Privacy Policy

Identification of the Data Controller

The data provided by the user will be processed by Tanja Ebersbach, with registered office at 29650 Mijas Costa (hereinafter, the “Controller”) for the purposes outlined in section number 3. You can contact the Controller via our email address privacy@ferienhausmarbella.com or via the email address of the Data Protection Officer dpo@ferienhausmarbella.com.

Purpose and Legal Basis for Data Processing

Below, we provide details about the purposes of the processing carried out by the Controller, the legal bases, and the retention period of the data.

Respond to queries submitted by the data subject.
- Legal basis: Consent of the data subject.
- Retention period: The data will be retained until the query raised by the data subject is resolved and for five (5) years to address the formulation, exercise, or defense of claims.
Provide the Service described in the Terms of Use:
- Manage the user’s registration through the registration form.
- Generate the selected coupons and provide anonymized history information to manage the proper redemption of coupons by:
  - Retail product distributors, such as supermarkets where the user redeems the coupon.
  - Manufacturers and brands of consumer products for which the user generates the coupon or their agencies.
Maintain a history of generated and redeemed coupons.
- Retention period: The personal data provided will be retained as long as the contractual relationship with the data subject is maintained and for five (5) years to address the formulation, exercise, or defense of claims.
- Legal basis: Performance of a contract.
Creation of profiles regarding the preferences of the data subject. The Controller performs profiling based on automated processing according to the coupons and other promotions chosen by the data subject, aimed at evaluating the data subject’s preferences for consumer products.
- Legal basis: Legitimate interest of the Controller.
- Expected consequences: The data processing does not foresee any consequences that could have a legal effect or significantly affect the data subject otherwise. The offered service remains unchanged if the user does not consent to such processing.
- Logic used: The data processing involves an automated procedure that filters all downloaded and redeemed coupons to classify the data subject based on their circumstances and preferences (age range, purchase location, type of products purchased, monthly spending in supermarkets or pharmacies, etc.).
- Data retention criteria: Data related to profile creation will be retained for a maximum period of one year from the last update. In this regard, if the data is not updated within the mentioned period, the information will be blocked in a way that it will not be available to companies. After three years without updating the information, the data will be deleted, ensuring full confidentiality, both in processing and subsequent destruction.
Send personalized promotional information about coupons, offers, or promotions from third parties published on optimacreativos, through email and notifications in the Apps themselves.
- Legal basis: Express consent of the data subject.
- We inform you that you can withdraw the consent given at any time, without affecting the lawfulness of processing carried out before by the Controller.
- Retention period: The personal data provided by the user will be retained as long as the user does not withdraw their consent.
Compilation of statistics relating to the association and redemption of coupons by the data subject. These statistics include information about when and where a coupon was associated with the data subject’s account, as well as when and in which establishment each coupon was redeemed.
- Retention period: The personal data provided will be retained as long as the contractual relationship with the data subject is maintained. Once the relationship ends, the data will undergo anonymization operations and will be retained by the Controller.
- Legal basis: Performance of a contract. Compatible purpose.
- Assessment and management of your job application for the selection and hiring of personnel, to offer you positions that match your profile.
- Legal basis: Consent of the data subject.
- Retention period: Personal data will be retained for a maximum period of one year.

Obligation to Provide Data

USERS, by marking the corresponding boxes and entering data in the fields marked with an asterisk (*) in the contact form or presented in download forms, expressly and freely and unequivocally accept that their data is necessary to address their request by the provider, with the inclusion of data in the remaining fields being voluntary. The USER guarantees that the personal data provided to the CONTROLLER are truthful and assumes responsibility for communicating any changes to them.

The CONTROLLER informs that all data requested through the website is mandatory, as it is necessary to provide optimal service to the USER. If not all data is provided, it is not guaranteed that the information and services provided will fully meet their needs.

Recipients of Your Data

Data Processors

The Controller contracts with third-party data processors to provide its services. Specifically, the Controller has agreements with the following service providers:

The Rocket Science Group (Mailchimp)
Microsoft 365
Google Analytics and Google Ads

The data you provide to us may be processed and/or communicated to the companies within our group (whose addresses are listed in section 2 of this privacy policy) for the same purposes previously indicated.

Recipients
- Additionally, we inform the data subject that their data related to registration (processing #2) and data related to the creation of a profile (processing #3) will be communicated to the following recipients:
  - Retail distributors or manufacturers and brands of consumer products for which the user generates the coupon or their agencies.

Transfers of Data to Third Countries

We do not plan to transfer personal data to third countries or international organizations.

Rights

Any person has the right to obtain confirmation about whether we process personal data concerning them or not.

In particular, interested parties may request the following:

Access to their personal data.
Rectification of inaccurate data.
Deletion of data.
Opposition to the processing of their data.
Request the limitation of the processing of their data.
Portability of their data.
Withdraw consent given.

To exercise your rights, you can use the forms provided by the company, request a template from our Data Protection Officer (dpo@ferienhausmarbella.com) or another legally recognized method.

Any interested party may file a complaint with the Spanish Data Protection Agency (www.aepd.es) if they consider that their rights have been violated.

Security Measures

The CONTROLLER has implemented the necessary technical and organizational security measures to ensure the security of your personal data and to prevent its alteration, loss, and unauthorized access or processing, considering the state of the technology, the nature of the stored data, and the risks to which it is exposed, whether from human action or the physical or natural environment.

Likewise, security measures have been implemented to prevent unauthorized access to or disclosure of your data, maintain data integrity, availability, and resilience on an ongoing basis, and ensure the recovery of data in the event of a physical or technical incident.

Modification of the Privacy Policy

The CONTROLLER reserves the right to modify its Privacy Policy, in accordance with its own criteria, or motivated by a doctrinal change of the Spanish Data Protection Agency or a change in legislation, jurisprudence, or business practice. If the CONTROLLER introduces any modification, the new text will be published on this same website, where the USER may be informed about it. In any case, the relationship with the USERS will be governed by the rules provided at the precise moment they access the website.