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Arbequina Apartment at Flamenca Village respects your privacy and is committed to handling personal information fairly, transparently and securely.

This Privacy Policy explains what personal information we collect when you visit our website, contact us, enquire about a stay, make or manage a reservation, or stay at the property; why we use that information; who may receive it; how long we keep it; and the rights available to you.

This Policy should be read together with our Cookie Policy and, where applicable, our Booking Terms.

1. Who is responsible for your personal data?

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Spanish data-protection legislation, the data controller is:

Name : Isabelle Leszowski
Trading name: Arbequina Apartment at Flamenca Village

Email: booking@myarbequina.com

Website: https://www.myarbequina.com/

In this Policy, “Arbequina Apartment”, “we”, “our” and “us” refer to the above data controller.

If you have any questions about this Privacy Policy or about how your personal information is handled, please contact us using the privacy email above.

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2. Who does this Privacy Policy apply to?

This Policy applies to people who visit or interact with our website, send us an enquiry, contact us by email or another communication channel, request information about the property, make or attempt to make a reservation, stay at the property, are included as a guest on a reservation, or otherwise communicate with us in connection with our accommodation services.

It also applies, where relevant, to information about additional guests supplied by the person making the reservation.

If you provide personal information about another person, you should ensure that you are authorised to provide it and, where appropriate, make that person aware of this Privacy Policy.

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3. What personal information do we collect?

The information we collect depends on how you interact with us.

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Website and technical information

When you visit the website, certain technical information may be collected automatically. This may include your IP address, approximate location derived from your IP address, browser type, operating system, device type, screen size, referring website, pages viewed, date and time of access, and technical information necessary to keep the website secure and functioning correctly.

Some of this information is collected through cookies or similar technologies. Non-essential analytics technologies are used only in accordance with your cookie choices.

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Enquiry and contact information

If you contact us, we may collect your name, email address, telephone number, preferred dates, number of guests, the content of your message, and any other information you choose to provide.

Please do not provide sensitive personal information unless it is genuinely necessary for us to assist you.

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Reservation information

If you request or make a reservation, we may process information such as your name, email address, telephone number, billing or residential address, nationality where required, reservation dates, arrival and departure information, number of guests, names or details of accompanying guests where required, booking reference, property booked, price, applicable charges, payment status, special requests, correspondence relating to the reservation, and information required to administer changes, cancellations or refunds.

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Guest registration and identification information

Spanish accommodation laws may require accommodation providers to collect, verify, record and communicate certain information concerning guests and reservations to the competent authorities.

Where legally required, this may include names and surnames, identity-document details, nationality, date of birth, usual place of residence, contact details, number of travellers, relationship between travellers where a minor is involved, reservation and contract information, arrival and departure details, and information concerning the payment method or transaction.

We collect and use this information only to the extent required to comply with applicable law and to operate the accommodation lawfully.

You may also be asked to present or provide information from an identification document so that legally required guest details can be verified.

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Payment information

Payments connected with a reservation may be processed by an independent payment-service provider or through the booking system used for the reservation.

Depending on the payment method, the payment provider may collect information such as the cardholder name, payment account details, transaction identifiers and billing information.

We do not intentionally store complete payment-card security credentials such as your card verification code.

Payment providers process payment information under their own security and privacy requirements.

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Communications

If you communicate with us before, during or after your stay, we may retain the correspondence and associated contact information where reasonably necessary to provide guest support, administer the reservation, respond to questions, resolve complaints, protect our legal interests or comply with legal obligations.

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4. How do we collect your information?

We may obtain personal information directly from you when you use our contact forms, send an email, contact us by telephone or messaging service, make a direct reservation, provide guest-registration information, communicate with us about your stay or otherwise provide information voluntarily.

We may also receive reservation information through a booking-management provider or, where you have booked through another legitimate booking channel, from the platform through which the reservation was made.

Technical information may be collected automatically when you use the website.

Where information concerning you is supplied by the person who made a group reservation, we may receive that information indirectly from the lead guest.

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5. Why we process your personal information

We only process personal information when we have a lawful reason to do so.

