1. Identification

• Data Controller: CODOMO LIVING EUROPE, S.L. (hereinafter, “CODOMO”)
• Tax ID (NIF): B19444314
• Registered office: Avenida del Conocimiento, 50, 18100, Armilla, Granada, Spain
• Email address: [email protected]

2. Information

By accepting this Privacy Policy, the user (hereinafter, the “User”) is informed that all personal data provided or collected by any means will be processed by CODOMO, including, by way of illustration and not limitation, data obtained through the website https://www.codomoliving.com/ (hereinafter, the “Website”), online or offline forms, booking or contracting tools (including booking platforms), electronic communications, video surveillance, as well as any other interaction channels, together with data derived from browsing activity and any data the User may provide in the future.

The User must carefully read this Privacy Policy, which has been drafted in a clear and simple manner to facilitate understanding, so that the User may freely and voluntarily determine whether or not to provide personal data to CODOMO.

3. Mandatory nature of providing data

The data requested by CODOMO is, as a general rule, mandatory (unless otherwise specified in the relevant field) in order to fulfill the purposes for which it is being collected.

Therefore, if the User does not provide such data, or does not provide it correctly, CODOMO may not be able to process the User’s requests, without prejudice to the fact that certain Website content may still be freely accessible.

4. Source of the data

The data processed by CODOMO for the purposes listed in the following section comes from:

• The User themselves:

  personal data provided directly by the User through any channel, including, by way of illustration and not limitation, Website forms, external forms, booking or contracting tools (including booking platforms), electronic communications, or any other means of interaction; as well as data obtained as a result of use of the Website, browsing activity (through cookies or other data storage and retrieval devices), and, where applicable, information collected through the User’s device.

• Intermediation platforms (such as Booking or similar):

  where the User makes a booking through such platforms.

• Third parties providing data:

  where a person other than the User provides personal data relating to third parties, that person guarantees that they have the necessary legal basis to provide such information and that they have previously informed the data subjects of the purpose of communicating their data to CODOMO. In such cases, liability arising from the truthfulness, accuracy, and lawfulness of the data lies solely with the person providing it.

5. For what purposes will codomo process the user's data?

CODOMO will process the User’s data for the following specific purposes:

a) Responding to User requests: using the User’s data to respond to inquiries, requests, or any communication made through the Website, forms, or any other channel, including those related to rooms, studios, services, or bookings, through electronic and conventional means.

b) Managing bookings and stays: processing the User’s data to manage the booking, contracting, and provision of services offered by CODOMO, whether carried out through the Website or external platforms (such as Booking or similar), as well as related administrative and customer care tasks.

c) Maintaining communication during service provision: using the User’s data to communicate during service provision, including, where applicable, the creation of messaging groups (for example, WhatsApp) to facilitate coordination, send relevant information, or respond to the User’s needs.

d) Sending commercial communications: managing the sending of commercial communications to Users through electronic and/or conventional means.

e) Sending commercial communications to CODOMO customers: managing the sending of commercial communications to Users who are CODOMO customers, related to services similar to those previously contracted, through electronic and/or conventional means.

f) Improving the Website experience: processing data derived from the User’s browsing activity on the Website (for example, through cookies) to analyze preferences and improve the functioning and content of the Website.

g) Compliance with legal obligations: processing the User’s data where necessary to comply with legal obligations applicable to CODOMO.

h) Service analysis and improvement: using the User’s data to prepare reports, statistics, and internal analyses regarding the use of the Website and services, in order to improve them and detect possible misuse.

i) Managing recruitment processes: processing the User’s data when the User applies for or expresses interest in working at CODOMO, for the purpose of managing their application.

j) Video surveillance: processing User data obtained through video surveillance systems in facilities managed by CODOMO, for the purpose of ensuring the security of persons, property, and premises.

k) User care and support: using the User’s data to manage incidents, complaints, or any support request related to CODOMO’s services.

l) Management of contractual relationships: processing the User’s data in connection with the management of relationships with customers, suppliers, and collaborators, including the formalization, performance, and monitoring of contracts.

