Privacy Policy
PRIVACY NOTICE
This
Privacy Notice is issued in accordance with the Federal Law on the Protection
of Personal Data Held by Private Parties, its Regulations, and the General
Guidelines for Privacy Notices (hereinafter, the Law ).
Identity of the Data Controller
Solaya
Hospitality Management Group, S. de R.L. de C.V.
(hereinafter, the Controller ), with registered address at Avenida Bonampak, Supermanzana 9, Manzana 2, Ground Floor, Tower N, Floors 7
to 11 and Tower S, Floor 7, Canc n, Quintana Roo,
Mexico, C.P. 77503, is responsible for the processing of the personal data of
the individuals (hereinafter, the Individual ).
Means of Collecting Personal Data
We
collect your personal data directly through:
●
Physical or electronic
forms completed by you, including those used to make reservations, complete
check-in and check-out procedures, request services, respond to surveys,
participate in promotions, or through any other interaction with the hotel.
●
Our own reservation and
communication channels, such as our website, applications, contact center,
email, instant messaging services, and other customer service channels.
●
The capture of images and,
where applicable, audio through video surveillance systems installed on our
premises, for security purposes.
We may also collect your personal data
indirectly through:
●
Travel agencies, online
booking platforms, tour operators, or other third parties with whom you have
contracted lodging or related services (for example, online travel agencies).
●
Affiliated companies,
suppliers, or commercial partners involved in the provision of contracted
services, to the extent that such transfer is necessary and permitted under
applicable law.
●
References, companions,
additional guests, or individuals who make reservations or requests on your
behalf.
What Personal Data Do We Collect?
The
personal data processed by the Controller are grouped
into the following categories:
1. Personal data
●
Identification and Contact
Data
●
Full name
●
Email address
●
Telephone number
●
Address
●
Billing and/or collection information
●
Demographic and General Data
●
Date of
birth
●
Place of
birth
●
Nationality
●
Age
●
Height
●
Weight
●
Official Identification
Data
●
Official identification number
2. Sensitive Personal Data
●
Health Data
●
Current health
status
●
Medical conditions
●
Allergies
●
Medications
●
Dietary habits
●
Pregnancy status, where applicable
●
Gender Data
●
Gender
3. Financial and/or Patrimonial Data
● Credit or debit card information
In cases where the Individuals are minors,
personal data will be collected with the express authorization of the person
holding parental authority, guardianship, or legal representation.
For What Purposes Will We Use Your Personal Data?
The
processing of personal information will be carried out in accordance with the
principles of legality, quality, consent, information, purpose limitation,
loyalty, proportionality, and accountability set forth in the Law.
Primary Purposes
The
primary purposes that give rise to the processing of personal data and are
necessary for the legal relationship between the Controller and the Individual
include:
●
To provide the contracted products and services, including tourism,
lodging, transportation, and other services offered during the Individual s
stay.
●
To identify and verify the
Individual s identity, as well as to create and maintain administrative,
operational, and control records related to the provision of services.
●
To manage reservations and
confirm services, and to maintain communication before, during, and after the
stay, including sending confirmations, operational notices, calls, text
messages, and other communications necessary for the proper provision of services.
●
To provide customer service
and support, including addressing inquiries, clarifications, complaints,
claims, suggestions, and incidents occurring at the facilities where services
are provided, as well as following up on compensations, bonuses, or adjustments
derived from guest experiences.
●
To provide complementary
services, including, without limitation:
i.
spa services and the
customization of such services according to the Individual s conditions and needs;
ii.
food and beverage services,
including the identification of potential dietary risks;
iii.
recreational services,
including activities for duly registered minors;
iv.
gym services;
v.
laundry services, including
garment identification;
vi.
luggage storage services;
vii.
shipment, receipt, and storage of packages, as well as
identification and recovery of lost items.
●
To manage room charges and
collect payment for products and services provided.
●
To follow up on accidents,
losses, emergencies, or contingencies, as well as to implement and comply with
civil protection measures, physical security, and applicable health
requirements.
●
To implement access
controls to facilities and restricted areas, as well as video surveillance
activities, which may include the capture of images and, where applicable,
audio, for the security of individuals, property, and facilities, as well as
for the attention and follow-up of related incidents. Recordings may be viewed
in real time and/or stored in accordance with applicable security measures.
Secondary Purposes
Additionally,
the Controller informs that personal data may be processed for the following
secondary purposes:
●
To conduct statistical
analyses, product and service usage analysis, market segmentation, and
demographic and sociographic analysis, as well as to enrich customer profiles
and generate similar audiences.
