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Privacy Policy

PRIVACY NOTICE

Last update:  December 21, 2020.

 

Operadora de Campos de Golf Pueblo Bonito, S.A. de C.V., Recursos Humanos PB Pacífica, S.A. de C.V., Operadora Hotelera Cabo Maz, S.A. de C.V., Operadora Pueblo Bonito Sunset Beach, S.A. de C.V., Operadora Rosé, S.A. de C.V., and Consultores Pueblo Bonito, S.A. de C.V., individually, the “Responsible Party” and jointly “Grupo Pueblo Bonito”), with conventional domicile at Predio Paraíso Escondido S/N, colonia Centro, Cabo San Lucas, C.P. 23450, Los Cabos, Baja California Sur; shall be responsible of the use and protection of your personal and sensitive personal data, in compliance with the Federal Law of Personal Data in Possession of Individuals, the Guidelines of the Privacy Notice, and with the EU’s General Data Protection Regulation (GDPR);  and in this regard we inform you the following:

This page informs you of our policies for the collection, use and disclosure of your personal data when you use our services, or you visit our facilities you accept the collection and use of the information in accordance with this policy. The use of any of the websites of Pueblo Bonito implies that you have read, understood and expressly accepted this Privacy Notice in all of its terms, including, as the case may be, any sensitive, property or financial data that Pueblo Bonito may obtain as a consequence of the use of the mentioned website.

 

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 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 Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) 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.

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

 

PURPOSES

The personal data in possession of Pueblo Bonito and that we receive from you, shall be used for the following purposes that are necessary for the service requested:

  • Rendering of reservation and lodging services as well as to process, update, modify and cancel the services requested by any means of communication: telephone, internet, electronic or in person.
  • Rendering of restaurant services and meal packages.
  • Rendering of catering services.
  • Rendering of event organization services.
  • Rendering of touristic and commercial services.
  • Rendering of SPA services and prevention in case any client presents a special health condition of which he/she must or desires to inform Pueblo Bonito. In this case, sensitive personal data may be requested.
  • Improve or satisfy the needs of the clients and the services provided.
  • Perform direct reservations or on-line through the internet and apply the necessary relevant charges and any other charge required in accordance with the purposes established herein.
  • Send e-mails or make telephone calls so as to confirm data related with reservations made, receive offers, or request identification documents of the client or holder of the credit card when necessary.
  • Administer memberships, including the processing of data for invoicing, handling of your account, maintain a transaction history; apply discounts and perform clarifications and investigations required so as to analyze if the client is under any physical or medical treatment that may restrict his/her participation in any treatment of the SPA and/or special care that must be in place for the client when offering other kind of services.
  • Perform charges, collections, refunds or reimbursements.
  • Inform with respect to aspects related with memberships and possible benefits.
  • Comply with the obligations related with the mentioned services.
  • Maintain an adequate communication with the clients.
  • The images and sounds captured by the surveillance cameras shall be used for your safety and well as of those that visit us.

 

Additionally, we shall use your personal data for the following purposes that are not necessary for the service requested, but allow and facilitate us to offer you better assistance:

  1. Inform with respect to new services, products or events related with the foregoing services, including sending advertising and informational bulletins, surveys and changes.
  2. Information regarding promotions and discounts related with the mentioned services.

 

The objection to the treatment of your personal data for these purposes, shall not be a motive to terminate the commercial relation with Pueblo Bonito.

 

PERSONAL DATA COLLECTED.- In order to achieve the purposes established herein, we shall use the following personal data:

  1. Full name.
  2. Gender
  3. Nationality
  4. Age
  5. Domicile
  6. Cell phone number.
  7. E-mail.
  8. Credit card number.
  9. The images and sounds captured by the surveillance cameras.

 

In addition to the mentioned personal data, for the purposes established herein, we shall use the following personal data which is considered sensitive and that require a special protection:

  1. Physical and medical condition, including taking the body temperature.
  2. Medical history.
  3. Racial or ethnic origin.

 

ARCO RIGHTS.- You are entitled to acknowledge the personal data we have of you, for what we use the same and the conditions of use (Access). In addition, it is your right to request the correction of your personal data, if it is not updated, incorrect or incomplete (Rectification); to eliminate from our records or database when you consider that the same is not being used in accordance with the principles, duties and obligations established in the law (Cancellation); as well as to object to the use of your personal data for specific purposes (Opposition). Such rights are known as “ARCO” rights.

In order to exercise any of the ARCO rights, you must submit the corresponding request by e-mail to: privacy@pueblobonito.com.mx, including the following information:

  1. Name of the holder
  2. Domicile of the holder or e-mail so as to respond your request.
  3. Documents accrediting your identity or authorization to represent you in the request.
  4. Description of the personal date with respect to which any ARCO right shall be exercised.
  5. Any other element that allows the location of the personal data and response of the request.

If your request does not satisfy the mentioned requirements, the Privacy Department may request you within the following 5 days after the reception of your request to submit the elements or documents necessary so as to respond the same. You shall have 10 days to comply with the request, otherwise the corresponding request shall be considered as not submitted.

