Date of publication of this Policy: 09/07/2025

Click here to view the Policy in effect until: 09/07/2025

DATA CONTROLLER

Details of the Controller: BE LIVE HOTELS, S.L.U., with VAT B38674792 and with registered office located at C/Aguilar y Quesada, 1 - 38400 Santa Cruz de Tenerife - Tenerife - Spain. (hereinafter BE LIVE).

Contact: consult here https://www.belivehotels.com/en/general-information/contact/

Contact details of the Data Protection Officer: you can contact us at the postal address indicated above and/or by email: delegadopd@belivehotels.com.

SCOPE OF THE POLICY

This Policy is drafted 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 Guarantee of Digital Rights (LOPDGDD as per Spanish acronym).

When you access and use this website, participate in the blog or our Social Networks, contact our hotels by telephone, book our services through third parties (travel agencies or tour operators) or any other means that involve the processing of personal data by BE LIVE, you agree to accept this Privacy Policy, as well as the provisions contained in the Legal Conditions and the Cookies Policy.

At BE LIVE we provide you all the necessary information so that, once you have filled in your personal data, you can easily access the Privacy Policy and any other relevant information on Data Protection.

PERSONAL DATA PROCESSED

Data Identification and contact details

When you book, whether by your own or on behalf of others (whether in the case of minors or other people, including travel agencies) the following identification and contact details of the client/guest will be requested: name and surname, gender, telephone, email and voice (if you call us at our Call Center).

The customer's payment data will also be collected, such as bank card (card number, holder, CVV/CVC/CID, expiry date).

Data required by the Spanish Authorities in case of accommodation in our hotels in Spain

According to Spanish Royal Decree 933/2021, which came into force on 2 December 2024, the data that BE LIVE must collect and report to the authorities includes:

• Basic Personal Data: Name, surname, gender, date of birth, country of nationality, identity document number, type of document and date of issue.
• Contact Details: Full address, telephone number (landline and mobile), and email.
• Stay Data: Date and time of check-in and check-out, number of rooms booked, and details of the accommodation contract.
• Payment Data: Means of payment used, including the cardholder and expiry date. In some cases, the IBAN of the bank account may also be required.
• Additional Data: Relationship of kinship between travellers if there are minors, and specific details of transactions made during the stay.

This data must be registered on the Authority's digital platform and kept for a period of three years.

Sensitive data

On certain occasions, and in order to adapt our service to your needs, you or a third party (travel agency) must provide us with data considered sensitive by the regulations, which need additional protection.

Some of these occasions may occur when requiring specific assistance needs (wheelchair, oxygen), or requesting food preferences, being able to provide, indirectly, indications on ethnic origin, religious beliefs or state of health (allergies, diabetes, pregnancy, etc.), as set out in Article 9 of the GDPR.

This data is only collected with your consent – when you request these services when you make the booking – and is used only to offer you the requested service during your stay. You can object to the collection of this data, but this could make it impossible to meet your requirements.

Newsletter registration data

If you subscribe to our newsletter, the data requested in the form (name and email) will be collected, as well as the data associated with the language and market through the website.

Data collected during your web browsing

When you enter our websites, BE LIVE will collect data related to the device you are using, such as IP address, browser, operating system, and web/app behavior/usage, all of which are collected using cookies and similar technologies. The user may consent to the use of geolocation data or other data that we request, and the refusal to use them will not affect in any way the provision of the service.

Communications with BE LIVE

If you communicate, through any of the enabled channels (forms, emails, telephone channel, social networks), the data provided in these communications will be kept for as long as your request is responded to and up to a maximum of 2 years depending on the means selected.

This includes recording phone calls (voice) if you go to the Customer Service Center (phone).

In the same way, the communications we make for the purpose of notifying the reservation or changes that occur related to the flight will be stored.

