In order to comply with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, its applicable Regulations and Guidelines (the "Law"), Guruhotel, SAPI de CV, its affiliates and/or subsidiaries, and/or or its related parties (“GURUHOTEL”), with address at Calle Bernia Lote 01 MZA 70, Colonia Andara, Chetumal, Quintana Roo, CP. 77014, (the "Domicile"), email address: owner of the Software rights called [*GuruHotel*] (the "Software") for use through the digital platform with email address www.guruhotel.com (the " Platform”) and other present and future digital platforms and web and/or mobile applications of its property, and with contact email firstname.lastname@example.org(the "Email"), makes this available to you:
NOTICE OF PRIVACY
In order to give a legitimate, controlled and informed treatment to your personal data, that you currently provide us or in the future and that work in our databases, or that have been collected by cookies, or any other web tracking technology, as well as to guarantee your privacy and your right to informative self-determination when providing us with said data, GURUHOTEL being responsible for the use and protection of your personal data, which will be treated based on the principles of legality, consent, information, quality, purpose, loyalty , proportionality and responsibility provided for in the Law.
USE OF INFORMATION
The information that you provide us through access, registration and creation of a User profile on the Platform, and/or email, and/or filling out forms or physical or electronic surveys, in real time or history, will be processed and ordered , so that it generates data indicators, which GURUHOTEL may use to make decisions relevant to its business. All the information that is collected will be used for statistical purposes, in a generic and non-personalized way, and is associated with the growth, maintenance and administration of GURUHOTEL, respecting your privacy at all times. These uses include our internal operations and administration, communication with you and the fulfillment of requests for services and/or products provided by GURUHOTEL, as well as to improve, develop, perfect and,
GURUHOTEL may also collect your IP (Internet Protocol) address to help diagnose problems with the GURUHOTEL server and to administer the Platform. An IP address is a number that is assigned to your computer when you use the Internet. Your IP address is also used to help identify you within a particular session and to gather general demographic information. GURUHOTEL may make use of “push” technology through the application that GURUHOTEL uses to send notifications with the prior authorization of the User. This means of communication does not have any type of access to other functions or information of the equipment with which it connects to the Platform. The information may include the URL from which they come (whether or not they are on the Platform, which URL they access next (whether or not they are on the Platform),
USE OF THIRD-PARTY PLATFORMS AS A MEANS OF OBTAINING DATA
Personal Data may be collected through the manual integration of the information requested on the Platform or through the authorization of the use of the data contained in the platform of Google Inc., Facebook, and Apple when the User has an email account registered in said platform. The request for the User's data is made through the link of the Platform to the API (by its abbreviated meaning in English Application Programming Interfaces) integrated in the Platform of Google Inc., Facebook and Apple.
In the same way, the entry of You as a user to the Services of the Platform, may also be subject to a first identity verification through the validity of the cell phone number, which is provided for this purpose, through a direct SMS message (for its acronym in English Short Message Service)
- PERSONAL DATA REQUESTED
GURUHOTEL, and/or its controlling companies and/or affiliated companies and/or subsidiaries and/or related parties (the "Related Third Parties") and/or those third parties that have contracted the use of the Platform to complement their business proposal and/or for personal use (the "Client"), and/or due to the nature of their work or functions they have the need to process and/or use the personal data of the Client, as suppliers or commercial allies of GURUHOTEL ("Business Partners ”), requests and obtains personal data in general, as well as personal data considered sensitive by Law (hereinafter “General Personal Data” and “Sensitive Personal Data”, respectively; and jointly referred to as the “Personal Data”) of the persons hereinafter described.
Sensitive Personal Data may be requested by electronic or physical means, with the understanding that all information provided in physical form will be considered and treated as if it had been provided and authorized on the Platform, and for which it will be governed by this document.
In all cases, the collection of Personal Data by GURUHOTEL is carried out in good faith and for the purposes set forth herein; for this reason, it is presumed that the data provided by their owners are true and complete, so they are the responsibility of the owner who provides them.
