Privacy Policy
Introduction
Last Updated: May 2018
Welcome to the Javearentals Sanders Mediterraneo SL privacy notice.
Sanders Mediterraneo SL respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1) Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Sanders Mediterraneo SL collects and processes your personal data through your use of this website, including any data you may provide through this website when you enquire about the availability of a property, sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller Sanders Mediterraneo SL is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Our full details are: Sanders Mediterraneo SL, Avenida Del Pla 135, Cabo La Nao, Javea, 03730, Alicante. tel 0034 965794059 Cif number B53634770 Full name of legal entity: Sanders Mediterraneo SL
Name or title of data privacy manager: Data Privacy Manager
Email address [email protected]
Postal address: Javearentals Sanders Mediterraneo SL, Avenida Del Pla 135, Cabo La Nao, Javea, 03730, Alicante.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the date set out at the top of this document and historic versions can be obtained by contacting us
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2) The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, depending on who you are, which we have grouped together as follows:
Contact Data includes billing address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, comments and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
The data that we collect about you may differ depending on your relationship with us and how you use the Javearentals website. We have set out below the different relationships we have with users of our website and the data we collect in relation to those people, for example:
Holidaymaker: Person(s) using the Javearentals.com website to find holiday accommodation. Holidaymakers can make booking enquiries through the site, or by phoning the Property Owner / Manager directly using the details found on our publicly available listing pages. Enquiry details are stored securely on the Javearentals server, in line with our data retention policy, and are only available to the relevant Property Owner / Manager and ourselves.
Owner: Owner of a holiday property or their manager or agent or other person responsible for the letting of the advertised holiday property. We do not get involved in the booking process, so all information provided by a Holidaymaker when making a booking enquiry is made available to the Property Owner / Manager.
Site Visitor: can include either Owner or Holidaymaker. The term “Site Visitor” is used where a particular point applies to Holidaymakers, Owners or any other website visitor, whatever their reason for using the site. For example reading our blog, or conducting research.
Summary of Key data captured about users of the Website:
Data Subject: Owner (Property Owner / Manager)
| Data Item | What we use it for |
| Allowing Holidaymakers and us to contact Owners about booking enquiries / bookings. | |
| Name | For correspondence purposes and is displayed on each property advert. |
| Address | So we can contact owners with matters relating to their account. For internal use only. |
| Phone No. | Displayed on advert (unless requested otherwise) so that Holidaymakers can contact Property Owners / Managers with specific questions about a property. |
| Mobile Phone No. | Used by us as an alternative, secure, means of correspondence. For internal use only but can be displayed on advert at Owners request. |
| Account and Payment | We also process (securely) various other forms of data in order to fulfil our contractual advertising obligations and provide our service to Owners. These include (but are not limited to) invoice details, summaries of payments made to us, renewal dates and necessary account details as reasonably required in order to keep Owners’ accounts secure and up-to-date. |
| Personal verification documents | All our advertisers are 100% verified via our own internal verification methods. As part of this process, it may be necessary to request documents such as utility bills and / or other forms of identification. No such data is retained for more than 7 days unless we have a very good reason for keeping it for longer. |
| Details of the property to be advertised | Required as part of advertising contract. |
| Availability Calendar | Dates of holiday bookings held in order to calculate and show availability calendar for each property. |
| Images/ property photos | To showcase Owners’ properties.
