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PRIVACY POLICY

I. ENTITY RESPONSIBLE FOR DATA PROCESSING

Contact information for the entity responsible: BE LIVE HOTELS, S.L.U., CIF B38674792 and registered address at C/Aguilar y Quesada, 1 - 38400 Santa Cruz de Tenerife - Tenerife - Spain. (hereinafter BE LIVE)

Contact information for the Data Protection Officer: they can be contacted via the postal address stated above and/or via email: delegadopd@globalia.com.

II. POLICY REACH

When you access and use this website or use any other media which implies the use of personal data you commit to accept this Privacy Policy as well as the provisions contained in the Legal Conditions and Cookie 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 concerning Data Protection.

III. DATA PROCESSING PURPOSES

What do we use your personal data for?

We collect the personal information necessary in order to manage and maintain some of our services, as well as for other purposes as set out in this Privacy Policy.

BE LIVE uses your personal data for the following purposes:

· CONTRACTUAL: To contract, maintain and review the fulfilment of the products and services BE LIVE contracts.

· CONSENT: For any commercial activity carried out which entails creating profiles based on personal preference, be they for our own products or those of a third party and via any medium, including online or via telephone.

· LEGITIMATE INTEREST: (i) To launch commercial activity, as well as product and services recommendations which take your previous purchases or interests into account. (ii) Also, for the prevention, investigation and detection of fraud. (iii) To record your voice to maintain quality of service and use the recordings as evidence, both in a legal and non-legal setting.

On what occasions do we request personal data through our website?

· When a client registers for the BE LIVE newsletter.

· When the client requests any of the services and/or products that we offer.

· When managing applications from candidates applying to work with us. In this case the data collection is carried out through Globalia Group's employment platform: https://www.globalia.com/es/empleo

· To respond to any enquiries and complaints that we receive.

How do we use the personal information we collect?

· We use it to promote and send information about our services if you have requested this.

· To manage our mailing list, send newsletters, promotions and related offers.

· To manage the sale of our services and any other product described on our website.

· To provide customer service and follow-up services.

How long will we store your information for?

The length of time for which we will store your personal data varies according to the service you end up contracting. In any case, we will keep your data for the duration of our contractual relationship with you. Once this relationship has come to an end, your data will remain blocked during the statutory time indicated by the obligations which arise as a result of the data processing and/or the legal period applicable, remaining subject to the competent authorities with regards to any possible liabilities which may arise as a result of the data processing.

IV. LEGITIMISATION

The lawful basis for us processing your data is so that we can provide the information or services you have requested.

In other cases, it may be necessary for the execution of a contract you enter into with us or be based on a legitimate interest to attend to a fundamental right as we describe in section III.

In each of these cases, you will have full rights over your personal data and the use of the same and you will be able to exercise these rights at any time.

Under no circumstances will we pass your data onto third parties without previously informing you and requesting your permission to do so.

The collection of your personal data is compulsory in order for us to be able to contact you and respond to your request. Failure to provide the personal information requested or to accept the present privacy policy will result in you being unable to subscribe and we will be unable to process your requests.

V. RECIPIENTS

Who do we transfer your data to?

1. Relevant public authorities, the Inland Revenue, State Security Departments, Judges and Tribunals, when BE LIVE has the legal obligation to do so.

2. In addition, BE LIVE partners with some third-party service providers who have access to your personal information and who process the data mentioned in the name of and on behalf of BE LIVE as a result of their provision of services.

Specifically, including and not limited to, the afore-mentioned providers carry out their services in the following sectors: logistics services, agencies, aerial, fraud prevention, commercial communication, legal advisory, multi-discipline professional service companies, maintenance-related companies, technology-provider companies, physical security companies and call-centre companies.

Under no circumstances will your personal data be shared with third-parties without having previously obtained your consent to do so, unless providing your data is necessary in order to maintain our relationship with you, as well as in cases as listed in the data protection regulations which are valid at the time.

VI. DATA PROTECTION RIGHTS

How can I exercise my rights?

You can contact us in writing by sending a letter to BE LIVE's registered address or to the following email address: delegadopd@globalia.com, including in both cases a photocopy of your ID card or similar ID document, to exercise the following rights:

· Right to request access to the personal data: you may ask BE LIVE if the company is using your data.

· Right to rectify, or to eliminate the same.

· Right to oppose the processing of your data: BE LIVE will stop using your data in the way you specify, except if they have to continue using it in order to exercise or defend any possible claims.

· Right to data portability: if you would like your data to be processed by another entity, BE LIVE will provide data portability to the new entity responsible.

· Right to request the limitation of its treatment, in which case the data will only be kept by BE LIVE for defence purposes against potential claims.

· The possibility of withdrawing your consent: if your consent was given for a specific purpose, you have the right to withdraw that consent at any time, without this having any effect on the legality of the data processing prior to the withdrawal of consent.

In any case, we provide you with a form which will allow you to exercise the afore-mentioned rights easily and quickly by contacting the Data Protection Officer at the address above.

How can I make a complaint at the Data Protection 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 the Data Protection Officer or to the corresponding data protection monitoring authority with the Spanish Data Protection Agency que corresponda, siendo la Agencia Española de Protección de Datos being the relevant authority in Spain.

VII. SECURITY

At BE LIVE we maintain the highest levels of security as required by Law in order to protect your personal information from fortuitous loss and unauthorised access, processing or sharing, considering the condition of the technology, the nature of the data stored and the risks which it is subjected to. When we receive your data, we use rigorous security procedures and functions to avoid any unauthorised access.

The actions described in this section and destined to guaranteeing an adequate level of security for the risk detected will include, if deemed necessary, the following measures:

Personal data pseudonymization and encryption.

Measures which are able to guarantee the permanent confidentiality, integrity, availability and resilience of the data processing systems and services.

Measures able to quickly restore availability and access to personal data in the event of a physical or technical incident.

The existence of a regular verification and evaluation process which measures the efficiency of the technical and organisational measures used to guarantee the security of the data processing.

Periodical evaluation of the risk of destruction, loss or accidental or illegal alteration of the personal information sent, stored or processed in a different way, or the unauthorised communication of or access to said data.

Measures to guarantee that any person acting under the authority of BE LIVE and who has access to personal data, can only use said data following BE LIVE's instructions.

VIII. CONFIDENTIALITY

The personal data which may be collected will be used with absolute confidentiality, and we commit to keep it secret and guarantee our duty to store it using all methods necessary to avoid its alteration, loss and unauthorised treatment or access, in accordance with what is set out in the applicable legislation.

IX. LIABILITY

The user will be held solely responsible if they fill in any forms using information which is false, inaccurate, incomplete or out-of-date.

X. COOKIES

Our website uses 'cookies' to collect information on the way in which the Website is used. If you would like to obtain more detailed information on how BE LIVE uses cookies, please read our Cookie Policy.

Date of publication of this Policy: 08/05/2018