1.- PRIVACY POLICY

Las Colinas Golf & Country Club understands that privacy is a fundamental part of the very essence of the unique experience we offer, where healthy living and harmony with nature are paramount. The guarantee of protection of your personal data allows you to enjoy all our services and experiences in a unique natural setting without any worries.

The purpose of this Privacy Policy is to clearly and precisely inform Users about the processing of their personal data obtained through the different websites linked to Las Colinas Golf & Country Club, whose main website is https://lascolinasgolf.com/ (hereinafter, all websites, separately or jointly, the “Website”), carried out by the data controller. The websites linked to the Website are: https://lascolinasresidences.com/es/inicio/, https://lascolinasgolfrealestate.com/, htts://restauranteumawa.com, https://restauranteilpalco.com and https://wowbeach.es.

2.- OBLIGATION TO PROVIDE THE DATA

The data requested through the Web Site are, in general, mandatory (unless otherwise specified in the required field) to fulfill the purposes for which they are being collected.

Therefore, if they are not provided or are not provided correctly, they will not be able to be attended.

3.- FOR WHAT PURPOSES WILL THE DATA CONTROLLERS PROCESS THE USER’S DATA AND ON THE BASIS OF WHAT LEGITIMACY?

Las Colinas Golf & Country Club is a complex managed by three different companies, Colinas Green Golf S.L. (B83977868); Campoamor Sun & Beach S.L. (B83835496); and Colinas Golf Residencial S.L. (B83995142), all of them with registered offices at C/ Luchana 23, 28010 Madrid and belonging to the Gmp Group.

Each of them has an independent and perfectly delimited scope of responsibility depending on the purposes of the specific processing, so that for each processing activity a data controller will be indicated, without prejudice to those treatments common to all data controllers. Thus, the corresponding responsible company will process the personal data provided by the User or that may be obtained directly through any of the channels provided for this purpose, for the following purposes  purposes indicated below, in accordance with the basis of legitimacy applicable in each case:

a. Processing and management of reservations and sports and wellness services (The Beauty Room, Sports & Health Club, Golf Academy, Toptracer Range, Racquet Club and Tennis and Paddle Tennis Academy, Golf outing reservations):

Responsible for the treatment: Colinas Green Golf S.L. Purposes of treatment:

1. Management of the User’s reservation through the Site
2. Management of the registration and deregistration of the User registered on the Website, when
3. Provision of the sports service requested by the
4. Processing and follow-up of the service contracting carried out by the
5. Collection management of services contracted by the customer
6. Contact the User when any circumstance of interest related to the services arises.
7. Conducting consultations with Users regarding quality and their satisfaction with goods or services.
8. Management of the security of the Web Site through the security measures implemented, as well as for the detection and prevention of fraud in transactions.
9. Comply with the provisions of the applicable regulations on accounting, tax and consumer matters, in relation to the contracting that may have been carried out.

Basis of legitimacy:

For purposes 1 to 6 the basis of legitimacy is the execution of the contractual relationship or, where appropriate, application of pre-contractual measures arising from the reservation and/or provision of the service (art. 6.1.b) RGPD).

For purpose 7 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting of being able to offer Users products with the highest quality and best possible experience, as well as to establish mechanisms to facilitate contact and the relationship with the service provider.

For purpose 8 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting of minimizing the risks assumed by the Data Controller and its customers in the marketing and purchase of its products.

For purpose 9 the basis of legitimacy is the fulfillment of the appropriate legal obligations of the data controller (art.6.1.c) RGPD).

b. Processing and management of reservations and accommodation and lodging services (Colinas Residences):

Responsible for the treatment: Campoamor Sun & Beach S.L. Purposes of treatment:

1. Management of the User’s reservation through the Site
2. Management of the registration and deregistration of the User registered on the Website, when
3. Provision of the sports service requested by the
4. Processing and follow-up of the service contracting carried out by the
5. Collection management of services contracted by the customer
6. Contacting the User when any circumstance of interest related to the services arises.
7. Conducting consultations with Users regarding quality and their satisfaction with goods or services.
8. Management of the security of the Web Site through the security measures implemented, as well as for the detection and prevention of fraud in transactions.
9. Comply with the provisions of the applicable regulations on accounting, tax, consumer and police matters regarding the obligation to register overnight stays and collect identification data in an official document, all in relation to the contracting that may have been made.

Basis of legitimacy:

For purposes 1 to 6 the basis of legitimacy is the execution of the contractual relationship or, where appropriate, application of pre-contractual measures arising from the reservation and/or provision of the service (art. 6.1.b) RGPD).

For purpose 7 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting of being able to offer Users products with the highest quality and best possible experience, as well as to establish mechanisms to facilitate contact and the relationship with the service provider.

For purpose 8 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting in minimizing the risks assumed by Data Controller and its customers in the marketing and purchase of its products.

