Training Plan

LEGAL NOTICE

1. Identification and contact of the owner of the web.

www.monhotels.com,www.hotelpergolamallorca.com,www.esprincep.com, www.hotelmonport.com (hereinafter the websites), are the property of MON HOTELS and the Companies that comprise it (hereinafter the Holder), telephone (+34) 971200222 and email lopd@monhotels.com

Other details of the owner:

2. Scope of application.

The browsing of the Owner's website means you are considered a user and implies absolute acceptance of that set out in this Legal Notice.

3. Age.

On our website we do not process data in relation to persons under fourteen years of age. In any case, our products and services are aimed at persons over eighteen years of age.

4. Intellectual or industrial property.

The content of the Website, for example, texts, images, graphs or source code, are protected by intellectual and industrialproperty rights.

Such content may not, for example, be reproduced or transformedwithout the Owner's prior, express permission. Users can access the content and make authorised private copies provided the reproduced elements are not subsequently passed onto third parties and are not installed on network servers or made subject to any type of exploitation.

5. Common rules of usage of the website.

Users undertake to use the Website according to the following rules:

Do not publish sales communications through the website.

Do not compile content or information in relation to other users.

Do not load viruses or malicious code of any kind.

Do not request the log in details nor access the account of another user.

Do not perform illegal, deceitful, malicious or discriminatory acts on the website, in accordance with these conditions and the Spanish legal system.

In general, do not do anything that might harm the rights of third parties.

The Owner may delete any content or suspend the service if it should consider you to have violated any of the rules and obligations described in this Legal Notice. Please contact us via email for any query or clarification in relation to these rules.

6. Links and limitation of liability.

The establishing of a hyperlink does not under any circumstances imply the existence of a relationship between the Owner and the owner of the website on which this should have been established, nor the acceptance and approval on the part of the Owner of its content or services.Any persons wishing to establish a hyperlink must first request written authorisation from the Owner. In any case, the hyperlink shall only allow access to the homepage of our website. Additionally, they must abstain from making false, inaccurate or incorrect statements or indications in relation to the Owner or including illegal content contrary to good practices and public order.

The Owner shall not be liable for the use each user should make of the materials made available to them on this website or anyaction they should take based on said materials. The content of the Website is of a general and merely informative nature.

The Owner shall not be liable for the content or functioning of the websites of third parties users of the Website may access through any type of link.

The Owner does not accept any liability, insofar as the legal system should allow, for any damage as a result of the presence of viruses, actions of third parties that should violate property rights, honour or privacy or illegal advertising.

If any user or third party should consider the Website to be committing any illegal conduct of any kind, this must be notified to the Owner thereof via the email address appearing in our contact details. You will need to duly identify yourself, specifying the facts you are reporting.

7. Privacy Policy.

If the Website should collect personal data, the Owner shall be responsible for this and shall process it in absolute confidentiality and security. You'll find more information in our privacy and cookies policies.

8. Changes

The Owner reserves the right to make changes to the content of its website as it should deem fit without prior notification. This applies to both the website's content and the usage conditions thereof and general contracting conditions. Said changes may be made through its website using any means admissible by law and shall be of obligatory compliance for as long as they should remain published on the website and until subsequently replaced with other conditions.

9. Applicable legislation, dispute resolution and competent forum.

The use of the Website shall be governed by Spanish legislation. Any dispute that should arise or bear a relation to the use of the Website shall be subject to the non-exclusive jurisdiction of the Courts and Tribunals of the municipality of the Owner's registered address.

PRIVACY POLICY -EXTENDED INFORMATION

LAST UPDATED: 19/04/2023

The Privacy Policy forms part of the General Terms and Conditions that govern the Website www.monhotels.com,www.hotelpergolamallorca.com,www.esprincep.com, www.hotelmonport.com, together with the Cookies Policy and the Legal Notice.

