to the application of longer periods/criteria imposed by legal obligations.
What rights can you exercise?
In accordance with current legislation on the matter, you are entitled to a set of rights which you may exercise by sending your request FAO the Data Protection Officer (DPO) at Calle Muñoz Olivé nº1, Portal 1 - Planta 3, C.P.: 41001, Sevilla, or to dpo@genteel-home.com, or by using the Data Protection Channel on the website. Such rights are as follows:
| Access: | Obtaining confirmation about the processing of your data and the possibility of accessing those held by the Data Controller. |
| Rectification: | Possibility of completing or rectifying incomplete or inaccurate data held by the Data Controller. |
| Erasure: | Request for the deletion, by the Data Controller, of all data held about the data subject. |
| Object: | Request to the Data Controller to cease processing activities concerning the data held about the data subject. |
| Portability: | Request for the data to be sent to the data subject or to a new Data Controller designated by the data subject in a structured, commonly used and machine-readable format, where the available technology allows. |
| Restriction: | Possibility of blocking the processing of your data (except storage) for any activity not specifically consented to by the data subject. |
| *You may revoke the consent given at any time, via the same channels made available for exercising the other rights mentioned. | |
GENTEEL HOME APARTMENTS Group will acknowledge receipt of your request and will process it within the legally established period of one month, within which you will receive notification of the actions taken in response to your request.
Occasionally, resolution of your request may be extended for a further two months, in which case you will be informed within the period indicated in the previous paragraph.
The competent authority for handling user claims is the AEPD (Agencia Española de Protección de Datos).
To whom are your data disclosed or communicated?
The data you provide are communicated to third parties outside GENTEEL HOME APARTMENTS Group as specified below, with whom the required Data Processing Agreement remains in force and with appropriate security measures implemented:
| DISCLOSURES/COMMUNICATIONS | |
| Processing Activity | Third parties outside the company |
| Guest | Territorial delegates. Owners. Tax advisory firm. Banking institutions. Providers of additional activities/experiences in the accommodation (depending on location). OpenAI – ChatGPT (possible automated responses to some communications) |
| Owner | Banking institutions. Tax advisory firm. Online rental platforms. Territorial delegates. |
| *The above is without prejudice to communications to authorities, courts and tribunals, and public administrations or bodies where required by law. | |
What data must you provide for the proper provision of the services offered?
All the data requested by GENTEEL HOME APARTMENTS Group and provided by you are necessary for the proper achievement of the purposes set out above, in strict compliance with the principles of purpose limitation and data minimisation set out in the General Data Protection Regulation (GDPR) EU 2016/679.
If you do not provide the requested data, GENTEEL HOME APARTMENTS Group will be unable to conduct the commercial/professional relationship with the appropriate quality standards. Such data are as follows:
| REQUIRED DATA | |
| Processing Activity | Data Categories |
| Guest | Identifying data (nombre, DNI, dirección, teléfono, ...) Financial data (cuenta bancaria, tarjeta, ...) |
| Owner | Identifying data (nombre, DNI, dirección, teléfono, ...) Financial data (cuenta bancaria, tarjeta, ...) Other data (property identification). |
| *The above is without prejudice to those data which, due to legal requirement or contractual relationship, must be obtained. | |
Are automated decisions taken or are profiles created?
GENTEEL HOME APARTMENTS Group does not carry out automated decision-making processes nor does it create profiles as a direct or indirect consequence of obtaining the data you provide.
Are international data transfers carried out?
GENTEEL HOME APARTMENTS Group does not carry out international transfers of the data you provide. Should the entity need to carry them out, you will be informed of this in advance and notified of any adequacy decisions, safeguards, binding corporate rules or specific situations that apply, as well as how to obtain a copy of such details.
INFORMATION NOTICE: Inside some accommodations you may find alarm or video surveillance devices. These devices are, in any case, out of service, disconnected and not linked to any contract with a security company. Therefore, under no circumstances will images (photos or videos) of guests be captured.