Privacy Policy

LAST UPDATED: 15/03/2025

The Privacy Policy forms part of the General Terms and Conditions governing the Website. www.sedaclubhotel.com together with the Cookies Policy and the Legal Notice.  

WANA INVERSIONES SAreserves the right to modify or adapt this Privacy Policy at any time. Therefore, we recommend that you review it each time you access the Website. In the event that the user has registered on the website and accesses their account or profile, upon accessing the same, you will be informed in the event that there have been substantial changes in relation to the processing of your personal data.  

Who is responsible for the processing of your data?

The data that is collected or that you voluntarily provide us with through the Website, whether by browsing it, as well as any data that you may provide us with in the contact forms, via email or by telephone, will be collected and processed by the Data Controller, whose data is indicated below: 

WANA INVERSIONES SA, CIF: A83057174 

Address: C/ Echegaray, 8, 2814, Madrid.  

SEDA CLUB HOTEL 

Address: Plaza de la Trinidad, 18001, Granada. 

Registered in the Mercantile Register of Madrid, volume 16743, folio 43, page M-285986. 

Contact WANA INVERSIONES S.A., for the protection of your personal information 

C/ Echegaray, 8, 28014, Madrid. 

Tel: 910 56 93 54 

Contact Data Protection Officer: lopd@hiddenhotels.com  

 

If, for any reason, you wish to contact us on any matter relating to the processing of your personal data or privacy (with our Data Protection Officer), you may do so by any of the means indicated above.

What data do we collect through the website?

By simply browsing the Website, WANA INVERSIONES SA, collect information concerning: 

- IP address. 

- Browser version. 

- Operating system. 

- Duration of the visit or browsing of the Website. 

Such information is stored by Google Analytics, so we refer to Google's Privacy Policy, as Google collects and processes such information. http://www.google.com/intl/en/policies/privacy/  

Similarly, the Website provides the utility of Google Maps, which may have access to your location, if you allow it to do so, in order to provide you with greater specificity about the distance and/or paths to our headquarters. In this regard, we refer to the Privacy Policy used by Google Maps, in order to know the use and processing of such data. http://www.google.com/intl/en/policies/privacy/  

The information we handle will not be related to a specific user and will be stored in our databases for the purpose of statistical analysis, improvements to the website, our products and/or services and to help us improve our business strategy. The data will not be communicated to third parties. 

User registration on the website/ Submission of forms

In order to access certain services, such as booking, the user must fill in a form. To do so, in the registration form, a series of personal data is requested. The data are necessary and obligatory to carry out such registration. If these fields are not provided, the registration will not be carried out.  

In this case, the browsing data will be associated with the user's registration data, identifying the specific user browsing the Website. In this way, it will be possible to personalise the offer of products and/or services that, in our opinion, best suits the user. 

 

The registration data of each user will be incorporated into the databases of WANA INVERSIONES S.A.The information will be stored in our databases, together with the history of operations carried out by the same, and will be stored in the same as long as the registered user's account is not deleted. Once the account has been deleted, this information will be removed from our databases, and will be kept aside for the duration of the account. 10 years those data relating to transactions carried outThe data will not be accessed or altered, in order to comply with the legal deadlines in force. Data that is not linked to the transactions carried out will be kept unless you withdraw your consent, in which case it will be deleted immediately (always taking into account the legal deadlines). 

 

The legal basis for the processing of your personal data is the performance of a contract between the parties. 

In relation to the sending of communications and promotions by electronic means and the response to requests for information, the legitimacy of the processing is the consent of the user.  

The purposes of the processing shall be the following:  

a) Manage your access to the Website.

b) To manage the purchase of the services made available to you through the Website.

c) Keep you informed of the processing and status of your requests, purchases and/or bookings.

d) Respond to your request for information.

e) Manage all the utilities and/or services offered by the platform to the user.

Thus, we inform you that you will be able to receive communications via email and/or on your telephone, in order to inform you of possible incidents, errors, problems and/or the status of your applications.  

For the sending of commercial communications, the user's express consent will be requested at the time of registration. In this regard, the user may revoke the consent given by writing to WANA INVERSIONES S.A.by using the means indicated above. In any case, in each commercial communication, you will be given the opportunity to unsubscribe from receiving them, either by means of a link and/or e-mail address.  

Newsletter Sending

In the event that, on the Website, the option to subscribe to the Newsletter of WANA INVERSIONES SAIf you do not provide us with an e-mail address, you will need to provide us with an e-mail address to which it will be sent. 

Such information will be stored in a database of WANA INVERSIONES SAIt shall remain registered until the person concerned requests to be removed from the register or, where appropriate, until it is terminated by WANA INVERSIONES SA, of sending it.  