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To respond to enquiries

We use the information you provide to answer questions, provide availability or property information, discuss a potential reservation and take steps requested by you before entering into a booking contract.

The legal basis is normally taking steps at your request before entering into a contract and, where appropriate, our legitimate interest in responding to legitimate enquiries about the property.

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To create and manage reservations

We use reservation information to process bookings, confirm dates, administer changes or cancellations, communicate important stay information, organise check-in and check-out, provide guest support, manage payments and refunds, and otherwise perform the accommodation agreement.

The legal basis is performance of the booking contract or taking steps at your request before entering into that contract.

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To comply with accommodation and guest-registration law

Where Spanish law requires us to obtain, verify, record or transmit guest or reservation information, we process the necessary personal data to comply with that legal obligation.

This may include communication of legally required information to the Spanish Ministry of the Interior or another competent authority.

The legal basis is compliance with a legal obligation.

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To comply with accounting, tax and legal obligations

Certain reservation, invoice, payment and business records may need to be kept because of tax, accounting, commercial, consumer-protection, security or other legal requirements.

The legal basis is compliance with our legal obligations.

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To protect the property, guests and our legal rights

We may process relevant information when reasonably necessary to prevent fraud or misuse, protect the security of the website and booking systems, investigate suspected unlawful activity, protect guests and the property, establish or defend legal claims, or resolve disputes.

The legal basis is our legitimate interest in operating the accommodation safely and securely and protecting our legal rights, except where those interests are overridden by your rights and freedoms.

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To analyse and improve the website

Where analytics is enabled and you have provided the required cookie consent, we may use aggregated or pseudonymous information about website activity to understand how visitors use the website, identify technical problems and improve the website's usability and effectiveness.

Where consent is legally required, the legal basis is your consent.

You can withdraw that consent through the website's Cookie Settings without affecting the lawfulness of processing that occurred before withdrawal.

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6. Spanish guest-registration obligations

Accommodation providers in Spain are subject to legal obligations concerning guest and reservation information.

Where applicable to your stay, we may be required to collect and communicate information concerning a reservation and the persons staying at the property to the competent Spanish authorities.

The information requested for this purpose is separate from ordinary marketing activity and is processed because the accommodation provider is legally required to obtain or communicate it.

Failure to provide information that is legally required for guest registration may mean that we are unable to complete the legally required registration process or, where the law prevents us from doing so, provide the accommodation service.

Information collected for statutory guest registration will not be used for unrelated marketing purposes.

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7. Cookies and similar technologies

The website uses cookies and similar technologies.

Some cookies are strictly necessary for the website to function correctly, maintain security, remember essential settings or provide a service specifically requested by you. These technologies may operate without separate consent where permitted by law.

Other technologies, including analytics or other non-essential cookies, are activated only in accordance with your choices in the cookie banner.

If analytics services such as Google Analytics 4 are enabled on the website, they are intended to help us understand website usage and performance. Analytics cookies or similar technologies requiring consent will not be intentionally activated for you before the required consent has been obtained.

You can accept, reject or configure non-essential cookies using the choices provided in the cookie banner and can change your preferences later through the Cookie Settings link made available on the website.

For more detailed information about the cookies actually used, their providers, purposes and durations, please see our separate Cookie Policy.

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8. Website hosting and technical infrastructure

Our website is built and hosted using Wix.

As part of operating and securing the website, Wix and its authorised service providers may process technical information associated with website visits and information submitted through Wix-based website functionality.

Wix acts under its own contractual and data-protection arrangements and provides infrastructure, security and other website services that enable us to operate the site.

Where we use a Wix feature that collects personal information on our behalf, we remain responsible for explaining our own purposes for processing that information.

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9. Booking-management services

We use Smoobu as part of our booking and accommodation-management infrastructure.

Where Smoobu processes guest information on our instructions in connection with our accommodation activity, Smoobu acts as a data processor on our behalf in accordance with its contractual data-processing obligations.

This may include processing information necessary to manage reservations, communications, availability, accommodation records and related booking functions.

