PRIVACY POLICY

EU PRIVACY NOTICE FOR OUR CUSTOMERS AND OTHER BUSINESS-RELATED PERSONAL DATA

1. Who is responsible for processing your data?
2. Categories and Sources of Personal Data and Purposes and Lawful Basis for Processing
3. Sharing of Your Information
4. Transfers of Personal Data outside the EEA
5. Your Rights


1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US

We provide hospitality services on a global scale and aim to please our customers with our approach to the quality of service. We are committed to respecting your privacy, and this privacy notice explains how we collect, use, disclose, retain and protect your personal data.

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), LUC ROYAL S.L, company registered in Tenerife, in Geranio 16, Los Gigantes, 38683, Tenerife (or "we" or "us" or "our") will be the data controller responsible for any personal data we process.

Please take the time to read this privacy notice, since it contains important information about the way that we process personal data.

Questions, comments, complaints and requests regarding this privacy notice, or our privacy practices in general, are welcomed and should be addressed to data@lucasmaes.com or by post to LUC ROYAL S.L, Tenerife, Geranio 16, Los Gigantes, 38683, Tenerife. Any queries and requests regarding this privacy notice may be emailed to data@lucasmaes.com

We request that you please do not send us any data that could be considered sensitive, for example, health information. Any sensitive data sent to us will be securely disposed of as soon as we receive it. Other correspondence will be securely disposed of once it has been read and responded to.



2. WHAT PERSONAL DATA DO WE COLLECT AND WHY?

We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data.

In each of the sections listed below, we describe how we obtain your personal data and how we treat it.

Section 2.1 Individual Customers

Section 2.2 Business Partners, and Vendors

Section 2.3 Website Visitors

Section 2.4 Visitors to our premises



2.1 INDIVIDUAL CUSTOMERS

We collect personal data related to individual customers.
A - Sources of personal data
B - Personal data that we collect and process
C - Why do we collect your personal data and what are our lawful bases for it?
D - How long do we keep your personal data?

A - Sources of personal data

We may obtain your personal data from the following sources
a) from you directly (over the phone, email, website or paper forms or in person)
c) from third parties (for example, partner organizations, such as reservations websites, service providers that are assisting us in providing you with a service, and/or
d) from our systems, such as wifi, if you have used our internet connection services at our restaurants.

B - Personal data that we collect and process

We may collect the following categories of personal data relating to our existing or prospective individual customers:

a) name
b) email
c) title
d) personal and/or business email address
e) home address
f) home and/or business telephone number
g) date of birth
h) family members and their dates of birth. Please note that it is your responsibility to obtain consent from adult family members for sharing their personal data with us prior to providing their personal information to us
i) credit card details
j) details of your request, for example, for booking a table in one of our restaurants this will include the date, time, party size, menu selection, table preferences
k) dietary preferences
l) voucher or other discount details, if you provide them to us
m) social occasion information
n) details and records of your request, complaint or query
o) details of orders (amount spent, date, time, table number, vouchers or offers used)
p) categorization of you as a customer based on the information, we have about you from various sources (for example, if this is your first experience with us or you are a regular customer); and/or
q) any feedback you submitted about your experience with us
r) regions from which users open our marketing emails: To ensure that we can better inform people of products and services relevant to their area.

C - Why do we collect your personal data and what are our lawful bases for it?

Individual Customers: Provide you with our products or services (for example, to book a table at our restaurants or a hotel room)

We may use your personal data to: Establish and manage our relationship (this covers making your experience with us personalized, adapting our services to your requirements, such as your food preferences, dealing with complaints or maintaining your account with us)

Learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us)

Security (ensuring confidentiality of personal information or preventing unauthorised access and modifications to our systems)

Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication

Our lawful basis for doing so is: Legitimate Interest of LUCAS MAES S.L and the customer

Our legitimate interests in doing so are:

Account Management, Management Reporting (including at an intra-group level)
Exercise or defend legal claims
Understand the market in which we operate
Managing security, risk and fraud prevention
Promote our goods and services

If you object to us using your personal data for these purposes, including direct marketing, please let us know using the email address provided in section 1.

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.



2.2 BUSINESS PARTNERS, AND VENDORS

We may collect personal data related to employees, directors, authorized signatories, or business partners, and vendors.

A - Sources of personal data
B - Personal data that we collect and process
C - Why do we collect your personal data and what are our lawful bases for it?
D – How long do we keep your personal data?

A - Sources of personal data

We may obtain your personal data from the following sources:

a) from you directly,
b) from a company that employs you, if you are an employee of our existing or prospective customer, business partner, or vendor,
c) from publicly available sources (for example, your company website or social media sites)

B - Personal data that we collect and process

We may collect the following categories of personal data relating to our existing or prospective customers', business partners', and vendors' employees, officers, authorized signatories, and other associated individuals:

a) name
b) business address
c) business email address
d) business telephone number
e) job title
f) details of booking (venue, date, party size, previous functions); and/or
g) any feedback you submitted about your experience.

C - Why do we collect your personal data and what are our lawful bases for it?

Business Partners and Vendors

Provide you with our products or services (for example, to book a table at our restaurants or a hotel room), or receive services from you

We may use your personal data to: Establish and manage our relationship (this covers making your experience with us personalized, adapting our services to your requirements, such as your food preferences, dealing with complaints or maintaining your account with us)

Learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us)

Security (ensuring confidentiality of personal information or preventing unauthorized access and modifications to our systems)

Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication

Efficiently fulfil our contractual and legal obligations

Our lawful basis for doing so is: Legitimate Interest of LUCAS MAES S.L and the customer

Our legitimate interests in doing so are:

Account Management, Management Reporting (including at an intra-group level)
Exercise or defend legal claims
Understand the market in which we operate
Managing security, risk and fraud prevention
Promote our goods and services

If you object to us using your personal data for these purposes, including direct marketing, please let us know using the email address provided in section 1.

Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your business relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.


2.3 WEBSITE VISITORS

A - Sources of personal data of personal data
B - Personal data that we collect and process
C - Why do we collect your personal data and what are our lawful bases for it?
D - How long do we keep your personal data?

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a) from you directly (for example, at the time of subscribing to any services offered on our website, including but not limited to email mailing lists, interactive services or requesting further goods or services); and/or
b) from your device or browser.
If you contact us, we may keep a record of that correspondence.

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

a) name
b) title
c) date of birth, and post code, if you are signed up to our e-newsletters
d) email address
e) operating system
f) browser type
g) information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions)
h) cookie data
i) preferences regarding online marketing; and/or
j) IP address.

C - Why do we collect your personal data and what are our lawful bases for it?

Website visitors: Provide you with our products or services (for example, to book a table at our restaurants or a hotel room)

We may use your personal data to: Establish and manage our relationship (this covers making your experience with us personalized, adapting our services to your requirements, such as your food preferences, dealing with complaints or maintaining your account with us)
Learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us)
Security (ensuring confidentiality of personal information or preventing unauthorised access and modifications to our systems)
Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication

Our lawful basis for doing so is: Legitimate Interest of LUCAS MAES S.L and the customer

Our legitimate interests in doing so are:

Account Management, Management Reporting (including at an intra-group level)
Exercise or defend legal claims
Understand the market in which we operate
Managing security, risk and fraud prevention
Promote our goods and services

If you object to us using your personal data for the above purposes, including direct marketing, please send us an email using the email address in section 1.

Where we use cookies or similar technologies, we will seek your prior consent where required to do so by law.

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep your personal data?

We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.


2.4 VISITORS TO OUR PREMISES


A - Sources of personal data
B - Personal data that we collect and process
C - Why do we collect your personal data and what are our lawful bases for it?
D - How long do we keep your personal data?

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from you directly and from our systems' records.

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

a) name
b) business or personal contact details
c) organization
d) role
e) time and date of your visit; and/or
f) image (for example, from CCTV cameras at our premises).

C - Why do we collect your personal data and what are our lawful bases for it?

Website visitors: Provide you with our products or services (for example, to book a table at our restaurants or a hotel room)

We may use your personal data to: Establish and manage our relationship (this covers making your experience with us personalized, adapting our services to your requirements, such as your food preferences, dealing with complaints or maintaining your account with us)

Learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us)

Security (ensuring confidentiality of personal information or preventing unauthorised access and modifications to our systems)

Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication

Our lawful basis for doing so is: Legitimate Interest of LUCAS MAES S.L and the customer

Our legitimate interests in doing so are:

Account Management, Management Reporting (including at an intra-group level)
Exercise or defend legal claims
Understand the market in which we operate
Managing security, risk and fraud prevention
Promote our goods and services

If you object to us using your personal data for the above purposes, including direct marketing, please send us an email using the email address in section 1.

Where we use cookies or similar technologies, we will seek your prior consent where required to do so by law.

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.


D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep your personal data for as long as necessary to ensure security of visitors to our premises and as soon as it is no longer necessary, usually after 90 days for CCTV, we delete it.

3. WHO DO WE SHARE YOUR PERSONAL DATA WITH
We do not sell your personal data to third parties.

Our Partner Organizations and Service Providers

We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of service providers:

a) technical support providers who assist with our website and IT infrastructure,
b) third party software providers, including 'software as a service' solution providers, where the provider hosts the relevant personal data on our behalf.
c) professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers.
d) providers that help us generate and collate reviews in relation to our goods and services.
e) our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf (for example, Facebook, Google, Instagram); and/or
f) service providers that assist us in providing our services.

Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

5. YOUR RIGHTS

The GDPR provides you with certain rights in relation to the processing of your personal data, including to:

  • Request access to personal data about you (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.
  • Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any inaccurate information we hold about you corrected.
  • Request personal data provided by you to be transferred in machine-readable format ("data portability").
  • Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below).
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it).
  • Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of Company, as explained above.
  • Withdrawal of consent. If we rely on your consent (for example, when setting cookies on your device or for direct marketing), you may withdraw your consent at any time.
These rights listed may be subject to various conditions under applicable data protection and privacy legislation.

If you would like to exercise any of your rights set out above, you can contact us by emailing using the email address in section 1.

You also have the right to lodge a complaint with our supervisory authority, the Spanish Agency for Data Protection, which can be contacted at the following:


Website: www.aepd.es

Telephone: 901 100 099

© All Rights Reserved.
LUC ROYAL SL / B-76825280
lucas@lucasmaes.com