- CLIENTS (GUESTS), AS USERS OF THE PLATFORM. The Personal Data that will be collected from the Clients who make use of the Platform are necessary to document the commercial and legal relationship that exists or may exist with each of them, and to be able to carry out the purpose of the contracted services. The Personal Data that you will provide voluntarily and freely by yourself or through your Administrators, consists of information that is included or may be included in contracts, letters, formats, lists, databases or other physical and/or electronic means, as appropriate, so that GURUHOTEL can document the relationship between the parties, the process of use and selection that it makes or is going to make of the Modules that make up the Services of the Platform; can keep proper records of the business relationship with its business partners; as well as to fully comply with the internal policies, procedures and other legal obligations applicable to GURUHOTEL.
The Personal Data that will be requested are the following:
- B) COMMERCIAL PARTNERS (MEMBER HOTELS), AS USERS OF THE PLATFORM. The Personal Data that will be collected from the Business Partners through the Platform, consist of information that is included or may be included in contracts, letters, formats, lists, databases or other physical and/or electronic means provided in each one. of the Modules of the Platform, as appropriate, in order to document the process of use and selection that you carry out or will carry out of the Service Modules that make up the Platform; an adequate record can be kept of the commercial relationship with the Business Partners that make use of the Platform; as well as to fully comply with the internal policies, procedures and other legal obligations applicable to GURUHOTEL.
The Personal Data that is collected for its integration as part of the Platform Services to Business Partners are:
- social denomination;
- registered office;
- Federal Taxpayer Registry key (“RFC”);
- name and position of the person who acts as the main contact;
- mobile and/or corporate phone number of the person who acts as the main contact; Y
- corporate email of the person who acts as the main contact;
All Personal Data is processed by GURUHOTEL and placed in a repository for processing and transfer, in order to comply with the purpose of the Services acquired by the Client. AS THE PLATFORM IS A DATA PROCESSING TOOL PLACED AT THE CUSTOMER'S SERVICE, WHICH ALLOWS THE MONITORING AND CENTRALIZATION OF ALL CUSTOMER INFORMATION, GURUHOTEL HAS NO INTERFERENCE OVER THE TRANSFER AND PURPOSE OF USE BY THE BUSINESS PARTNERS, THEREFORE THESE ACTIVITIES ARE GOVERNED BY THE PRIVACY NOTICE THAT EACH COMMERCIAL PARTNER PROVIDES FOR THIS PURPOSE.
- PURPOSES OF THE PROCESSING OF PERSONAL DATA
The Personal Data provided to GURUHOTEL through the Platform will be used as mentioned above, for the purpose of:
- carry out the data processing that allows creating a record of the Clients and the Modules of the Services that you use, administer or manage through the Platform, as a link tool with the Commercial Partners,
- process the request for services made through the Platform;
- complete the reservations made by the Client on the Platform;
- correctly operate and provide the Services acquired by the Client;
- provide the necessary advice and follow-up to the contracted Services;
- offer additional third-party services such as tours, experiences, flights, and lodging in different destinations;
- that the Client can manage, operate, administer and monitor the business relationship with its Business Partners;
- make the payment for the Services and guarantee the direct reservation of the rooms made on the Platform;
- promotional and marketing activities for new products and/or services available on the Platform;
- inform about changes in products and/or services;
- carry out internal studies on habits of consumption of the Services;
- develop new products and/or services;
- interrelation of databases to know the Client's profile and their needs; Y
- process the bank data to make the payment of the contracted Services and/or any business procedure with the Business Partners, through the payment engines provided.
Once the purposes of the processing of your Personal Data have been fulfilled, and when there is no legal provision that establishes otherwise, GURUHOTEL, at its sole discretion and under the authorization of the Owner of the data, may use the data collected solely for statistical purposes of generic and non-personalized way, and are associated with the growth, maintenance and administration of GURUHOTEL, respecting at all times the privacy of the owner of the Personal Data.
The treatment that the Commercial Partners, as well as the payment engines arranged by GURUHOTEL, grant to the Personal Data collected, will be subject to the terms and conditions of the Privacy Notice of the Commercial Partners as well as those contained in the website of the third party that performs the payment engine services.
TRANSFER OF PERSONAL DATA AND INFORMATION. The Personal Data referred to in this Notice may be transferred to: (i) related third parties and/or commercial allies, in order to enhance GURUHOTEL's value proposition, as well as offer it, based on its needs, other products and services; (ii) Mexican and foreign judicial authorities, in order to comply with the Law, legislation, notifications, requirements or judicial orders; (iii) to internet service providers on which the technological infrastructure of GURUHOTEL is mounted; and/or (iv) to providers of technical support services of the Platform. In case of making any transfer of your Personal Data, in which your express consent is required, we will inform you in order to collect it.