Owners should ensure that any personal data contained within such photos (including, but not limited to Guestbook photos) is blurred out unless they are happy for that personal data to be made public, or have the express consent of the Holidaymaker or guest concerned. |
Data Subject: Holidaymaker* (enquirers / people looking to rent holiday accommodation)
| Data Item | What we use it for |
| Name | Required so Owners and us know who is making the booking. |
| Required so Owners can communicate with Holidaymakers about the Booking Enquiry and to send Holidaymaker confirmations as necessary. | |
| Phone Number | To contact Holidaymakers regarding their booking enquiry / booking. Also used as an emergency contact in case of unforeseen issues with the booking or a need to contact the Holidaymaker with other urgent matters. |
| Date of trip / duration | Necessary to fulfil the booking request and provide availability and pricing confirmation. |
| Address | Necessary to fulfil the booking request and used for correspondence. May also be used for emergency contact in case of unforeseen issues with the booking. |
| Party size | No. of Adults, Children, Pets. This is used by the owner to calculate price and determine guest / property suitability. |
| Requirements | Optional – General questions that the Holidaymaker might have. This may supplement other data items (above) where requirements are vague or as yet unknown, such as travel dates or party size.
Holidaymakers are advised to consider the amount of personal data they are willing to divulge to an (as yet) unknown party i.e. the Owner. Owners may also further add to these notes in order to fulfil specific Holidaymaker requests. For example: making extra beds available or late / early check in / check out information. |
| Uploaded photos / user generated content | We might give Holidaymakers the opportunity to upload photos of their trip and the property visited or make comments about them.
Holidaymakers should ensure that any personal data contained within such photos is blurred out unless you are happy for that personal data to be made public, the same goes for your feedback and comments as you may be posting them onto a public forum for the world to see. |
*The data items (above) can only be accessed by ourselves, or the relevant Property Owner / Manager where a booking enquiry / booking has been made by a Holidaymaker. We Do Not store credit card details.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3) How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(a) Submit queries or make booking enquiries / bookings via the website;
(b) create an account on our website;
(c) subscribe to our service or publications;
(d) request marketing to be sent to you;
(e) enter a competition, promotion or survey; or
(f) give us some feedback or leave a review.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- a) analytics providers such as Google and Facebook based both inside and outside the EU;
Owners/ Holidaymakers may send us information regarding bookings if they use our services to manage their bookings. We may also receive feedback from Owners and Holidaymakers about their experiences.
4) How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- a) Where we need to perform the contract we are about to enter into or have entered into with you.
- b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- c) Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message or where we need to process a special category of your personal data. You have the right to withdraw consent to marketing at any time by contacting us
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new Property Owner or Holidaymaker | (a) Identity
(b) Contact |
Performance of a contract with you or with a view to entering into a contract with you |
| To process and deliver your booking enquiries or other services that we offer including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Transaction (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send you marketing that is relevant to the nature of our relationship with you. If you are a Holidaymaker seeking accommodation, we may send you details of other properties that we have available. If you are a Property Owner, we may send you details regarding our advertising services. We will not send you marketing from any other third parties or for any other reason or purpose that is not related to the services we provide. Because you have either made a booking enquiry via the site, registered with us and or purchased services using our systems, we believe that it is in both of our legitimate interests to send you details of our products and services and make you aware of offers or promotions that we run. If you find this annoying or no longer relevant to you, you are able to opt-out of receiving marketing from us at any time. This can be done by either contacting us or unsubscribing by clicking the link in our emails to you.
The GDPR doesn’t require your consent for this, because you will only get marketing in line with our services. That means we don’t send you third party marketing, see below to read more about third-party marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Sanders Mediterraneo SL group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a booking enquiry or product / service purchase or , warranty registration, product/service experience or other transactions and we may continue to contact you in relation to these issues.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We use “session” cookies to track what you are searching for whilst you are using the website. Those cookies are then deleted when you close your web browser.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5) Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- a) Internal Third Parties as set out in the Glossary.
- b) External Third Parties as set out in the Glossary.
- c) Specific third parties listed in the table in paragraph 4 above.
- d) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6) International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7) Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8) Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Specific details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9) Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (the Glossary) for details of these rights and what they mean for you.
If you wish to exercise any of the rights set out above, please contact us
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated, but we may need a further two months to process your request.
10) Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
We don’t have any other group members, but Sanders Mediterraneo SL is the company name for the business trading as “Javearentals”.
External Third Parties
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Spain who provide consultancy, banking, legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