6. What user data will codomo process?

During use of the Website, the following personal data may be processed:

7. What is the legal basis for processing of the User’s data by CODOMO?

CODOMO processes the User’s data on the basis of the following legal grounds:

a) Responding to User requests:this processing is based on the performance of a contract.

b) Managing bookings and stays:this processing is based on the performance of a contract.

c) Maintaining communication during service provision: this processing is based on the performance of a contract. However, where instant messaging groups (such as WhatsApp) are created or used, the inclusion of the User in such groups and the processing of their data in that context shall be based on the User’s consent, which may be withdrawn at any time.

d) Sending commercial communications: the processing for this purpose is based on the User’s consent, which may be withdrawn at any time.

e) Sending commercial communications to CODOMO customers: the processing for this purpose is based on legitimate interest, pursuant to the exception provided for in Article 21.2 of Law 34/2002 of July 11, on Information Society Services and Electronic Commerce, and Recital 47 of the GDPR. The legitimate interest is based on direct marketing in order to offer the User services that may be of interest and thereby foster loyalty. However, the User has the right to object to this processing at any time.

f) Improving the Website experience: the processing for this purpose is based on consent, which the User provides by selecting the relevant option through the initial cookie banner and which may be withdrawn at any time.

g) Compliance with legal obligations: all processing for this purpose is based on compliance with a legal obligation.

h) Service analysis and improvement: all processing for this purpose is based on legitimate interest recognized by data protection regulations. This legitimate interest is based on being able to provide Users with CODOMO services at the highest possible quality and experience.

i) Managing recruitment processes: the legal basis is the implementation of pre-contractual measures.

j) Video surveillance: the processing for this purpose is based on the performance of a task carried out in the public interest, consisting of ensuring the security of persons, property, and premises.

k) User care and support: the processing for this purpose is based on the performance of the contractual or pre-contractual relationship with the User and, where applicable, CODOMO’s legitimate interest in properly handling and managing requests, incidents, or complaints.

l) Management of contractual relationships: the processing for this purpose is based on the performance of the contract entered into with the User or, where applicable, the application of pre-contractual measures.
The consents obtained for the aforementioned purposes are independent, so the User may withdraw only one of them without affecting the others.

8. Data retention

The User’s personal data will be retained by CODOMO for the following periods:

a) Responding to User requests:such data will be retained for the duration of the relationship with the User and, once terminated, for the statutory limitation period applicable to any legal actions arising therefrom.

b) Managing bookings and stays:such data will be retained for the duration of the relationship with the User and, once terminated, for the statutory limitation period applicable to any legal actions arising therefrom.

c) Maintaining communication during service provision: such data will be retained for the duration of the relationship with the User and, once terminated, for the statutory limitation period applicable to any legal actions arising therefrom or, where applicable, until the User withdraws consent or leaves the instant messaging group (such as WhatsApp).

d) Sending commercial communications: such data will be processed for this purpose until the User withdraws previously granted consent.

e) Sending commercial communications to CODOMO customers: such data will be processed until the User objects to the sending of commercial communications.

f) Improving the Website experience: such data will be processed until the User objects to the processing and, in no event, shall relate to a period longer than one (1) year.

g) Compliance with legal obligations: such data will be retained for the periods established by law.

h) Service analysis and improvement: such data will be retained for the period necessary to prepare the relevant reports and detect possible misuse and, once these periods have ended, for the statutory limitation periods applicable to any possible legal actions.

i) Managing recruitment processes: data will be retained for the period necessary to process the job application; however, if the User is not selected, the data will be retained for a maximum period of one (1) year.

j) Video surveillance: data will be retained for a maximum period of thirty (30) days from collection, unless it must be retained for longer in order to prove acts affecting the integrity of persons, property, or premises, or where necessary for the formulation, exercise, or defense of claims.

k) User care and support: data will be retained for the time necessary to manage and resolve the request, incident, or complaint raised by the User and, once finalized, for the statutory limitation periods applicable to any possible legal actions.

l) Management of contractual relationships: data will be retained for the duration of the contractual relationship and, once terminated, for the statutory limitation periods applicable to any legal obligations, including, where applicable, tax, accounting, and administrative regulations.

9. With which recipients will the user's data be shared?

All personal data provided by the User through the Website may be disclosed to:

• Public Administrations, in the cases provided for by law, on the basis of compliance with a legal obligation.
• Courts and Tribunals, in the cases provided for by law, on the basis of compliance with a legal obligation.
• Companies belonging to the CODOMO group of companies, for internal administrative purposes, commercial management, coordination of real estate services, intermediation in transactions, customer management, and monitoring business opportunities, on the basis of the group’s legitimate interest in the efficient and coordinated management of its activity, as well as, where applicable, for the performance of the contractual relationship requested by the User. Group entities shall act as independent data controllers.
• Intermediation platforms and providers linked to booking management (such as Booking or other equivalent platforms), as well as other third parties necessary for the proper provision of accommodation services (including cleaning, maintenance, technology, or customer care providers), where disclosure is necessary for the management, coordination, and performance of the booking, stay, or related services, on the basis of the performance of the contractual or pre-contractual relationship with the User.
• Third-party service providers that may have access to the User’s personal data, who will process the personal data on behalf of and for CODOMO in connection with service provision. CODOMO follows strict provider selection procedures in order to comply with its data protection obligations, including the execution of the relevant data processing agreement in accordance with Article 28 GDPR.

