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PRIVACY POLICY FOR CLUB SOLARIS

Last update: 01-April-2020

STATEMENTS

VILLAS SOLARIS S. DE R.L. DE C.V. Being a company incorporated under the Mexico laws, with mailing address at Av. Reforma Sur No. 1000 Col. Industrial Jorge Carreño, Tehuacán Puebla, CP 75770. It is responsible for collecting Personal Data, using it at its convenience, taking care of it, using it for electronic bills. Personal data will be used to provide the service requested, to notify about any changes and to assess the quality service provided by VILLAS SOLARIS. The data will be processed in accordance with the Mexican Federal Law, Personal data Protection issued by authorities in the field. The Confidentiality of Data is ensured through administrative secure measures.

OBJECTIVE & IMPORTANCE

The Privacy Notice has as an objective to establish the terms and conditions under which VILLAS SOLARIS S. DE R.L. DE C.V. protects Personal Data for its Costumers, Members, Guests and Suppliers. This is controlled under the Mexican Federal Law terms and conditions on Protection of Personal Data Held by Private Parties (“LFPDPPP”). This Privacy Notice allows VILLAS SOLARIS S. DE R.L. DE C.V. to accomplish its Contractual obligations, as well as those derived from Legislation and Administrative Regulation on the Protection of Personal Data in Mercantile and Tax matters.

VILLAS SOLARIS S. DE R.L. C.V. undertakes to observe the Principles of Legality, Consent, Information, Quality, Purpose, Loyalty and Responsibility in the management of Collecting Personal Data without using fraud or deception. The use of Personal Data is limited to the fulfillment of the set out Purposes in this Privacy Notice. VILLAS SOLARIS S. DE R.L. DE C.V. agrees to cancel or delete the Information provided once this information is no longer in service, only in that case, the customer is no longer required to fulfill the purposes set out in this Privacy Notice. This has as aim to preserve such information and documentation required to comply with the Obligations stated on the Commercial Code, on the Federal Tax Code and other Tax Laws current or future applicable law.

LIABILITY POLITIC: In order to comply with this Privacy Notice (LFPDPPP) and with the Administrative Law, VILLAS SOLARIS S. DE R.L. DE C.V. has established the Personal Data Department at the company to process applications to enforce the Costumers' Rights.

INFORMATION AND DOCUMENTATION OF THE DATA COLLECTION

VILLAS SOLARIS S.A. DE C.V. Collects and uses the Personal Data, Information that can identify Customers fairly and information that can be recorded in several legal documents. Personal Data that can be collected includes: Name, Last Name; birthdate and place of birth; country of origin and nationality; profession, occupation or activity; mailing address; Email address; phone number and/or cellphone number; Credit and/or debit card number, financial institution that issues it, date of issuance and expiration, security digit and bank account; Social Security Number; auto-register data; any Official ID with the Customer photo, this last one needs to be scanned to have it on file. VILLAS SOLARIS members, customers, guests and suppliers have the Right to advice any illness, disability or handicaps that do not allow them to enjoy completely of the facilities at Solaris.

INFORMATION PURPOSES

Personal Data will be collected and processed for the following purposes:

  1. Manage VILLAS SOLARIS members, customers, guests, and suppliers Data and keep it updated on file.
  2. Establish communication with VILLAS SOLARIS members, customers, guests and suppliers providing information of Contracted Services and Activities.
  3. Carry out Marketing Services based on: booking confirmation form and receipt of payments.
  4. Record and ensure the confirmed booking according to conditions previously agreed.
  5. Provide legible information to VILLAS SOLARIS members, customers, guests and suppliers regarding Politics in the Contract, kind of services provided, facilities, the ways of payment, services rates, calendars and any other information needed for reservation, the confirmation of the reservation, Services dates and time.
  6. Release the Meal and Beverage service, room service, room maintenance, telephone service, parking, and entertainment based on predefined policies.
  7. Arrange the payments schedule of VILLAS SOLARIS members, customers, guests and future members. Arrange the way of payment, being by credit card, cash, check or a wire transfer.
  8. Process payment, elaborate and send the physical or digital invoice.
  9. Manage credit to Customers, guests, members, and future members.
  10. Send advertising brochures, including Specials' Notifications that can provide information from the Resorts' suppliers, these will be sent to each Member of VILLAS SOLARIS. Members who do not want to receive such notifications need to request it by email to info@clubsolaris.com
  11. Manage check in and check out of Members, guests, suppliers, and future members based on predefined and communicated policies.
  12. Control access to the Resort facilities.
  13. Control Guests access to the Resort.
  14. Safeguard All VILLAS SOLARIS members' goods. VILLAS SOLARIS destroys or sends and delivers the Member's objects, documents, or any other members' valuables.
  15. Visualize upcoming Members and Suppliers, consider the benefits in both parties and make the negotiation, agreement and arrange the purchase and/or sale.
  16. VILLAS SOLARIS S. DE R.L. DE C.V. has implemented on-site video surveillance cameras for security purposes. These recordings will be stored in a secure and restricted are, where only Managers and Directors will have access. These recordings also will be destroyed unless they are needed for legal searching or any other follow-ups based on Mexico Law.

TRANSFER OF PERSONAL DATA TO A THIRD PERSON

VILLAS SOLARIS S. DE R.L. DE C.V. responsible for the personal data obtained may transfer to related parties, whether national or foreigners who are part of the economic group to which it belongs. In that case VILLAS SOLARIS S. DE R.L. DE C.V. adopt the measures and provisions necessary for persons and entities who have access to their personal data, comply with the privacy and security standards themselves. Including in them the principles of protection of personal data provided in the applicable legislation. In effect, lend their services and carry out the processes described in paragraph V above.

STORE AND SECURE PERSONAL DATA

VILLAS SOLARIS S. DE R.L. DE C.V. stores Personal Data as long as necessary to process Members' requests and/or services as well as to keep up-to date the accounting, the financial statements and the auditing in terms of Commercial law, tax and administrative regulations. Personal Data collected by VILLAS SOLARIS S. DE R.L. DE C.V. is protected by administrative security measures suitable to any damage, loss, alteration, destruction or use of none authorize Data access based on the National Law (LFPDPPP). All Personal Data is stored in Electronic form, in confidential and secure databases. When processing Personal Data assets as well as Bank Account Information, VILLAS SOLARIS S. DE R.L. DE C.V. uses procedures designed to protect Members' Personal Data by using Secret Usernames and Passwords. Such Data is stored in Computer Systems protected against viruses, spyware and other malicious codes. In addition, VILLAS SOLARIS uses Firewall-protected networks and controlled access facilities.

PERSONAL DATA DEPARTMENT

In case of making any update to the Privacy Notice, VILLAS SOLARIS MEMBERS will be notified by this website. At the same time, Members have the right to access, correct and/or cancel his/her Personal Data, as well as to disagree on VILLAS SOLARIS using such Data. In order to know and to have the procedure done, the Member needs to contact the Personal Data Department by sending the request to the following e-mail address: info@clubsolaris.com Members can also go to the Main Office at Av Reforma Sur No. 1000 Col. Industrial Jorge Carreño, Tehuacán Puebla, Mexico, CP 7577, visit VILLAS SOLARIS website https://clubsolaris.com and/or call to +52 (998) 800 1352.

ARCO RIGHTS (Access, Ratification, Cancellation and Opposition)

VILLAS SOLARIS MEMBERS have the right to get their Data corrected or updated on file, have the right also to request the removal of Data Information anytime. VILLAS SOLARIS will respect Members' decision not using their Personal Data for any purpose once the member requested not to use such Data. Therefore, Data will be cancelled and deleted from the system.

CHANGES TO PRIVACY NOTICE

VILLAS SOLARIS S. DE R.L. DE C.V. may modify this Privacy Notice any time in order to implement improvements or to add new and innovative Secure Measures updated also in the National Law. Due to this, VILLAS SOLARIS encourages you to check your account often to keep you updated.

