Privacy Policy

1. DATA PROCESSING

How do we process your personal data?

– In accordance with Regulation (EU) 2016/679 and the Spanish Organic Law on Personal Data Protection, we inform you that your personal data may be subject to some of the following processing activities:

  • TR04 – Advertising campaigns (Legal basis: Law 34/1988 of 11 November, the General Advertising Law.)
  • TR08 – Obtaining feedback from data subjects (Legal basis: Regulation (EU) 2016/679 on data protection and the LOPD.)
  • TR03 – Recruitment of our own staff (Legal basis: Royal Legislative Decree 3/2015 of 23 October, approving the consolidated text of the Employment Law.)
  • TG01 – Our own accounting and bookkeeping, as data controller. (Legal basis: Royal Decree 1514/2007 of 16 November, governing the General Accounting Plan.)
  • TG25 – Collection of data for our own tax management (Legal basis: Law 58/2003 of 17 December, the General Tax Law.)
  • TG12 – Our own employment administration: data collection (Legal basis: Royal Legislative Decree 1/1994 of 20 June, approving the consolidated text of the General Social Security Law.)
  • TR09 – Safeguards concerning technical and organisational measures in the software used (Legal basis: Regulation (EU) 2016/679 on data protection and the LOPD.)
  • TE08 – Personal Data Protection (Legal basis: Regulation (EU) 2016/679 and Organic Law 3/2018.)
  • TE02 – Prevention of occupational risks (Legal basis: Law 31/1995 of 8 November on the Prevention of Occupational Risks.)
  • TE07 – Document destruction (Legal basis: Regulation (EU) 2016/679)
  • TV01 – Sales / Provision of Services (Legal basis: Commercial and Tax Legislation)
  • TE03 – Transport and/or parcel delivery service (Legal basis: Royal Decree of 22 August 1885 publishing the Commercial Code.)
  • TR05 – Emails (Legal basis: Commercial Code and other applicable legislation.)
  • TR01 – Information requests received (Legal basis: Commercial Code and other commercial provisions.)
  • TR07 – Management of incidents and/or security breaches (Legal basis: Regulation (EU) 2016/679 on data protection and the LOPD.)
  • TE04 – Management of our own legal matters (Legal basis: Applicable commercial and employment legislation.) TE01 – Maintenance of IT systems (Legal basis: Commercial Code.)

2. DATA CONTROLLER

Who are we?

– We are the controller responsible for processing your data. We therefore expressly, precisely and unambiguously inform both data subjects and the competent authorities of the following details concerning the data controller:

  • RODA GOLF COURSE, S.L. B73413981
  • CRTA F27 SAN CAYETANO-LOS NAREJOS S/N URB. RODA GOLF & BEACH RESORT SAN JAVIER
  • 30739
  • MURCIA
  • agalindo@calidonaresorts.com

3. PURPOSES

What do we use your personal data for?

– In this organisation, we may process your personal data exclusively for the purposes listed below:

  • To check that all technical measures necessary for the proper management of personal data are being implemented in the software used.
  • To send commercial and/or advertising information by email.
  • To manage information requests received from data subjects about our products or services. To manage exclusively internal incidents detected in complying with GDPR requirements. To conduct advertising campaigns promoting our services and/or products.
  • To obtain feedback from data subjects.
  • To recruit staff to fill the necessary job vacancies.
  • To comply with all requirements of the Law on the Prevention of Occupational Risks. To send parcels and correspondence.
  • To manage any legal matters affecting the company. To manage, maintain and repair IT storage systems. To carry out our own employment administration.
  • To carry out our own tax and accounting management.
  • To comply with the principle of limiting the retention period for personal data.
  • To comply with the requirements of Regulation (EU) 2016/679 and Organic Law 3/2018. Administrative management of individual customers.
  • To carry out the sale or provide the contracted service.
  • A commercial or user profile may be created based on information provided or obtained. We expressly inform you that profiles will never be created using the data of a minor.
  • The personal data you provide will be retained for the duration of the contractual relationship or, where applicable, until you exercise your right to object or withdraw your consent. To do so, you may visit the relevant section of our website or send an email to the address indicated in the section concerning the data controller.

