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Privacy policy

1. Data controller

  • Identity: PASIMONACHA, S.L.
  • Tax ID (NIF): B45870722
  • Address: Carretera CM-4002 (Km 3,200), 45682 Los Cerralbos (Toledo), España
  • Email: reservas@fincalasimona.es
  • Telephone: 615 401 581

PASIMONACHA, S.L. has not appointed a data protection officer, as none of the circumstances in article 37 GDPR apply. For any question about your data you may write to reservas@fincalasimona.es.

2. Processing activities, purposes and legal bases

a) Contact form

Purpose: to answer your enquiry and maintain any resulting correspondence. Legal basis: your consent (article 6(1)(a) GDPR), given by ticking the acceptance box. Data: name, email, telephone if provided, and the content of the message.

b) Booking request

Purpose: to check availability for the requested dates, prepare a quote and reply to you. Legal basis: steps taken at your request prior to entering into a contract (article 6(1)(b) GDPR). Data: name, telephone, email, dates, number of guests and any message you add.

c) Managing the stay, deposit and invoicing

Purpose: to enter into and perform the accommodation contract, take and return the deposit and issue invoices. Legal basis: performance of the contract (article 6(1)(b)) and compliance with accounting and tax obligations (article 6(1)(c), in connection with the Spanish Commercial Code and the General Tax Act).

d) Guest register and reporting to the authorities

Purpose: to comply with the obligation to keep a documentary register of guests and report it to the competent authorities. Legal basis: legal obligation (article 6(1)(c) GDPR), under Spanish Royal Decree 933/2021 of 26 October and Organic Act 4/2015 of 30 March on the protection of public safety. Data: those required by law (full name, identity document, date of birth, address and travel details) for every guest over fourteen years of age.

e) Website security and prevention of automated submissions

Purpose: to protect the forms against automated submissions using Cloudflare Turnstile and to keep server technical logs. Legal basis: the controller's legitimate interest in the security of its systems (article 6(1)(f) GDPR).

f) Website analytics

Purpose: to understand in aggregate how the website is used in order to improve it. Legal basis: your consent (article 6(1)(a) GDPR), which you may accept or reject with equal ease in the cookie notice and withdraw at any time via «Cookie settings» at the foot of any page. If you do not accept it, no analytics script is loaded.

3. Retention periods

  • Contact form enquiries: one year from the last contact, unless a contractual relationship arises from the enquiry.
  • Unconfirmed booking requests: one year from the request.
  • Accommodation contracts, deposits and invoices: six years under accounting and commercial law, and four years for tax purposes, counted from the close of the relevant financial year.
  • Guest register: three years from the end of the stay, under Royal Decree 933/2021.
  • Technical security logs: only for as long as strictly necessary for the purpose that justifies them.

4. Recipients

No data is disclosed to third parties except where required by law. The following providers do access it as processors, under an article 28 GDPR agreement, because they are necessary to deliver the service:

  • The web hosting and email provider.
  • Cloudflare, Inc., for the anti-bot verification of the forms.
  • Google Ireland Ltd., for website analytics, only if you accept analytics cookies.
  • The tax and accounting advisers, for invoicing.

Where a booking arrives through a third-party portal (for example, a holiday rental portal), that portal acts as an independent controller of the data it collects; its own privacy policy governs that processing.

Guest register data is reported to the Spanish Ministry of the Interior and the State security forces, as required by law.

5. International transfers

Some of the providers listed may process data outside the European Economic Area. In that case the transfer relies on the standard contractual clauses approved by the European Commission or on an adequacy decision, such as the EU-US Data Privacy Framework. You may request a copy of the safeguards applied by writing to reservas@fincalasimona.es.

6. Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, and withdraw any consent given, by writing to reservas@fincalasimona.es or to Carretera CM-4002 (Km 3,200), 45682 Los Cerralbos (Toledo), España, stating the right you are exercising and enclosing a copy of your identity document.

If you believe the processing does not comply with the rules, you may lodge a complaint with the Spanish Data Protection Agency, C/ Jorge Juan 6, 28001 Madrid, www.aepd.es.

7. Minors

The forms on this website are intended for people over fourteen years of age. PASIMONACHA, S.L. does not knowingly collect data from children under that age without the consent of a parent or guardian.

8. Accuracy of the data and security measures

The data subject warrants that the information provided is true and undertakes to report any change. PASIMONACHA, S.L. applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk, and requires the same level of protection from its processors.

9. Changes to this policy

This policy may be updated to reflect changes in the law or new processing activities. The version in force is always the one published on this page.