PURPOSES OF DATA PROCESSING

BE LIVE processes your personal data for the following purposes:

• Management of individual or group bookings (more than 20 people or more than 10 rooms).
• Management of the services contracted during the accommodation (SPA, activities, special requests, etc.).
• Management of queries, complaints/incidents, claims and requests made by the client, as well as any other communication.
• Management of the membership program, among which the sending of commercial communications stands out.
• Newsletter management.
• Management of Price Match requests for your stay, based on our "Best Online Price Guaranteed" policy.
• Management of analytical tasks and market research, through cookies, and other similar technologies and tools.
• Managing the tracking of customers who use the Web, to identify ways to improve the browsing experience.
• Management of personal data communications to suppliers and/or collaborators that it additionally hires.
• Management of emergency situations, catastrophes or in general force majeure.
• Website, app, social media and blog management.
• Fraud management and prevention, as well as compliance with legal obligations.
• Service quality management through online surveys or similar services.

DATA PROCESSING LEGITIMACY

Data protection regulations (articles 6 and 9 GDPR) contemplate enabling cases for which personal data may be processed. BE LIVE legitimises the processing it carries out on the basis of:

Pre-contractual measures and/or contractual performance

• To communicate, via email or SMS, all matters related to the accommodation (new reservations, status updates and service or operational communications, check-in process), and, in general, the provision of the service contracted by the client himself; Understanding that this information is essential for the correct execution of our services, but that in no case will it be considered advertising communication.
• For the management of queries, complaints/incidents, claims and requests made by the customer and/or passenger, as well as any other communication.
• Conducting satisfaction surveys with the service.
• For the management of complementary services to the accommodation (SPA, activities, special requests, etc.).

Legal obligation

• The communication of data to the competent authorities ("Recipients" section).
• When the data subject exercises their data protection rights.
• For the exercise of legal actions brought by or directed against BE LIVE.
• To manage emergency situations, catastrophes or in general force majeure.

Legitimate interest (BE LIVE)

• For the investigation, prevention and detection of fraud against BE LIVE.
• To offer and provide services that fit the needs of the client, providing a more personalized treatment.
• To conduct analytical and market studies.
• To send commercial communications of products or services similar to those contracted by the customer by electronic means (email, SMS, etc.) and/or telephone.

Consent

• To send commercial communications from BE LIVE and other third parties when subscribing to our newsletter.
• To transfer personal data to some of our suppliers and/or collaborators.
• To process sensitive data (health, beliefs or biometrics) provided by the customer.
• To accept cookies and other similar technologies and tools on the website.
• To interact on our social networks, including subscribing to the newsletter.

Failure to provide the requested personal data or not accepting this Privacy Policy means that it is impossible to subscribe to and enjoy the services we offer.

HOW LONG WILL WE KEEP YOUR DATA FOR?

The period of storage of personal data will vary depending on the service you may contract. In any case, your data will be kept for the duration of the contractual relationship. Once this has ended, we will keep your data blocked for the limitation periods of the obligations that may have arisen from the processing and/or the applicable legal periods, remaining at the disposal of the competent authorities, for the attention of the possible responsibilities arising from the processing, and subsequently, they will be deleted.

In the same way, your data will be kept as long as you do not object to the processing or revoke your consent (previously granted), as well as when there is no commercial need or legitimate interest, being able to (i) anonymise them, to process them for statistical purposes allowing us to better understand our customers, as well as their preferences or needs; (ii) block them, remaining at the disposal of the competent authorities, during the legally established limitation periods to deal with any possible liabilities arising from the processing of their data; or (iii) delete them.

RECIPIENTS

Who do we transfer your data to?

• Competent Public Bodies, State Security Forces and Bodies, Judges and Courts, when BE LIVE has the legal obligation to provide them.
• Companies that own hotels under the BE LIVE brand. This communication may mean, depending on the contracted destination, the carrying out of an international transfer of data. They will only receive the personal data necessary to manage the booking or any request made by the user.
• Online payment service providers whose systems are connected to our website, in order to charge for contracted services and any additional charges.
• We will communicate your data to those entities that you have used to obtain information about our hotels or service offers (e.g. offer metasearch engines or travel agencies) to manage the relationship between BE LIVE and these entities (e.g. accrual of conversion commissions on purchase) and always ensuring that the personal information is as low as necessary.
• In addition, BE LIVE has service providers who have access to your personal data and who process the data in the name and on behalf of BE LIVE as a result of its provision of services (processors and sub processors). Specifically, and by way of example and without limitation, the aforementioned providers carry out their services in the following sectors: logistics services, agencies, fraud prevention, commercial communications, offer bookings, legal advice, multidisciplinary professional services companies, technology service providers, physical security companies and call centre service companies.

