General information
The person responsible for the processing of personal data is EVERGREEN 2000 S.L. ('htopgroup'), with registered office in Palafolls (08389 - Barcelona-Spain), Riera d'en Jordà, s/n, and CIF B-61333845. This data will be processed in accordance with the provisions of the European General Data Protection Regulation 2016/679 (GDPR) and the Organic Law 3/2018, of 5 December, on Data Protection and Guarantee of Digital Rights (LOPDGDD).

Consent.
By reading this Privacy Policy, the user is informed about the way 'htopgroup' collects, processes and protects personal data that are provided through the website www.htophotels.com (hereinafter the website), as well as the own connection and navigation through the website and those other data that may be provided in the future to 'htopgroup' through the Hosting Agreement or any other means enabled.

For what purposes do we process your data? 
At 'htopgroup' we may process your personal data for the following purposes: 

• To manage bookings made, including managing payment (where applicable) and managing your requests and preferences.
• To manage the subscription to the newsletter and subsequent sending of the same.
• Manage your requests for contact with 'htopgroup' through the channels provided for this purpose.
• Manage the sending of personalized commercial communications 'htopgroup', by electronic and / or conventional means, in cases where the user expressly consents.
• Manage the provision of the contracted accommodation service, as well as additional services to the stay.
• To manage the carrying out of surveys and/or evaluations relating to the quality of the services provided by 'htopgroup'.  
• Process orders, requests, respond to queries or any type of request that is made by the user through any of the forms of contact that are made available on the website.
• Through implicit data capture measures, such as the study of the most read pages and the use of cookies.

What data do we process and from what source are they obtained?

The data processed comes from:

• Data provided by you, through the completion of the forms provided for this purpose.
• Data derived from the provision of the service. This category includes browsing data through the public website or access to the Customer and Booking Area that you provide indirectly and which are derived from the provision and maintenance of this activity.
• Data obtained from marketing studies in which you have agreed to participate and have given us your consent to use.
• Data provided or transferred (with your consent) by third party companies that provide outsourced services in 'htopgroup' establishments (e.g. telecommunication networks, internet access, excursions, etc.). Depending on the service, the data processed comprises the following typology:

1. identifying data (ex. name, surname, first name, ID card, postal address e-mail, telephone number or mobile device identifiers).
2. Economic and operational data related to the transactions carried out in the 'htopgroup' (ex. data on consumption in the 'htopgroup' establishments).
3. Transaction data relating to goods and services (ex. payments for services provided).
4. Commercial information data (ex. interests in products or services).
5. For quality assurance and training purposes, we record most of the calls you make to us.
6. Cookies. Each website owned and operated by htopgroup uses cookies. A cookie is a small text file of which there are three types.

Session cookies: These are used to maintain something called session state. If you consider your journey through the site to be a conversation with us and this cookie only remembers where we were in that conversation (for example, if at some point in the conversation you asked us to add a hotel to your basket, the next time you click on the basket it will still be there). These are necessary for the site to function but are not used in any way to identify you personally.
Persistent Cookies: These store some numbers on your hard drive. You can see them by looking in the cookie directory of your browser installation if you are interested. They last a long time and each time you come to our site you send us a copy of them. We use them to identify you between visits. For example, if the last time you were on the site you were looking for hotels in London and we have a great range of hotels, we can use this cookie to recognise you and show you our great range. They are not necessary for the site to work but may improve your experience. We do not store any personal data in these cookies, just a unique number that identifies you to us.
Third party cookies. You may have noticed that we carry third party advertising on our site. Occasionally they may send you a cookie. We have no control over them.
Although you cannot block "session" cookies, as they are necessary for our site to function properly, you can set your internet browser so that you can refuse both "persistent" and "third party" cookies. How you do this will depend on the Internet browser you use (e.g. Internet Explorer 5, Netscape 4 or Opera, etc.). Please consult the website of the manufacturer of the relevant Internet browser, where you can receive all the information you need.
 

What is the legal basis for the processing of your data?

The processing of your data relating to "Contact" and "Customer Area Registration / Booking / My Bookings" and other communication channels at your disposal, are based on the maintenance of your request and, where appropriate, for the provision of contracted services.

Similarly, the legal basis for the processing of your data derived from the contract is the execution of the contract for the provision of services or products of 'htopgroup' (according to the terms and conditions contained on the website).

The sending of advertising of own products may be based on the legitimate interest of 'htopgroup' when you register in the Client Area or hire a service or make a reservation.

In all other cases, as well as when the advertising is from third parties, the processing of your data will be based on the consents you have given us and that we will keep as long as you do not request the deletion or opposition to the processing of your personal data.

The enrichment of your data with external sources is based on your consent. 

To whom is your data communicated?

Your data may be communicated to:

- Investee companies or companies of the 'htopgroup' business group, solely for internal administrative purposes and/or for the aforementioned purposes.

- Entities operating the hotels managed by 'htopgroup' or franchised hotels, solely for internal administrative purposes and/or for the aforementioned purposes.

- Suppliers of 'htopgroup' or of the hotel operators necessary for the proper fulfilment of the legal obligations and/or for the aforementioned purposes.

- Public Administrations, in the cases provided for by law.

- Third party advertising. Advertisements that appear online, both personalised and non-personalised, are delivered to you on our behalf by our web advertising partners. These third parties include companies such as Amadeus, Affilired and Google. See Google's terms and conditions here.

We may send your information internationally, including to countries outside the EEA. Some of these jurisdictions offer different levels of protection for personal information. 

How long will we keep your data?

Personal data will be kept for the time necessary to provide the service or as long as you do not withdraw your consent. Subsequently, the data will be deleted in accordance with the provisions of the data protection regulations, which implies its blocking, being available only at the request of Judges and courts, the Public Prosecutor's Office or the competent Public Administrations during the period of limitation of the actions that may arise, and after this, we will proceed to its complete deletion.

What are your rights?

You have the right to obtain information about whether 'htopgroup' is processing your personal data, so you can exercise your rights of consultation, access, rectification, deletion and portability of data and opposition or limitation to their treatment, at EVERGREEN 2000 S.L., Paseo Riera d'en Jordà, s/n, 08389 Palafolls (Barcelona) or at the email address protecciondatos@htophotels.com , attaching a copy of your ID card or equivalent document. 

What data is compulsory?

The data requested in the forms accessible from the 'htopgroup' website are, in general, mandatory (unless otherwise specified in the required field) to meet the established purposes. Therefore, if they are not provided or are not provided correctly, it is not guaranteed that the information and services are completely tailored to your needs.

Security measures

'htopgroup' will treat your data at all times in strict confidence and keeping the mandatory duty of secrecy regarding them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organizational measures to ensure the security of your data and avoid its alteration, loss, treatment or unauthorized access, given the state of technology, the nature of the data stored and the risks to which they are exposed.