Last updated: February 2021.
- GENERAL INFORMATION
- The Sol Group Corporation, with offices at 800 Brickell Ave., Suite 601, Miami, FL 33131, hereinafter, “TSGC” or “us”, “our”, “we”), operates the www.romancebyparadisus.com website (hereinafter, the “Website”).
- WHY WILL TSGC PROCESS THE USER’S PERSONAL DATA AND FOR HOW LONG?
- Depending on the User’s request, the Personal Data collected may be processed by TSGC to provide the services, identify and communicate with you, respond to your requests/inquiries, and improve our Websites.
- The User’s data may be kept so long as TSGC has a legitimate basis for doing so.
- WHICH KIND OF PERSONAL DATA WILL TSGC PROCESS?
- TSGC may process the following information:
- Identifying details: name, surname(s);
- Contact details: Postal and e-mail address, phone number;
- Data from website cookies (as described in section 4 below).
- Any other data expressly collected by TSGC with User’s prior consent;
- Any other data expressly provided by User to TSGC for an specific purpose (including but not limited to: contests, sweepstakes, promotional activities, etc.).
- COOKIES POLICY
- TSGC may utilize cookies or log files to ensure the functionality of the Website. Cookies are files sent by the website and stored on the User’s browser by a web server in order to maintain the browsing session by storing the user’s IP address (of their computer) and other navigation data. These files are exclusively associated with a unique user ID and the device they navigate the website with.
- This table shows the cookies used on the Website, the information obtained by them, and their purpose:
||User session, registration details, bookings.
||Registration and management of user sessions, personalised browsing, load balancing.
- Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, the Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit www.allaboutdnt.com.
- WHAT IS THE LEGITIMATE BASIS FOR PROCESSING PERSONAL DATA?
- TSGC has a legitimate basis for processing Personal Data if the User consents to the processing of their Personal Data or if such processing is necessary:
- For performing a contract with the data subject;
- To comply with a legal obligation of TSGC;
- To protect the vital interests of the data subject or another natural person;
- For a task carried out in the public interest; and/or
- For some other legitimate interest of TSGC.
- TO WHICH RECIPIENTS WILL THE USER’S DATA BE DISCLOSED?
- Data collected through the website may be disclosed to:
- TSGC subsidiaries or group companies, solely for internal administrative purposes and/or for the purposes indicated above;
- Entities operating the hotels managed by TSGC or franchises, solely for internal administrative purposes, for the management of selection processes, or for the management of the complaints channel;
- Public Administrations, as required by law; and/or
- TSGC’s service providers (example.g., IT hosting providers) when necessary. Under no circumstances will the service providers process the data for additional purposes that have not been previously legitimized.
- For other specific purposes expressly announced and accepted by User.
- Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Data, to the United States and process it there. Your continued use of the Website represents your agreement to that transfer.
- We may disclose your Personal Data where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Website.
- We may use your Personal Data to e-mail you with promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by sending a letter to The Sol Group Corporation at 800 Brickell Ave., Suite 601, Miami, FL 33131.
- SECURITY MEASURES
- TSGC employs technical and organizational measures required to ensure Personal Data are secure and to prevent them from being altered, lost, or processed or accessed illegally, depending on the state of the technology, the nature of the stored data, and the risks to which they are exposed. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure, so we are unable to guarantee the absolute security of the Personal Data we have collected from you.
- CALIFORNIA CALIFORNIA CONSUMER PRIVACY ACT
Effective January 1, 2020.
- California consumers have specific rights under the CCPA. You can access the full text of the CCPA by clicking https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375 .
- The California Consumer Privacy Act (“CCPA”), requires that we make certain disclosures about our collection, use, and sharing of California Consumers’ Personal Information (“PI”) as defined by the CCPA and provides California Consumers certain rights regarding User´s PI. Generally, we collect your PI from you, from our affiliates and from our service providers. We collect the following categories of PI which we may share with affiliates, service providers and owners of properties we manage:
- Identifiers (e.g., Name, Phone Number, Email Address, I.P. Address)
- Personal Records (e.g., Name, Phone Number, Email Address, Credit Card Number)
- Consumer Characteristics (e.g., age)
- Customer Account Details / Commercial Information (e.g., your vacation history, rewards program details)
- Internet Usage Information (e.g., information regarding your interaction with our online services)
- Geolocation Data (e.g., if you enable this feature on your device while using our app)
- Sensory Data (e.g., recordings of customer service calls, property security camera footage)
- Inferences from PI Collected (e.g., your preferences, your likelihood of interest in certain of our services)
We process the PI we collect from you for the following business purposes defined in the CCPA:
- Providing our website, including maintaining and servicing your account on the Site, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
- Detecting security incidents and protecting against malicious, deceptive, or illegal activity
- Debugging our website to identify and repair errors
- Internal research and development
- Quality and safety assurance, and improving, upgrading, and enhancing our website
- Processing and managing interactions and transactions on our website
We do not “sell” PI that we collect from you, including PI of minors under the age of 16, as “sell” is defined in the CCPA and will treat PI we collect from you as subject to a do not sell request.
Some browsers have signals that may be characterized as do not track signals, but there is no industry consensus on recognizing or responding to such signals and we currently do not recognize or respond to these signals.
California Consumers have the right to exercise the privacy rights under the CCPA personally or via an authorized agent who meets the agency requirements of the CCPA. Before fulfilling your CCPA request, we must require you to provide sufficient information to reasonably verify your identity and residency. Depending on the type of request, this verification process may include confirming you are the owner of an email address we have in our records and/or requiring you to provide us at least three (3) unique data points. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you and take other steps permissible under the CCPA to ensure it is a genuine request.
To make a request according to your rights to know or to request deletion of your personal data set forth below, you may email us at [insert email] or call us at [insert toll free number].
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following from the twelve months prior to the date of your request:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties to whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months or that no disclosure occurred.
- A list of the categories of PI sold about you in the prior 12 months or that no sale occurred. If we sold your PI, we will explain:
- The categories of your PI we have sold.
- The categories of third parties to which we sold PI by categories of PI sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the twelve months prior to the date of your request and are maintaining.
Except to the extent we have a basis for retention under the CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining.
You have the right to not receive discriminatory treatment in a manner prohibited by the CCPA as a result of your exercising your rights under the CCPA.
Separate from the CCPA, California’s Shine the Light law permits customers in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates if that personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at [insert contact email] or to the address: 800 Brickell Ave., Suite 601, Miami, FL 33131, with the applicable reference, enclosing a photocopy of his/her national identity document or passport, in force, at any time and free of charge.
To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.