MON HOTELS reserves the right to amend or adapt this Privacy Policy at any time. We therefore recommend that you check it each time you access the Website. Users who have registered with the website will be informed if there have been substantial changes in relation to the processing of personal data on accessing their account or profile.

Who controls your data?

The data collected or voluntarily provided to us through the Website, even by just browsing such, in addition to any data you should provide on the contact forms, via email or by telephone will be collected and processed by the File Controller, the details of which are as follows:

CAS MIOT SL CIF: B07790512

Ctra. Manacor, 272, 07198, Palma (Illes Balears).

MON PORT HOTEL & SPA, Cala d´Egos, Finca La Noria, 07157, Port d´Andratx.

HOTEL ES PRINCEP, C/ Bala Roja, 1, 07001, Palma.

ENIX SL CIF: B07018781

Ctra. Manacor, 272, 07198, Palma (Illes Balears).

Registered in the Commercial Register of the Balearic Islands, Volume 106, Page 1, Book 2306, Section 1ª, Entry no. 23-01-1968.

APARTHOTEL LA PÉRGOLA, Avinguda s´Almudaina, 16ª, 07157, Port d´Andratx.

Contact at MON HOTELS, for the protection of your personal data

Phone: 971200222

Mail Data Protetion Officer: lopd@monhotels.com

Should you wish to contact us (our Data Protection Officer) regarding any matter in relation to the processing of your personal data or privacyfor whatever reason, you can do so through any of the channels indicated above.

What data do we collect through the website?

Simply by your browsing the website, MON HOTELS will collect information in relation to the following:

-IP address.

-Browser version.

-Operating system.

-Duration of your visit or browsing of the website.

This information is stored by Google Analytics, for which reason we must refer you to Google's Privacy Policy, as this is the party that collects and processes said information. http://www.google.com/intl/en/policies/privacy/

Likewise, the Website provides the Google Maps tool, which may have access to your location, if you have allowed this, in order to provide you with more accurate information regarding the distance to and/or routes to reach our offices. In this respect, we refer you to the Privacy Policy used by Google Maps for more information on the usage and processing of said data: http://www.google.com/intl/en/policies/privacy/

The information we handle shall not be related to a specific user and shall be stored in our databases for the purpose of performing statistical analyses and improving the Website and our products and/or services and will help us to improve our sales strategy. The data will not be communicated to third parties.

Registration of users on the website/Sending of forms

In order to access certain products and/or services, the user must register on the Website or fill in a form. The registration form requests a series of data for this purpose. The necessary, obligatory data to be provided by users to carry out said registration is marked with the * symbol. If these fields are not filled in, registration will not be carried out.

The username and password generated are personal and non-transferable, the user being responsible for custody thereof. We recommend these not be written down anywhere or revealed to third parties.In this case, the browsing data will be associated with the user's registration data, identifying the same specific user who is browsing the Website. This allows us to personalise the offer of products and/or services to offer that which we believe best suits the user, in addition to recommending specific products and/or services.

The registration data of each user will be incorporated into the databases of MON HOTELS, together with a record of the operations carried out by said user, and will be stored in said record unless the registered user's account is deleted. Once said account has been deleted, said information will be separated from our databases and any data in relation to the transactions carried out kept separate for 10 years, without being accessed or altered, for the purpose of complying with the current legal periods. Any data not linked to the transactions carried out will be kept unless you should withdraw your consent, in which case it shall be immediately deleted (always taking the legal periods into account).

The legal basis for the processing of your personal data is the execution of a contract between the parties. In relation to the sending of electronic communications and promotions and answers to requests for information, the legitimisation for the processing is the consent of the affected party.

The purposes of the processing shall be as follows:

a) To manage your registration with the user area and access to the Website.

b) To manage the purchasing of the products and/or services made available to you through the Website.

c) To keep you informed of the processing and status of your requests, purchases and/or reservations.

d) To respond to your request for information.

We also inform you that you may receive communications via email and/or on your phone to inform you of possible incidents, errors, problems and/or the status of your requests.