The legal basis for the processing of this personal data is the express consent given by all interested parties who subscribe to this service by ticking the box provided for this purpose. 

The data from e-mails will only be processed and stored for the purpose of managing the sending of the Newsletter by users who request it.  

For the Newsletter to be sent, the user's express consent will be requested when registering for the Newsletter by ticking the box provided for this purpose. In this regard, the user may revoke the consent given by writing to WANA INVERSIONES SAby using the means indicated above. In any case, in each communication, you will be given the possibility to unsubscribe from receiving them, either by means of a link and/or e-mail address.  

If you are one of the following groups, please see the information below: 

WEB OR EMAIL CONTACTS

For what purposes will we process your personal data? 

  • Respond to your queries, requests or petitions. 
  • Manage the requested service, answer your request, or process your request.  
  • Information by electronic means, concerning your application. 
  • Commercial or event information by electronic means, subject to express authorisation.
     

What is the legitimacy for the processing of your data? 

Acceptance and consent of the interested party: In those cases where it is necessary to fill in a form and click on the send button in order to make a request, the completion of the form will necessarily imply that the interested party has been informed and has expressly given their consent to the content of the clause attached to said form or acceptance of the privacy policy.  

All our forms have a checkbox with the following formula in order to send the information: "□ I have read and accept the Privacy Policy". 

CLIENTS/GUESTS

For what purposes will we process your personal data? 

  • Preparation of the budget and monitoring of the budget through communications between both parties.  
  • Information by electronic means, concerning your application and our services. 
  • Commercial or event information by electronic means, subject to express authorisation. 
  • Manage the administrative, communications and logistical services provided by the Head.  
  • Carry out the relevant transactions. 
  • Invoicing and declaration of the appropriate taxes. 
  • Control and recovery management. 

What is the legitimacy for the processing of your data? 

The legal basis is your consent and the execution of a contract. 

SUPPLIERS.

For what purposes will we process your personal data? 

  • Information by electronic means, concerning your application. 
  • Commercial or event information by electronic means, subject to express authorisation. 
  • Manage the administrative, communications and logistical services provided by the Head.  
  • Billing. 
  • Carry out the relevant transactions. 
  • Invoicing and declaration of the appropriate taxes. 
  • Control and recovery management. 

What is the legitimacy for the processing of your data? 

The legal basis is the acceptance of a contractual relationship, or alternatively your consent to contact us or offer us your products by any means. 

SOCIAL MEDIA CONTACTS

For what purposes will we process your personal data? 

  • Respond to your queries, requests or petitions. 
  • Manage the requested service, answer your request, or process your request.  
  • Engage with you and create a community of followers. 

What is the legitimacy for the processing of your data? 

Acceptance of a contractual relationship in the relevant social network environment, and in accordance with its privacy policies:  

Facebook http://www.facebook.com/policy.php?ref=pf  

Instagram https://help.instagram.com/155833707900388  

Whatsapp: https://www.whatsapp.com/legal/#privacy-policy 

How long will we keep personal data? 

We can only consult or remove your data in a restricted way when you have a specific profile. We will treat them for as long as you let us by following us, being a friend or by "liking", "following" or similar buttons.  

Any rectification of your data or restriction of information or publications must be made through the configuration of your profile or user in the social network itself.  

VIDEO SURVEILLANCE

For what purposes will we process your personal data? 

  • Video surveillance of our facilities. 
  • Control of our employees. 
  • They may sometimes be transferred to courts and tribunals for the exercise of legitimate claims. 

What is the legitimacy for the processing of your data? 

The unequivocal consent of the data subject upon accessing our facilities after viewing the information sign of the video-surveilled area. 

JOB SEEKERS

For what purposes will we process your personal data? 

  • Organisation of selection processes for the recruitment of employees. 
  • Call you for job interviews and evaluate your application. 
  • If you have given us your consent, we may pass it on to collaborating or related organisations, with the sole aim of helping you to find employment. 

What is the legitimacy for the processing of your data? 

The legal basis is your unambiguous consent, by submitting your CV and receiving and signing information regarding the processing we will carry out. 

How long will we keep personal data? 

The curriculum vitae will be stored for the period of one yearafter which, if we have not contacted you, it will be deleted. 

 HR

For what purposes will we process your personal data? 

  • Management of the employment relationship and the employee's file. 
  • To carry out all the administrative, tax and accounting procedures necessary to comply with our contractual commitments, obligations in terms of labour regulations, social security, occupational risk prevention, tax and accounting. 
  • Management of payroll payments through a financial institution. 
  • Time control via fingerprint/card access control system (if applicable). 
  • Management of the entity's group insurance / pension plan. 
  • To carry out training activities both for subsidised and non-reimbursed training. 

