Privacy Policy

Privacy Policy for Bastion Luxury Hotel

PERSONAL INFORMATION PROCESSING POLICIES:

FIRST: GENERALITIES

We have a special interest in protecting and respecting your personal information and data, which is why we have designed these information processing policies within the framework of Law 1581 of 2012 and Regulatory Decree 1377 of 2013.

1.1 Introduction

The HOTEL, other GHL hotels, the companies that operate them, and GHL LOGISTICS GHL may collect personal data from their users, guests, or visitors through various means provided for accessing the services provided by them. In any case, collection will be done with the express authorization of the data owner, and the processing of this data will be subject to what is established by the law. The personal information subject to the considerations established here may be collected by the Hotel through the website www.bastionluxuryhotel.com, by visiting or acquiring services offered on the platform. The considerations set forth here will be understood as accepted by the Information Owner when they visit or use the website www.bastionluxuryhotel.com and/or when they enter data or personal information through the functions established for this purpose, regardless of the purpose.

1.2 General Principles

The collection and gathering of personal data, as well as the use, processing, exchange, transfer, and transmission of such data by the HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS, will always be guided by principles of legality, freedom, truthfulness, transparency, security, confidentiality, the principle of access, and restricted circulation.

1.3 Legal Definitions

In accordance with Law 1581 of 2012 and Decree 1377 of 2013, the following definitions will govern the policies for the processing of personal information.

1.3.1 Data Processor: By data processor, we mean the natural or legal person, public or private, who, on their own or in association with others, processes personal data on behalf of the Data Controller. 1.3.2 Data Controller: By data controller, we mean the natural or legal person, public or private, who, on their own or in association with others, decides on the database and/or the processing of the data. 1.3.3 Database: By database, we understand the organized set of personal data that is subject to processing. 1.3.4 Personal Data: By personal data, we mean any information linked or that can be associated with one or more specific or identifiable natural persons. 1.3.5 Sensitive Data: Sensitive data are those that affect the privacy of the Data Owner or whose improper use could lead to discrimination, such as data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations, or promoting interests of any political party or ensuring the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data. 1.3.6 Public Data: Public data is data that is not semi-private, private, or sensitive. Data related to a person's marital status, profession, trade, or public servant status are considered public data, among others. By their nature, public data may be contained, among others, in public records, public documents, gazettes and official bulletins, and duly executed court judgments that are not subject to confidentiality. 1.3.7 Transfer: Data transfer occurs when the Data Controller and/or Data Processor, located in Colombia, sends information or personal data to a recipient who is also a Data Controller and is located within or outside the country. 1.3.8 Transmission: Processing of personal data that involves the communication of such data within or outside the territory of the Republic of Colombia when the purpose is to carry out Processing by the Processor on behalf of the Controller.

SECOND: OWNER'S AUTHORIZATION:

The provided data will be subject to authorized processing, granted in advance, expressly and informed by the Owner of the data, directly to the HOTEL or through other GHL hotels, the companies that operate them, or GHL LOGISTICS.

However, visiting, entering, or using the website www.bastionluxuryhotel.com constitutes prior, express, and informed authorization for the storage, collection, and processing of information in accordance with the data processing policy contained herein.

In any case, the collection of data will be limited to those personal data that are relevant and appropriate for the purpose pursued with them.

THIRD: INFORMATION PROCESSING:

3.1 Collected Data. The collection of data for the development of the Processing and the purposes pursued by it will focus on personal data received and stored by the HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS. It will encompass all the information provided or provided during the visit to the website www.bastionluxuryhotel.com, as well as all information related to services or reservations made, and accommodation and lodging data provided to the HOTEL or any of the GHL hotels.

Without prejudice to the fact that in some cases they are public data, the collected information will correspond to the name, citizenship card number, profession, nationality, date of birth, email address, personal preferences and interests, work or activity, consumption habits or travel habits, among others. If a reservation is made through the website www.sonestapereira.com, information related to the credit card provided for the purposes of the reservation and stay will be collected.

3.2 Processing to which the data will be subjected and its purpose.

The data and information obtained and collected will be used in the normal course of its business activities only for the purpose established in these information processing policies, in a way that allows for direct and effective communication with the client, leading to establishing a closer relationship.

The processing consists of sending digital information through different communication channels, with the intention of contacting the Owner to send service surveys after each stay to allow for the rating of the service provided, and communicating invitations, offers, promotions, service portfolios, or information from the HOTEL or other GHL hotels, without at any time providing, transferring, or delivering your data to individuals or entities other than the Hotel that collected the information, or to GHL hotels and activities and companies linked to GHL and the activities they perform. Additionally, through data collection, the aim is to: make, process, handle, and/or complete hotel reservations or purchase of hotel nights or other services; conduct internal studies on tourism habits; evaluate the quality of our services; send surveys and questionnaires regarding the services provided; promptly address your requests, petitions, or needs; communicate invitations, offers, promotions, and general information about the service portfolios offered by natural or legal persons directly linked to hotel operations and specifically with the services provided by GHL Hotels or GHL and the companies and hotels that operate them.