10. International Data Transfers

Some of the external providers referred to in the previous section may be located in, or provide services from, countries outside the European Economic Area. In such cases, an international transfer of personal data may take place in accordance with Articles 44 et seq. of the GDPR.

Where destination countries do not benefit from an adequacy decision, CODOMO guarantees that it will adopt appropriate safeguards to protect the User’s data through the execution of the relevant Standard Contractual Clauses (“SCCs”) approved by the European Commission. Transfers may also be based on one of the exceptions set out in Article 49 GDPR, such as the explicit consent of the data subject, the necessity of the transfer for the performance of a contract, or the establishment, exercise, or defense of legal claims.

11. User Responsibility

The User guarantees that they are over fourteen (14) years of age and that the data provided to CODOMO is true, accurate, complete, and up to date. For these purposes, the User is responsible for the truthfulness of all data communicated and shall keep the information provided duly updated so that it reflects their real situation.

Likewise, the User guarantees that, where they provide third-party data, they have informed such third parties of the matters contained in this document. The User also guarantees that they have obtained authorization to provide such data to CODOMO for the purposes indicated.

12. Exercise of Rights

As data subject, the User may send a written request to CODOMO at the address indicated at the beginning of this Privacy Policy, or by email to: [email protected], at any time and free of charge. If CODOMO has reasonable doubts regarding the User’s identity, it may request additional information or documentation to verify it before processing the request.

• Right of access:
  You have the right to obtain confirmation as to whether or not CODOMO is processing your personal data and, where that is the case, to access such data and receive information about the purposes of the processing, the categories of data concerned, the recipients to whom the data has been disclosed, and the envisaged retention period, among other information.
• Right to rectification:
  You have the right to request the rectification of inaccurate personal data concerning you where, among other reasons, such data is no longer necessary for the purposes for which it was collected.
• Right to erasure:
  You have the right to request the erasure of personal data where the legal requirements are met.
• Right to restriction of processing:
  In certain circumstances (for example, where the applicant contests the accuracy of their data while accuracy is being verified), you may request the restriction of the processing of your personal data, in which case the data will only be processed for the establishment, exercise, or defense of claims.
• Withdrawal of consent:
  You have the right to withdraw consent given for reasons relating to your particular situation where the processing is based on your previously given consent (including processing for direct marketing purposes).
• Right to object, in whole or in part, to processing:
  You have the right to object to processing at any time where the processing is based on our legitimate interest or that of a third party. In such case, CODOMO will cease processing unless it demonstrates compelling legitimate grounds.
• Data portability:
  You have the right to receive the personal data you have provided to CODOMO in a structured, commonly used, and machine-readable format, and to transmit it to another data controller without hindrance from the controller to which it was provided, in the cases provided for by law.
• Automated individual decisions:
  In addition, besides the rights mentioned above, where automated decisions, including profiling, are adopted, you have the right to obtain human intervention from CODOMO, to express your point of view, and to contest the decision.
• Other:
  You may also lodge a complaint relating to the protection of your personal data with the Spanish Data Protection Agency (Agencia Española de Protección de Datos), located at calle Jorge Juan, 6, 28001 Madrid, with website www.aepd.es, when the User considers that CODOMO has infringed the rights granted under applicable data protection regulations.

13. Security Measures

CODOMO shall at all times process the User’s data in an absolutely confidential manner and shall observe the duty of secrecy required under applicable regulations, adopting for this purpose the technical and organizational measures necessary to ensure the security of the data and prevent its alteration, loss, unauthorized processing, or access, taking into account the state of the art, the nature of the stored data, and the risks to which it is exposed.

14. Changes

CODOMO reserves the right to review its Privacy Policy whenever it deems appropriate, in which case Users will be informed. For this reason, Users are requested to regularly review this privacy statement in order to read the most recent version of CODOMO’s Privacy Policy.

15. Acceptance and Consent

The User declares that they have been informed of the conditions relating to the protection of personal data and accepts the content of this Privacy Policy.