I.- Who is responsible for processing your data?
The entity in charge of your data is Barceló Gestión Hotelera, S.L. (hereinafter, for the purposes of this document, “BGH” or “Barceló”) with registered office at c/ Josep Rover Motta, 27, 07006, in Palma de Mallorca. If you have any queries regarding data protection, please contact the Barceló Group Data Protection Office by sending an e-mail to firstname.lastname@example.org.
II.- Why do we process your data?
BGH hereby informs the Interested Party that their personal data will be processed by Barceló for the following purposes:
1. Managing bookings and services. There are two direct channels available to users to manage and confirm their purchases of BGH products and services: the website (Barcelo.com) or the call centre. When products or services are booked over the phone, BGH will record the call in order to confirm and verify the bookings made by users. BGH shall always inform users that the call will be recorded, with users acknowledging that, by continuing with the call, they consent to being recorded, and that any non-conformity means the user’s booking request cannot be processed or confirmed. In order to manage bookings requested by users, BGH shall process the personal data submitted by users via the data collection forms. For the same purpose, BGH shall transfer users’ data to the company that owns the hotel, depending on the hotel chosen by users during the booking process. This data transfer may involve an international transfer to a country that does not provide the same level of personal data protection offered within the European Union. Pursuant to the provisions established in data protection regulations, an international transfer shall be made in order to process the service requested by users. The only data transferred to said entities shall be information that is essential for processing the hotel booking chosen by the user and shall only be used for this purpose. Likewise, BGH shall solely process the information required to process booking modifications or cancellation requests made by users. If users provide information on their health in open form fields, or when expressly requested by the tour operator or Call Centre representative in order to provide specific services, BGH understands that said data are expressly provided voluntarily by the user, given that this information has not been requested previously and will only be used in order to process the user’s request (for example, rooms adapted to individual needs).
Legal basis: This data will only be processed if BGH has received user consent.
2. Sending reminders of unfinished bookings (abandoned shopping baskets). 1. BGH, if specifically requested by users, may send said users reminders if they have not completed a booking which they initiated, by using information entered by the users on the website payment form and only if the user expressly agreed to receive reminders when they initiated the unfinished booking. Legal basis: This processing shall only be carried out by BGH if the user has given consent by ticking the appropriate consent request box displayed during the booking process. However, if users identified themselves as myBarceló users, BGH shall process the data based on a legitimate interest, since the user is already part of the myBarceló programme and the sole purpose is to send a reminder of an unfinished booking.
3. For the fulfilment of accounting, legal, tax and administrative obligations.
Legal basis: This data processing is necessary for the execution of the contract.
4. Electronic communications with information regarding offers and promotions about products and services offered by BGH.1. In order to offer users products and services that may be of interest to them, offers on products and services relating to those booked with BGH shall be sent to them. If applicable, users that are signed up to myBarceló, in accordance with paragraph 10, may receive special commercial communications for programme users with discounts or exclusive offers aimed solely at said users.
Legal basis: Such data processing is necessary to comply with the obligations under the Law on Information Society Services and Electronic Commerce, as well as to satisfy Barceló’s legitimate interest in guaranteeing internet and data security.
5. For commercial communications about offers related to products and/or services already requested by users or booked previously with BGH that may be of interest to the users, personal data may be processed in order to create profiles based on internal sources (e.g. browser cookie data, historical data and statistics regarding BGH products). These results allow personalised products to be designed and analysed through segmentation of different groups based on common patterns. These profiles will only be used to send personalised communications about products and/or services offered by BGH.
BGH would like to inform users that, for marketing purposes and with the aim of continuously improving its products, it uses a provider located in the United States called Salesforce Inc., which involves an international transfer of data regarding its users. This provider complies with the Privacy Shield agreement, which regulates international transfers between entities located in the European Union and those located in the United States, ensuring that transfers are carried out in line with the agreed terms and that the provider processes the data in compliance with the stipulations agreed upon.
Legal basis: Such processing is required to satisfy the legitimate interests of BGH.
6. Commercial communications regarding offers not related to contracted products and/or services.BGH may send promotional offers about certain products available to users in the hotel (e.g. room features, SPA, Golf, Barceló Experience). Likewise, BGH may send information on activities related to tourism and leisure, as well as cultural activities, excursions, sporting events, etc. which may or may not be offered, together with the accommodation services available in our hotels.
Legal basis: This data will only be processed if BGH has received user consent.
