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PRIVACY POLICY OF DAKIA UMUSIC HOSPITALITY LLC

This Privacy Policy (hereinafter referred to as “Policy”) is intended to regulate the acts of processing of personal data carried out by the entities of the group DAKIA UMUSIC HOSPITALITY LLC , which are included in the following list (hereinafter referred to as “UMusic Hotels”) of the interested parties (hereinafter referred to as “Users”).

 

Data controller

UMUSIC HOTELS

Purpose

  • Track the User’s navigation on the Website; 
  • Manage bookings and all kinds of requests;
  • Manage guest check-ins digitally;
  • Manage subscriptions and subsequent commercial communications from UMusic Hotels;
  • Manage queries and requests received through the ChatBot; 
  • Manage satisfaction surveys during and after the stay at the hotel;
  • Manage the provision of the contracted accommodation service; 
  • Manage and solve queries, requests, complaints, incidents or suggestions; 
  • Manage job applications to fill vacancies and/or to submit spontaneous applications; and
  • Manage the sending of information about the contracted services, or about which the User shows interest. 

Basis of legitimization 

  • Performance of a contract between the parties.  
  • Consent. 
  • Legitimate interest of UMusic Hotels.

Rights

 Users may exercise their rights of access, rectification, erasure, restriction, portability, and to object by sending an e-mail to dataprivacy@umusic-hotels.com

Source

 Some of the personal data we process at UMusic Hotels come from other companies within Universal Music Group, Inc., as well as from third parties.

Recipients

 UMusic Hotels may disclose your data to third parties.

Cookies

 If the User provides his/her consent, the Website will install cookies in their browser. 

1.                  Identity and contact details of the data controller. 

In compliance with the provisions of the applicable data protection regulations, UMusic Hotels informs that personal data provided by the User will be added to a file duly reflected in the Record of Processing Activities owned by UMusic Hotels. 

Likewise, users are informed that the controller of their personal User data is UMusic Hotels whose contact details are in the list indicated at the beginning of this Policy.

In case of any doubts regarding data protection, you may contact UMusic Hotels’ Privacy Manager through the e-mail address dataprivacy@umusic-hotels.com

2.                  What is UMusic Hotels’ purpose for processing the User’s personal data and what is the Lawful Basis for the Processing?

Personal data collected through the Website and the App will be processed by UMusic Hotels for the following purposes and with the following lawful bases:

  • Track the User’s navigation on the Website through the installation of Cookies, being the consent given by the User the lawful basis;
  • Manage bookings (including the payment) and attend to all kinds of requests, confirmations and documents, modifications or cancellations related to these, being the lawful basis the performance of a contract  between the parties;
  • Manage guest check-ins digitally upon their arrival at the hotel, being the lawful basis the contractual relationship between the parties.
  • Manage subscription and later sending of commercial communications (including the newsletter) about the services, updates and news regarding the activities of UMusic Hotels, its partners and collaborators, as well as cancellation requests, being the lawful basis, the consent given by the User.
  • Manage queries and requests received via the ChatBot available on the Website, being the lawful basis the application of pre-contractual measures at the User's request;
  • Manage satisfaction surveys during and after the stay at the hotel in relation to the quality of the services provided by UMusic Hotels, being the lawful basis UMusic Hotels’ legitimate interest in analyzing the quality of the services rendered.
  • Manage the provision of the contracted accommodation service, as well as additional services during the stay via the App, being the lawful basis the contractual relationship between the parties and the User’s consent, respectively. 
  • Manage and solve queries, requests, complaints, incidents or suggestions through the contact form on the Website and/or App, being the lawful basis the User’s consent.
  • Manage job applications and CVs received to cover vacancies and/or submit spontaneous applications, being the lawful basis the User’s consent; and
  • Manage the sending of information and reminders related to initiated bookings that have not been completed by the User, being the lawful basis UMH’s legitimate interest in direct marketing.

