1. Data controller

The company Rooms Port, S.L. (hereinafter “FeelFree” or “Data Controller”) acts, under the terms established in the data protection regulations, as Data Controller in relation to the processing of personal data (website users, information requesters, owners, etc.) that are made through FeelFree’s websites and social media presence.

Data controller: Rooms Port, S.L. “FeelFree”

NIF: ES-B56813546

Addresse: Calle Peña y Goñi, 3. 20002 Donostia – San Sebastián (Guipúzcoa, España)

Telephone: +34 943563654

Email: hola@feelfreestays.com

The basic regulations regarding the protection of personal data applicable to the data processing carried out by FeelFree are:

1. EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons regarding the processing of personal data and the free circulation of these data (“RGPD”).

2. Organic Law 3/2018, of December 5, regarding the Protection of Personal Data and digital rights guarantee (“LOPDGDD”).

3. Their respective complementary and development regulations.

FeelFree’s official website is located at feelfreestays.com. FeelFree’s main official channels in social and professional networks are:

Facebook: https://www.facebook.com/FeelFreeRentals

Instagram: https://www.facebook.com/FeelFreeRentals

Linkedin: https://es.linkedin.com/company/byfeelfree

For the purposes of this Privacy Policy, the official FeelFree website, APPs, and official channels on social or professional networks will all be referred to hereinafter as “the website”, except when otherwise specified.

In compliance with current regulations on the Protection of Personal Data, users are informed that the personal data they provide through any means located on the website, apps, or official channels on FeelFree’s social or professional networks (by email, forms, subscription to newsletters, etc.), or as a result of their use, may be incorporated into FeelFree’s data processing systems.

The purposes of the data processing that FeelFree can carry out through the website are:

CUSTOMERS AND WEBSITE USERS:

– Purpose: Offering and managing our holiday acommodation services, other tourist services, real estate, and related activities, with the possibility to hire them online.

– Legal Basis: We need to process the data to manage our services (“contractual” or “pre-contractual” relationship according to article 6.1.b of the RGPD).

– Possible recipients: In its offer of accommodation services, FeelFree makes a series of optional services available to its clients, specific to each destination, to help make their stay as pleasant as possible. To provide these services, FeelFree can rely on its own staff or external collaborators. The client who contracts optional services is informed that FeelFree may, where appropriate, communicate their data (identification, contact, and any data related to the contracted accommodation and services) to companies and people collaborating with FeelFree. Only the employees and collaborators of FeelFree who need to know such data to effectively provide each of the services requested by you may have access to them.

– Possible recipients: The client who contracts accommodation services is informed that, in compliance with state and international regulations on citizen security, their identification data, as well as those relative to any person that accompanies them, may be communicated to the Public Administrations with competence in the matter, with special reference to Law Enforcement Forces and Agencies.

– Rights: Please read the “Rights of Interested Parties” section.

INFORMATION REQUESTS:

– Purpose: Providing contact, consultation, and communication tools with interested and related people, responding to applications and requests.

– Legal basis: Consent from the interested party (RGPD art. 6.1.a), when they provide their data for these purposes, by filling in “Contact” forms or similar, and checking the required boxes to accept the conditions and the privacy policy.

– Possible recipients: We do not foresee the communication of data to third parties.

– Rights: Please read the “Rights of Interested Parties” section.

NEWSLETTER SUBSCRIBERS AND RECIPIENTS OF INFORMATIVE MAILS:

– Purpose: Sending informative and commercial communications related to our activities and services.

– Legal basis: Consent from the interested party (RGPD art. 6.1.a), when they provide their data for these purposes, by subscribing to the “newsletter” or by checking the required boxes to accept the receipt of this type of communication.

– Possible recipients: We do not foresee the communication of data to third parties.

– Right to no longer receive communications: If they are subscribed to newsletters or similar services, users may request to unsubscribe from said services at any time they wish by sending a request to the email address hola@feelfreestays.com or using any other means that FeelFree facilitates for this purpose, such as the mechanism called “Leave” or “Unsubscribe”, located at the end of the newsletters themselves.

– Other rights: Please read the “Rights of Interested Parties” section.

USERS OF THE WEBSITE AND THE SOCIAL NETWORK CHANNELS:

– Purpose: Informing, organizing, and disseminating FeelFree’s activities and initiatives, or those in which FeelFree participates, as well as the opinions and assessments made by third parties and entities.

– Legal basis: FeelFree’s legitimate interest (RGPD art. 6.1.f) in publicizing its activity.

– Possible Recipients: We do not foresee the communication of data to third parties.

– Rights: Please read the “Rights of Interested Parties” section.

