Privacy Policy
PRIVACY POLICY
Last modified: June 30, 2021.
This privacy policy applies to data processing carried out by Smy Hotels. Please read it carefully, in it you will find important information about the processing of your personal data and the rights recognised by current regulations on the matter.
We reserve the right to update our privacy policy at any time due to business decisions, as well as to comply with any legislative or jurisprudential changes. If you have questions or need any clarification regarding our Privacy Policy or your rights, you can contact us through the channels indicated below.
You declare that the data you provide us, now or in the future, are correct and truthful and you agree to communicate any modification thereof. In case of providing personal data of third parties, it undertakes to obtain the prior consent of those affected and to inform them about the content of this policy.
In general, the fields of our forms that are indicated as mandatory, must necessarily be completed in order to process your requests.
Who is responsible for the processing of your data?
Unless specifically indicated otherwise, the person responsible for the processing of the data collected on the website www.smyhotels.com (hereinafter the "Web") is the entity Hotelogy S.L., with address in Ed. LOGITRAVEL, Parc Bit, 07121, Palma de Mallorca, Spain, and provided with NIF B57964629 (hereinafter Smy Hotels). You can contact the Smy Hotels Data Protection Officer at privacy@smyhotels.com.
What will we process your data for and on what legal basis?
Management of reservations and provision of the requested services. The data provided in your reservation requests or services will be processed for the management of such reservations and the provision of the requested services. The categories of data we process for these purposes are as follows:
Identification and contact data of the reservation holder;
Data of the reservation itself (dates of stay, number and age of guests and services included in the reservation).
Economic and transaction data.
The processing of this data is necessary for the provision of the requested services, the execution of the hosting contract or for the application of pre-contractual measures at your own request.
The economic data and transactions of goods and services will be processed for the purposes of accounting and administrative management and compliance with our legal obligations in accounting and tax matters.
Online check-in. In compliance with the Convention implementing the Schengen Agreement and the 4/2015 Organic Law, of March 30, on the protection of citizen security, hotels have the obligation to register the information of all guests who stay in them. This information, which is recorded in an entry report and serves to establish a passenger record book, consists of the following data: Name and surname, gender, date of birth, country of nationality, number and type of identity document, date of issue of the document, check-in date and signature.
The data provided in the online check-in form will be communicated to the destination hotel. The on-line check-in functionality allows you to pre-fill in the check-in report to expedite your check-in at the time of your arrival at the hotel. The use of online check-in is optional and does not condition your entry into the hotel. If you do not use this feature, you must complete the check-in form at the time of arrival.
The processing of the information necessary to pre-complete the check in report is based on the consent materialised through the use of this functionality.
Likewise, the photo you have provided for the online check-in will be registered in the hotel management system of the destination hotel. The purpose is to allow the hotel staff to identify you as en in-house guest and control the charge of the consumption you make during your stay in your room. This photo will be deleted at the time of check-out.
This processing is based on the legitimate interest of the hotel in identifying the guests staying for security and charge control purposes. For the weighing of this interest with respect to your rights and freedoms, it has been determined that the treatment had a limited impact on your privacy, since:
There is a contractual relationship and the processing is carried out in connection with that relationship;
This security measure benefits the guests themselves by ensuring the correct imputation of charges to their room and avoiding possible impersonation;
Access to your picture is restricted to hotel staff;
The period of conservation of your picture is limited to the time of your stay.
Attention to queries and complaints. The data provided in your queries or claims will be processed to meet your requests and manage any complaints. This processing is necessary for the execution of a contract, the application of pre-contractual measures to your own request or the defence against customer claims.
The processing of any health data that you have provided in your claim is covered by art. 9.2. f) of the RGPD, as such treatment is necessary for the formulation, exercise or defence of claims.
Statistical and quality management purposes: In order to evaluate and manage the quality of our services and products, we make statistics from aggregated data obtained from transaction data and web browsing data, e.g. IP address, weblogs, pages visited or actions taken on the Web (+ info in our cookies policy).
We also make anonymous statistics from aggregated booking data to measure the performance of our products.
These treatments are based on our legitimate interest to evaluate and manage the quality of our services and products. For the weighing of this interest with respect to their rights and freedoms, it has been determined that the treatment had a limited impact on the privacy of the interested parties, as it corresponded to their reasonable expectations and did not pose significant threats as they were based on aggregated data and with the consent of the interested parties regarding the metrics made with the use of cookies.
Sending personalised sales communications: If you have consented to receive our sales communications, your identification and contact data will be processed to send you personalised advertising related to the Smy Hotels chain and the hotels within its portfolio.
For the personalisation of our communications we elaborate a sales profile based on your reservation history (dates of expired stays, number and age of guests, services included in the reservations and amounts), for example, to determine the periods of the year in which you have stayed or usually stay in our properties or the type of product likely to be of interest taking into account your past reservations (for example products aimed at family holidays, if you have travelled as a family).
If you have authorised the use of advertising cookies, we will also use the information generated by your browsing on the Web (IP address, pages visited, products viewed and actions taken) to make sales contacts and offer you products similar to those you have consulted on the Web.
