Islas Secas Reserve and Resort Management, S.A. (“we,” “us,” or “our”) respects your privacy. This Privacy Notice explains how we, and our affiliates, collect, use, disclose, and protect Personal Information (defined below), and your choices about the collection and use of Personal Information.
This Privacy Notice applies to Personal Information collected or processed through any of our websites, apps, social media pages, or other platforms that link to this Privacy Notice (collectively, the “Site”).
“Personal Information” is information that identifies or relates to a particular individual. Examples of Personal Information include, among others, name, email address, phone number, mailing address, and online identifiers.
As described in more detail below, we collect Personal Information from you in two ways – when you voluntarily submit Personal Information through a form on the Site; and through information we automatically collect when you use the Site.
A. Information that You Provide Us
In various places on the Site, we request information from you via forms. The exact Personal Information we need to collect will depend on the purpose of the form.
For example, if you submit a booking inquiry, we request contact information, including your full name, email address, and country of residence.
We will indicate on the form whether a particular field of Personal Information is mandatory or optional. If you choose not to provide certain Personal Information, we may not be able to provide requested services.
B. Information We Automatically Collect from You
We collect the following types of information automatically through your use of the Site:
- Cookies, Device Identifiers, and Similar technologies
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services, including Google Analytics. For more information on Google Analytics’s processing of your information, please see “How Google uses data when you use our partners’ sites or apps.” You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- Log File Information
When you use our Site, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients.
We use Log File Information collected from our implementation of the Site to help secure the Site by identifying potential threats and vulnerabilities and in analyzing the effectiveness of our Site to improve the Site’s function and content.
We use Personal Information the following purposes:
- Responding to your inquiries and customer service requests;
- Making our Site available to you;
- Analyzing, administering, and improving the Site;
- Enabling secure use of the Site and preventing fraud;
- Sending information and promotional materials (e.g., newsletters and service updates);
- Protecting our rights or our property;
- Meeting legal obligations; and
- For other purposes related to the reasons for which you provide Personal Information.
We will retain your Personal Information for at least as long as necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Notice or any longer retention period required by law.
We will not disclose Personal Information except as set forth in this Privacy Notice or with your consent. This section describes to whom we disclose Personal Information and for what purposes.
- We disclose Personal Information with our affiliated businesses. Our affiliated business may use Personal Information in accordance with this Privacy Notice, including for those affiliates’ marketing purposes.
- Our Service Providers. We engage service providers to perform tasks on our behalf and to assist us in operating the Site or providing our products and services. For example, we engage third parties to provide analytics services, send newsletters, and Site functionality. We take commercially reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
- Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of our business or assets to another organization (g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Site, including Personal Information, may be among the items sold or transferred.
- Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies; in response to subpoenas, court orders, or other legal process; to establish, protect, or exercise our rights; to defend against a legal claim; to protect the rights, property, or safety of any other person; or as otherwise required by law.
We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process.
Despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.
If you would like to access, update, or delete Personal Information about you, you may submit a request using the contact information in Section 12, below. We will promptly review all such requests in accordance with applicable law.
If you are a resident of California, please see the information below in Section 8 (California Residents) for more information regarding your rights.
We may send newsletters, notifications, promotions, or other information via email (“Communications”). You may choose to stop receiving Communications by clicking on the unsubscribe link at the bottom of our emails. Please note that certain Site-related Communications are necessary for the proper functioning and use of the Site (e.g., to send you emails following your booking inquiry) and you may not have the ability to opt out of those Communications.
If you are using our websites from outside the United States, please be aware that Personal Information will be collected, stored, and processed in the United States. Please be aware that the data protection laws of the United States might not be as comprehensive as those in your country.
We do not knowingly collect or solicit any Personal Information from children. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.
We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing Personal Information to third parties.
We may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Notice as appropriate under the circumstances. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Site.
Depending on your relationship with us, certain rights may apply with respect to your personal data. Please contact us using the information in Section 12 for more information about your rights, and how to exercise them.
12. How to Contact Us
If you have any questions about this Privacy Notice or the Site, please submit a request using the following:
13. California Residents
This section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. Please note that the CCPA is experiencing further changes as part of the rulemaking activity process. As a result, please check back often as this Section may change to comply with future CCPA requirements.
If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 12 above.
A. Categories of Personal Information Collected, Used, and Disclosed
In accordance with California law, we collected and disclosed the following categories of Personal Information within the past 12 months:
|Categories of Personal Information Collected & Disclosed|
|Identifiers – A real name, Internet Protocol address, or email address,|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – e.g., a name, address, telephone number. Some personal information included in this category may overlap with other categories.|
|Internet or other similar network activity – Information on a consumer’s interaction with a website, application, or advertisement.|
|Geolocation data – Physical location or movements.|
|Inferences drawn from other personal information – Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
We disclose each of these categories of Personal Information to our service providers to the extent necessary for them to facilitate our business purposes (including any purpose specified in Section 2, above). Additionally, some of our online advertisers may have used and disclosed Usage Information collected automatically from the Service. Regardless of whether this a “sale” of Personal Information as defined by California law, we provide you the right to opt out of cookies used for online behavioral advertising as described in Section 1(B), above.
In the last 12 months, we do not have knowledge that we sold any Personal Information of California Consumers, nor actual knowledge that we sold the Personal Information of California Consumers under the age of 16 years old. The CCPA defines “sale” as: selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to another business or third party for monetary or valuable consideration.
If we do sell your Personal Information, we will notify you, and if you submit to us a verifiable consumer request using the contact information in Section 7 below, we will disclose to you a list containing the categories of Personal Information that we sold in accordance with the CCPA’s requirements.
B. Your California Privacy Rights
If you are a resident of California, you have the following rights:
- Right to Know. You may have the right to request information on the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.
- Right to Delete. You may have a right to request us to delete Personal Information that we collected from you.
If you would like to exercise your rights listed above, please contact (or have your authorized agent contact) us at the contact information provided in Section 12, above. When doing so, please tell us which right you are exercising and provide us with contact information to direct our response.
We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes (e.g., tax accounting). You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.
The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.
14. Individuals in the EU
In this section, we provide additional information relating to how we process Personal Information of individuals in the EU, in accordance with the General Data Protection Regulation (GDPR). If you need more information or would like to exercise your rights under the GDPR, you may contact us at firstname.lastname@example.org.
A. Basis for Processing
- where we need Personal Information to perform a contract with you;
- where the processing is in our legitimate interests (including the purposes described, above, in Section 3);
- where the processing is necessary for us to meet our applicable legal obligations; or
- if we otherwise have your consent.
B. Your Privacy Rights
Depending on applicable law, you may have the right to:
- Request access to Personal Information about you.
- Request correction of the Personal Information that we hold about you.
- Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of Personal Information to you or to a third party.
- Withdraw consentat any time where we are relying on consent to process Personal Information about you.
If you wish to exercise any of these applicable rights, please contact us at email@example.com.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at firstname.lastname@example.org, so we have an opportunity to address your concerns directly before you do so.