Vacation Care International Espana SA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we use and look after your personal data when you visit our website and when we provide our services to you, regardless of where you visit from, and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how Vacation Care International Espana SL collects and processes your personal data through all your engagements with us, when using our services, and use of this website, including any data you may provide when you sign up to our services, our newsletters or request information about other services from Vacation Care International Espana SL.
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.
Vacation Care International Espana SL is the controller and responsible for your personal data (collectively referred to as “Vacation Care International Espana SL”, “Vacation Care International Espana SL”, “we”, “us” or “our”, in this privacy notice). Vacation Care International Espana SL is a data processor for Rancho Club and Aloha Gardens. Vacation Care International Ltd is a data processor for Crown Points Club and CRHPC.
We have appointed a Data Protection Lead 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 (including an opt-out mentioned in this privacy notice), please contact the Data Protection Lead using the details set out below.
Data Protection Lead
Vacation Care International Espana SL, Aloha Gardens Reception, Urb. Aloha Gardens, Avda Del Prado s/n, Nueva Andalucia, 29660, Malaga Spain.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or the Spanish data protection authority (Agencia Española de Protección de Datos (AEPD)), We would, however, appreciate the chance to deal with your concerns before you approach the ICO or AEPD so please contact us in the first instance.
This version was last updated on 14th September 2020 and previous versions can be obtained by contacting us.
The data protection law in the UK changed on 25 May 2018. This privacy notice sets out your rights under the new laws.
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.
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.
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 which we have grouped together as follows:
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).
If you provide us with information about your health, for example, or a disability so we can allocate you to a suitable apartment, we will only use the information with your specific consent.
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 rental services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Vacation Care International Espana SA collects information before or during your reservation which is necessary to provide you with the services you have requested and that you have contracted with us or to comply with legal requirements.
When you make a booking, or stay with us, you must provide at least your contact details, your name, phone, e-mail, dates of stay, payment document or credit card.
When you arrive at one of our resorts, we must take a copy of your passport or identity document for the Guardia Civil, which is a legal requirement.
If you use our payment service via Wifi, your user details, the information of the devices from which you access the network, and the connection history, will be stored by the service provider, a requirement of the security regulations for a period of time established by law. This information remains stored confidentially during the period of time established by law and can only be transferred to law enforcement forces and authorised agencies.
In the resorts there may be cameras connected to a closed-circuit video, which serve to monitor and uphold the security of the complex and your own. These images are recorded in accordance with applicable law. The video recording only records images from the public areas of the resorts and no audio. These recordings are not under our control and are operated by the various communities in which we have apartments. There are no cameras in any apartment.
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:
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client/member/occupier, or as an exchangee.||(a) Identity
|Performance of a contract with you|
|To process your agreement including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) 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:
(b) Sending our newsletter, invite to an event, partake in a draw or take a survey
(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 clients, members, occupiers and exchangees use our services
|To deliver relevant website content, and advertisements and information about potential available properties to you and measure or understand the effectiveness of the details we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests to study how clients, members, occupiers and exchangees use our services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, services, marketing, for the benefit of clients, members, occupiers and exchangees||(a) Technical
|Necessary for our legitimate interests to define types of Leaseholder/client/occupiers 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 properties or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing, advertising and communications.
You will receive marketing communications from us if you have requested information from us or entered into a contract for services from us or if you provided us with your details when you registered interest, and, in each case, you have not opted out of receiving that marketing.
Third-party marketing – We do share your details with the on-site membership marketing team within the resort. You can manage your preferences about what information you want to receive from us, see the opting out section. We will never sell your data to third parties.
You can ask us or third parties to stop sending you our newsletters, marketing communications or details of properties at any time by following the opt-out links on any marketing or communication message sent to you or by contacting us at any time –by emailing to: email@example.com, or writing to: Vacation Care International Espana SL,.Aloha Gardens Reception, Urb. Aloha Gardens, Avda Del Prado s/n, Nueva Andalucia, 29660, Malaga Spain.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship we have with you.
We employ cookie technology to help log visitors to our web site. Cookies are pieces of data that are often created when you visit a website, and which are stored in the cookie directory of your computer or mobile device. A number of cookies may be created when you visit the Vacation Care International Espana SL website. The cookies do not contain any personal information about you, and they cannot be used to identify an individual user.
When you visit this website we collect web statistics concerning your visit, which are stored in a log file. Log files allow us to record visitors’ use of the site. Log files are also used to detect potential harmful users which may be reported to the relevant authorities.
We may have to share your personal data with relevant third parties for the operation of your contract with us, for example to enable us to provide maintenance and service facilities.
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.
We may disclose your personal data to a third party where required by it in connection with a potential or actual restructuring, acquisition, buy-out, consolidation or divestiture of all or part of Vacation Care International Espana SL or its business, including any restructuring or transfer of our rights or duties under our agreement with you as a member. Such third party would be required to keep the data secure and to use it only for the purposes for which you provided it to us and as described in the third party’s privacy notice.
We do not transfer your data outside the European Economic Area, apart from the use of MailChimp and Sendinblue which are used send newsletters and other relevant information. Although these are US products, adequate safeguards are in place in accordance with the GDPR, allowing us to use it to process personal data.
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.
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.
By law we have to keep basic information about our Clients, Members, Occupiers and Exchanges (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being Clients, Members, Occupiers or Exchangees.
In some circumstances you can ask us to delete your data. Please email firstname.lastname@example.org 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see these within the glossary below.
If you wish to exercise any of the rights set out above, please contact us by emailing - email@example.com or writing to: Vacation Care International Espana SL, Vacation Care International Espana SL, Aloha Gardens Reception, Urb. Aloha Gardens, Avda Del Prado s/n, Nueva Andalucia, 29660, Malaga Spain.
No fee is 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.
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.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 at: firstname.lastname@example.org.
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.
You have the right to: