Code of ethics

Complaint channel
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"PROMOTURIST, S.A.U. has included in its organization and gesture model the following Denunciation Channel to have preventive efficacy and enable the detection of acts or behaviors that could be contrary to the general or regional legislation applicable in accordance with the Penal Code, when it imposes "the obligation to report possible risks and non-compliances to the agency responsible for monitoring the operation and the observance of the prevention model".

The Denunciation Channel is enabled for all members who are part of our company and for third parties that can inform the Compliance Officer of the existence of procedural and organizational weaknesses that may lead to a criminal risk or the commission or omission of a criminal act.

PROMOTURIST, S.A.U. guarantees the confidentiality, anonymity and exclusion of reprisals of any form against the person who made the facts known. The data will be kept in the system only during the time essential for the investigation of the facts denounced. In any case, three months after the introduction of your personal data, our company will proceed with its removal from the system. If it is necessary to preserve it, in order to continue the investigation, our company will be able to continue processing its data in a different environment to which it legally corresponds.

Complaints should be communicated to the Compliance Officer by the following means:

Model complaint form

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RESPONSIBLE FOR THE TREATMENT

 

Identity: PROMOTURIST S.A.U. (also the provider)

NIF: A07256100

Postal address: Playa de Son Bou s/n, Alaior, Menorca, 07730, (Baleares)

Email: gdpr@royalsonbou.com

Data Protection Officer: ORFILA ASSESSORS SL

DPD contact: lopd@orfilaassessors.com

In compliance with Chapter II of Act 34/2002, LSSICE, we inform you that this Website is the property of PROMOTURIST S.A.U, henceforth also of the Provider, with address in Playa de Son Bou. Alaior 07730, Menorca, telephone number +34971372358 and email: gdpr@royalsonbou.com.

PROMOTURIST S.A.U. is responsible for this Website and in accordance with the provisions of current regulations on the protection of personal data, Regulation (EU) 2016/679 as of April 27, 2016 (GDPR) on the Protection of Personal Data, with regard to the processing of personal data and the free circulation of said data, Spanish Organic 3/2018 de 5 de diciembre (LOPDGDD), Protection of Personal Data (LOPD) and Law 34/2002, as of 11 July, of the Information Society and Electronic Commerce Services (LSSICE), has implemented all security measures, both technical and organizational, established by the Spanish Royal Decree 1720/2007 of December 21 (which develops the LOPD) to guarantee and protect confidentiality, integrity, and availability of the data entered.

For the purposes of the provisions of the LOPD, PROMOTURIST S.A.U. informs you that the information you are voluntarily providing us will be incorporated into our information systems in order to carry out the necessary commercial and administrative procedures with website users. The operations foreseen to be carried out are as follows: respond to inquiries and/or provide information requested by the User; perform the provision of services and/or products contracted or subscribed to by the User; carry out all those activities of PROMOTURIST S.A.U, described in this legal notice, and submit the newsletter. Send personalized commercial communications by email or equivalent methods about our offers and services.

The signer guarantees the veracity of data provided and undertakes the need to communicate any changes that may occur in them.

The Provider, in the corresponding boxes of the contact form, informs the User of these obligations, indicating what data is necessary. By indicating and entering the data, the User grants unambiguous consent to PROMOTURIST S.A.U, to proceed with the processing of said data provided for the purposes previously mentioned.

Failure to provide the requested personal data or failure to accept this data protection policy means that it is impossible to subscribe, register, or receive information about the Provider's products and services.

In accordance with the regulations in force regarding the protection of personal data, the Provider is complying with all the provisions of the regulations GDPR and LOPD for the treatment of personal data in their responsibility, markedly with the principles described in Article 5 of the RGPD and to Article 4 of the LOPD, by which they are treated in a lawful, loyal and transparent manner in relation to the interested party and adequate, relevant, and limited to what is necessary in relation to the purposes for which they are treated.

The Provider guarantees that he has implemented appropriate technical and organizational policies to apply the security measures established by the GDPR and the LOPD to protect the rights and freedoms of the Users.

In accordance with these regulations, we inform you that you have the right to request access, rectification, portability, and deletion of your data and the limitation and opposition to your treatment by contacting Playa de Son Bou s/n Alaior 07730, Menorca, sending an email to rgpd@royalsonbou.com., indicating as Subject: "LOPD, ARCO Rights", and attaching a photocopy of your ID or any similar legal identification, as indicated by law. You have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the lawfulness of the treatment carried out before the withdrawal of consent. You also have the right to submit a claim to the supervisory authority if you believe that your rights may have been violated in relation to the protection of your data (agpd.es).