In all cases, GURUHOTEL will communicate this Privacy Notice to these third parties and will ensure, through the signing of agreements and/or the adoption of other binding documents, that said third parties maintain the administrative, technical and physical security measures necessary to safeguard your Personal Data, as well as that said third parties only use your Personal Data for the purposes for which they were collected. Likewise, both the Client as the person responsible for collecting the Personal Data and GURUHOTEL, which facilitates the collection and processing thereof through the Platform, as well as any other person related to GURUHOTEL who has access to the information contained in this Privacy Notice, will be obliged to safeguard it under the same security and confidentiality standards,
Notwithstanding the foregoing, GURUHOTEL will not transfer your Personal Data to third parties not related to GURUHOTEL, except in the aforementioned cases and those provided for in the Law, without your prior consent.
- MEANS AND PROCEDURES FOR THE EXERCISE OF ARCO RIGHTS
You, as the owner of the Personal Data provided to GURUHOTEL, may request at any time, the exercise of your rights of access, rectification, cancellation or opposition (the "ARCO Rights") to the processing of your Personal Data, consisting of: (i ) access your Personal Data and the details of its treatment; (ii) rectify your Personal Data if it is inaccurate or incomplete; (iii) cancel your Personal Data when you consider that they are not required for any of the purposes indicated in this Privacy Notice, are being used for non-consensual purposes or have terminated your contractual or service relationship or another with GURUHOTEL; and (iv) object to the processing of your Personal Data for specific purposes.
For this purpose, you must follow the process of submitting your request in writing to GURUHOTEL, or send your request to the Email, as applicable, which must contain, at a minimum, the following information: (a) your full name and address, or other suitable means to communicate the response to your request; (b) the documents that prove your identity or, where appropriate, that of your legal representative; (c) the clear and precise description of the Personal Data with respect to which one seeks to exercise any of the aforementioned rights; and (d) any other element or information that facilitates the location of the Personal Data, as well as any other document required by the current regulation at the time of submitting the request.
The response to your request will be made known to you by GURUHOTEL in the terms and periods established in the Law. However, you may obtain more information about the status of your request and its response time by contacting GURUHOTEL or sending your request to the Email, where you can also address any clarification or doubt you may have regarding the processing of your Personal Data and the exercise of your ARCO Rights.
- REVOCATION OF CONSENT; LIMITATION OF USE AND DISCLOSURE OF PERSONAL DATA
You may also revoke, at any time, the consent you have given to GURUHOTEL for the processing of your Personal Data, as well as request that the use and disclosure thereof be limited, as long as it is not prevented by a legal provision. For this purpose, you must submit your request in writing to GURUHOTEL, or send your request to the Email, as applicable. Said request must meet the same requirements mentioned in Section 4. above.
The response to your request will be made known to you by GURUHOTEL in the terms and periods established in the Law. However, you may obtain more information about the status of your request and its response time by contacting GURUHOTEL or sending your request to the Email, where you can also address any clarification or doubt you may have regarding the treatment and these rights that correspond to you regarding your Personal Data.
In the event that your Personal Data had been sent prior to the date of revocation of consent, and continue to be processed by those in charge of GURUHOTEL, GURUHOTEL will inform the latter of said revocation, so that they proceed to carry out the appropriate action.
- CHANGES TO THE PRIVACY NOTICE
GURUHOTEL reserves the right to modify and/or update this Privacy Notice, in some or all of its parts, at its sole discretion, in which case it will communicate it here through its Platform; and, depending on the particular case of each holder, through their internal networks, or by means of a notice that will be placed in the usual means of communication (physical or electronic) of GURUHOTEL and in a visible place of the Home, or by means of a written notice addressed to your email, as legally required.
- DIGITAL, ELECTRONIC OR ONLINE
The Parties agree that the way to perfect the agreement of wills between them may be in Digital, Electronic or Online format, where it will suffice to express their will by accepting it, as well as providing personal data, on the GURUHOTEL Platform. without requiring to stamp the signature on any document.
Date of first issue: October 16, 2020
Date of last modification: September 14, 2022