For purpose 9 the basis of legitimacy is the fulfillment of the appropriate legal obligations of the data controller (art.6.1.c) RGPD).

c.  Processing and management of reservations and catering services (Umawa, Ilpalco and Unik):

Responsible for the treatment: Colinas Green Golf S.L. Purposes of treatment:

1. Management of the User’s reservation through the Site
2. Management of the registration and deregistration of the User registered on the Website, when
3. Provision of the catering service requested by the User. Where appropriate, special category data of the User (health data) may be processed, if intolerances or allergies are reported.
4. Processing and follow-up of the service contracting carried out by the
5. Contacting the User when any circumstance of interest related to the services arises.
6. Conducting consultations with Users regarding quality and their satisfaction with goods or services.
7. Management of the security of the Web Site through the security measures implemented, as well as for the detection and prevention of fraud in transactions.
8. Comply with the provisions of the applicable regulations on accounting, tax and consumer matters, in relation to the contracting that may have been carried out.

Basis of legitimacy:

For purposes 1 to 5 the basis of legitimacy is the execution of the contractual relationship or, where appropriate, application of pre-contractual measures arising from the reservation and/or provision of the service (art. 6.1.b) RGPD).

For purpose 6 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting of being able to offer Users products with the highest quality and best possible experience, as well as to establish mechanisms to facilitate contact and the relationship with the service provider.

For purpose 7 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting in minimizing the risks assumed by the Data Controller and its customers in the marketing and purchase of its products.

For purpose 8 the basis of legitimacy is the fulfillment of the appropriate legal obligations of the data controller (art.6.1.c) RGPD).

d. Processing and management of reservations and services offered in WOW Beach:

Responsible for the treatment: Campoamor Sun & Beach S.L. Purposes of treatment:

1. Management of the User’s reservation through the Website
2. Management of the registration and deregistration of the User registered on the Website, when
3. Provision of the service requested by the In the case of provision of catering services, special category data of the User (health data) may be processed, if intolerances or allergies are reported.
4. Processing and follow-up of the service contracting carried out by the
5. Contact the User when any circumstance of interest related to the services arises.
6. Conducting consultations with Users regarding quality and their satisfaction with goods or services.
7. Management of the security of the Web Site through the security measures implemented, as well as for the detection and prevention of fraud in transactions.
8. Comply with the provisions of the applicable regulations on accounting, tax and consumer matters, in relation to the contracting that may have been carried out.

Basis of legitimacy:

For purposes 1 to 5 the basis of legitimacy is the execution of the contractual relationship or, where appropriate, application of pre-contractual measures arising from the reservation and/or provision of the service (art. 6.1.b) RGPD).

For purpose 6 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting of being able to offer Users products with the highest quality and best possible experience, as well as to establish mechanisms to facilitate contact and the relationship with the service provider.

For purpose 7 the basis of legitimacy is the legitimate interest (art. 6.1.f) RGPD), consisting in minimizing the risks assumed by the Data Controller and its customers in the marketing and purchase of its products.

For purpose 8 the basis of legitimacy is the fulfillment of the appropriate legal obligations of the data controller (art.6.1.c) RGPD).

e. Inform the User by any means of products and services related to Complejo Las Colinas Golf & Country Club, by sending commercial communications:

Responsible for processing: Colinas Golf Residenciel S.L.

Purposes of processing: To send commercial communications to the e-mail address and telephone number provided for this purpose by the user.

Basis of legitimacy: the processing derived from this purpose will be based on the express consent of the User by expressly accepting, without any kind of obligation in this regard, the subscription to the communications service of Las Colinas Golf & Country Club by e-mail or telephone messaging (art. 6.1.a) RGPD).

f. Respond to questions raised in the contact forms:

Responsible for the treatment: Colinas Golf Residencial S.L.

Purposes of processing: In cases where a User raises any type of question, their data will be processed to manage, process and respond to requests, applications, incidents or queries from the User.

The reception of curricula vitarum does not form part of the purposes foreseen for the questions and doubts section. However, in the event that the User spontaneously sends them requesting their consideration, they may be processed exclusively for the purpose of taking them into account in selection processes opened by the company.

Basis of legitimacy: the processing derived from the purpose of resolving doubts, questions or queries, will be based on the express consent of the User to expressly accept without any obligation to be contacted through the data provided to respond to your request (art. 6.1.a) RGPD).

In the case of CVs received, they may be processed on the basis of the legitimacy of the pre-contractual interest expressed when sending the CV and/or cover letter (art. 6.1.b) GDPR).

4.- WITH WHICH RECIPIENTS WILL THE USER’S DATA BE SHARED?

The correct attention of the service provided to the User implies that other third party service providers access the User’s personal data as data processors, with which the corresponding Data Controller has signed the corresponding service provision agreements with access to data.