In order to acknowledge the procedure and requirements so as to exercise the ARCO rights, you may contact our Privacy Department sending an e-mail to: privacy@pueblobonito.com.mx, same that shall respond to the request for the exercise of such rights, and shall resolve any doubts you might have regarding the treatment of your information. The contact information of the Privacy Department are the following: Predio Paraíso Escondido S/N, colonia Centro, Cabo San Lucas, C.P. 23450, Los Cabos, Baja California Sur; Mexico, e-mail: privacy@pueblobonito.com.mx.

You may revoke the consent you granted for the treatment of your personal data. However, it is important that you consider that we cannot address your request or conclude the use immediately, in virtue that it is possible that due to any legal obligation we require to continue treating your personal data. In addition, you must consider that for certain purposes, the revocation or your consent shall imply that we may no longer may render the service requested, or the termination of the relation with us. In order to revoke your consent you must submit your request by e-mail to: privacy@pueblobonito.com.mx.

In order to acknowledge the procedure and requirements for the revocation of the consent you may contact our Privacy Department.

So as to limit the use and disclosure of your personal information we offer you the following means:

  • The recording before the Public Registry to Avoid Advertising, in Spanish Registro Público para Evitar Publicidad, of the Federal Consumer Protection Agency, in Spanish Procuraduría Federal del Consumidor (“PROFECO”), so that your personal data is not used to receive advertising or promotions of companies of goods and services. For more information with respect to such recording, you may visit the website of PROFECO, or directly contact the same.
  • The recording in the exclusion list “Exclusions Pueblo Bonito”, so that your personal data is not treated for marketing, advertising or commercial prospecting. For more information, send an e-mail to privacy@pueblobonito.com.mx.

 

In order to protect your confidentiality; we shall send the response to your request to the e-mail provided and the same shall be available for the petitioner at the domiciles established herein.

 

NOTIFICATION OF CHANGES TO THE PRIVACY NOTICE.- We reserve the right to perform at any time modifications or updates to this privacy notice in order to comply with statutory and jurisprudential authorizations, internal policies, new requirements for contracting services or any other cause. In such case, the modifications shall be available at the following domicile: Predio Paraíso Escondido S/N, colonia Centro, Cabo San Lucas, C.P. 23450, Los Cabos, Baja California Sur; Mexico.

We shall inform you by e-mail and/or a notice in our website or our facilities, before the modification is effective and we shall update the date of the “last update" in the upper part of this privacy notice.

 

FORM OF COLLECTING THE PERSONAL DATA.- For the purposes established herein, we may collect your personal data by several forms:

 

  1. When the information is directly provided by the client.
  2. When we obtain information by means different to those mentioned and that are permitted by law.

 

RETENTION OF PERSONAL DATA.- We shall withhold your personal data only during the time necessary for the purposes established herein. We shall withhold and use your personal data to the necessary extent in order to comply with our legal obligations (for example, if we are obligated to maintain your data so as to comply with applicable laws), resolve disputes and enforce our agreements and legal policies.

 

TRANSFER OF PERSONAL DATA.- Pueblo Bonito, transfers the personal data in is possession to:

  • Companies that pertain to the same corporate group.
  • Employees or third parties subcontracted for the rendering of the services and/or the purposes established herein.
  • Credit institutions or bank institutions in order to perform clarifications due to incorrect or improper charges that derive from the rendering of services and the activities of Pueblo Bonito.

 

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.

  • - 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 the 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/

  • Behavioral Remarketing.- Pueblo Bonito uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

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/

Facebook
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

 

LINKS TO OTHER SITES.- Our Service 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 anyone under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has 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.

 

USE OF TECHNOLOGY.

We inform you that on our website we use cookies, web beacons and other technologies by means of which it is possible to monitor your conduct as an Internet user, provide you a better service and experience as user when browsing our website, as well as to offer you new products and services based on your preferences.

The cookies are small portions of information that are sent by the website to your browser. The cookies are stored in the hard drive of your device and are used to determine your preferences when you connect to the services of our sites, as well as to track determined behaviors or activities performed by the client in our sites. 

On the other hand, the web beacons are images inserted in a website or e-mail, which may be used to monitor the behavior of a visitor, as well as to store information of the IP address of the user, time of interaction in such site and the type of browser used.

The personal data that we obtain from these tracking technologies are the following: type of browser and operating system, the websites you visit. The links you follow, the IP address, browsing schedule, browsing time on our website, sections consulted, and websites accessed prior to our website.

Such cookies and other technologies may be disabled, however, this may cause you to be unable to use certain parts of our Service. The “help” button that is located in the toolbar of the majority of browsers will indicate how to avoid accepting new cookies, how the browser can notify you when you receive a new cookie, or how to disable all cookies.

 

DISCLOSURE OF PERSONAL DATA.- Under certain circumstances, we might be obligated to disclose your personal data, if required by law or as per valid requests of public authorities (for example, a court or governmental agency).

In addition, we may disclose your personal data if we consider in good faith that such action is necessary in order to:

  • Comply with a legal obligation.
  • Protect and defend the rights or property of Pueblo Bonito.
  • Prevent or investigate possible errors related with the service.
  • Protect the personal safety of the users of the service or of the public.
  • Protect against any legal liability.
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