USERS OF THE WEBSITE AND THE SOCIAL NETWORK CHANNELS:

– Purpose: Managing and analyzing the use of the website and its corporate presence in social and professional networks.

– Main Legal Basis: FeelFree’s legitimate interest (RGPD art. 6.1.f) in knowing and managing the operation of its website and its channels on social and professional networks.

– Specific Legal Basis: Consent from the interested party (RGPD art. 6.1.a), when the data analysis is based on the use of analytical cookies, advertising cookies, or similar technologies, granted by accepting the use of cookies.

– Possible Recipients: We do not foresee the communication of data to third parties.

– Right to Modify or Revoke the Consent Granted for the Use of Cookies: The user has the “Cookie Settings” tool available at all times on the website for this purpose.

– Other Rights: Please read the “Rights of Interested Parties” section.

The personal data provided will be kept for the time necessary to fulfill the purpose for which they are collected, determine the possible responsibilities that may arise from the purpose, or for the period that the applicable regulations establish in each case (accounting, tax, commercial, citizen security, etc.), after which they will be deleted by adopting the necessary security measures to guarantee their confidentiality.

You can exercise the rights related to the protection of your personal data (access, rectification, deletion, limitation to treatment, portability, and opposition), as well as withdraw the consent granted or make any other request on this matter by writing to FeelFree, at Calle Peña y Goñi, 3, at 20002 Donostia – San Sebastián (Guipúizcoa, Spain), telephone +34 943 563 654, or at the email address  hola@feelfreestays.com.

The application must include a copy of a document proving the applicant’s identity. If you make the request in your capacity as legal representative, you must attach, in addition to a copy of a document proving the identity of the applicant, a document proving such representation.

The control authority to which you can go if you do not agree with the resolution of the requests or to file a claim is the Spanish Agency for Data Protection: https://www.aepd.es/es

The Data Controller does not require you to provide personal data to access the website. However, the website contains utilities and forms (for example, reservation, contact, subscription to newsletters, etc.) whose use requires the user to provide personal data, mostly identification or contact data and, in the case of reservations, data related to the contracted service, payment method and the people who are going to use it. The user provides their personal data freely and voluntarily. FeelFree does not request more personal information than necessary to carry out each requested service.

Any user who sends/includes any type of content (data, documents, texts, images, videos, sound, graphics, messages, or other material) declares and guarantees to do so in such a way that it complies with the conditions expressed herein and with the current legislation. Any user who includes third-party personal data declares that they have their prior and express consent for their processing. The inclusion of third-party data without their prior and express consent is prohibited.

The user is solely responsible for the veracity, correctness and legitimate processing of the data included, exonerating FeelFree from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity, and authenticity of the personal data provided and undertake to keep them duly updated. The non-completion or erroneous completion of fields indicated as mandatory in the forms on the website may result in the Data Controller not being able to attend to the user’s request.

The Data Controller will collect personal data appropriately, according to the purposes, utilities, services, or features included on its website, in a determined, explicit, and legitimate manner, so that in no case will fraudulent, unfair, illicit, or illegal means be used that in any way endanger the legitimate rights of users.

Sending information through this website necessarily entails the express authorization for the data processing described in this privacy policy and in the general conditions of the website.

The services of the Data Controller are not specifically aimed at minors and must be contracted by persons of legal age. In the event that some of our services are specifically aimed at minors, the Data Controller will request the consent of the parents or legal guardians for the collection of personal data or, where appropriate, for the processing of the data.

The Data Controller recommends that users consult the different materials that control authorities have developed in relation to the protection of personal data pertaining to children and young people. This information (recommendations, manuals for the use of new technologies, educational videos, etc.) is available on the websites of the Basque and Spanish Data Protection Agencies.

Any person who provides their curriculum vitae offering their candidacy to work at FeelFree through forms, email, social or professional network channels or similar mechanisms, is informed, in accordance with the provisions of the Personal Data Protection regulations, that the data provided through their job application will be incorporated into our data processing section called “Resumes and Personnel Selection”.

Their data may be used for the purpose of making them participate in future personnel selection processes inside our company, which may be carried out internally or by external companies that FeelFree hires to carry out personnel selection processes.

FeelFree will keep their resume for approximately one year. After this, the data will be destroyed, applying the necessary security measures to guarantee its confidentiality.

If you do not agree with any of the purposes described, please notify us in writing as soon as possible. Likewise, if there is any change in your data, please keep us informed. You can exercise the rights related to the protection of your personal data (deletion, access, rectification, treatment limitation, portability, opposition, etc.), as well as any request on this matter as indicated in the section “Rights of Interested Parties” of this Privacy Policy.

