PRIVACY POLICY

________________________________________________________

 

ISLA CANELA TOURS AND SERVICES S.L is a company that offers intermediation and management services for vacation rental of apartments from private owners, as well as inns and contracted hotels indicated on our website, offering a comprehensive service of accommodation services as well as reception and treatment of guests, for which it is necessary to process personal data of users or customers and in compliance with our obligation to inform we have developed the following privacy policy aimed at providing you with all the information you need to understand the scope and purpose of the data processing we carry out.

 

All of this is to ensure that acceptance of the processing we carry out is based on fully informed consent as required by Organic Law 3/2018, of December 5, on Data Protection and Guarantee of Digital Rights and Regulation 2016/679, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

 

IDENTIFICATION

 

Data Controller: ISLA CANELA TOURS AND SERVICES S.L. hereinafter HUELVA HOLIDAY.

 

Tax ID: B21376850

 

Registered address: Avda. Cayetano Feu 41, 21409, Ayamonte (HUELVA), Spain.

 

Email: admin@homanetwork.com

 

INFORMATION

 

By accepting this Privacy Policy, the user (hereinafter, the "User") is informed that the personal data derived from their browsing and any other data that may be provided in the future, that they provide or that are collected through the website located at the URL www.huelvaholiday.com (hereinafter, the Website), will be processed by HUELVA HOLIDAY.

 

The User must read this Privacy Policy carefully, which has been written in a clear and simple manner to facilitate its understanding, allowing the User to determine, freely and voluntarily, whether they wish to provide their personal data to HUELVA HOLIDAY.

 

MANDATORY NATURE OF PROVIDING DATA

 

The data requested in the Website forms are, in general, mandatory (unless the required field specifies otherwise) to fulfill the purposes for which they are being collected. Therefore, if the User does not provide them or does not provide them correctly, their requests cannot be attended to, without prejudice to the fact that they may freely view certain content on the Website.

 

ORIGIN OF DATA

 

The data processed by HUELVA HOLIDAY for the purposes listed in the following section come from:

 

From the User themselves: data provided by the User themselves through the Website forms, data obtained from the User's use of the Website and their browsing through it (through cookies or data storage and retrieval devices), as well as information obtained from the User's mobile device, according to the consents that, where appropriate, they give to HUELVA HOLIDAY.

 

Provided by third parties responsible for the data: in cases where a person other than the User provides personal data of third parties (for example, to manage reservations, include companions, make invitations or purchases on behalf of others), that person guarantees that they have the necessary legitimacy to provide that information and that they have previously informed the data subjects about the purpose of communicating them to HUELVA HOLIDAY. In these cases, the responsibility for the veracity, accuracy and legality of the data rests exclusively with the person who provides them.

 

FOR WHAT PURPOSE WILL HUELVA HOLIDAY PROCESS THE USER'S DATA?

 

HUELVA HOLIDAY will process the User's data for the following specific purposes:

 

Personal data is processed for the following purposes:

 

Management of commercial relationship with the User: Manage compliance and execution of the service provision contract, as well as reservations formalized by the User. Send communications to Users related to the reservation or contracted service, through any electronic or telephone means, including instant messaging applications. Manage the registration and identification of the User, manage reception, stay and attention to guests.

 

Respond to questions raised by users through enabled contact channels, as well as manage, process and support requests, petitions, incidents, claims or queries from User/customers made through the different communication channels made available to them.

 

Sending commercial communications: manage the sending of commercial communications to Users, by electronic and/or conventional means.

 

Sending commercial communications to User customers: manage the sending of commercial communications to Users already customers of HUELVA HOLIDAY, related to similar products and services previously acquired, by electronic and/or conventional means.

 

Collection and storage of User data based on their browsing preferences, using their behaviors on the Website through cookies or similar storage technologies.

 

Compliance with legally established obligations: when processing is necessary to comply with a legal obligation derived from Spanish law or European Union law that may be applicable to HUELVA HOLIDAY. Among them, for example, provide traveler information to competent authorities, in cases required (domestic reservations) by applicable regulations, and specifically Royal Decree 933/2021 on traveler registration, when appropriate.