In turn, personal data may be communicated to other entities of the Gmp group of companies, with your consent where necessary, which may access the personal data and information to assist us in the management of the pre-contractual relationship or processing of the request made. We ensure that all these entities comply with data protection regulations, which are also directly applicable to them.

In addition to the above, the User understands that personal data may be transferred or communicated to meet their obligations to the Public Administrations in cases where this is required in accordance with the legislation in force at any time and, where appropriate, also to other bodies such as State Security Forces and Bodies and the Judiciary.

In the case of the curricula vitarum received, your data may be transferred to the companies belonging to the group of companies of which Gmp Property SOCIMI

S.A. is the parent company of the group to which all those responsible for the processing of the Websites belong, exclusively for the purposes and subject to the conditions indicated herein (section 3f).

5.- INTERNATIONAL DATA TRANSFERS

Users’ personal data may be communicated or made known to third parties located outside the EU for the correct execution of the provision of the contracted services, as well as for the attention of Users’ requests or for the fulfillment of any of the indicated purposes.

In cases where there is no adequacy decision in force, it is guaranteed that the aforementioned international transfer of data will be carried out in compliance with the applicable data protection regulations and, in any case, through the granting of the appropriate guarantees. Specifically, by signing the standard contractual clauses approved by the European Commission and, when necessary, by adopting any additional guarantee measures that may be appropriate.

6.- CONSERVATION OF DATA

Users’ data will be kept as long as the relationship with the User remains in force, without prejudice to the conservation that may be necessary for the formulation, exercise or defense of potential claims and/or as long as permitted by applicable law. Once the aforementioned period has expired, the data will be deleted.

In the case of curricula vitarum received, they may be retained for one year and thereafter may be kept – limited to contact details and possible positions for which the user’s profile fits – duly blocked for up to three years.

7.- USER’S RESPONSIBILITY

The User guarantees that he/she is over eighteen (18) years of age or, if applicable, that he/she is capable of entering into the corresponding contracts for goods and services by him/herself, and that the information provided is true, accurate, complete and up to date. To these effects, the User is responsible for the veracity of all the data that he/she communicates and will keep the information provided conveniently updated, in such a way that it corresponds to his/her real situation.

Likewise, the User guarantees that he/she has informed the third parties whose data he/she provides, if he/she does so, of the aspects contained in this document. Likewise, he/she guarantees that he/she has obtained their authorization to provide their data for the aforementioned purposes.

In this regard, the User is informed that he/she will be responsible for any false or inaccurate information provided through the contact channels provided and for any damages, direct or indirect, that this may cause to the Data Controller or third parties.

8.- EXERCISE OF RIGHTS

The User has the possibility of exercising free of charge the rights of access, rectification, opposition, suppression, portability and limitation of the treatment, as well as to reject the automated treatment, of the personal data by means of a written and signed request addressed to the following address: C/Luchana, 23 – Madrid or through privacidad@grupogmp.com . For this purpose, the User must send such written communication indicating the request or right being exercised, name and surname. A copy of your ID card or valid document proving your identity (photocopy of passport) will only be requested in cases where there may be reasonable doubts about it and taking into consideration the nature of personal data subject to the exercise of the right.

The User has the right to object to the processing of their data for promotional purposes for the receipt of commercial communications with the simple notification of their will. To do so, the User may address his request through the procedure described in the preceding paragraph. Likewise, the User may cancel the receipt of commercial communications in the manner provided for in each commercial communication (for example, through the link included in each of them).

In addition to the above rights, the User shall have the right to withdraw the consent given at any time by means of the procedure described above, without such withdrawal of consent affecting the lawfulness of the processing prior to the withdrawal of consent. In any case, the User’s data may continue to be processed to the extent permitted by applicable law.

Likewise, the User may file a complaint regarding the protection of his/her personal data before the Spanish Data Protection Agency at the address C/ Jorge Juan, 6, 28001 – Madrid, when the interested party considers that the processing of his/her personal data has violated the rights recognized by the applicable data protection regulations.

9.- SAFETY MEASURES

The User’s data will be treated at all times with absolute confidentiality and keeping the mandatory duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organizational measures to ensure the security of your data and avoid its alteration, loss, treatment or unauthorized access, given the state of technology, the nature of the data stored and the risks to which they are exposed.

10.- WARNING AND CHANGES

This privacy policy applies only to personal data collected or provided by the user through any of the channels provided. The User should be aware that we are not responsible for the practices on personal data protection carried out by the websites whose links may be displayed on the various websites of the companies linked to Las Colinas Golf & Country Club.

These external websites will be responsible for the processing of personal data provided by the User through such external website, without us being able to acquire any responsibility for such processing. We encourage the User to read the privacy statement of each and every website that collects personal data.

The Data Controller has the right to review and amend this Privacy Policy at any time it deems appropriate, in which case it will be communicated to Users. For this reason, please check this privacy statement regularly to read the most recent version of the Privacy Policy, available on this Web Site.

Last update: May 2024