●
To evaluate the
Individual s profile for commercial purposes, including pre-qualification for
sales presentations.
●
To use the Individual s
image (photographs and/or video) for advertising, promotional, marketing,
corporate image, and campaign purposes in printed, digital, or any other media.
●
Commercial prospecting.
If the Individual does not wish their
personal data to be processed for these additional purposes, they may express
their refusal through a written request signed by the Individual or their
authorized representative and sent to the following email address:
privacy@pamhotels.com. Refusal to allow the processing of personal data for
these secondary purposes shall not be grounds for denying the provision of
contracted services.
Automated Processing of Personal Data
The
Controller informs that personal data are not used in automated decision-making
processes, without human intervention, that produce legal effects or
significantly affect Individuals. However, for operational and service
administration purposes, the Controller may use technological tools or systems
to support the management of services provided to the Individual.
With Whom Do We Share Your Personal Information and for What Purposes?
Transfers
of personal data, within or outside Mexican territory, may occur as necessary
to fulfill the purposes described above, to the following third parties, who
may act as data processors, following the direct instructions of the
Controller:
|
Third parties |
Purposes |
|
Service providers of the Controller |
To carry out the contracted services, necessary for the provision of
services to the Individual or for the fulfillment of the purposes previously
described in this Privacy Notice. The
personal data collected may be shared with: ●
SMTouring ●
AGILYSYS NV, LLC ●
Mankara Technologies Inc. ●
Sabre GLBL Inc. ●
Worldpay, LLC ●
ParGolf ●
Book4Time, Inc. ●
Odyssey Proyecci n Empresarial, S.A. de
C.V. ●
Oracle Hospitality LLC ●
Nuvola, Inc. ●
Inversiones Zahena, S.A. ●
Inversiones Valozo,
S.A. ●
Hard Rock Limited ●
Nobu LLC ● Marriot Switzerland Licensing Company, S.A.R.L. |
How Can You Access, Rectify or Cancel Your Personal Data, or Object to
Its Use?
You have
the right to know what personal data we hold about you, what we use it for, and
the conditions under which it is used (Access). You also have the right to
request the correction of your personal information if it is outdated,
inaccurate, or incomplete (Rectification); to request that we delete it from
our records or databases when you consider that it is not being used in
accordance with the principles, duties, and obligations provided by applicable
law (Cancellation); and to object to the use of your personal data for specific
purposes (Objection). These rights are known as ARCO rights.
To exercise any of your ARCO rights, the
Individual must submit a written request addressed to the Data Protection
Office, either by email to privacy@pamhotels.com or in writing to Avenida
Bonampak, Supermanzana 9, Manzana 2, Ground Floor,
Tower N, Floors 7 to 11 and Tower S, Floor 7, Canc n, Quintana
Roo, Mexico, C.P. 77503.
When submitting a request to exercise ARCO
rights, the following must be considered:
●
The applicant must be the
Individual to whom the personal data belongs, or their legal representative. In
both cases, identity must be duly accredited through official documentation
(Voter Identification Card, Passport, Military Service Card, or Professional
License). If a legal representative exists, their identity and legal authority
must be accredited by attaching the corresponding documents (Public Instrument
such as a Power of Attorney, declaration made by the Individual in a personal
appearance, or, where applicable, a power of attorney signed before two
witnesses).
●
The request must state the
name of the Individual and the means by which the
response should be communicated, indicating whether the Individual consents to
being contacted by email.
●
In addition to
documentation proving identity and legal authority, a clear and precise
description of the personal data in respect of which one of the aforementioned rights is to be exercised must be provided,
as well as any other element or document that facilitates the location of such
personal data. Documentation required for the specific right to be exercised
must also be included, in accordance with the Federal Law on the Protection of
Personal Data Held by Private Parties.
●
The following specific
requirements apply to each ARCO right:
i.
ACCESS: Indicate the
personal data to which access is requested and that are believed to be held in our databases.
ii.
RECTIFICATION: Specify the
corrections to be made and attach documentation supporting the request.
iii.
CANCELLATION: Identify the
personal data requested to be deleted.
iv.
OBJECTION: Specify the
personal data for which processing is opposed and the reasons for the alleged
harm caused by such processing.
If the information provided in the request
is insufficient or inaccurate, or if the required documents are not attached,
the Data Protection Office may request additional information and/or
documentation within a period not exceeding five (5) business days. The
Individual will then have ten (10) business days from receipt of such request
to provide the requested information.
If the request contains sufficient
information, the resolution period will be twenty (20) business days from the
date the request is received. This period may be extended once for an equal
period, when justified by the circumstances of the case, in accordance with
applicable law.