 

Preparation of reports, statistics and internal analysis to improve services and detect improper uses on the Website: analyze, manage and prepare internal reports and statistics on User behavior to implement improvements on the Website.

 

WHAT USER DATA WILL HUELVA HOLIDAY PROCESS?

 

During the use of the website or other means enabled to contact us, the following personal data may be processed:

 

Management of commercial relationship and reservations with the User:

- Identification data: name, surnames, ID number, passport or similar document, nationality.

- Contact data: email address, telephone number.

- Economic data: credit card number and similar.

- Website browsing data.

- Location data: User's address, country.

- Additional data: sensitive data indicated in data protection regulations, art.9, will not be processed, except rare exceptions and only if users have made them available to HUELVA HOLIDAY, as necessary for the correct provision of services (for example, allergies).

 

Management of User registration and identification through the Website:

- Identification data: name, surnames, identification documents.

- Contact data: email address, telephone number.

- Location data: locality and province.

- Website browsing data.

 

Responding to questions raised by the User through enabled contact channels:

- Identification data: name, surnames.

- Contact data: email address, telephone number.

- Other data: any data that the User may provide.

 

Sending commercial communications to Users:

- Identification data: name, surnames.

- Contact data: email, telephone number.

 

Sending commercial communications to HUELVA HOLIDAY User customers:

- Identification data: name, surnames.

- Contact data: email, telephone number.

 

Collection and storage of User data based on their browsing preferences, using their behaviors on the Website through cookies or similar storage technologies:

- Identification data: name, surnames, User nickname.

- Contact data: email, telephone.

- Data about social circumstances: language.

- Location data: country.

- Data about contracted services or products: service or product, list of followers and followed.

- Browsing data on the Website and other portals: IP, advertising ID, their behavior on the Website and other portals.

 

Compliance with legally established obligations:

- Identification data: name, surnames.

- Contact data: email address, telephone number.

- Other data: any other personal data that may be legally required.

 

Preparation of reports, statistics and internal analysis to improve services and detect improper uses on the Website:

- Location data: country.

- Browsing data on the Website and other portals: IP, advertising ID, their behavior on the Website and other portals.

 

In case the User provides third party data, they declare to have the consent of these and/or sufficient legitimacy and undertake to transfer the information contained in the Privacy Policy to them, exempting HUELVA HOLIDAY from any responsibility in this regard. However, HUELVA HOLIDAY may carry out appropriate verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

 

WHAT IS THE LEGAL BASIS FOR PROCESSING THE USER'S DATA BY HUELVA HOLIDAY?

 

HUELVA HOLIDAY processes User data according to the following legal bases:

 

Management of commercial relationship and reservations with the User: data processing derived from management, compliance and execution of the sales or service provision contract formalized by the User through the Website will have contractual execution as its legal basis. In cases where personal data accessory to the correct provision of the requested service is provided to HUELVA HOLIDAY directly or through tourism sector professionals and which, by their nature, may refer to the User's health (such as information about allergies, food intolerances, disabilities or other similar conditions), the processing will have the User's consent as its legal basis.

 

Management of User registration and identification through the Website: data processing derived from User registration and identification will have execution of the contractual relationship as its legal basis.

 

Responding to questions raised through enabled contact channels: data processing derived from this purpose is the consent that the User may withdraw at any time. This processing may also be based on legitimate interest if the User decides to contact HUELVA HOLIDAY through other means without using the contact form.

 

Sending commercial communications to non-customer Users: processing derived from this purpose is legitimized by consent that the User may withdraw at any time.

 

Sending commercial communications to HUELVA HOLIDAY User customers: processing derived from this purpose is legitimized by legitimate interest, based on the exception provided in article 21.2 of Law 34/2002, of July 11, on information society services and electronic commerce and the provisions of recital 47 of the GDPR. Legitimate interest is based on conducting direct marketing to offer the User customer products and services that may be of interest to them and thus achieve their loyalty. However, the User has the right to object to this processing at any time.