7. Disclosure of personal data to owner companies of Barceló hotels in order to offer personalised services for users in the hotel. BGH may transfer users’ data to the owner company of a Barceló branded hotel with which users have made a booking, in order to improve the user experience in the hotel. Accordingly, BGH shall provide the owner company of the hotel with information obtained from the relationship between BGH and users and information obtained from other sources in accordance with the provisions of paragraph 8.
This communication may involve an international data transfer when the destination hotel is located outside the European Union. In any event, user data shall only be transferred with their express consent and only to the hotel chosen by the user with the aim of offering personalised services offered in the hotel in which the booking has been made.
Legal basis: Data shall only be processed if BGH has obtained users’ valid consent.
8. Implementation of market analyses. For the purpose of offering users more personalised services, BGH will create profiles based on data taken from user sales, and taking into account their tourism preferences, holiday experiences and financial capacities. The data used in these profiles may have been obtained from data generated by users at the hotel in which they stayed, or from external sources (for example, internet, social media). This information is very useful for BGH in order to offer its users personalised products based on their commercial preferences as demonstrated by their use of services offered in the hotels, thus enabling BGH to enhance the user experience in terms of services provided and future bookings.
Legal basis: This data will only be processed if BGH has received user consent.
9. Managing the subscription to receive newsletters by electronic means with information regarding offers and promotions about products and services offered by BGH. Users may request to subscribe to the BGH newsletter by ticking the box “I want to subscribe”. From then on, BGH may send users regular newsletters with information on products and services offered by BGH.
Legal basis: Data processing shall only be carried out if BGH has obtained users’ valid consent by ticking the newsletter subscription box.
10. User registration for the myBarceló Loyalty Programme. BGH shall process identification data required to enable users to register with the myBarceló Loyalty programme, designed for users to enjoy specific discounts when booking BGH products, request information concerning hotels or regarding services or benefits solely available to myBarceló users.
Where applicable, myBarceló users may:
- Receive exclusive commercial communications about the Programme through the contact channels provided by users during the registration process (email, post or phone number).
- Receive special gifts as a reward for using the benefits and the special promotions offered by myBarceló.
If users wish to register by identifying themselves via Facebook or Twitter, please be aware that in such cases said entities will provide us with information relating to your identity (name, surname(s) and/or relevant network ID), together with any information users wish to share when using this option to register.
Legal basis: data shall only be processed if BGH has received users’ consent via one of the following channels:
- Through voluntary registration in the programme by users via the online registration form.
- By ticking the consent box when users register with the myBarceló Programme during the booking of a BGH product.
- Through proactive user identification via Facebook or Twitter.
Notwithstanding the foregoing, BGH may send or offer special gifts to myBarceló users based on a legitimate interest, based on the relationship between BGH and the user.
If myBarceló users provide personal data pertaining to a third party, said users shall guarantee the veracity of the information disclosed to BGH, and ensure that the third party has been informed and express consent has been obtained for the aforementioned transfer.
11. SMS alert programme for myBarceló users. After registering with the myBarceló Loyalty Programme, users will receive an SMS offering the option to subscribe to BGH’s SMS Alerts Programme, BGH Alerts. The Programme sends registered users SMS alerts relating to updates to their stays and alerts regarding promotions and abandoned online shopping baskets. To subscribe to the BGH Alerts Programme, users must be registered with the MyBarceló Loyalty Programme and answer YES to the SMS received to confirm subscription to the BGH Alerts Programme. If help is required regarding the Programme, users must send an SMS with the word HELP. To unsubscribe from the Programme, users must send an SMS with the word STOP. Users subscribed to the BGH Alerts Programme shall receive two messages per month. Data and/or message rates established by their operator may apply.
Legal basis: Data shall only be processed if BGH has obtained users’ valid consent by sending YES confirming their subscription to the Programme.
12. Complaints management. In order to centrally manage any complaints submitted by users based on the services requested by users, BGH shall receive the information relating to the complaint issued in the hotel, in order to process said complaint and offer users the best possible solution. Accordingly, BGH will need to access the information generated by users in the hotel in order to handle the complaint issued in the best possible manner. When applicable, if the complaint warrants compensation for damage suffered by the user, BGH shall transfer this information to the insurance company contracted by BGH in order to investigate the damage suffered by the user. Legal basis: This data processing is necessary for the execution of the contract.
13. Query management and other requests. BGH shall process data required to address queries or requests sent by users via the different contact forms available on the website and through the point of contact form via live chat sessions.
