Respecting the provisions of current legislation, San Sebastian Suites (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
The person responsible for the processing of personal data collected at San Sebastian Suites es: Gember Inversiones S.L., provided with NIF/CIF: B30787485 and registered in: with the following registration data: whose representative is: Bernardino Garcia Garcia (hereinafter, Data Controller). Its contact details are as follows:
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal information collected by San Sebastian Suites, by means of the forms extended in its pages will be incorporated and will be treated in our file with the purpose of facilitating, expediting and fulfilling the commitments established between San Sebastian Suites and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query from the User. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD applies, a record of processing activities is kept that specifies, according to their purposes, the processing activities carried out and other circumstances established in the RGPD.
The processing of the User’s personal data shall be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
The categories of data processed in San Sebastian Suites are solely identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.
The legal basis for the processing of personal data is consent. San Sebastian Suites undertakes to obtain the express and verifiable consent of the User for the processing of his personal data for one or more specific purposes.
The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.
In the occasions in which the User must or may provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.
Personal data are collected and managed by San Sebastian Suites in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or inquiry.
Likewise, the data may be used for commercial purposes of personalization, operational and statistical purposes, and for activities related to the corporate purpose of San Sebastian Suites, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.
At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the information collected.
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 12 months, or until the User requests their deletion.
At the time the personal data is obtained, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.
The User’s personal data will not be shared with third parties.
In any case, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.
Respecting the provisions of Articles 8 of the GDPR and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by San Sebastian Suites. In the case of a minor under 14 years of age, the consent of the parents or guardians is required for the processing, and the processing will only be considered lawful to the extent that the parents or guardians have authorized it.
San Sebastian Suites undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
The Web Site has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.
However, because San Sebastian Suites cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.
The User has about San Sebastian Suites and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
Right of deletion («the right to be forgotten»): This is the User’s right, unless otherwise provided for by the legislation in force, to obtain the erasure of his or her personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the deletion of any link to such personal data.
Thus, the User may exercise his/her rights by writing to the Data Controller with the reference «RGPD»-https://sansebastiansuites.com/en«, specifying:
This application and any attachments may be sent to the following address and/or e-mail address:
The Web Site may include hyperlinks or links that allow access to third party web pages other than San Sebastian Suites, and are therefore not operated by San Sebastian Suites.The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).