I. Privacy Policy

In compliance with the provisions of Law 34/2002 of 11 July on Information Society Services and E-Commerce (LSSICE), the general information details for the website www.keyfamilyapartments.com are indicated below. This includes information on the activity developed by:

• KEY FAMILY, S.L.
• Tax ID (CIF) B66094848
• Commercial Registry of BARCELONA Volume 43878, Sheet 11, Page 440766, Entry 1.
• Entry Date: 26 July 2013.
• Registered Office: Calle Guinardó, 24. 08041 Barcelona.
• Telephone: +34 93 349 47 42
• Email Address: info@keyfamilyapartments.com

II. Use of the Website

The website, www.keyfamilyapartments.com, is offered with information purposes in relation to the activity developed by the company KEY FAMILY, S.L. The activities undertaken by said company focus on tourist apartment management.

III. Privacy

The information that KEY FAMILY, S.L. gathers from users of this website will be used exclusively to attend to the information requests made.

IV. Links to Third Parties

Regarding links to third-party websites, the user will be governed by the Terms and Conditions of Use and the Privacy Policy of the new website, accepting that KEY FAMILY, S.L. will not be liable nor will it have any legal obligation in relation to the use of said sites.
V. Copyright
All brands, logos, commercial names, distinctive signs, services, contents, texts, photographs, graphics, images, software, links and information of any kind that appear on this website are the property of KEY FAMILY, S.L., meaning they may not be reproduced, distributed, publicly communicated, transformed or modified without express authorisation.

VI. Modifications to the Terms and Conditions of Use and the Privacy Policy

KEY FAMILY, S.L. reserves the right to modify its Terms and Conditions of Use and Privacy Policy when it considers any changes necessary. The user undertakes to review the content of the Terms and Conditions of Use and the Privacy Policy, as they may be modified without prior notice. Furthermore, the user understands and accepts each of the clauses contained herein. The user is fully liable for reviewing the aforementioned terms and conditions.

VII. Data Protection Policy

This website belongs to KEY FAMILY, S.L. and is offered with information purposes in relation to the activity developed by the company KEY FAMILY, S.L.
KEY FAMILY, S.L. wishes to guarantee your privacy when using its services, for which reason the following declaration will inform you of our personal data protection policy, allowing you to voluntarily decide to what degree you wish to provide said data.
Pursuant to the provisions of the Data Protection General Ruling mentioned previously, the personal data you send us via the forms on our website will undergo “Website user and client” data processing.
To process the data of our users, we implement every technical and organisational security measure established in current legislation.
The personal data you provide will be solely and exclusively used to offer you the information you request regarding any of our products or services.
The user undertakes to correctly facilitate the contact information requested, such as name, email address, passport number and postal address. In some cases financial information will be requested, such as credit card number and expiry date, or personal information, such as a copy of your passport. We ask for this information in our accommodation booking form for billing purposes and to formalise the contract.
Your data will be processed at all times in accordance with data protection legislation, guaranteeing the confidentiality and integrity of the information you provide, in view of the state of technology, the nature of the data stored, and the risks to which it may be exposed, all in accordance with the provisions established in current regulations.
With regard to personal data processing for the data provided by people requesting information, we hereby inform you that, in cases in which it is required for the suitable provision of service, your data will be included in a personal file, duly registered with the Spanish Data Protection Agency, with the aim of attending to the corresponding requests for information.
All procedures with a credit card are carried out by a company specialised in online payments: BBVA.

Principles we will apply to your personal information

When processing your personal data, the following principles will be applied, all of which adapt to the demands of the new Data Protection General Ruling:

• Principle of legality, fairness and transparency: We will always require your consent to process your personal data for one or several specific purposes, which you will be informed of previously in a fully transparent manner.
• Principle of data minimisation: You will only be asked for the data that are strictly necessary in relation to the purposes for which we require them. These will be the minimum possible.
• Principle of storage period limitation: Data will only be kept for the time necessary for the purposes of processing. Depending on the aim, you will be informed of the corresponding storage time frame. In the case of subscriptions, our lists will be periodically reviewed and we will remove any subscriptions that have been inactive for considerable time.
• Principle of integrity and confidentiality: Your data will be processed such that appropriate security of the personal data involved is guaranteed, as is their confidentiality. You should know that we take every precaution necessary to prevent unauthorised access or undue use of our users’ data by third parties.