If the resolution is favorable, it will be
implemented within fifteen (15) business days following notification of the
decision. This period may also be extended once for an equal period, when
justified by the circumstances, and the Individual will be notified through the
previously selected contact method.
The means by which the Individual may
obtain the requested personal data through the exercise of the right of access
may include simple copies, electronic documents, or any other selected medium.
For questions regarding the procedure and
requirements for exercising ARCO rights, the Individual may contact the Data
Protection Office, which will process such requests and address any questions
regarding the processing of personal data. Contact details are as follows:
●
Authorized office: Data
Protection Office
●
Address: Avenida Bonampak, Supermanzana 9, Manzana 2, Ground Floor, Tower N, Floors 7
to 11 and Tower S, Floor 7, Canc n, Quintana Roo,
Mexico, C.P. 77503
●
Email:
privacy@pamhotels.com
How Can You Revoke Your Consent for the Use of Your Personal Data?
The
Individual may revoke the consent granted for the processing of their personal
data at any time. However, the Individual should be aware that in certain cases
it may not be possible to immediately comply with such request or to cease
processing, due to legal obligations that require continued processing of
personal data. Likewise, the Individual should consider that revoking consent
for certain purposes may result in the inability to continue providing the
requested services or the termination of the legal relationship with us.
To revoke consent, the Individual may
follow the same procedure established for the exercise of ARCO rights, by
sending an email to privacy@pamhotels.com or submitting a written request to
Avenida Bonampak, Supermanzana 9, Manzana 2, Ground
Floor, Tower N, Floors 7 to 11 and Tower S, Floor 7, Canc n, Quintana Roo, Mexico, C.P. 77503.
For questions regarding the procedure and
requirements for revoking consent, the Individual may contact the Data
Protection Office, which will process revocation requests and address any
related inquiries. Contact details are as follows:
●
Authorized office: Data
Protection Office
●
Address: Avenida Bonampak, Supermanzana 9, Manzana 2, Ground Floor, Tower N, Floors 7
to 11 and Tower S, Floor 7, Canc n, Quintana Roo,
Mexico, C.P. 77503
●
Email:
privacy@pamhotels.com
To submit a consent revocation request,
the applicant must be the Individual or their legal representative, and
identity must be duly accredited using official documentation (Voter
Identification Card, Passport, Military Service Card, or Professional License).
If a legal representative exists, their authority must be accredited through
the corresponding documents (Public Instrument such as a Power of Attorney,
declaration made by the Individual in a personal appearance, or, where
applicable, a power of attorney signed before two witnesses). The resolution of
a consent revocation request will be issued within twenty (20) business days
from the date the request is received.
How Can You Limit the Use or Disclosure of Your Personal Data?
In order to limit the use or disclosure of personal
data, the following options are available:
●
Registration in the Public
Registry to Avoid Advertising, administered by the Federal Consumer Protection
Agency (PROFECO), to prevent personal data from being
used for advertising or promotional communications from providers of goods or
services. Additional information may be obtained through PROFECO s
official website or by contacting the agency directly.
●
Sending an email to
privacy@pamhotels.com requesting that personal data not be processed for
marketing, advertising, or commercial prospecting purposes.
Use of Cookies
The
Controller s website uses cookies and other similar technologies that allow
monitoring of user behavior in order to provide a
better browsing experience and offer products and services aligned with user
interests. Personal data collected through these technologies may include,
without limitation: browser type, operating system, IP address, pages visited,
browsing time, and usage preferences.
The Individual may disable or adjust
cookie settings directly through their browser. However, disabling cookies may
affect the functionality of certain features of the website. For additional
information regarding the use of cookies and similar technologies, the
Individual may consult the Cookie Notice available on the Controller s website.
How Can You Be Informed of Changes to This Privacy Notice?
This
Privacy Notice may be modified, updated, or amended due to new legal
requirements; changes in the products or services offered; updates to privacy
practices; or changes to the business model.
The Controller undertakes to keep the
Individual informed of any changes through its website at www.pamhotels.com
Notifications regarding changes or updates
to this Privacy Notice will be carried out as follows:
●
Publication of banners on
the Controller s website informing of the changes or updates.
●
Any modification or update
will become effective the day following its publication through the aforementioned means.
The Individual
declares that they have read and understood this Privacy Notice and grants
express, informed, and voluntary consent for the processing of their personal
data, including sensitive personal data and, where applicable, personal data of
minors, in accordance with the purposes described herein, except where
otherwise permitted by law. Such consent shall be deemed granted upon
acceptance of this Privacy Notice, without prejudice to the Individual s right
to revoke consent at any time in accordance with the procedure described above.