2. What Personal Data Do We Process?
We process personal information or other information about you when you interact with any of our properties or facilities, visit our Sites or otherwise use our Services. The information we may process depends upon your interaction with us. The types of personal data that we may process include the following:
- Reservations and Account Information: In order to access and use certain features, content or functions of the Services, including, for example, booking a hotel reservation, applying for membership at one our clubs, reserving a tee-time at a Capital Realty Services, making a restaurant reservation, purchasing products from the Capital Realty Services Store, signing up for loyalty programs or using any of our Apps, you may need to register for an account. When you create an account, we will process personal data as necessary to offer and fulfill the Services you request. Depending on the Services you elect to use and only as necessary to provide such Services, we may ask you to provide your name, name of your spouse or partner, mailing address, arrival and departure information, email address, name of pet, proof of identity (e.g., driver’s license number, mother’s maiden name), phone number, Facebook credentials in order to authenticate your account, date of birth, gender or other descriptive information or preferences, and ask you to create login credentials (i.e., a unique user name and password). Also, when you book a reservation, we may ask for additional specific account information such as corporate account number, group or convention code, travel agent number or AAA number. If you limit our processing of certain information that we obtained from you via consent, you may not be able to use all of the features of the Services.
- Additional Profile Information: We may also process information about our hotel guests, golf course members or players, customers (including prospective customers), residents and visitors so that we can best provide them with a personalized experience to fit their needs. Such information may include information or data relating to your room preferences, in-room dining preferences, Capital Realty Services and other concierge services, preferred dining seating, equipment rental, leisure activities and interests, and other information as necessary to fulfill special requests made by you regarding your stay or services you request from us (e.g., health conditions that require special room accommodations or accessibility). We may also process other information associated with a guest’s stay, or a member’s, player’s, customer’s or other visitor’s use of the Services, such as the hotels where you have stayed, check-in/check-out dates, goods and services used, special requests made, observations about your service preferences (including room and vacation preferences, times of play, etc.), real estate preferences (e.g., attributes of properties you are interested in, desired neighborhoods or school districts), telephone numbers dialed and faxes, texts and telephone messages received.
- Images: We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas of our properties. We may also use closed-circuit television and other technologies that record sound or video for loss prevention and security purposes, and the protection of our guests and visitors to our properties where permitted by law.
- Payment Information and Purchase History: If you purchase products or services on or through our Services (e.g., Capital Realty Services Store) your payment information (e.g. credit or debit card number, card type and expiration date and address associated with such credit or debit card) and additional information to fulfill the services or deliver the products (e.g. name, date of birth and shipping address) may be processed by us and/or third party payment processors. We also process the details of any purchased services or products, including the date of purchase, rate or product purchase price, food/beverage purchase history, and any wording you may suggest for a gift card.
- Location Information: With your permission, we may process the specific geographic location of your Device (e.g. by accessing your Device’s GPS) via our Sites or Apps to provide you with directions to our properties or to determine your proximity to our properties or other specified location (for example, to determine yardage when playing a golf course). If no longer wish to have this location information processed, you can withdraw your consent at any time by disabling the location and/or Bluetooth features in the operating system of your Device and/or in the App. If you have any questions about disabling you location and/or Bluetooth features, you can contact us firstname.lastname@example.org
- Personal Data You Choose to Provide for Marketing or Additional Services: We may process personal data that you choose to provide to us when you elect to participate in optional Site-features or Services. For example, if you sign up to receive newsletters, marketing emails, promotions or other communications regarding the Services and/or promotions from our preferred third-party products or services or other Capital Realty Services brands, participate in contests, surveys and other promotions related to the Services, we may process your name, email address, mailing address, gender, interests and phone number in order to provide the additional features or Services. We will make clear what information we may process as a result of your engagement with the optional Site-features or Services.