How have we obtained your data?

The personal data we process here at KEY FAMILY, SL come from:

• Contact form
• Returning customers

What are your rights when you provide us with your data?

Stakeholders have the right to:

• Request access to their personal data
• Request their rectification or suppression
• Request the limitation of processing
• Oppose their processing
• Request data portability
• Revoke consent

Stakeholders will also have the right to effective judicial protection and to present a claim before the control authority, in this case the Spanish Agency for Data Protection, if they believe the processing of personal data that concerns them has violated their rights or freedoms.

For what purposes do we process your personal data?

When a user connects to this website to, for example, comment on a post, send an email to the owner, contract a service, etc. they are facilitating personal information for which KEY FAMILY, SL is responsible. This information may include personal data, such as your IP address, name, physical address, email address, telephone number, and other information. By providing this information, the user consents to their information being gathered, used, managed and stored by KEY FAMILY, SL as described in our Privacy Policy.
At KEY FAMILY, SL there are different systems for gathering personal information and processing the information provided to us by the people in question for the purposes indicated according to each gathering system (forms):

• Contact form: We request the following personal data: Name and surname(s), email address to reply to the requests of KEY FAMILY, SL users. For example, we use these data to answer your request and reply to the questions, complaints, comments or concerns you may have in relation to the information included on the website, the services that are offered via the website, processing of your personal data, or any other consultations you may make and which are not subject to the terms and conditions of contracting. The data you provide will be stored on the servers of CDMon and Icnea Tecnología S.L. (KEY FAMILY, SL supplier) within the EU.
• Contracting form: We request the following personal data: Name and surname(s), ID or passport number, address, email address, period of stay, credit card details, etc. to make the booking at the KEY FAMILY, SL apartment. For example, we can use these data to answer your request and reply to the questions, complaints, comments or concerns you may have in relation to the information included on the website, the services that are offered via the website, processing of your personal data, or any other consultations you may make and which are not subject to the terms and conditions of contracting. The data you provide will be stored on the servers of CDMon and Icnea Tecnología S.L. (KEY FAMILY, SL supplier) within the EU.

There are other purposes for which we process your personal data:

• To guarantee fulfilment of the terms and conditions of use in addition to applicable legislation. This may include the development of tools and algorithms that help this website guarantee the confidentiality of the personal data it gathers.
• To support and improve the services this website offers.
• Other non-identification data are also gathered. These are obtained via cookies that are downloaded onto the user’s computer when they browse on this website, as detailed in the Cookies Policy.

KEY FAMILY, SL does not sell, hire out or transfer personal data that may identify the user, nor will it do so in the future, to third parties without prior consent. However, in some cases it may collaborate with other professionals, in which cases users’ prior consent will be required and they will be informed of the collaborator’s identity and the purpose of collaboration. Collaboration will always be developed following the strictest security and confidentiality standards.

Legitimacy for data processing

The legal basis for data processing is: consent.
To contact or make comments on this website, consent to this.

Privacy Policy is required

The prospective or commercial offer of products and services is based on the consent requested, without withdrawal of this consent conditioning execution of the subscribed contract in any case.

Data categories

The data categories that are to be processed are identification data: name, surname(s), address, telephone number, passport number and tax identification number. Protected data categories are not processed.

How long are your data stored for?

The personal data provided will be stored:

• Until their suppression is requested by the stakeholder.
• For the time the stakeholder is a customer. And up to five years after they have been removed as a customer, in accordance with fiscal regulations.