Smoobu may use authorised subprocessors to provide its services. Where processing involves transfers outside the European Economic Area, appropriate transfer safeguards must be used in accordance with applicable data-protection law.

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10. Who may receive your personal information?

We do not sell or rent your personal information.

We may disclose relevant personal information only where reasonably necessary to the following categories of recipients.

Website and technology providers. This includes Wix and providers necessary to host, secure, maintain or technically operate the website.

Booking-management providers. This includes Smoobu and authorised service providers involved in administering reservations.

Payment-service providers and financial institutions. These parties process payments, refunds, fraud checks and payment transactions where required.

Authorised co-hosts or property-support personnel. Relevant information may be shared with an authorised person responsible for check-in, key handover, guest support, property access, cleaning coordination, maintenance or another legitimate part of delivering your stay. Such persons are given only the information reasonably necessary for their role.

Professional advisers. Information may be shared with accountants, tax advisers, insurers, lawyers or other professional advisers where reasonably necessary.

Public authorities. We may disclose information to the Spanish Ministry of the Interior, law-enforcement authorities, courts, tax authorities or other public bodies where required by law or a legally valid request.

Business service providers. We may use other carefully selected providers that support legitimate business functions. Where they process information on our behalf, appropriate contractual and data-protection obligations apply.

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11. International transfers of personal information

Some of the technology providers used to operate the website or provide connected services may process information from locations outside Spain or outside the European Economic Area.

Where personal information is transferred to a country that does not benefit from an applicable adequacy decision, we require or rely on an appropriate transfer mechanism where legally required. Depending on the provider and circumstances, this may include European Commission Standard Contractual Clauses, participation in an applicable approved data-transfer framework, or another safeguard recognised by Chapter V of the GDPR.

You may contact us if you would like further information about the safeguards applicable to a particular transfer involving your personal information.

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12. How long we keep your information

We do not intend to retain personal information indefinitely.

The appropriate retention period depends on why the information was collected, our contractual relationship with you, legal requirements and whether the information may reasonably be required for a legal claim.

Unsuccessful enquiries. Enquiries that do not lead to a booking will normally be retained only for as long as reasonably necessary to respond and follow up. As a general internal guideline, we aim to remove or anonymise ordinary enquiry correspondence within approximately 12 months after the last meaningful contact unless there is a legitimate reason to keep it longer.

Booking and contractual records. Reservation, invoice, accounting and related commercial records may be kept for the period required by applicable Spanish tax, commercial and accounting legislation. Business documentation subject to Spanish commercial recordkeeping requirements may need to be retained for up to six years.

Guest-registration records. Information processed under Spanish accommodation-registration legislation is retained for the statutory period that applies to the relevant accommodation operator. Where the three-year electronic recordkeeping requirement applies, the required information is retained for three years from completion of the accommodation service.

Legal disputes. Information relevant to a complaint, dispute, insurance issue or legal claim may be kept for as long as reasonably necessary to establish, exercise or defend legal rights.

Cookie and analytics information. Cookie preferences and analytics information are retained according to the settings and lawful retention periods applicable to the relevant technology.

When information is no longer required, we take reasonable steps to delete, anonymise or securely dispose of it.

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13. How we protect your information

We take reasonable technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

These measures may include secure website connections, access controls, passwords, provider security controls, limiting access to persons who genuinely require the information, appropriate processor agreements and other measures proportionate to the nature of the information and the risks involved.

No internet-based system can be guaranteed to be completely secure. For that reason, we cannot promise absolute security, but we take reasonable measures appropriate to the nature of our accommodation business and the systems we use.

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14. Your data-protection rights

Depending on the circumstances, the GDPR gives you a number of rights in relation to your personal information.

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Right of access

You may ask whether we process personal information about you and request a copy of the personal information we hold about you, together with information about the processing.

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Right to rectification

You may ask us to correct personal information that is inaccurate or complete information that is incomplete.

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Right to erasure

You may ask us to delete your personal information in circumstances where the GDPR gives you a right to erasure.

The right to erasure is not absolute. We may need to retain certain information where processing remains necessary to comply with a legal obligation, establish or defend legal claims, or for another lawful reason.