Express consent for the sending of commercial communications will be requested of users during registration. In this respect, users may revoke their consent by contacting MON HOTELS using the means indicated previously. In any case, each sales communication will include the option to opt out of these by means of a link and/or email address.

Sending of Newsletter

In the event that the option to subscribe to the MON HOTELS Newsletter is allowed on the Web, it will be necessary for you to provide us with an email address to which it will be sent.

Said information will be stored in a database belonging to MON HOTELS where it will remain until the interested party should request that this be deleted or, if applicable, until MON HOTELS should cease sending this.

The legal basis for the processing of this personal data is the express consent given by all interested parties who subscribe to this service by ticking the box provided to this effect.

The email data will be processed and stored solely for the purpose of managing the sending of the Newsletter to the users who request such.

For the sending of the Newsletter, express consent will be requested of users during registration through the ticking of the box provided for this purpose. In this respect, users may revoke their consent by contacting MON HOTELS using the means indicated previously. In any case, each communication will include the option to opt out of these by means of a link and/or email address.

If you belong to any of the following groups, please check the drop-down information:

+ INTERNET OR EMAIL CONTACTS

For what purposes will your personal data be processed?

• -Managing your queries and requests.
• -Managing the requested service and answering and processing requests.
• -Information via electronic means relating to your request.
• -Sales information or information on events via electronic means, provided there is express authorisation.

What is the legal basis for the processing of your data?

The acceptance and consent of the interested party: In cases where you need to fill in a form to make a request and click on the send button, this will necessarily imply that you have been informed and have consented tothe content of the clause annexed to said form or accepted the privacy policy.

All our forms have a tick box with the following sentence, in order to send the information: “□ I have read and accept the privacy policy."

+ CUSTOMERS

For what purposes will your personal data be processed?

• -Preparation of quotes and follow-up through communication between the two parties.
• -Information relating to your request via electronic means.
• -Sales information or information on events via electronic means, provided there is express authorisation.
• -Management of administrative, communication and logistic services performed by the Data Controller.
• -Invoicing.
• -Performing the corresponding transactions.
• -Invoicing and declaration of the corresponding taxes.
• -Control and recovery management.

What is the legal basis for the processing of your data?

The legal basis is your consent and the execution of the service contract.

+ SUPPLIERS

For what purposes will your personal data be processed?

• -Information relating to your request via electronic means.
• -Sales information or information on events via electronic means, provided there is express authorisation.
• -Management of administrative, communication and logistic services performed by the Data Controller.
• - Invoicing.
• -Performing the corresponding transactions.
• -Invoicing and declaration of the corresponding taxes.
• -Control and recovery management.

What is the legal basis for the processing of your data?

The legal basis is the acceptance of a contractual relationship, or in the absence thereof, your consent in contacting us or offering us your products through any channel.

+ SOCIAL NETWORK CONTACTS

For what purposes will your personal data be processed?

• -Managing your queries and requests.
• -Managing the requested service and answering and processing requests.
• -Connecting with you and creating a community of followers.

What is the legal basis for the processing of your data?

The acceptance of a contractual relationship in the context of the social network in question and in accordance with its Privacy Policies:

Facebook http://www.facebook.com/policy.php?ref=pf

Instagram https://help.instagram.com/155833707900388

YouTube: https://www.youtube.com/yt/policyandsafety/es/policy.html

Whatsapp: https://www.whatsapp.com/legal/#privacy-policy

How long will we keep your personal data for?

Our consultation or removal of your data is restricted according to the profile it belongs to. We will process it for as long as you allow us to do so by following us, being our friend, "liking" us or similar.

Any rectification of your data or restricting of information or posts must be done through your profile or user settings within the social network itself.

+ VIDEO SURVEILLANCE

For what purposes will your personal data be processed?

• -Video surveillance of our facilities.
• -Monitoring of our employees.
• -This may occasionally be provided to courts and tribunals for the exercising of legitimate action.

What is the legal basis for the processing of your data?