4. LEGAL BASIS

Why do we use it? We are entitled to process your personal data for the following reasons:

  • Your unambiguous, informed and express consent, where legally required. Withdrawing this consent will not affect other processing carried out on a different legal basis, nor will it affect the lawfulness of processing carried out before its withdrawal.
  • A legal obligation of the data controller.
  • Performance of the contract for services and/or the sale of the relevant products entered into by you.
  • The legal basis for processing your data is a legitimate interest of the controller. This interest is supported by a prior proportionality assessment or balancing test between the controller’s legitimate interest and the interests or rights and freedoms of data subjects. This assessment has involved evaluating the interest, evaluating the impact of processing on data subjects, balancing these two considerations and implementing additional safeguards. As the final assessment favours the controller, processing may take place in accordance with applicable personal data protection legislation. For any questions or clarification, please contact us using the email address provided in the section concerning the data controller.

5. RECIPIENTS

Who may we share your personal data with?

  • Your personal data will be disclosed to the following companies and organisations:
  • Spanish Tax Agency
  • State Public Employment Service
  • General Treasury of Social Security
  • National Data Protection Agency
  • Banks and savings banks
  • Your personal data will not be transferred to any third country or international organisation.

6. SOURCES

What data do we process and how have we obtained it?

Your personal data will be included in the following files owned by the organisation: FG01 Our own accounting management

  • FG02 Our own employment administration
  • FG15 Our own tax management. Data collection
  • FE01 IT maintenance
  • FE02 Prevention of occupational risks
  • FE03 Transport and shipping
  • FE04 Our own legal matters
  • FR01 Information requests received FR03 Recruitment of our own staff
  • FR04 Advertising campaigns
  • FR05 Emails
  • FR07 Management of incidents and/or security breaches
  • FR08 Obtaining feedback from data subjects
  • FR09 Software and hardware security
  • FE07 Document destruction
  • FE08 Personal Data Protection
  • FP01 Customers
  • The personal data processed by our organisation comes from the following sources: The data subject themselves

7. RIGHTS

What rights can you exercise?
We guarantee the exercise of your rights in relation to the processing of your personal data.

In particular, we inform you that you have the right to:

  • ·Obtain confirmation as to whether your data is being processed.
  • ·Exercise your right of access to the personal data we hold, obtaining information about the purposes of processing, the categories of data processed, potential recipients, retention periods, the source of the data and, where applicable, profiling or automated decision-making.
  • ·Exercise your right to rectification. Please remember that the personal data we hold must always accurately reflect the facts, so do not hesitate to exercise this right if any data is amended, changed or cancelled. You guarantee that the personal data you have provided to us by any means is true and accurate, and you undertake to notify us of any changes or amendments. You are solely responsible for any loss or damage caused to the controller or any third party by communicating incorrect, inaccurate or incomplete information.
  • ·On grounds relating to your particular situation, you may object to the processing of your data. In that case, our organisation will stop processing it unless there are legitimate grounds preventing this.
  • ·Request the erasure of your personal data when, among other reasons, it is no longer necessary for the purposes described above or we no longer have a legal basis for processing it.
  • ·Request portability of your data where processing is carried out by automated means and you have a contractual relationship with our organisation or have given consent for the processing. In these cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format, or to have it transmitted directly to another controller where technically feasible.
  • ·In certain circumstances, you may request restriction of the processing of your data. In that case, we will retain it only for the establishment, exercise or defence of legal claims.
  • ·Object to automated decision-making, including profiling.
  • These rights may be exercised free of charge, except where the law provides otherwise, by submitting a written request signed by you or, where applicable, your representative, addressed to the controller at the addresses provided for this purpose in the first section, or in person at any of our premises.
  • You also have the right to lodge complaints with the Spanish Data Protection Agency (at https://www.agpd.es/) or with the relevant supervisory authority.
  • You may also bring a claim for compensation before the courts.
  • Finally, you have the right to withdraw your consent as easily as you gave it. To do so, visit our website, where you will find the information needed to quickly and easily withdraw the authorisation you have given us to send these communications. You may also send an email to the address indicated in the section concerning the controller.
  • We also inform you that, for each processing activity involving your personal data, we identify potential threats and their possible impact. We mitigate or, where possible, eliminate potential harm by implementing appropriate security measures, which are periodically reviewed to assess their effectiveness.

Our control system also enables us to comply with the principles governing the processing of your data and to demonstrate to data subjects compliance with purpose limitation, storage limitation, data minimisation, and integrity and confidentiality.

Lastly, we inform you that you will periodically receive surveys enabling us to obtain your views on any suggestions concerning the processing of your personal data and to comply with the principles of transparency and accuracy of the data processed.

For any questions or clarification, please contact us using the email address provided in the first section.

Yours faithfully,

The Data Controller.