- Comments, Feedback, Customer Service and Other Inquires: You have the ability to use the Services to contact us with questions you may have, inquire about memberships, request to be contacted about properties available for sale or rent, provide us with comments and or feedback about the Services (e.g., completing a “Contact Us” form on our Sites or surveys relating to your hotel stay) or to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users. We will process any information you submit, post or provide in the course of such activities to respond to your comments or feedback. In the event you contact one of our properties or customer call centers, we may process information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and to verify your identity.
- Application Information: When you apply for membership to any of our golf courses, clubs or loyalty programs, or submit an application(s) in connection with the rental or purchase of a property to our realty or brokerage service, we process information that you choose to provide to us through your application process, which may include your name, email address, mailing address, phone number, gender, date of birth, dependent information and references.
- Third Party Platform Information: If you access the Services by logging in using your account credentials from a third-party owned or operated platform/service (e.g., Apple (iTunes, etc.), Spotify, OpenTable, Facebook, Twitter, LinkedIn, etc.) (each, a “Third Party Platform”), post content from our Sites or Apps to a social network, or use various social media features (e.g., “Like” button), we may process certain information from the Third Party Platform, such as your username, “likes”, location, birthday, check-ins, comments and reviews, direct messages you may send to us, interests, photos, friends, status updates and other information you provided to the Third Party Platform in connection with your account. Depending on your account and privacy settings, we may also be able to see information that you post when using these Third Party Platforms whether or not you are using our Services. The information you post or provide to Third Party Platforms, as well as the controls surrounding these disclosures are governed by the respective policies of these third parties.
- Browsing Information, Logs, Usage Data and Other Device Information: When you visit our Sites and use our Apps, we may process information about your activities on our Sites and Apps through the use of technology such as cookies, web beacons and other tracking technologies, as further explained in Sections 13 – 17 below. Providing this information is not mandatory and cookies can be disabled by clicking here Cookie Settings. However, please note that our Sites and Apps may not offer the same functionalities when certain cookies are disabled.
3. How Do We Use the Personal Data We Process?
- To fulfill our contractual obligations under an existing agreement with you to provide you with products and services you requested, or in anticipation of entering into such an agreement with you, including, without limitation:
- To complete and fulfill your hotel reservation and stay, including, processing your payment, providing you with information relating your stay, sending you booking confirmations, cancellations, modifications or pre-arrival/post-arrival messages, and providing you with other information about the area and property in which you are going to stay;
- To communicate with you about your account, transactions, applications, the Sites and the Services;
- To respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
- To administer the Capital Realty Services Card loyalty program, including sending you information about your account status and provide you with the benefits of the loyalty program;
- To manage, evaluate and administer applications you have submitted to us for membership and/or rental or purchase of real estate;
- To fulfill orders and provide you with products and services you have requested and/or paid for, including for our accounting, auditing or other internal functions, and to offer you an overview of your transactional history;
- To manage and administer your accounts, including sending you transaction-related emails for such things as account verification, purchase and billing confirmation, processing membership dues, and contacting references you provide;
- To enforce your legal rights under an agreement; and
- To provide you with an estimate for our products or services.
- To pursue our legitimate business interests, including, without limitation:
- To provide you with a more personalized level of service, including information and services related to the products and services you purchase from us, available from a trusted third party (such as on-site restaurants and spas, local attractions and transportation options);
- To manage our business needs, such as monitoring, analyzing, modifying and improving our Services’, including the Sites’, functionality and performance, including changes/updates to features of the Sites/Apps, technical and security notices;
- For the security and safety of our guests, members and visitors, and for purposes of fraud prevention, including preventing fraud and abuse on and unauthorized access to the Services and Sites;
- To provide you with information about products and services you have purchased or indicated your interest in;
- To determine which features and functionality of the Services users like best to help us operate, enhance and improve the Services, including by asking you to participate in a survey relating your use of the Services;
- To respond to any customer service requests, such as resolving your problems or responding to your questions, managing any complaints or feedback you provide;
- For statistical analysis of aggregated data to help us segmenting our offering and develop our Services;
- To better understand the way in which our Sites and Apps are working and offer you a better Site and/or App user experience, to create statistics in relation to the use of our Sites, Apps and our Services generally;
- To help us diagnose technical issues and problems related to our Services;
- To grow our business, including our portfolio of Capital Realty Services branded properties, products and services;
- To get to know our potential and existing guests, members, clients, consumers, and users; and
- To identify relevant content shared with potential and current users.