Likewise, users can submit queries or requests over the phone, in which case BGH informs users that calls may be recorded in order to handle users’ requests as effectively as possible and for security purposes. Legal basis: BGH shall only process data if user consent has been obtained by ticking the boxes provided on the aforementioned contact forms or when understood by voluntarily submitting queries over the phone.
14. Monitoring of online reputation.. BGH may carry out checks on the ratings submitted by users on websites such as TripAdvisor and the like, in order to monitor its online reputation and be able to make business decisions that ensure the continuous improvement of its services, contacting users who have had a negative experience in order to offer possible solutions. BGH understands that it has a legitimate interest in improving its services and protecting its brand.
Legal basis: This processing is based on the legitimate interest held by BGH to protect its brand’s online reputation and resolve claims and complaints made on websites such as those mentioned.
15. Legal or administrative procedures. BGH, in the event of possible legal or administrative procedures that may arise from services offered or provided by BGH, shall process the necessary information to submit the relevant allegations, exercise its lawful right to defence, or file any claims deemed appropriate based on the facts.
Legal basis: This processing is based on legal obligations established by administrative regulations (mainly, the Law on Common Administrative Procedure) or, if required, to ensure that BGH can exercise its legitimate right to effective legal protection, in terms of its right to defence and its right to file any judicial claims deemed necessary, based on the Civil Procedure Act or the Criminal Procedure Act.
16. Submission of quality surveys. In order to assess the level of user satisfaction regarding the requested products and/or services, BGH shall send quality surveys in order to obtain users’ opinion on these products and services and in order to continuously improve the quality of the services provided.
Legal basis: This processing is based on the legitimate interest of BGH.
17. Implementation of controls for the detection of fraudulent activities. For the purpose of controlling and following up on actions that may be considered fraudulent, either currently or in the future, BGH would like to inform customers that it carries out analysis on the transactions they make. This allows BGH to identify and analyse those customers it detects as acting fraudulently in detail during the booking process and, if necessary, to draw up a list of those temporarily excluded from the booking process.
Legal basis: This processing is based on the legitimate interest of BGH, given that it involves controlling and monitoring all the operations carried out by its users in order to detect possible fraudulent activities in the transactions that take place during the booking process.
18. Cookies and data processing: information about our cookies policy can be found at the following link
IV.- Who will we share your data with?
BGH may communicate data to:
- Holding companies of Barceló brand hotels. This communication may entail an international transfer of data. They will receive any personal data required to manage the booking or manage the request submitted by users.
- Insurance brokerage and insurance company of BGH should users suffer damages that entitle them to compensation.
- Competent Public Bodies, Judges and Courts.
- Beside the aforementioned data sharing, BGH works with third parties who provide services and have access to the personal data of the customers, which they process in representation and on behalf of BGH as a result of providing said services. Specifically, BGH hires third parties to supply, for example and not limited to, services in the following sectors: legal advice, multidisciplinary professional services, tech services, IT services. Providers include Salesforce Inc., a company located in the United States that complies with the Privacy Shield.
V.- What rights do you have when providing us with your data?
Users may, if they so wish, exercise their right to access, amend and delete their data, as well as request that the processing of their data be limited, oppose said processing, request the portability of their data, and request not to be subject to individual decisions based on automated processing, by means of the following:
- By writing to the postal address provided above.
- By emailing your request to email@example.com.
Users may withdraw their consent for the data processing carried out on the basis of their consent, by following the steps described in the previous paragraph. Users may oppose the processing of their data based on the legitimate interests of BGH, particularly with regard to receiving commercial communications, the creation of commercial profiles and receiving surveys.
VI.- How have we obtained your data?
The personal data processed by BGH is that which has been gathered through:
– Our direct channels:
- Website (www.barcelo.com).
- Call centre for telephone enquiries.
- Companies owning the hotels, if user consent has been obtained.
- Internet and social media, if user consent has been obtained.
VII.- With which authority can you exercise your right to claim?
Users may file a claim with the Agencia Española de Protección de Datos [Spanish Data Protection Agency] regarding any response received from BGH in addressing their rights.
In any event, users are hereby informed that any claims relating to the processing of personal data shall be managed and processed by the Data Protection Officer of the Barceló Gestión Hotelera, S.L., located at c/ Josep Rover Motta, 27, 07006, in Palma de Mallorca, or by sending an email to: firstname.lastname@example.org, attaching to this request, in both cases, a copy of their National Identity Document, Tax ID number, or an official document that identifies them.