 

What is the legitimacy for the processing of your data? 

The legal basis for processing your data is the performance of your employment contract. Compliance with the relevant legal obligations. The consent of the data subject. 

Do we include personal data of third parties? 

No, as a general rule we only process the data provided to us by the owners. If you provide us with data of third parties, you must inform and request their consent beforehand, otherwise you exempt us from any liability for failure to comply with this requirement.  

 

What about data on minors?  

By law, we do not process data from children under 14 years of age on our website. Therefore, please refrain from providing them if you are under that age.  

Will we communicate electronically? 

  • They will only be used to process your request, if it is one of the means of contact you have provided us with. 
  • If we send commercial communications, they will have been previously and expressly authorised by you. 

 

What security measures do we apply?  

You can rest assured: We have adopted an optimal level of protection for the personal data we handle, and have installed all the technical means and measures at our disposal, according to the state of technology, to prevent the loss, misuse, alteration, unauthorised access and theft of personal data.  

To what extent will decision-making be automated? 

            WANA INVERSIONES SA, does not use fully automated decision-making processes to enter into, develop or terminate a contractual relationship with you. Should we use such processes in a particular case, we will keep you informed and inform you of your rights in this respect if required by law. 

¿Will profiling take place? 

            In order to be able to offer you products and/or services according to your interests and to improve your user experience, we may create a "marketing profile" based on the information provided. However, no automated decisions will be made on the basis of this profile. 

To which recipients will your data be communicated? 

Specifically, they will be communicated to the State Tax Administration Agency and to banks and financial institutions for the collection of the service provided or product purchased, as well as to the data processors necessary for the execution of the agreement.  

In case of purchase or payment, if you choose any application, website, platform, bank card, or any other online service, your data will be transferred to that platform or processed in its environment, always with maximum security. 

Your data may be transferred to the entities that make up the HIDDEN AWAY HOTELS group. They will not be transferred to other third parties, unless legally obliged to do so. 

In the event that you have given us your consent to the processing of your name and images and other information in connection with the business of WANA INVERSIONES SAwill be publicised on the different social networks and the website of the entity.  

International transfers. 

In the event of the need for international data transfers to be carried out by WANA INVERSIONES SAshall ensure that such transfers are possible in accordance with the General Data Protection Regulation or any other requirements laid down by applicable law. To this end, the company shall adopt the necessary arrangements to ensure a level of data protection equivalent to that provided for in European legislation.  

In case of working in a system of shared folders in applications such as Dropbox, Google Drive, Microsoft OneDrive, Amazon, Apple, HubSpot, etc., an international transfer to the United States will be carried out under the authorisation of Article 49.c) of the General Data Protection Regulation or any other mechanism that guarantees a level of data protection equivalent to that provided for in the European regulations. 

What rights do you have?  

  • To know whether we are processing your data or not. 
  • To access your personal data.  
  • To request the rectification of your data if it is inaccurate. 
  • To request the deletion of your data if they are no longer necessary for the purposes for which they were collected or if you withdraw your consent. 
  • To request the limitation of the processing of your data, in certain cases, in which case we will only keep them in accordance with the regulations in force. 
  • To submit your data, which will be provided to you in a structured, commonly used or machine-readable format. If you prefer, we can send them to the new person in charge that you designate. This is only valid in certain cases. 
  • To file a complaint with the Spanish Data Protection Agency if you believe that we have not dealt with you correctly. 
  • To withdraw consent to any processing for which you have consented, at any time. 

If you change any data, please let us know so that we can keep them up to date.  

Do you want a form for exercising your rights?  

  • We have forms for the exercise of your rights, ask us for them by email or if you prefer, you can use those prepared by the Spanish Data Protection Agency or third parties.  
  • These forms must be electronically signed or be accompanied by a photocopy of the ID card.  
  • If someone is representing you, you must attach a copy of their ID card, or have them sign it with their electronic signature.  
  • The forms can be submitted in person, by letter or by mail to the address of the Responsible at the beginning of this text.  

You have the right to lodge a complaint with the Spanish Data Protection Agency if you consider that your rights have not been adequately addressed.  

The maximum time limit for a decision by WANA INVERSIONES SAThe period of grace period is one month, counting from the effective receipt of your request by us.  

You have the right to withdraw your consent at any time for any of the processing operations for which you have given your consent.  

Do we process cookies? 

If we use other types of cookies that are not necessary, you can consult the cookie policy in the corresponding link at the top of our website.  