- To comply with our regulatory and legal obligations or to enforce our legal rights, including, without limitation:
- To meet reporting requirements (e.g. filing tax forms);
- To retain documents and information related to a legal action;
- To enforce the Terms of Service; and
- To report data breaches or unauthorized access to the Services.
- With your consent*, including, without limitation:
- To provide location-specific functionality, features, services or offers;
- To market to you by delivering marketing materials about our Capital Realty Services brands, products and services, as well as the products and services of unaffiliated third party businesses;
- To display online advertising and marketing information based on your use of the Services and other websites services and platforms that you have visited;
- To provide you with tailored advertisements about our Capital Realty Services portfolio of brands on third party websites, we may provide your personal information to Third Party Advertising Providers that combine such data with information collected by third-parties to send you advertisements on our Sites and third party websites, about our exclusive offers, brand news and events tailored to you and your interests;
- To provide personalized services offered by us on third-party websites and online services;
- To enable you to connect with others who use our Services; and
- For other purposes for which you may grant consent.
4. With Whom Do We Share Your Personal Data?
In connection with our global operations, we may share information we collect from you or about you with some of our affiliates, licensees and third party service providers as necessary to assist us in providing the Services to you, as set forth in more detail below:
- Our Group Entities: We may disclose your personal data to our group entities that are affiliates and/or subsidiaries or parents of Capital Realty Services in order to provide you with tailored products, services and communications.
- Service Providers: We may partner with other companies to help us operate certain aspects of our businesses, including the hosting of our Sites and Apps, operation of our technology infrastructure, processing of payments and reservations, and fulfillment certain of the services or products you request from us. We carefully select such third party operators, merchants, website hosts, service providers and participants to your transactions, including our on-property service providers, such as our spa operators, restaurants, valets and concierge services, for the purpose of (1) assisting with facilitating transactions on or through the Services, (2) providing information technology and customer service assistance, and (3) providing, offering, supporting, administering, maintaining and enabling the Services (including providing a full range of content, activities, services, features and functions offered on or in connection with the Services).
- Advertising Providers: In order to provide you with marketing and exclusive offers, including emails and advertisements tailored to you and your interests on and off the Services, we may provide your information to Third Party Advertising Providers.
- Co-Sponsors of Promotions: From time to time, we may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
- Credit Authorization: When you submit an application for the purchase or rental of real estate, or membership at one our golf courses or clubs, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining your credit worthiness and whether to approve your application.
- Corporate Transactions or Events: We may disclose your personal data in connection with a merger, sale of substantially all of our assets or stock, joint venture, transfer, corporate reorganization or other disposition of our business.
- To Fulfill Your Requests: If you elect to use certain authentication or sharing features available on the Sites or via the Services, we may use your personal data to fulfill your request to share content with or provide access to such third parties (e.g. Facebook, LinkedIn, or Twitter).
5. How Will We Protect Your Personal Data?
While no data transmission over the internet or wireless networks is 100% secure from intrusion, we maintain and have implemented reasonable physical, electronic, technical and procedural security policies and measures to protect the personal data that we process, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data. The security measures can change and be modified over time, but generally include, but are not limited to, firewalls, data encryption, physical access controls to our data centers, servers and hardware and information access authorization controls, regular testing and updating of the systems and training programs.