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Right to restriction

In certain circumstances, you may ask us to restrict how we process your personal information.

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Right to object

Where processing is based on legitimate interests, you may object on grounds relating to your particular situation.

If personal information were ever processed for direct marketing, you would have the right to object to that processing at any time.

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Right to data portability

Where the statutory conditions are met, you may have the right to receive personal information you provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller.

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Right to withdraw consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before the consent was withdrawn.

For cookie-related consent, you can use the Cookie Settings available on the website.

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15. How to exercise your rights

To exercise a data-protection right, contact us at:

booking@myarbequina.com

Please state which right you wish to exercise and provide enough information for us to identify the records concerned.

We may need to request reasonable information to verify your identity before releasing, changing or deleting personal information. This is intended to protect your information from unauthorised access.

We will respond in accordance with the time limits and requirements established by applicable data-protection law.

There is normally no fee for making a valid data-protection request. A reasonable fee may be permitted, or a request may be refused, where a request is manifestly unfounded or excessive and applicable law allows us to do so.

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16. Right to complain to a supervisory authority

If you believe that your personal information has been processed in a way that infringes applicable data-protection law, you have the right to lodge a complaint with a supervisory authority.

For processing connected with our accommodation activity in Spain, the relevant supervisory authority is the Agencia Española de Protección de Datos (AEPD) — the Spanish Data Protection Agency.

We would appreciate the opportunity to address your concern directly first, so you are welcome to contact us at : booking@myarbequina.com, although doing so does not affect your right to complain to the supervisory authority.

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17. Children and information about minors

The website is not directed at children for the purpose of independently making accommodation reservations.

A parent, guardian or responsible adult may, however, make a reservation that includes children.

Spanish accommodation laws may require certain information concerning minors travelling as part of a booking, including information about their relationship to accompanying travellers.

Where information about a minor is required for a reservation, accommodation service or legal guest-registration obligation, it is processed only for the relevant booking, safety, legal or accommodation purpose.

We do not knowingly use children's personal information for behavioural advertising or unrelated marketing.

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18. Sensitive personal information

We do not ordinarily require health information or other special-category personal data to make a reservation.

You should avoid sending sensitive information unless it is genuinely necessary.

If you voluntarily provide information concerning accessibility, health or another sensitive matter because you need a particular accommodation or assistance, we will use it only as reasonably necessary to respond to that request and in accordance with an appropriate legal basis.

Where appropriate, we may ask for your explicit consent before processing sensitive information.

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19. Marketing communications

We do not use information supplied solely for a booking or ordinary accommodation enquiry to send unrelated promotional emails unless there is a lawful basis for doing so.

If we introduce an email newsletter or another optional direct-marketing service that requires consent, you will be given a clear and separate choice before being subscribed.

Where marketing is based on consent, you may withdraw that consent at any time.

Transactional communications concerning your enquiry, reservation, check-in, stay, payment, cancellation, safety information or another service-related matter are not marketing communications and may be sent where necessary to provide the service or comply with legal obligations.

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20. Automated decision-making

We do not currently use your personal information to make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

If this changes, this Privacy Policy will be updated and the information required by applicable law will be provided.

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21. Third-party websites and external services

Our website may contain links to third-party websites, maps, social networks, booking services or other external resources.

When you follow an external link, the third party may process personal information under its own privacy policy.

We are not responsible for the privacy practices of independent third-party websites and recommend reviewing their privacy information before providing personal data.

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22. Changes to this Privacy Policy

We may update this Privacy Policy when our website, booking process, service providers, legal obligations or data-processing activities change.

The current version will be published on this page and will show the date on which it was last updated.

Where a change materially affects how existing personal information is processed, we will take any additional steps required by applicable law.

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23. Contact

Questions about this Privacy Policy, requests concerning your personal information or other privacy enquiries should be sent to:

Arbequina Apartment at Flamenca Village
Data Controller: Isabelle Leszowski
Email: booking@myarbequina.com
Website: https://www.myarbequina.com/

We aim to handle privacy enquiries carefully, fairly and without unnecessary delay.