The information or data provided and collected in accordance with these policies may be shared, transmitted, updated, and/or deleted between the HOTEL, other GHL hotels, the companies that operate them, and GHL LOGISTICS for the purpose defined in these policies, to be used in the manner established here. By accessing the website www.bastionluxuryhotel.com, you authorize your information and data to be shared with the tourism providers to which they refer and with whom your reservations and/or requests are processed.

It is assumed that all the information or data provided or deposited through the website www.bastionluxuryhotel.com is true, accurate, and complete, and it may be withdrawn at any time

without any liability on the part of the HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS, for any claim arising from the effects caused by such withdrawal.

In all cases, you will have the possibility to opt-out and request not to receive digital information through the means enabled for this purpose.

FOURTH: RIGHTS OF THE INFORMATION OWNER:

4.1 The Owner of the information and personal data collected through the HOTEL, other GHL hotels, the companies that operate them, and GHL LOGISTICS, in accordance with the processing and protection of personal data policies, will be entitled to exercise the rights of access, correction, updating, deletion, and revocation of authorization, as well as make inquiries and claims, regarding their personal data.

4.2 Right of Access: The Owner of the information may obtain from the HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS, at any time and without any restriction, information about the existence of data that concerns them.

4.3 Right of Correction, Updating, and Deletion: The Owner of the information is entitled to request from the HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS, the correction, updating, or deletion of their data, when they consider them to be partially or entirely inaccurate, erroneous, incomplete, or outdated.

4.4 Right of Revocation of Authorization: The Owner of the information and data provided is entitled to revoke at any time the authorization for the processing of their data, without any retroactive effects being attributed to this action.

4.5 Mechanisms for Exercising Rights: The rights of access, correction, updating, deletion, and revocation of authorization can be exercised by sending a written communication to the HOTEL's email address, which can be consulted on the website www.bastionluxuryhotel.com.

4.6 Query and Claim Mechanism: For queries or claims related to the processing of personal data, the Owner may contact the HOTEL through the communication channels enabled for this purpose on the website www.bastionluxuryhotel.com.

4.7 Data Processing Security: The information and personal data provided by the Owner will be stored and maintained under security measures that are required by the nature of the data and will be used only for the purpose for which they were collected.

4.8 Confidentiality of the Owner's Information and Data: The information provided by the Owner will be treated with confidentiality. The HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS, in accordance with the processing and protection of personal data policies, may assign, transmit, and transfer the information provided by the Owner to natural or legal persons directly linked to hotel operations and specifically with the services provided by GHL Hotels or GHL and the companies and hotels that operate them.

FIFTH: CONSENT:

By using the website www.bastionluxuryhotel.com, providing information, and using the services offered, you accept and authorize the HOTEL, other GHL hotels, the companies that operate them, and GHL LOGISTICS to collect, use, process, transmit, and transfer your information and personal data under the terms established in these processing policies. Also, you expressly accept the transmission of your data and information to other countries for the purpose of carrying out the processing as set out in these policies.

SIXTH: TRANSFER OF DATA TO THIRD PARTIES:

The information provided by the Owner and/or User may be shared, transmitted, updated, and/or deleted between the HOTEL, other GHL hotels, the companies that operate them, and GHL LOGISTICS for the purpose defined in these policies, as well as to be used in the manner established in this document. By accessing the website www.sonestapereira.com, you authorize your information and data to be shared with the tourism providers to which they refer and with whom your reservations and/or requests are processed.

SEVENTH: MODIFICATIONS TO INFORMATION PROCESSING POLICIES:

The HOTEL reserves the right to modify, at any time, the policies for the processing of personal information or data. The modified policies will be informed to the Owners of the information and data through the means of dissemination deemed appropriate by the HOTEL, other GHL hotels, the companies that operate them, or GHL LOGISTICS.

EIGHTH: EFFECTIVENESS OF THE INFORMATION PROCESSING POLICIES:

The present policies for the processing of personal information or data will take effect as of the date of their publication on the website www.bastionluxuryhotel.com.

The terms contained in these information processing policies will be governed and interpreted in accordance with the laws of the Republic of Colombia. Any controversy that arises from this document, its validity, execution, compliance, modification, termination, or termination, total or partial, will be submitted to the competent courts in accordance with the laws of the Republic of Colombia.

[End of Privacy Policy]

Please note that this template is provided for informational purposes only and may not cover all specific legal requirements in your jurisdiction. It's recommended to consult with legal professionals to ensure that your privacy policy complies with all applicable laws and regulations.