APPROVAL

You as Member agree on VILLAS SOLARIS collecting your Personal Data in accordance with this Privacy Notice. You also agree on stating on a form by your own that you will provide the requested information voluntarily, form that can be sent by email, fax or postal mail. On the other hand, VILLAS SOLARIS S. DE R.L. DE C.V. agrees on not destroying the form, having it on records for tax and accounting purposes to comply with Legal Obligations. However, the Personal Data provided will not be used for any other purposes once you request to delete such information.

NATIONAL LAW

This Privacy Notice is based on the Federal Law on Protecting Personal Data in Possession of Individuals, the Federal Civil Code and other laws and administrative regulations that currently apply.

YOUR PRIVACY

Our Website follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information.

Definitions

Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies: Cookies are small pieces of data stored on a User's device.

Data Controller: Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject: Data Subject is any living individual who is the subject of Personal Data.

User: The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Trackers/Pixel: A piece of software that gathers non-personal information and follows and records the behaviors of users across different websites.

Transactional email: is a method of customer communication in which automated, real-time messages are sent to users through email after a specific action has been performed within an application or website. ... These emails often contain valuable information that is critical to the customer experience.

Information Collection And Use

We collect several types of information (personal and/or contact data) for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data: While using our web page and reservation online system, we may ask you to provide us with certain personally identifiable information that can be used to identify you Personal Data". Personally, identifiable information may include but is not limited to: Name, Address, State, Province, ZIP/Postal code, City, Cookies, and Usage Data.

We may use your Personal Data to contact you with marketing or promotional information you are or were interested in. For instance: you are interested in having a holiday at Club Solaris and fill out the form at the check out of the reservation system we will hold your personal information for further use. Your payment information will be securely transferred to the third-party service for payment processing.

Contact Data: Using our web page and reservation online system, we may ask you to provide us with certain contact information that can be used to contact you ("Contact Data"). This data may include but is not limited to: Name, email address, Phone number Cookies, and Usage Data.

We may use this information Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

For instance: you are interested in having a holiday at Club Solaris and fill out the contact form we will hold your contact information for further use (contact you back), for the given channels and give you more information about holidays, news and promotions. You can safely unsubscribe from the newsletters in the link at the bottom of each email.

If you are filling the form at the checkout page and the email field has data and the system is interrupted abruptly, as part of our customer service, our online reservation system will use that data to send you a customer service email for one single time, so that you do not lose the possibility of booking with us. We will NOT store that contact data information in compliance with the GDPR and CCPA guidelines.

Usage Data: We may also collect information on how the Service is accessed and used Usage Data. This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data:We use cookies and similar tracking technologies to track the activity on our website and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from the website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use: session cookies and preference cookies (we use these cookies to remember your preferences and various settings).

Use of Data

We use the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Disclosure Of Data

Disclosure for Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), TermsFeed legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Club Solaris may process your Personal Data because:

  • You have given us permission to do so
  • The processing is in our legitimate interests and it's not overridden by your rights
  • For payment processing purposes
  • To comply with the law

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Club Solaris aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information
  • The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time when Club Solaris relied on your consent to process your personal information.
  • Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

"Do Not Sell My Personal Information" Notice for California consumers under California Consumer Privacy Act (CCPA)

Under the CCPA, California consumers have the right to:

  • Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
  • Request that a business deletes any personal data about the consumer that a business has collected.
  • Request that a business that sells a consumer's personal data, not sell the consumer's personal data (Club Solaris do not sell your personal data)
  • If you make a request, we have 30 days to respond to you. If you would like to exercise any of these rights, please contact us.

Service Providers

We may employ third party companies and individuals to facilitate our Service Service Providers, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Google Ads

Google Ads is a targeted ad service offered by Google, it uses a pixel, which is a code in our website that allows collecting information to track Google Ads conversions, optimize it, build targeted audiences in conjunction with Google Analytics, and re-target the public that has already taken action on this website.