How long will we keep your personal data? 

  • Personal data will be kept for as long as you remain connected with us. 
  • Once you unsubscribe, the personal data processed for each purpose will be kept for the legally stipulated periods, including the period in which a judge or court may require them in accordance with the statute of limitations for legal actions.  
  • The data processed will be kept until the expiry of the aforementioned legal periods, if there is a legal obligation to keep them, or, if there is no such legal period, until the data subject requests their deletion or revokes the consent granted.  
  • We will retain all information and communications relating to your purchase or the provision of our service, for the duration of product or service warranties, to address potential claims. 
  • For each processing or type of data, we provide you with a specific period, which you can consult in the following table: 

Data relating to  

Document 

Conservation 

Customers and suppliers 

 

 

By way of example and without limitation, the following are some of the most significant documents. Invoices (issued by the company and drawn on the company). Contracts between traders (purchase and sale, commission, transport, provision of services, etc.) Contracts with individuals. Real estate contracts (leasing of business premises, sale, purchase, exchange, etc.) Business correspondence Bank contracts and documentation (current accounts, deposits, leasing, renting, etc.) Expense notes. 

Obligation to keep documentation for at least 6 years. It is advisable to keep it depending on the case of prescription of actions. Article 30 of the Commercial Code stipulates that entrepreneurs shall keep the books, correspondence, documentation and supporting documents relating to their business for six years from the date of the last entry made in the books. However, this rule merely establishes a minimum period of time during which, in the general interest, the trader must keep the documents that have been generated in the course of his business.  

Tax relevant documents and records 

Ley General Tributaria arts. 66 a 70 

4 previous financial years (years) 

Parties subject to the Prevention of Money Laundering Act, documentation accrediting compliance with AML obligations 

Law 10/2010 art. 25 

10 years 

Human Resources 

Payrolls, TC1, TC2, etc. 

10 years (Royal Legislative Decree 5/2000, of 4 August, approving the revised text of the Law on Offences and Penalties in the Social Order). 

CVs 

Until the end of the selection process, and for a further 2 years unless the data subject revokes consent or requests deletion. 

Training of workers 

Art 5.2, Order TAS/2307/2007 

4 years 

Working Time Records 

Art. 34.9 Royal Legislative Decree 2/2015, approving the revised text of the Workers' Statute Law. 

4 years 

Severance pay documents.  

Contracts. 

Data on temporary workers.  

RD 425/2005 par. 3 Additional Provision 1 

4 years 

Article 30 of the Commercial Code establishes a minimum period of 6 years. Organic Law 7/2012 recommends keeping it for 10 years. 

Worker's file. 

Up to 5 years after leaving (Royal Legislative Decree 5/2000, of 4 August, approving the revised text of the Law on Offences and Penalties in the Social Order). 

Documentation or computer records accrediting compliance with ORP regulations. 

RDL 5/2000 art. 4 

5 years 

Marketing 

Databases or web visitors. 

For the duration of treatment. 

Access control and video surveillance 

Visitor registration 

Instruction 1/1996 AEPD 

30 days  

Video surveillance 

The images/sounds captured by video surveillance systems shall be cancelled within a maximum period of one month from their capture. 

 

The recordings shall be destroyed within a maximum of one month from their recording, unless they are related to serious or very serious criminal or administrative offences in the field of public security, to an ongoing police investigation or to an ongoing judicial or administrative procedure. 

Instruction 1/2006 AEPD 

30 days 

Accounting 

Accounting books and documents. Annual accounts 

Shareholders' agreements and boards of directors, articles of association, minutes, regulations of the board of directors and delegated committees. 

Financial statements, audit reports 

Records and documents related to grants 

Commercial Code art. 30: 

6 years 

Corporate Documentation 

 

 

 

 

 

 

 

 

Deeds of incorporation of the company together with the articles of association, deeds of elevation of corporate resolutions, deeds of granting/renewal of powers of attorney, deeds of purchase/sale of shares, deeds of purchase/sale of assets, deeds of shares, dissolution/settlement, etc.). 

 

 

 

 

 

 

 

Books of minutes of meetings of the general meeting and the board of directors (commercial companies), register of shares, register of shareholders, register of contracts with the sole shareholder, other books. 

 

 

 

 

 

 

 

Other corporate documentation (private share purchase agreements, shareholder loans, pledges of shares, etc.) 

 

 

 

 

It is recommended to keep them throughout the life of the company, from its incorporation until at least 6 years after its dissolution and liquidation. In the event that the deeds will incorporate rights or obligations for the company, it is recommended to adhere to the above-mentioned limitation periods. 

