In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), we hereby inform you about the processing of your personal data by Calido Living.
This policy applies differently depending on the stage of your relationship with Calido Living. If you are not yet a guest or customer of ours and are simply exploring our services via the website (for example, via a contact form, a quote request or a visit request), please refer to Section 1. If you are already a guest or customer of ours, with a valid booking or accommodation contract, please refer to Section 2, which governs the processing of your data throughout your stay.
SECTION 1 – IF YOU ARE NOT YET ONE OF OUR GUESTS (WEBSITE USER)
This section governs the processing of personal data of individuals who visit the Calido Living website, fill in a contact or quote form, request a viewing of a property or subscribe to our communications, without there yet being a contractual accommodation relationship.
Data controller
The data controller for the personal data collected via the website is Flexible Living Innovative Ventures, S.L. (FLIV), with tax identification number (NIF) B10702264 and registered office at C/ Alfonso XII, 32, 1st floor, 28014 Madrid.
If your enquiry relates specifically to a particular Calido Living building or residence (for example, a request for a viewing or a quote for that building), the company that owns that building may act as a joint data controller alongside FLIV, in accordance with the terms set out in Section 2 of this policy.
Retention periods
Data will be retained in accordance with the following criteria, depending on the purpose of the processing:
(i) Enquiries, requests for quotations and requests for viewings: your data will be retained whilst the enquiry or request is being processed by and, once resolved, for a further period of two years from your last interaction with Calido Living, in order to properly handle any new enquiries or requests you may make in the future. Once this period has elapsed without any further interaction, Calido Living will delete your contact details.
(ii) Marketing communications: your data will be retained until you withdraw your consent or request to unsubscribe from the service. You may do so at any time by sending an email to dpo@calido-living.com or via the link provided in each communication.
(iii) Cookies and similar technologies: the information will be retained for as long as the consent you have given remains valid or for the duration of the cookies installed. You can manage your preferences in our Cookies Policy.
Recipients
Your data may be disclosed to technology providers (web hosting, maintenance and analytics), messaging and email service providers, social media platforms (when you interact with our profiles) and, in the case of enquiries relating to a specific building, to the company that owns that building.
No international data transfers take place outside the European Economic Area unless the provider offers adequate safeguards in accordance with the GDPR, in which case the user will be informed.
Purposes of processing, categories of data and legal basis
The data processed in this section is obtained directly from the data subject via the forms on the website. The purposes of processing, the categories of data processed and the applicable legal basis are set out below:
|
Purpose |
Categories of data |
Legal basis |
|---|---|---|
|
To manage and respond to enquiries; to prepare quotations; to manage requests for visits |
Identification and contact details (first name, surname, email address, telephone number); details relating to the enquiry or request; accommodation preference details |
Legitimate interest (Article 6(1)(f) of the GDPR) / Pre-contractual measures (Article 6(1)(b) of the GDPR) |
|
Sending of marketing communications |
Identification and contact details (first name, surname, email address, telephone number) |
Consent (Article 6(1)(a) of the GDPR) |
|
Management of the use of cookies and similar technologies in accordance with the Cookies Policy |
Browsing data and cookies (IP address, device identifiers, preferences) |
Consent for non-essential cookies (Article 6(1)(a) of the GDPR); legitimate interest for strictly necessary cookies (Article 6(1)(f) of the GDPR) |
Security measures
Calido Living has implemented appropriate technical and organisational measures to ensure the confidentiality, integrity, availability and resilience of the personal data processed via the website, taking into account the state of the art, the costs, the nature and the risks of the processing.
Data subjects’ rights
You may exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability by contacting FLIV via email at dpo@calido-living.com or in writing to C/ Alfonso XII, 32, 1st floor, 28014 Madrid. Your request will be dealt with within a maximum of one month, which may be extended by a further two months in the event of complexity or a high volume of requests (Article 12.3. of the GDPR).
If you consider that your rights have not been properly addressed, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
SECTION 2 – IF YOU ARE ALREADY A GUEST OR CUSTOMER OF OURS
This section governs the processing of personal data of individuals who already have, or have entered into, a contractual accommodation relationship with Calido Living, from the time the booking is made until the end of the stay. If your data stems from an enquiry, quote or request for a viewing previously made via the website, such data was initially processed in accordance with Section 1 of this policy and will be processed in accordance with this Section 2 from the moment you confirm your booking or accommodation contract.
Data controller
The company that owns the building in which you have made your accommodation booking is the data controller for your personal data. Depending on the building, this company is one of the following:
All of these companies have their registered office at C/ Alfonso XII, 32, 1st floor, 28014 Madrid.
For the provision of the accommodation service, we rely on Dazia Capital Specialist, S.L., which acts as a joint data controller alongside the company that owns the building, particularly in relation to the operational management of the booking and the stay.
Recipients
Your data may be disclosed to: law enforcement agencies and competent authorities (guest registers or criminal incidents captured by CCTV); banks and financial institutions (management of collections and payments); providers of hotel management systems (PMS), booking platforms and operational management technology tools; providers of maintenance, cleaning, security and building management services; and other companies within the Calido Living group.
No international data transfers are made outside the European Economic Area unless the relevant supplier provides adequate safeguards in accordance with the GDPR, in which case the guest will be specifically informed.
Retention periods
Your data will be retained for the duration of the contractual relationship and, once this has ended, for a further period of five years from the end contract, during which time any claims arising from that contract may be brought. CCTV footage will be retained for a maximum of one month, unless it needs to be retained to provide evidence of acts that threaten the safety of persons, property or facilities, in which case it will be made available to the competent authority within the legally established timeframe. Data provided to the authorities via the passenger register will be retained for three years from the end of the service, in accordance with the applicable regulations on the documentary registration of passengers.
Purposes of processing, categories of data and legal basis
The data processed in this section is obtained directly from you, except for images captured by the video surveillance system. The purposes of processing, the categories of data processed and the applicable legal basis are set out below:
|
Purpose |
Categories of data |
Legal basis |
|---|---|---|
|
Management of the booking, conclusion of the contract and pre-arrival communications (including details of dependent minors) |
Identification and contact details (first name, surname, email address, telephone number, address, identity document); details identifying dependent minors; details relating to the booking (dates, type of accommodation) |
Performance of the contract (Article 6(1)(b) of the GDPR) |
|
Registration of travellers with the relevant authorities |
Travellers’ registration details (first name, surname, gender, date of birth, nationality, identity document, usual place of residence, telephone number, email address, total number of travellers, relationship to minors) |
Compliance with a legal obligation (Article 6(1)(c) of the GDPR; Royal Decree 933/2021) |
|
Management of the stay, services (cleaning, parking), invoicing, payments and complaints |
Booking and stay details (dates, type of accommodation, services booked); financial and banking details (payment details, invoicing); vehicle registration number (if parking is booked) |
Performance of the contract (Article 6(1)(b) of the GDPR) |
|
Building security via CCTV |
Images captured by CCTV |
Legitimate interest (Article 6(1)(f) of the GDPR; Article 22 of the LOPDGDD) |
|
Access control and visitor registration for guests |
Visitors’ identifying details (first name, surname, identity document, date and time of access) |
Legitimate interest (Article 6(1)(f) of the GDPR) |
|
Events and social activities; recording of images and/or voice (subject to prior consent) |
Event participation data (first name, surname, image and/or voice) |
Consent (Article 6(1)(a) of the GDPR) |
|
Management of breaches of the Internal Regulations; notification to the Calido Living group; refusal of admission or continued membership |
Identification and contact details; reason for the breach |
Performance of the contract (Article 6(1)(b) of the GDPR) / Legitimate interest (Article 6(1)(f) of the GDPR) |
Rights of data subjects
You may exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability by contacting the company that owns the building in which you reside, via email atdpo@calido-living.com or in writing to C/ Alfonso XII, 32, 1st floor, 28014 Madrid. Your request will be dealt with within a maximum of one month, which may be extended by a further two months in the event of complexity or a high volume of requests (Article 12.3 of the GDPR).
If you consider that your rights have not been properly addressed, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
Security measures
Calido Living has implemented appropriate technical and organisational measures to ensure the confidentiality, integrity, availability and resilience of the personal data processed within the framework of the activities described in both sections of this policy, taking into account the state of the art, the costs, the nature and the risks of the processing.
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