This code works by placing and activating cookies on your computer that tracks the interaction with this website and Google Ads.

For more information on the privacy practices of Google, please visit the Facebook Privacy and Cookies web page:
https://policies.google.com/privacy

Crazy egg

Crazy egg is a web service offered by Crazy Egg, Inc. that tracks your clicks and randomly, session recordings to provide reports of the user's behavior while surfing certain pages of our website with the purpose of knowing relevant areas and improving the quality of the content you receive.

For more information, on the privacy practices of Crazy egg privacy practices please visit the privacy web page:
https://www.crazyegg.com/privacy

Facebook

Facebook is a social network that offers targeted ads services for business, to do so, it uses a pixel, which is a code in our website and works as an analysis tool. This code allows collecting information to track Facebook Ads conversions, optimize it, build targeted audiences, and re-target the public that has already taken action on this website.

This code works by placing and activating cookies on your computer that tracks the interaction with this website and Facebook Ads.

For more information on the privacy practices of Facebook, please visit the Facebook Privacy and Cookies web page:
https://www.facebook.com/policies/cookies/#
https://www.facebook.com/privacy/explanation#

Sojern

Sojern is a provider of data-driven digital travel marketing solutions using programmatic purchasing and machine learning technology. It uses a pixel, which is a code on our website and works as an analysis tool. This code allows us to show you ads on travel or related websites and track conversions.

For more information on privacy practices of Sojern, please visit the Sojern Privacy web page:
https://www.sojern.com/privacy/

SugarCRM

SugarCRM (CRM stands for Customer Relationship Management) is a web application provided by SugarCRM Inc. We use this platform to organize, store, maintain, manage and segment your personal, contact and booking data, but is not limited to the latter. All this, to send you marketing campaigns and/or adequately track your reservations and requests

For more information on privacy practices of SugarCRM, please visit SugarCRM Inc. Privacy web page:
https://www.sugarcrm.com/legal/privacy-policy/?noredirect=en-US

SendGrid/Twilio and MailGun

SendGrid is a cloud-based solution we use to send marketing and transactional emails to our customers. This service processes part of your Contact Data such as Email, Name, Last name, and phone number to send you SMS messages.

This service stores securely for a limited period of time your Contact data with the purpose of keeping you informed and for our internal statistics, these logs are stored for a maximum of 5 days and then deleted from this third party service.

For more information on privacy practices of SendGrid, and Mailgun please visit their Privacy web page:
https://www.twilio.com/legal/privacy
https://www.mailgun.com/privacy-policy/ https://www.mailgun.com/gdpr/

TCA innsist

TCA Innsist is a cloud based software we use to operate and administer bookings and its distribution across our resorts, this software recollects and storage Personal Data and Contact Data of former reservations including, but not limited to: First Name, Last Name, Email, Phone number, special requests, and Payment reference, no sensitive data is stored.

For more information on privacy practices of SendGrid, and Mailgun please visit their Privacy web page:
https://www.tcass.com/en/privacy-policy

Google Tag Manager

Additional to the providers mentioned above, we use the service of Google Tag Manager, which is a service that allows the management of some pixels mentioned above.

Payments

We may provide paid service for booking reservations within the subdomain https://reservations.clubsolaris.com. In that case, we use third-party services for payment processing, in this case, FLAP.

We will not store or collect your payment card details. That information is provided directly to our third-party payment processor whose use of your personal information is governed by their Privacy Policy. The payment processor adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processor we work with is:
Flap Their Privacy Policy (in Spanish) can be viewed at https://www.flap.com.mx/aviso-de-privacidad/

Links To Other Sites

This Website may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address to sale of reservations at Club Solaris anyone under the age of 18 (Children)

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email, prior to the change becoming effective and update the effective date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

National Law

This Privacy Notice is based on the Federal Law on Protecting Personal Data in Possession of Individuals, the Federal Civil Code and other laws and administrative regulations that currently apply.

Contact Us

If you have any questions about this Privacy Policy, please contact us by using the following email address: info@clubsolarisresorts.com


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