CONFIDENTIALITY AND TRANSFER OF DATA TO THIRD PARTIES

The information you provide will be treated confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the treatment of the data and to avoid its alteration, loss, theft, treatment, or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises, and centers comply with the requirements and conditions of integrity and security as established in the current regulations.

PROMOTURIST S.A.U. will not transfer personal data to third parties, except by legal obligation. However, in the case of being transferred to a third party, information would be prior obtained by the User requesting the express consent for such assignment. The entity responsible for the database, as well as those that intervene in any phase of the treatment, and/or the entities to which they have been notified, -in any case always with the corresponding authorization granted by the user-, are obligated to observe professional secrecy, the adoption of protection levels, as well as technical and organizational measures necessary to ensure the security of personal data, avoiding, as far as possible, unauthorized access, illegal modifications, subtractions and/or loss of data, in order to ensure the corresponding level of security of the Providers’ files, according to the nature and sensitivity of the data provided by the users of this Website.

ACCEPTANCE AND CONSENT

The User declares to have been informed of the conditions regarding the protection of personal data, accepting and consenting to the automatic treatment of the same by PROMOTURIST S.A.U. in the manner and for the purposes indicated in this Policy of Protection of Personal Data.

Through this Privacy Policy we inform you that the photographs that are posted on the website are the property of PROMOTURIST S.A.U, including those of minors, of which, in order to obtain these, prior consent has been obtained from parents, tutors, or legal representatives by signing the forms made for that purpose by the centers in which the minors are part of. However, the parents, guardians, or representatives of the minors, as legal holders of the exercise of rights of previously mentioned minors, and always providing a previous formal request in writing, may indicate the refusal to use the image of the minor; in this case, the image will be shown in a pixelated form.

ACCURACY AND TRUTHFULNESS OF DATA

The User is solely responsible for the accuracy and veracity of the data sent to PROMOTURIST S.A.U. exonerating the Provider of any responsibility in this respect. Users guarantee and are held liable, in any case, regarding the accuracy, validity, and authenticity of the personal data provided, and undertake to keep the data provided properly updated. The User agrees to provide complete and correct information in the registration or subscription form.

CONTENT OF WEBLINKS

PROMOTURIST S.A.U. reserves the right to update, modify, or eliminate the information contained in the website, and may even limit or refuse access to information.

PROMOTURIST S.A.U does not assume any type of responsibility for the information contained in the websites of third parties that can be accessed through the links from any Web age owned by the Provider.

The presences of links are for informational purposes only and in no case does it imply any suggestion, invitation, or acknowledgment regarding them.

SUBMITTING OF CV (CURRICULUM VITAE)

In the event that the User submits his CV through our website, we inform them that the information provided will be treated to make them participant in the selection processes that may exist, carrying out an analysis of the applicant's profile in order to select the best candidate for the vacancy of the Provider. In case of any change in the data, please inform us in writing as soon as possible, in order to keep your data properly updated.

The data will be kept for a maximum period of one year, after which the data will be deleted guaranteeing a total respect to confidentiality, both in the treatment and in its subsequent destruction. In this sense, once the aforementioned deadline has elapsed, and if you wish to continue participating in the selection processes of the Responsible Party, please resubmit your CV.

PROMOTURIST S.A.U. NEWSLETTER SUBSCRIPTION

In the event that the User subscribes to the newsletter, we inform you that the information provided will be processed to manage your subscription to the newsletter with update notices and that it will be kept until there is a mutual interest to arrive to the end of the treatment. When it is no longer necessary for that purpose, they will be eliminated with adequate security measures to guarantee the total destruction of the data. The data will not be communicated to third parties, except where there is a legal obligation to do so.

CHANGES IN THIS PRIVACY POLICY

PROMOTURIST S.A.U. reserves the right to modify the current policy in order to adapt it to new legislation or jurisprudence.

COMMERCIAL MAIL

According to the LSSICE, PROMOTURIST S.A.U, does not perform spam practices. Consequently, in each of the forms of the Web Page, the User has the possibility of giving his express consent to receive our newsletters, independently of the commercial information punctually requested.

LEGISLATION

For all purposes, the relations between PROMOTURIST S.A.U. and the Users of its telematic services, present on this Website, are subject to the Spanish legislation and jurisdiction to which the parties expressly submit, being competent for the resolution of all disputes arising or related to their use the Courts of Baleares.

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