To which recipients will your data be communicated?

In order to provide services that are strictly necessary to develop KEY FAMILY, SL’s activity, it shares data with the following providers under the corresponding privacy terms and conditions:
Google Analytics: a website analysis service provided by Google, Inc., a Delaware company whose registered office is located at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, which are text files located on your computer, to help KEY FAMILY, SL analyse how users use its website. The information that a cookie generates about your use of KEY FAMILY, SL (including your IP address) will be transferred directly to and stored by Google on servers in the United States.
Likewise, data regarding travellers will be transferred to the Police and Civil Guard, whose legitimacy is found in art. 45.1 of the Schengen Agreement, ratified by Spain on 23 July 1993, in addition to art. 12 of Law 1/1992, of 21 February, on Citizen Safety Protection, based on the implementing regulations for the actions of documentation and information registration, Order INT/1922/2003, of 3 July, on registration books and items regarding the entry of travellers to hospitality establishments and similar.

Data security and secrecy

In using and processing users’ personal data, KEY FAMILY, SL undertakes to respect their confidentiality and use them in accordance with their purpose, as well as comply with its obligation to store them and adapt every measure to prevent their alteration, loss, unauthorised processing or access, in compliance with the provisions established in current data protection regulations.
This website includes an SSL certificate. It is a security protocol that ensures your data travel securely and wholly. In other words, the transfer of data between a server and a website user, and vice versa, is fully encrypted.
KEY FAMILY, SL cannot guarantee the absolute impregnability of the Internet and, therefore, violation of data via fraudulent access by third parties, and it is not liable for these attacks.
With regard to the confidentiality of processing, KEY FAMILY, SL will ensure that any person who is authorised by KEY FAMILY, SL to process the user’s data (including its staff, collaborators and suppliers) will be obliged to maintain their confidentiality (either contractually or legally).
If a security incident should occur, and when KEY FAMILY, SL becomes aware of this, it will notify the customer and user without undue delay if their rights and freedoms have been violated and it will provide appropriate information related to the security incident where possible: the information that is known at the time or when the customer makes a reasonable request.

Exactness and veracity of data

As the user, you are solely responsible for the veracity and correctness of the data you send us, exempting KEY FAMILY, SL from all liability in this regard, including when you provide us third-party data.
In any case, users guarantee and are liable for the exactness, validity and authenticity of the personal data provided and they undertake to keep them duly updated. The user agrees to provide full, correct information in the contact or registration form. If the data of third parties is provided, you must have been granted their prior consent.

Acceptance and consent

The user hereby declares they have been informed of the personal data protection terms and conditions, accepting and consenting to their processing by KEY FAMILY, SL in the manner and for the purposes indicated in this Privacy Policy.
Revocability and exercising of rights
The consent granted, either for processing or the transfer of stakeholders’ data, may be revoked at any time by communicating this to KEY FAMILY, SL in the terms established in this Privacy Policy for exercising rights of access, rectification, limitation, opposition, suppression and portability, writing to the address mentioned previously or by emailing info@keyfamilyapartments.com. Revoking consent will not be retrospective under any circumstance.

Changes to the Privacy Policy

KEY FAMILY, SL reserves the right to modify this Privacy Policy to adapt it to new legislation or jurisprudential modifications, in addition to industry practices. In such cases, KEY FAMILY, SL will announce the changes made on this page with reasonable notice ahead of their implementation.

Marketing emails

In accordance with Law 34/2002, on information services and e-commerce, KEY FAMILY, SL will not develop spam practices, meaning it will not send marketing emails that have not been previously requested or authorised by the user. Consequently, in each form on the website the user has the chance to grant their express consent to receive marketing communications for services and products offered by KEY FAMILY, SL, regardless of the commercial information occasionally requested.
Pursuant to the provisions of Law 34/2002, on information services and e-commerce, KEY FAMILY, SL shall not send marketing communications without duly identifying them as such.