 

 

 

Obligation to keep the documentation for at least 6 years. From the last entry made in the books. They must be kept throughout the life of the company from its incorporation until at least 6 years after its dissolution and liquidation. 

 

 

 

It is recommended to keep them throughout the life of the company, from its incorporation until at least 6 years after its dissolution and liquidation. 

Fiscal/ Tax 

Administration of the entity's administration, rights and obligations relating to the payment of taxes. 

Administration of dividend payments and withholding taxes. 

All documents that justify the taxpayer's tax actions (proof of income and expenditure), including both accounting and supporting documentation (contracts, invoices, receipts, delivery notes...) All types of tax declarations. 

Obligation to keep the documentation: Minimum 4 years. Articles 66, 67 and 68 of the General Tax Law. The general limitation period for tax obligations is 4 years. With regard to tax returns, the 4-year limitation period starts to run from the day on which the voluntary tax filing period ends. In the event that there has been a subsequent action by the administration (inspection, partial verification) or by the taxpayer (corrective return, appeal) that has interrupted the limitation period, a new 4-year period starts to run from that action. However, it is advisable to keep the physical documentation, as Organic Law 7/2012 recommends keeping it for 10 years. Order EHA/962/2007 provides for the possibility of destroying invoices received on paper if a certified digitalisation process has been previously carried out to obtain electronically signed digital copies. 

Health and Safety 

Clinical Histories. 

Workers' Medical Records 

Health data of Spa clients (wellness treatments). 

 

Article 17.1 of Law 41/2002 of 14 November, on patient autonomy and rights and obligations regarding clinical information and documentation.  

5 years  

Insurance  

Insurance policies 

6 years (general rule) 

2 years (damage) 

5 years (personal) 

10 years (life) 

Legal 

 

Intellectual and Industrial Property Documents. 

Contracts and agreements. 

5 years 

Permits, licences, certificates 

6 years from the expiry date of the permit, licence or certificate. 

10 years (criminal statute of limitations) 

Confidentiality and non-competition agreements 

Always the period of duration of the obligation or of confidentiality 

Data protection regulations 

Records and documents proving compliance with the requirements of the data protection regulation (audits, reports, contracts with data protection officers, etc). 

For the duration of the data processing and thereafter during  

3 years 

Documentation accrediting that requests for the exercise of data subjects' rights are dealt with. 

During  

3 years after application 

Logs/ Logs of accesses to information systems 

2 years 

If the processing is based on the data subject's consent, proof of consent 

For the duration of the data processing and thereafter during  

3 years 

Traffic data relating to internet connections, e-mails and calls sent or received from fixed-line telephony. 

User ID, IP address (source/destination), phone number, IMSI and IMEI (source/destination), date and time of communication (start/end), identification of the type of service or communication used (voice, data, SMS or MMS). 

Article 5 of Law 25/2007 on the retention of data relating to electronic communications and public communications networks. 

1 year 

Biometric data (fingerprint, facial recognition), if applicable, under the guidelines published by the AEPD. Their use is currently not permitted. 

Biometric data are registered in the tool/software enabled for this purpose by the entity, in case a positive Impact Assessment has been carried out, within the current legal framework. 

In compliance with the principle of limitation of the storage period, personal data may be processed for no longer than is necessary for the purposes of the processing, therefore, taking into account the provisions of article 34.9 of the ET, the company will keep the records for four years and they will remain at the disposal of the employees, their legal representatives and the Labour and Social Security Inspectorate. It will be the user who notifies and initiates the procedure for definitive sick leave. 

Access control buildings: 30 days, files to control access (Inst. 1/1996 AEPD) 

INACTIVE FOOTPRINTS: 6 MONTHS OF INACTIVITY. RECORDS: EMPLOYED, 4 YEARS, NON-EMPLOYED: 30 DAYS 

Academic data, academic history, student identification data, attendance data, sanctions, psycho-pedagogical reports, continuous assessment data and final results, scholarship and grant applications. 

Academic record, personal data file of the educational centre, academic history, disciplinary reports and reports, evaluation reports and report cards, scholarship application and decision files.  

Academic record and history: permanently. 

Disciplinary reports and reports: 5 years. 

Evaluation reports and report cards: permanently for reports and 5 years for report cards. 

Scholarship application and resolution files: 6 years from the resolution. 

Guests 

Check-in of travellers/guests. 

3 years (Ley Orgánica 4/2015 de protección de seguridad ciudadana, Orden INT/1922/2003 and in RD 933/ 2021, of 26 October (obligations of documentary registration and information of natural or legal persons carrying out accommodation activities). 

 

 

 

 

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