This website offers links to social networks and external websites and channels. FeelFree assumes no responsibility in relation to these linked sites. Any user who accesses social and professional networks and external websites and channels related to FeelFree, from the links located on this website or in any other way, is previously and expressly informed that the conditions of use, privacy policies, cookie policies and any other conditions or regulations depend on the entities responsible for said social networks and websites and channels, and never on FeelFree.

FeelFree can have profiles on social and professional networks, with the main purposes of disseminating its products, services, and activities, and establishing channels of communication with companies, professionals, and individuals. The publications offered through these channels are indicative in nature. By registering in the FeelFree profiles with their profile on a social or professional network, the user gives their express authorization to FeelFree for the processing of their personal data in accordance with this Privacy Policy.

Any information and personal data provided voluntarily by the user through FeelFree’s social or professional networks may be processed for the purpose of contacting the user and dealing with queries, reservations, and requests made, sending informative or commercial communications, managing events, raffles, invitations and similar activities, to know their opinion or assessment about FeelFree and its publications and to manage, in general, the presence of FeelFree in social and professional networks.

Users are informed that the information and content (data, texts, videos, sound, photographs, graphics, comments, messages or other material) that they publish through FeelFree’s social or professional networks (including, where appropriate, personal data) may be made publicly available to other users of these social or professional networks and may be freely visible, commented on and shared by their visitors, under the terms established by each social or professional network.

From the configuration of the user profile of each social or professional network, the user can configure what information they want to make public in each case, check the permissions they have granted, delete or deactivate them, and manage their publications according to their criteria and the rules of use of each social or professional network.

The user will be solely responsible for their publications respecting current legislation, the rules of use and privacy policies established by the corresponding social or professional network, and those of FeelFree, which does not assume any responsibility in relation to the publications that each user performs. FeelFree will unilaterally and without prior notice remove content that it considers to be in violation of current legislation, the rules of use and established privacy policies, or that it considers inappropriate.

FeelFree can follow other profiles on other social or professional networks, without this fact implying a link of any kind with them.

In turn, the FeelFree channels in different social or professional networks can be followed by other people or users of those networks, without this fact implying any kind of connection with them.

FeelFree reserves the right not to respond to messages or comments received through these channels. FeelFree may modify or delete at any time and without prior notice the publications issued on its social networks.

By becoming a follower or clicking “Like” on social or professional networks, you consent to the processing of your personal data in the environment of the corresponding social or professional network, in accordance with its privacy policies, FeelFree’s access to data contained in the contact list and that of their publications, expressly including those of a commercial nature, appear in your notices and notifications.

If the user wants to stop following the official channels on FeelFree’s social or professional networks, they must do so using the tools provided for this purpose by each network.

FeelFree will process the personal data contained in its data processing, adopting the technical and organizational measures that are necessary to guarantee its security and avoid its alteration, loss, processing or unauthorized access, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment, in accordance with current legislation that is applicable in terms of security measures for personal data processing. However, users are informed that computer security measures are not impregnable and are not safe from possible illegal and improper interference, which would not be the responsibility of the Data Controller.

To guarantee the security and privacy of the user, this website uses encryption technology based on secure connection layer protocols (https), so that browsing is as secure as possible.

The user must immediately notify FeelFree of any incident, security breach, improper or unauthorized access detected in relation to the website, private areas, access codes, presence in social or professional networks or any other circumstance that jeopardizes the security and confidentiality of the information or the proper functioning of the website.

The telephone number + 34 943 563 654 and the email address hola@feelfreestays.com are established as preferential notification mechanisms.

The Data Controller is committed to the privacy and protection of user data. The processing of their personal data will be carried out confidentially and in compliance with these regulations.

The Data Controller reserves the right to modify its privacy policy according to its criteria, to introduce legislative or jurisprudential changes. If the Data Controller introduces any modification, the new text will be published on this same website, where the user may have knowledge of it. In any case, the relationship with the users will be governed by the rules established at the precise moment in which the website is accessed. That is why the Data Controller recommends that you visit this privacy policy each time you connect to the website.

Any relationships established between FeelFree and the user will be governed by the provisions of the current regulations regarding the applicable legislation and the competent authority. However, for cases in which the regulations provide for the possibility for the parties to submit to an authority, FeelFree and the user, expressly waiving any other authority that may correspond to them, submit to the Courts and Tribunals of Donostia San Sebastián (Gipuzkoa, Spain).

FeelFree will pursue the breach of this Privacy Policy, as well as any improper use of the contents presented on this website, exercising all civil and criminal actions that may correspond by law, including those of an economic nature.