 

Collection and storage of User data based on their browsing preferences, using their behaviors on the Website through cookies or similar storage technologies: processing derived from this purpose will have consent as its legal basis, which the User provides by marking the corresponding box and which may be withdrawn at any time.

 

Compliance with legally established obligations: all processing derived from this purpose will be based on compliance with a legal obligation.

 

Preparation of reports, statistics and internal analysis to improve services and detect improper uses on the Website all processing derived from this purpose will have legitimate interest as its legal basis, recognized to the data controller by data protection regulations. This legitimate interest is based on being able to offer Users HUELVA HOLIDAY services with the best possible quality and experience.

 

Consents obtained for the mentioned purposes are independent so the User may revoke only one of them without affecting the others.

 

DATA RETENTION

 

The User's personal data will be retained by HUELVA HOLIDAY for the following periods:

 

Data provided for management of commercial relationship and reservations with the User: this data will be retained during the duration of the commercial relationship and, once it has ended, during the statute of limitations period for legal actions that may derive from it.

 

Data provided for User registration and identification through the Website: this data will be processed during the validity of the user account and will be retained during the statute of limitations period for legal actions that could derive from it.

 

Data used to respond to questions raised through enabled contact channels: this data will be retained for the period necessary to process and respond to your request and, once it has ended, during the statute of limitations period for legal actions derived from said request.

 

Data used for sending commercial communications: this data will be processed according to said purpose until the User withdraws the previously granted consent.

 

Data used for sending commercial communications to customers: this data will be processed until the User objects to receiving commercial communications and, in no case, will refer to a period exceeding one (1) year.

 

Collection and storage of User data based on their browsing preferences, using their behaviors on the Website through cookies or similar storage technologies: this data will be processed until the User objects to processing and, in no case, will refer to a period exceeding one (1) year.

 

Compliance with legally established obligations: this data will be retained for legally established periods.

 

Preparation of reports, statistics and internal analysis to improve services and detect improper uses on the Website: this data will be retained for the period necessary to process and prepare said reports, as well as detect possible improper uses and, once said periods have ended, during the statute of limitations periods for possible legal actions.

 

Incorporation in instant messaging application groups owned by HUELVA HOLIDAY: this data will be processed until the User revokes their consent or requests exclusion from enabled groups or channels. Once revoked, data will be retained blocked during the statute of limitations period for legal actions that could derive.

 

WITH WHAT RECIPIENTS WILL USER DATA BE SHARED?

 

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

 

Public Administrations, in cases provided by law, based on compliance with a legal obligation.

 

Courts and Tribunals, in cases provided by law, based on compliance with a legal obligation.

 

Third party providers, for correct management of reservations, organization and contracting of trips, experiences or activities, and based on the legitimizing basis of contractual execution, who will act as independent data controllers, such as:

- Accommodations and hotel establishments or similar.

- Receptive agencies and local tour operators.

- Insurance companies and travel insurance intermediaries.

- Catering companies linked to the contracted activity.

 

Third party service providers who may have access to the User's personal data, who will process on behalf and on behalf of HUELVA HOLIDAY the personal data provided, on the occasion of service provision. HUELVA HOLIDAY follows rigorous supplier selection procedures in order to comply with its obligations in data protection matters, including the subscription of the corresponding data processing contract in accordance with art. 28 of the GDPR.

 

INTERNATIONAL DATA TRANSFERS

 

It is possible that some of the external providers indicated in the previous section are located or provide their services from countries located outside the European Economic Area. In these cases, an international transfer of personal data may occur in accordance with the provisions of articles 44 et seq. of the GDPR.

 

When destination countries do not have an adequacy decision issued by the European Commission, HUELVA HOLIDAY guarantees that it will adopt adequate guarantees to protect User data, through the subscription of the corresponding Standard Contractual Clauses (the "SCCs") approved by the European Commission.

 

In these cases, HUELVA HOLIDAY undertakes to evaluate, case by case, the circumstances of the transfer and, when necessary, will adopt additional technical, organizational or contractual measures (such as encryption, pseudonymization or restricted access protocols) in order to guarantee a level of protection equivalent to that required by the General Data Protection Regulation.