6. How Long Do We Keep Your Personal Data?
7. What Rights and Choices Do You Have with Regard to Your Personal Data?
If you are an EU citizen or reside in the EU, you may have certain additional rights with respect to the personal data you provided to us. To the extent permitted by applicable data protection laws, under EU laws you may:
- Access or modify your personal data;
- Object, on grounds relating to your particular situation, at any time to the processing of your personal data if the legal ground we are relying on is our legitimate interest or in the public interest;
- Request that your personal data be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal data and we meet no other legitimate basis for such processing or it has been unlawfully processed;
- Restrict the processing of your personal data if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
- Stop receiving our marketing communications. If you opt out of marketing emails, you will continue to receive messages from us about your relationship with us where permitted by law;
- Under certain circumstances, have your personal data transferred to another company; and
- Withdraw any consents that you have previously provided to allow us to process your personal data.
If you wish to exercise any of these rights please contact us at email@example.com Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority. Please note that some requests may require you to verify your identity.
How to Unsubscribe from Capital Realty Services Marketing: If you want to unsubscribe from receiving tailored advertisements on third party sites (as described in “Advertising Data” in Section 2) and/or marketing emails sent by or on behalf of Capital Realty Services, you can do so by visiting our email subscription center or by following the instructions in any such marketing email you receive from us.
How to Unsubscribe from Capital Realty Services Brands’ Marketing: If you want to unsubscribe from receiving tailored advertisements on third party sites (as described in “Advertising Data” in Section 2) and/or marketing emails sent by or on behalf of all other Capital Realty Services brands, you may unsubscribe by emailing firstname.lastname@example.org (by clicking email@example.com, an auto-filled email will be generated and you must hit “send” to submit your unsubscribe request) or by following the instructions in any such marketing email you receive from us.
How to Cancel Your Loyalty Membership: To end your Capital Realty Services membership, please email firstname.lastname@example.org.
Modifying Privacy Settings: You also may be able to adjust certain privacy, permission and user account settings under the Capital Realty Services emails subscription center, by responding to request alerts or notifications on your Device or by navigating to the settings, account or privacy section (as the case may be) of your Device or the applicable Third Party Platform and limiting certain Service functionality (e.g., location services, etc.). Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Services.
8. Will Personal Data be Transferred Outside of the European Economic Area (EEA)?
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our subsidiaries and affiliates, servers, vendors and service providers may not be located in your jurisdiction and may also be located outside of the European Economic Area and Switzerland. If you are an EU citizen or resident in the EU, we will transfer your personal data to the EU in accordance with EU data protection law requirements by using model contractual clauses that have been approved by the European Commission or other appropriate means.
Please note that such transfers may also be necessary in order to perform our obligations under a contract with you, to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining you express consent. If you make transactions with parties outside the EEA or Switzerland or connect our Service with platforms, such as Facebook, outside the EEA or Switzerland, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you. If you wish to gain more information about such transfers, please contact us at email@example.com.
9. Can Children Use Our Sites and Apps?
Our Sites and our Apps are not directed to children under the age of majority. We do not knowingly collect information via our Sites and Apps from children or other individuals who are not legally able to use our Sites and/or our Apps. If we obtain actual knowledge that we have collected personal data from someone under the age of majority, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the age of majority, please contact us at firstname.lastname@example.org. For users in the United States, please also visit ftc.gov for information from the Federal Trade Commission about protecting children’s privacy online.
10. What Are My California Privacy Rights?
If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as “unsubscribe”), as described in Section 7, or opt-in for use of your information by third parties (such as advertisers) for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your information for marketing purposes during the preceding year. If you are a California resident and you wish to request information about how to exercise your third party disclosure choices, please submit your request at email@example.com or by postal mail to Capital Realty Services, c/o Privacy Administrator, Avenida de las Naciones Unidas Centro Comercial Cristamar, Local 37 Puerto Banús, Marbella, 29660 Málaga, Spain . All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. You can always opt-out or unsubscribe by emailing firstname.lastname@example.org.
11. What Other Information Should You Know?
12. How Can You Contact Us?
By Email: email@example.com
Avenida de las Naciones Unidas
Centro Comercial Cristamar