The sending of personalised advertising is based on the consent you have given. Not giving or withdrawing your consent does not condition access to the Web or the provision of the requested services.
At any time, you can revoke your consent and request your withdrawal from the treatments for sales purposes. To this end, you can:
Send an email to the following email address: privacy@smyhotels.com
Use the link provided for this purpose in our newsletters
You can also revoke the consent you have given for the use of advertising cookies at any time by means of the set up panel of the website or the modification of the privacy options of your web browser or your terminal. + info about the use of cookies and similar technologies in our cookie policy.
We do not make automated individualised decisions that produce legal effects on our customers or similarly significantly affect them based on this profile. However, we inform you that you have the right to object to the adoption of automated individual decisions, when this right is fulfilled in accordance with the provisions of Article 22 of Regulation (EU) 2016/679.
Smy Club loyalty programme. The Smy Club programme rewards our customers with a number of advantages, including the submission of personalised early bird offers and discounts based on their booking history. You can consult more information about the content and operation of the programme under the conditions applicable to it in INDICATE
Your participation in the programme involves the following data processing:
We will process the identification data of the members of the programme in order to identify them as such in order to apply the advantages to which they are entitled.
We prepare a sales profile based on your booking history (dates of expired stays, number and age of guests, services included in the reservations and amounts) to personalise our offers according to your consumption profile, for example, to determine the periods of the year in which you have stayed or usually stay in our properties or the type of product likely to interest you taking into account your past reservations (for example products aimed at family holidays, if you have travelled as a family). This profile is also used to apply special discounts to you based on the frequency of your bookings, the products contracted and the amounts spent. We do not make automated individualised decisions that produce legal effects on our customers or similarly significantly affect them based on this profile. However, we inform you that you have the right to object to the adoption of automated individual decisions, when this right is fulfilled in accordance with the provisions of Article 22 of Regulation (EU) 2016/679
These treatments constitute the very purpose of the programme and are necessary for its operation These treatments are based on the contractual relationship originated by your request to register in the programme. At any time you can request your withdrawal from the programme by sending an email to privacy@smyhotels.com.
To whom can we communicate your data?
In general, we will communicate your data or those of the guests included in the reservations by legal obligation, with your consent or when necessary for the correct processing of the reservation or the provision of the requested services. Specifically:
We will communicate the reservation details to the destination hotel. The hotel will communicate the check in reports of guests to the State Security Forces and Bodies in compliance with the regulations of control of travellers and citizen security.
In the event that your reservation contains additional services provided by third party suppliers or that your requests affect such services, the personal data necessary for the processing of said reservation / request for availability, will be communicated to the corresponding suppliers, only for this purpose. In the same way, when they are necessary for their resolution, we will transfer your claims to the service providers affected by them. Likewise, depending on the nature of your claim, the recipients of the data included in it may be, among others, administrations or public entities, official bodies, attorneys, judges and courts or insurance entities. These communications are necessary either for the provision of the contracted services or for the application of pre-contractual measures at your own request, or for the formulation, exercise or defence of claims.
How long will we keep your data?
Without prejudice to the specific retention periods indicated in the previous sections, in general we keep your data during the validity of the relationship you have with us and, in any case, during the periods provided for in the applicable legal provisions. For example, in accounting and tax matters, and for the time necessary to attend to possible responsibilities arising from the treatment. We will cancel your data when they are no longer necessary or relevant for the purposes for which they were collected.
Data processed for sales purposes, including sales profiles, will be kept active as long as you do not object to the processing or request its deletion.
The commercial profiles and booking history of the members of our loyalty programme will be kept as long as they do not request their withdrawal from said programme.
The expiration periods of the cookies used on this website are indicated in our cookies policy.
What are your rights?
You have the right to obtain confirmation of whether or not we are processing your personal data and, if so, access it. You can also request that your data be rectified when they are inaccurate or that the data that is incomplete be completed, as well as request its deletion when, among other reasons, the data is no longer necessary for the purposes for which they were collected.
In certain circumstances, you may request the limitation of the processing of your data. In such a case, we will only process the data concerned for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions and for reasons related to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims.
Likewise, and under certain conditions, you can request the portability of your data so that they can be transmitted to another person responsible for the treatment.
You can revoke the consent you have given for certain purposes, without affecting the legality of the treatment based on the consent prior to its withdrawal.
You also have the right to object to the adoption of automated individual decisions that produce legal effects on you or similarly significantly affect you, where this right is fulfilled in accordance with Article 22 of Regulation (EU) 2016/679.
You also have the right to lodge a complaint with a data protection authority. You can consult the list and contact details of European data protection agencies on the European Commission's website in http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
To exercise your rights, you must send us a request by post or email at the addresses indicated in the section Who is responsible for the processing of your data?
Who is responsible for the processing of your data?
You can obtain more information about your rights and how to exercise them on the page of the Spanish Agency for Data Protection in www.aepd.es or on the site of the data protection authority of your country.