 

The User may request additional information about applied guarantees or a copy of subscribed SCCs, through the contact channels indicated in this policy.

 

USER RESPONSIBILITY

 

The User guarantees that they are over fourteen (14) years old and that the data they provide to HUELVA HOLIDAY is true, accurate, complete and up to date. For these purposes, the User is responsible for the veracity of all data they communicate and will keep the information provided conveniently updated, so that it responds to their real situation.

 

Similarly, they guarantee that they have informed third parties whose data they provide, if applicable, of the aspects contained in this document. They also guarantee that they have obtained their authorization to provide their data to HUELVA HOLIDAY for the indicated purposes.

 

In any case, the User will be responsible for false or inaccurate information provided through the Website and for damages, direct or indirect, that this causes to HUELVA HOLIDAY or third parties.

 

EXERCISE OF RIGHTS

 

As data subject, the User may send a written communication to HUELVA HOLIDAY, to the address indicated in the header of this Privacy Policy, or by email to: admin@homanetwork.com at any time and free of charge.

 

If HUELVA HOLIDAY has reasonable doubts regarding their identity, it may request additional information or documentation to verify it before attending to their request.

 

Requests will be attended to as diligently as possible and, generally, within a maximum period of one (1) month from receipt:

 

Right of access: You will have the right for HUELVA HOLIDAY to inform you whether or not it is processing your personal data and, if so, to access such data and receive information about the purposes for which they are processed, the categories of data affected by processing, the recipients to whom your personal data was communicated and the expected data retention period, among other information.

 

Right to rectification: You will have the right to request rectification of inaccurate data concerning you when, among other reasons, they are no longer necessary for the purposes for which they were collected.

 

Right to erasure: You will have the right to request deletion of personal data provided legal requirements are met.

 

Right to restriction of processing: In certain circumstances (for example, if the applicant contests the accuracy of their data, while the accuracy thereof is being verified), you may request that processing of your personal data be restricted, being processed only for the exercise or defense of claims.

 

Revocation of consent: You will have the right to revoke consent given for reasons related to your particular situation, if processing is based on your previously given consent (including processing aimed at direct marketing).

 

Total or partial opposition to processing: You will have the right to object to processing at any time if processing is based on our legitimate interest or the legitimate interest of a third party. In this case, HUELVA HOLIDAY will cease processing, except accreditation of compelling legitimate reasons.

 

Portability of your data: You will have the right to receive personal data you have provided to HUELVA HOLIDAY in a structured, common and machine-readable format, and to transmit it to another data controller without the controller to whom you had provided it preventing it, in legally provided cases for these purposes.

 

Automated individual decisions: Likewise, in addition to the mentioned rights, if automated decisions are adopted, including profiling, you will have the right to obtain human intervention by HUELVA HOLIDAY, to express your point of view and to challenge the decision.

 

Others: You may also file a claim regarding protection of your personal data with the Spanish Data Protection Agency, with address at calle Jorge Juan, 6, 28001 Madrid and website www.aepd.es, when the User considers that HUELVA HOLIDAY has violated the rights recognized by applicable data protection regulations.

 

SECURITY MEASURES

 

HUELVA HOLIDAY will process User data at all times in an absolutely confidential manner and keeping the mandatory duty of secrecy regarding them, in accordance with the provisions of applicable regulations, adopting to this effect the necessary technical and organizational measures that guarantee the security of your data and prevent their alteration, loss, processing or unauthorized access, taking into account the state of technology, the nature of stored data and the risks to which they are exposed.

 

CHANGES

 

HUELVA HOLIDAY reserves the right to review its Privacy Policy when it deems appropriate, in which case Users will be notified. For this reason, we ask the User to regularly check this privacy statement to read the most recent version of HUELVA HOLIDAY's Privacy Policy.

 

ACCEPTANCE AND CONSENT

 

The User declares having been informed of the conditions on personal data protection, accepting the content of this Privacy Policy.

 

Last update: January 2026.