INTERNATIONAL DATA TRANSFERS

We inform you that some of our hotels, as well as those of the above-mentioned service providers, as well as some partners, are located in territories outside the European Economic Area and sometimes in territories that do not provide a level of data protection comparable to that of the European Union.

In such cases, BE LIVE carries out these international data transfers based on an adequacy decision or with adequate safeguards (standard contractual clauses). In the absence of adequate guarantees, it will be carried out with the explicit consent of the user or under the protection of the need to execute the contract established with the user.

DATA PROTECTION RIGHTS

What rights do I have and how can I exercise them?

The regulations grant you a series of rights regarding the personal data that you provide to BE LIVE. These rights are:

• Right of access. You authorise us to contact us to find out if your data is being processed and, if it is being processed, to obtain information on this matter.
• Right of rectification. You can request the rectification of any data you consider inaccurate, and we will proceed to correct it with the new data you provide us with.
• Right to object. Whenever the processing is covered by a public or legitimate interest, profiles are created or the processing is intended for direct marketing, you may oppose it. BE LIVE (except for direct marketing) may prove reasons that prevail over this right.
• Right of withdrawal. You can request the deletion of the data provided that the causes stipulated by the regulations are met (see article 17 GDPR).
• Right to request the limitation of processing. This is an auxiliary right whereby, while you have requested the deletion, rectification or opposition to the processing, BE LIVE will block the data until your complaint has been resolved.
• Law on data portability. You may request, when the processing is carried out by automated means, the transfer of your data to another company, provided that the processing is legitimate, based on the consent or in the framework of the execution of a contract.
• Right not to be subject to a decision based solely on automated means. This right aims to ensure that you are not the subject of a decision based solely on the processing of your data, including the creation of profiles, if the decision produces legal effects concerning you or significantly affects you in a similar way.

You can exercise your rights quickly and easily by completing the following form.

In any case, you can send a letter to the registered address of BE LIVE or by email to our Data Protection Officer to request the exercise of your rights.

How can I file a complaint with the Control Authority?

If a user thinks that there is a problem with the way in which BE LIVE is managing his/her data, they can direct their complaints to our Data Protection Officer or to the corresponding Data Protection Control Authority, the Spanish Data Protection Agency the relevant authority in Spain.

SECURITY

At BE LIVE we maintain the highest levels of security required by law to protect your personal data against accidental loss and unauthorised access, processing or disclosure, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed. When we receive your data, we use rigorous procedures and security features to prevent any unauthorized access.

The actions described in this section and aimed at ensuring an adequate level of security for the identified risk shall include, if necessary, the following measures:

• Pseudonymization and encryption of personal data.
• Measures capable of guaranteeing the permanent confidentiality, integrity, availability and resilience of processing systems and services.
• Measures capable of restoring the availability and access to personal data quickly in the event of a physical or technical incident.
• Existence of a process of regular verification, evaluation and assessment of the effectiveness of technical and organisational measures to guarantee the security of the processing.
• Periodic assessment of the risk of accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.
• Measures to ensure that any person acting under the authority of BE LIVE and having access to personal data can only process such data on instructions from BE LIVE.

CONFIDENTIALITY

The personal data that may be collected will be treated with absolute confidentiality, undertaking to maintain secrecy with respect to them and guaranteeing the duty to keep them by adopting all the necessary measures to prevent their alteration, loss and unauthorised processing or access, in accordance with the provisions of the applicable legislation.

COOKIES

Our website uses "cookies" to collect information about how you use the Website. For more detailed information on how BE LIVE uses cookies, please see the Cookie Policy.

UPDATE TO PRIVACY POLICY

BE LIVE may modify this privacy policy because of legislative changes, jurisprudential doctrine and opinions of the AEPD that are of direct, indirect or sectoral application.

Any changes, modifications or amendments we make to our Privacy Policy will be posted on this page.

Date of publication of this Policy: 09/07/2025