The unequivocal consent of the interested party on accessing our facilities after seeing a sign regarding the area subject to video surveillance.

+ JOB APPLICANTS

For what purposes will your personal data be processed?

• -Organisation of selection processes for the hiring of employees.
• -To arrange employment interviews and assess your candidacy.
• -If you have given us your consent, we will be able to pass this on to collaborating or similar entities for the sole purpose of helping you find employment.

What is the legal basis for the processing of your data?

The legal basis is your unequivocal consent in sending us your CV and receiving and signing information in relation to the processing we carry out.

How long will we keep your personal data for?

Your CV will be stored for a period of one year after which it will be deleted if we have not contacted you.

+ HUMAN RESOURCES

For what purposes will your personal data be processed?

• -Management of the employment relationship and employee file.
• -To perform all necessary administrative, tax and accounting tasks in order to fulfil our contractual obligations and those in relation to employment legislation, Social Security, occupational risk prevention, taxes and accounting.
• -Management of the payment of wages through a financial entity.
• -Timetable control through the fingerprint/card access control system (if applicable).
• -Management of the entity's collective insurance/pension plans.
• -To perform ongoing training, both subsidised and non-subsidised.

What is the legal basis for the processing of your data?

The legal basis for the processing of your data is the execution of your employment contract. Fulfilment of the corresponding legal obligations. The consent of the interested party.

Do we include personal data in relation to third parties?

No, as a general rule we only process data provided to us by the owner thereof. If you provide us with data belonging to third parties, you must have informed and requested the consent of said people beforehand, otherwise you exempt us from any liability for failure to comply with this requirement.

And personal data in relation to minors?

We do not process data in relation to minors under 14 years of age and therefore ask you not to provide us with your data if you are under this age.

Do we send communications through electronic means?

• -These will only be sent to manage your request, if this is one of the contact means you have provided us with.
• -If we send sales communications, these will have been expressly authorised by you beforehand.

What security measures do we apply?

You can rest easy: we have implemented an optimum level of protection of the Personal Data we handle and have installed all the technical means and measures available to us, according to the state of the art, to avoid the loss, misuse, alteration, unauthorised access to and theft of the Personal Data.

To what extent is decision-making automated?

MON HOTELS does not use completely automated decision-making processes to initiate, develop or end contractual relationships with users. Should weuse these processes in a particular case, we will keep you informed and inform you of your rights in this respect if required to do so by law.

Does the company use profiling?

In order to be able to offer you products and/or services according to your interests and improve your user experience, we may create a "sales profile" based on the information provided. Nonetheless, no automated decisions will be made based on said profile.

Who will receive your data?

Your data may be passed on to collaborating entities to offer the services offered on the website.

Your data shall also be disclosed when there is a legal obligation. Specifically, it shall be disclosed to the State Tax Administration Entity and to banks and financial entities in order to charge for the service rendered or product acquired, in addition to data processor companies as necessary for the execution of the agreement.

In the event of a purchase or payment, if you choose any application, website, bank card or any other online service, your data will be passed on to this platform or processed within such, always with maximum security.

In the event that you have given your consent for the processing of your name and images and other information in relation to the activity of MON HOTELS, these will be published on the various social networks and website of MON HOTELS.

International transfer.

If it is necessary to carry out international data transfers, it will ensure that such transfers are possible in accordance with the General Data Protection Regulations or any other requirement established by applicable regulations. For this purpose, the company will adopt the agreements that are necessary to guarantee a level of data protection equivalent to that provided for in European regulations.

In case of working in a system of shared folders in applications such as Dropbox, Google Drive, Microsoft OneDrive, Amazon, Apple, HubSpot, etc ... an international transfer will be made to the United States under the enabling of article 49.c) of the General Regulations of Data Protection or any other mechanism that guarantees a level of data protection equivalent to that provided for in European regulations.

What rights do you have?