3.                  How long will UMusic Hotels process the Users’ personal data?

According to applicable regulations, UMusic Hotels will process personal data from the Users until they become unnecessary for the purposes they are being processed or until the User requests their erasure to UMusic Hotels, objects or revokes their consent (in case of a request of the purpose of the user’s consent). Once such period finalizes, UMusic Hotels will keep the Users’ data duly blocked during the applicable retention periods applicable in order to determine the possible liabilities associated with the processing performed. The blocking of data means UMusic Hotels will only be able to process them with the purpose of attending to liabilities of any kind that may arise from the processing performed. Personal data will be deleted once the aforementioned periods end.

4.                  Security Measures

UMusic Hotels has adopted the security levels for the protection of Personal Data legally required by current legislation and has installed all means and technical and organizational measures at its disposal to guarantee the security of the Personal Data provided by the User and avoid their destruction, loss, misuse, alteration, unauthorized access and theft. In determining these measures, criteria such as the scope, context and purposes of the processing, the state of the art and the risks involved were taken into account.

5.                  Source of personal data

UMusic Hotels will collect personal data directly from its Users. However, it is possible that some of Users' personal data may be obtained through third parties, in particular: 

  • Companies from UMusic Hotels.
  • Third-party aggregators such as Booking.com and other platforms that permit online booking and are able to provide: (i) the User’s contact details; (ii) information about the contracted booking (date, type of room, additional services contracted, etc.); 
  • Travel agencies hired by the User to contract UMusic Hotels’ services, which may provide: (i) the User’s contact details; (ii) information about the contracted booking (date, type of room, additional services contracted, etc);

6.                  Recipients of the personal data

The Users’ data may be disclosed to third parties in the following scenarios: 

  • To companies belonging to UMusic Hotels, for the purposes mentioned above.
  • To the competent authorities and courts, when necessary for the fulfillment of legal obligations of UMusic Hotels or for the exercise of defense and/or formulation of claims.

Likewise, for the management of the purposes detailed in section 3 above, it is possible that some of the entities subcontracted by UMusic Hotels access personal data and information on its behalf to provide you with a service or assist you in the management of the Website. Said third parties are considered processors for the purpose of the processing of personal data. UMusic Hotels will guarantee that the access by the processors complies with the current regulations, as well as with the instructions provided by UMusic Hotels.  

7.                  International transfer of data

In order to manage the purposes detailed in section 3 above, it is possible that the addressees described in section 7 access UMusic Hotels' personal data from third countries located outside of the European Economic Area (EEA). In such cases, UMusic Hotels shall ensure to previously subscribe with such third parties valid mechanisms for the international transfer of the Users' data. In particular, UMusic Hotels will transfer Users’ personal data to: 

  • To third parties established in countries outside of the EEA when there is an adequacy decision of the European Commission recognizing that country or territory as safe; or
  • Third parties established in countries located outside the EEA for which there is no adequacy decision of the European Commission but UMusic Hotels and such third parties have previously signed the Standard Contractual Clauses approved by the European Commission.

Users may request further information on the types of mechanisms employed by UMusic Hotels via the following email address: dataprivacy@umusic-hotels.com

8.                  Users’ rights

Users may exercise their rights detailed below before UMusic Hotels. To this end, they should send a letter to the following e-mail address dataprivacy@umusic-hotels.com. If their request does not meet the necessary requirements, UMusic Hotels may require its correction. Likewise, if there were any doubts regarding their identity, UMusic Hotels may request additional information to prove such identity.

The data protection rights are as follows:

Rights

What does it consist of?

Right of access

See what personal data UMusic Hotels processes.

Right to rectification

Modify personal data processed by UMusic Hotels when these are inaccurate.

Right to object 

Request that UMusic Hotels does not process personal data for some specific purposes.

Right to erasure

Request that UMusic Hotels deletes the User’s personal data.

Right to restriction of processing

Request that UMusic Hotels limits the processing of the User’s personal data.

Right to data portability

Request that UMusic Hotels delivers information about the Users in a machinereadable format.

Lastly, if you consider your request has not been duly answered, you can file a complaint against UMusic Hotels before the Spanish Data Protection Agency (AEPD). 

Last update: October 2022.