• -The right to know whether or not we are processing your data.
• -The right to access your personal data.
• -The right to the rectification of your data if it is incorrect.
• -The right to the erasure of your data if it is no longer necessary for the purposes for which it was collected or if you withdraw your consent.
• -The right to the limitation of the processing of your data, in some cases, in which case we will only retain this in accordance with current legislation.
• -The right to port your data, which will be provided to you in a commonly used, machine-readable, structured format. If you prefer, we can send this to your designated new data processor. This is only valid in certain circumstances.
• -The right to make a complaint with the Spanish Data Protection Agency if you believe we have failed to correctly address any request.
• -The right to withdraw your consent at any time for any processing you may have given your consent for.

If any of your data should change, we would ask that you inform us so we can keep this up to date.

Would you like a form to exercise your rights?

• -We have forms you can fill in to exercise your rights. Ask us for one via email or if you prefer, you can use those provided by the Spanish Data Protection Agency or third parties.
• -These forms must be signed electronically or accompanied by a photocopy of your National Identity Document.
• -If you are representing someone, you need to attach a copy of their National Identity Document, or they need to sign using their electronic signature.
• -Forms may be submitted in person or sent by mail or by email to the address of the Data Controller at the start of this text.

You have the right to file a complaint with the Spanish Data Protection Agency should you consider that your request to exercise your rights has not been dealt with appropriately.

The maximum period MON HOTELS has to deal with a request is one month from effective receipt of your request.

You have the right to revoke your consent for any of the processing for which you may have granted such at any time.

Do we use cookies?

If we use any type of cookies that are not necessary, you can check the cookies policy at the corresponding link from the home page of our website.

How long will we keep your personal data for?

• -Your personal data will be kept for as long as you remain connected to us.
• -Once you cease to be connected to us, your personal data processed for each purpose will be retained for the legally established periods, including the period during which a judge or tribunal may request such according to the statute of limitations for legal action.
• - The data processed will be retained until the expiry of the legal periods mentioned above, where there is a legal obligation to retain such, or where there is no legal period, until the interested party should request the erasure thereof or revoke their consent given.
• -We will retain all information and communications in relation to your purchase or the provision of our service for as long as the guarantees for the products or services should remain in force in order to deal with any claims.
• -There is a specific period provided for each type of processing or data which you can consult in the following table:

File	Document	Storage
Customers	Bills. Forms and coupons. Contracts	10 years. 15 years. 5 years
Human Resources	Pay slips, TC1, TC2, etc. CVs. Dismissal compensation docs. Contracts. Data of temporary workers. Worker's file.	10 years. Until the end of the selection process, and 1 year more with your consent. 4 years. For up to 5 years after leaving.
Marketing	Databases or web visitors	While processing is taking plac
Suppliers	Bills. Contracts.	10 years. 5 years
Access control and video surveillance	Visitors list. Videos	30 days. 30 days block. 3 years destruction
Accounting	Accounting books and documents. Partner and management boards agreements, company bylaws, minutes, board of directors regulation and delegated committees. Financial statements, audit reports. Records and documents related to grants.	6 years
Fiscal	Running the administration of the Data Controller, rights and obligations related to the payment of taxes. Administration of dividend payments and tax withholdings.	10 years
Health and safety	Medical Records	5 years
Insurance	Insurance policies	6 years (general rule). 2 years (damages). 5 years (personal). 10 years (life)
Purchases	Register all deliveries of goods or services, intra-community acquisitions, imports and exports for VAT purposes.	5 years
Legal	Documents Intellectual and Industrial Property. Contracts and agreements. Permits, licences, certificates. Confidentiality and non-competition agreements	5 years. 6 years from expiry date of permit, licence or certificate. 10 years (limitation period for bringing criminal action). Always the term of the obligation or confidentiality.
Protection of personal data	Processing of personal data, if different from the processing notified to the AEPD (Spanish Data Protection Agency). Personal data of employees stored in the networks, computers and communications equipment used by them, access controls and internal management/administration systems.	3 years. 5 years
Guests	Entry registration of travelers / guests (check-in).	3 years

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